Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Private Funds
Private funds reported by Synovus Securities, Inc..
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.
Ownership
Reported direct and indirect ownership ranges
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Synovus Securities, Inc...
No indirect ownership information reported in the source’s Schedule B.
Reported ownership and control details
Form ADV · Filing date 2026-01-28 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | GUY LEONARD SEXTONEVP/DIRECTORIndividual | SYNOVUS SECURITIES, INC. | Less than 5%Code NA | Yes | EVP/DIRECTOR08/1985 | Schedule APDF page 37 |
| 2 | ROBERT PARKER VARNERPRESIDENTIndividual | SYNOVUS SECURITIES, INC. | Less than 5%Code NA | Yes | PRESIDENT11/2022 | Schedule APDF page 37 |
| 3 | GENE FREDERICK GUNDERSONDIRECTOR OF COMPLIANCE, TRUST & BROKERAGEIndividual | SYNOVUS SECURITIES, INC. | Less than 5%Code NA | Yes | DIRECTOR OF COMPLIANCE, TRUST & BROKERAGE11/2022 | Schedule APDF page 37 |
| 4 | ROBERT WARD LAWPRESIDENT - CFG DIVISIONIndividual | SYNOVUS SECURITIES, INC. | Less than 5%Code NA | Yes | PRESIDENT - CFG DIVISION01/2011 | Schedule APDF page 37 |
| 5 | LEAH JEANETTE KIRKCHIEF OPERATIONS OFFICERIndividual | SYNOVUS SECURITIES, INC. | Less than 5%Code NA | Yes | CHIEF OPERATIONS OFFICER07/2006 | Schedule APDF page 37 |
| 6 | MICHELLE JESSUP MCKENZIEROPIndividual | SYNOVUS SECURITIES, INC. | Less than 5%Code NA | Yes | ROP12/2020 | Schedule APDF page 37 |
| 7 | WILLIAM THOMAS BROOKSCHIEF COMPLIANCE OFFICERIndividual | SYNOVUS SECURITIES, INC. | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER12/2022 | Schedule APDF page 37 |
| 8 | JENNA KELLEY ELEAMCHIEF FINANCIAL OFFICER / FINOPIndividual | SYNOVUS SECURITIES, INC. | Less than 5%Code NA | Yes | CHIEF FINANCIAL OFFICER / FINOP11/2025 | Schedule APDF page 37 |
| 9 | PINNACLE FINANCIAL PARTNERS INC.SYNOVUS SECURITIES, INC. PARENTDomestic entity | SYNOVUS SECURITIES, INC. | 75% or moreCode E | Yes | SYNOVUS SECURITIES, INC. PARENT01/2026 | Schedule APDF page 37 |
Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.
Compliance & Disclosures
Filing dated 1/28/2026 1:07:58 PM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
AFelonies2 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?No
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions2 Yes3 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?No
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions1 Yes4 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?Yes
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions1 Yes3 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 10 source blocks
Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.
