FLORIDA

FOUR OF HEINRICHS CUSTOMERS HAD INAUTHENTIC SIGNATURES ON DOCUMENTS THAT WERE SUBMITTED TO MORGAN KEEGAN IN CONNECTION WITH TRANSACTIONS FOR WHICH HEINRICHS WAS RESPONSIBLE.

Stipulation and Consent

Cease and Desist

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

$5,000.00

MR. HEINRICHS AGREED TO WITHDRAW HIS APPLICATIONS FOR REGISTRATION AS AN ASSOCIATED PERSON OF BROKER DEALER AND INVESTMENT ADVISER; AGREED NOT TO APPLY FOR REGISTRATION WITH THE OFFICE FOR A PERIOD OF TEN (10) DAYS FROM THE DATE OF THE FINAL ORDER; AFTER SAID TIME, IF HEINRICHS SUBMITS AN APPLICATION AND THE OFFICE APPROVES SUCH APPLICATION, THEN HEINRICHS AGREES THAT THE REGISTRATION OR LICENSE SHALL BE SUBJECT TO A TWO (2) YEAR REGISTRATION AGREEMENT; AND AGREED TO PARTICIPATE IN AND COMPLETE THE S101 REGULATORY ELEMENT OF THE SECURITIES CONTINUING EDUCATION PROGRAM WITHIN NINETY (90) DAYS OF THE ENTRY OF THE FINAL ORDER.

Advisor denied on the record to signing documents on behalf of clients, which were not sales related, but rather consolidated household forms. Advisor did admit to assisting clients fill in information on documents such as name, address, phone number, which a client would then sign. Unknown to the advisor, new firm policy changes in 2008 made filling in information for clients on documents clients have to sign disallowed, which caused him to be penalized by the State of Florida . Advisor agreed to State of Florida penalty so that he could get his practice up and running again.

MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED

Permitted to Resign

PERMITTED TO RESIGN DUE TO MANAGEMENT'S LOSS OF CONFIDENCE RELATING TO STATE OF FLORIDA'S INVESTIGATION INTO THE REGISTERED REPRESENTATIVES' CONDUCT WITH HIS PRIOR FIRM.

WRITTEN COMPLAINT SUBMITTED BY [THIRD PARTY], POA ALLEGES NEGLIGENCE AGAINST THE FA IN REGARDS TO RMDS NOT TAKEN FROM HER MOTHER'S ANNUITY CONTRACTS FOR THE YEAR 2008. [THIRD PARTY] FURTHER ALLEGES NEGLIGENCE BY FA IN NOT REGISTERING ACCOUNTS CORRECTLY AND ALLEGES FORGERY ON DESIGNATED BENEFICIARY DOCUMENTS. SEE CASE #'S 2488 & 2302 FOR FURTHER DETAILS.

$2,381.00

Complaint was made by the daughter of one of my clients who did not believe her brother would be made a larger majority beneficiary. Firm met with client who confirmed her signature. Daughter then asked for RMD penalty of her deceased father to be covered by the firm, which was rejected by the firm due to RMD's being the clients responsibility. Matter was closed with no action.

CUSTOMER COMPLAINT ALLEGING MISREPRESENTATION OF TWO VARIABLE ANNUITIES PURCHASED IN DECEMBER 2007.

$90,000.00

THE CUSTOMER RESCINDED THE COMPLAINT VIA LETTER TO ADVISOR AND BRANCH MANAGER AND IN THAT LETTER THE CLIENT STATED THE INVESTMENT WAS SUITABLE FOR HIM AND HIS WIFE. HENCE, NO CLAIM PAID TO CLIENT."