CLIENT ALLEGES THE ADVISOR DID NOT DISCLOSE THE FRONT END SALES CHARGE WHEN THEY AGREED TO TRANSFER THEIR ACCOUNT TO AMERIPRISE. THE CLIENT IS REQUESTING REIMBURSEMENT FOR THE SALES CHARGE.

$62,510.28

$6,251.28

DURING THE FIRM'S INTERNAL COMPLIANCE INVESTIGATION REGARDING THE ABOVE CLIENTS, IT WAS DISCOVERED THAT THE CLIENTS MAY NOT HAVE RECEIVED FULL DISCLOSURE OF THE SALES CHARGE. THE REGISTERED REPRESENTATIVE WAS NOT THE SELLING ADVISOR. HOWEVER, THIS REGISTERED REPRESENTATIVE WAS PRESENT DURING ALL CLIENT MEETINGS AND WAS ACTING AS A COACH FOR THE SELLING ADVISOR.

CLIENTS ALLEGE THEY DID NOT PROVIDE AUTHORIZATION TO PURCHASE THE VARIABLE UNIVERSAL LIFE INSURANCE IN NOVEMBER 2006.

$14,690.00

$1,527.00

VARIABLE UNIVERSAL LIFE (VUL) PURCHASES APPEARED SUITABLE,HOWEVER WE WERE UNABLE TO VERIFY DATE OF CONTRACT DELIVERY AND FREE-LOOK PERIOD. IN THE INTEREST OF GOOD CLIENT RELATIONS, WE CANCELLED THE VUL POLICIES UNDER THE FREE-LOOK PROVISION.