regulatory · block 1PDF pages 38–40
- Regulator name — filed text
- STATE OF NEW MEXICO DIVISION OF SECURITIES
- Monetary/Fine Amount — filed text
- $ 1,840.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
SSI ENHANCED SUPERVISORY PROCEDURES FOR ENHANCED MONITORING OF STATE LICENSING REQUIREMENTS
Other filed details
Description of allegations — filed text
THAT SSI CONDUCTED BROKERAGE BUSINESS IN THE STATE OF NEW MEXICO PRIOR TO RECEIVING THE APPROPRIATE STATE REGISTRATION
Sanction detail — filed text
SSI PAID CIVIL PENALTY FO $500 AND AN ADMINISTRATIVE ASSESSMENT OF $1,340 AND OFFERED TO RESCIND ALL TRANSACTIONS THAT WERE EFFECTED PRIOR TO NEW MEXICO REGISTRATION
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) STATE OF NEW MEXICO DIVISION OF SECURITIES 2. Principal Sanction: Other Sanctions: CIVIL AND ADMINISTRATIVE 3. Date Initiated (MM/DD/YYYY): 12/14/1998 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Mutual Fund(s) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THAT SSI CONDUCTED BROKERAGE BUSINESS IN THE STATE OF NEW MEXICO PRIOR TO RECEIVING THE APPROPRIATE STATE REGISTRATION 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 12/14/1998 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 1,840.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: SSI WAS ORDERED TO OFFER RESCISION OF ALL TRANSACTIONS THAT WERE EFFECTED FOR NEW MEXICO CLIENTS PRIOR TO STATE REGISTRATION Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: SSI PAID CIVIL PENALTY FO $500 AND AN ADMINISTRATIVE ASSESSMENT OF $1,340 AND OFFERED TO RESCIND ALL TRANSACTIONS THAT WERE EFFECTED PRIOR TO NEW MEXICO REGISTRATION 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). SSI ENHANCED SUPERVISORY PROCEDURES FOR ENHANCED MONITORING OF STATE LICENSING REQUIREMENTS
regulatory · block 2PDF pages 40–41
- Regulator name — filed text
- NORTH DAKOTA DIVISION OF SECURITIES
- Monetary/Fine Amount — filed text
- $ 3,500.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
SSI ENHANCED SUPERVISORY PROCEDURES FOR ENHANCED MONITORING OF STATE LICENSING REQUIREMENTS
Other filed details
Description of allegations — filed text
THAT SSI CONDUCTED BROKERAGE BUSINESS IN THE STATE OF NORTH DAKOTA PRIOR TO RECEIVING THE APPROPRIATE STATE REGISTATION
Sanction detail — filed text
SSI REFUNDED COMMISSIONS TO NORTH DAKOTA CLIENTS IN THE AMOUNT OF $1,785.43 AND PAID A FINE IN THE AMOUNT OF $3,500
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) NORTH DAKOTA DIVISION OF SECURITIES 2. Principal Sanction: Other Sanctions: CIVIL AND ADMINISTRATIVE 3. Date Initiated (MM/DD/YYYY): 11/04/1998 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Mutual Fund(s) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THAT SSI CONDUCTED BROKERAGE BUSINESS IN THE STATE OF NORTH DAKOTA PRIOR TO RECEIVING THE APPROPRIATE STATE REGISTATION 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 11/04/1998 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 3,500.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: REFUND SALES CHARGE OF $1,785.43 FOR TRANSACTIONS MADE IN VIOLATION OF NORTH DAKOTA LAW Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: SSI REFUNDED COMMISSIONS TO NORTH DAKOTA CLIENTS IN THE AMOUNT OF $1,785.43 AND PAID A FINE IN THE AMOUNT OF $3,500 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). SSI ENHANCED SUPERVISORY PROCEDURES FOR ENHANCED MONITORING OF STATE LICENSING REQUIREMENTS
regulatory · block 3PDF pages 41–43
- Regulator name — filed text
- MAINE DIVISION OF SECURITIES
- Monetary/Fine Amount — filed text
- $ 3,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
SSI ENHANCED SUPERVISORY PROCEDURES FOR INCREASED MONITORING OF STATE LICENSING REQUIREMENTS
Other filed details
Description of allegations — filed text
THAT SSI CONDUCTED BROKERAGE BUSINESS IN THE STATE OF MAINE PRIOR TO RECEIVING THE APPROPRIATE REGISTRATION
Sanction detail — filed text
SSI PAID AN ADMINISTRATIVE FINE OF $ 3,000
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) MAINE DIVISION OF SECURITIES 2. Principal Sanction: Other Sanctions: CIVIL ADMINISTRATIVE 3. Date Initiated (MM/DD/YYYY): 09/01/1998 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THAT SSI CONDUCTED BROKERAGE BUSINESS IN THE STATE OF MAINE PRIOR TO RECEIVING THE APPROPRIATE REGISTRATION 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 09/01/1998 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 3,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: SSI PAID AN ADMINISTRATIVE FINE OF $ 3,000 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). SSI ENHANCED SUPERVISORY PROCEDURES FOR INCREASED MONITORING OF STATE LICENSING REQUIREMENTS
regulatory · block 4PDF pages 43–45
- Regulator name — filed text
- RHODE ISLAND DIVISION OF SECURITIES
- Monetary/Fine Amount — filed text
- $ 1,200.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
SSI ENHANCED SUPERVISORY PROCEDURES FOR INCREASED MONITORING OF STATE LICENSING REQUIREMENTS
Other filed details
Description of allegations — filed text
THAT SSI CONDUCTED BROKERAGE BUSINESS IN THE STATE OF RHODE ISLAND PRIOR TO RECEIVING THE APPROPRIATE STATE REGISTRATION
Sanction detail — filed text
SSI PAID A $1000 ADMINISTRATIVE FINE & $1600 IN BACK REGISTRATION FEES
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) RHODE ISLAND DIVISION OF SECURITIES 2. Principal Sanction: Other Sanctions: CIVIL AND ADMINISTRATIVE 3. Date Initiated (MM/DD/YYYY): 08/19/1998 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THAT SSI CONDUCTED BROKERAGE BUSINESS IN THE STATE OF RHODE ISLAND PRIOR TO RECEIVING THE APPROPRIATE STATE REGISTRATION 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 09/09/1998 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 1,200.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: SSI PAID A $1000 ADMINISTRATIVE FINE & $1600 IN BACK REGISTRATION FEES 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). SSI ENHANCED SUPERVISORY PROCEDURES FOR INCREASED MONITORING OF STATE LICENSING REQUIREMENTS
regulatory · block 5PDF pages 45–47
- Regulator name — filed text
- STATE OF CONNECTICUT SECURITIES DIVISION
- Monetary/Fine Amount — filed text
- $ 4,140.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
SSI ENHANCED SUPERVISORY PROCEDURES FOR INCREASED MONITORING OF STATE LICENSING REQUIREMENTS
Other filed details
Description of allegations — filed text
ALLEGED THAT SSI CONDUCTED BROKERAGE BUSINESS IN THE STARE OF CT. PRIORT TO RECEIVING THE APPROPRIATE STATE REGISTRATION
Sanction detail — filed text
SSI REFUNDED $ 5,423.59 IN COMMISIONS TO CLIENTS, IMPLEMENTED REVISED SUPERVISORY AND COMPLIANCE COMPLAINTS INITIATED BY CONNECTICUT CLIENTS FOR TWO YEARS AND PAID AN ADMINISTRATIVE FINE OF $3,000 AND $1,140 IN BACK REGISTRATION FEES
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) STATE OF CONNECTICUT SECURITIES DIVISION 2. Principal Sanction: Other Sanctions: CONSENT 3. Date Initiated (MM/DD/YYYY): 01/28/1998 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ALLEGED THAT SSI CONDUCTED BROKERAGE BUSINESS IN THE STARE OF CT. PRIORT TO RECEIVING THE APPROPRIATE STATE REGISTRATION 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 01/28/1998 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 4,140.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IMPLEMENT REVISED SUPERVISORY AND COMPLIANCE PROCEDURES, SUBMIT A REPORT OF ALL COMPLAINTS INITIATED BY CONNECTICUT CLIENTS FOR TWO YEARS AND REFUND $5,423.59 IN COMMSISIONS TO CLIENTS Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: SSI REFUNDED $ 5,423.59 IN COMMISIONS TO CLIENTS, IMPLEMENTED REVISED SUPERVISORY AND COMPLIANCE COMPLAINTS INITIATED BY CONNECTICUT CLIENTS FOR TWO YEARS AND PAID AN ADMINISTRATIVE FINE OF $3,000 AND $1,140 IN BACK REGISTRATION FEES 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). SSI ENHANCED SUPERVISORY PROCEDURES FOR INCREASED MONITORING OF STATE LICENSING REQUIREMENTS
regulatory · block 6PDF pages 47–48
- Regulator name — filed text
- NASD REGULATION, INC
- Monetary/Fine Amount — filed text
- $ 8,500.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
ON OCTOBER 27,1999, SSI SUBMITTED AN EXECUTED LETTER OF ACCEPTANCE, WAIVER AND CONSENT FOR REVIEW BY THE NASD. AN $8,500.00 MONETARY SANCTION WAS PAID ON 6/20/2000.
Other filed details
Description of allegations — filed text
ON OCTOBER 25, 1999, SYNOVUS SECURITIES,INC RECEIVED AN UNEXECUTED LETTER OF ACCEPTANCE, WAIVER AND CONSENT FOR THE NASD. THE "AWC" RELATED TO ALLEGED TRADE REPORTING VIOLATIONS FOR TRADE DATES JUNE 2,1997 THROUGH JUNE 13, 1997. SSI HAS EXECUTED THE "AWC" AND ACCEPTS AND CONSENTS, WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, TO THE ENTRY OF THE FINDING BY NASD REGULATION INC.
Sanction detail — filed text
TOTAL FINE OF $8,500 WAS PAID ON 06/20/2000
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) NASD REGULATION, INC 2. Principal Sanction: Other Sanctions: ACCEPTANCE, WAIVER, AND CONSENT 3. Date Initiated (MM/DD/YYYY): 10/25/1999 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: MRD 199700194 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Equity - OTC Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ON OCTOBER 25, 1999, SYNOVUS SECURITIES,INC RECEIVED AN UNEXECUTED LETTER OF ACCEPTANCE, WAIVER AND CONSENT FOR THE NASD. THE "AWC" RELATED TO ALLEGED TRADE REPORTING VIOLATIONS FOR TRADE DATES JUNE 2,1997 THROUGH JUNE 13, 1997. SSI HAS EXECUTED THE "AWC" AND ACCEPTS AND CONSENTS, WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, TO THE ENTRY OF THE FINDING BY NASD REGULATION INC. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 05/31/2000 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 8,500.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: TOTAL FINE OF $8,500 WAS PAID ON 06/20/2000 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). ON OCTOBER 27,1999, SSI SUBMITTED AN EXECUTED LETTER OF ACCEPTANCE, WAIVER AND CONSENT FOR REVIEW BY THE NASD. AN $8,500.00 MONETARY SANCTION WAS PAID ON 6/20/2000.
Show 4 more source blocks
regulatory · block 7PDF pages 48–50
- Regulator name — filed text
- ATLANTA OFFICE OF THE SEC
- Monetary/Fine Amount — filed text
- $ 200,000.00
- How was matter resolved — filed text
- Decision & Order of Offer of Settlement
Action status / disposition — filed text
SSI HAS AGREED TO HIRE A CONSULTANT TO REVIEW ITS COMPLIANCE PROCEDURES AND MAINTAIN SAFEGUARDS TO INSURE COMPLIANCE WITH WITH APPLICABLE LAWS
Other filed details
Description of allegations — filed text
THE SEC ALLEGED THAT CONTRARY TO ITS REGULATORS, SYNOVUS SECURITIES THROUGH ITS NOW RETIRED PRESIDENT, CLARK REED, JR., INTERPOSED A THIRD PARTY BETWEEN ITSELF AND THE MARKET IN OVER 120 MUNICIPAL TRADES FOR 1988 TO 1991
Sanction detail — filed text
SSI WAS CENSURED BY THE SEC, PAID TO THE SEC A $200,000 CIVIL PENALTY, HAS AGREED TO MAINTAIN SAFEGUARDS TO INSURE COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS AND AGREED TO HIRE A CONSULTANT TO REVIEW ITS COMPLIANCE PROCEDURES
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) ATLANTA OFFICE OF THE SEC 2. Principal Sanction: Other Sanctions: CIVIL AND ADMINISTRATIVE CEASE AND DESIST 3. Date Initiated (MM/DD/YYYY): 07/05/1994 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Debt - Municipal Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE SEC ALLEGED THAT CONTRARY TO ITS REGULATORS, SYNOVUS SECURITIES THROUGH ITS NOW RETIRED PRESIDENT, CLARK REED, JR., INTERPOSED A THIRD PARTY BETWEEN ITSELF AND THE MARKET IN OVER 120 MUNICIPAL TRADES FOR 1988 TO 1991 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Decision & Order of Offer of Settlement 11. Resolution Date (MM/DD/YYYY): 07/05/1994 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 200,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: SSI AGREED TO HIRE A CONSULTANT TO REVIEW ITS COMPLIANCE PROCEDURES AND TO MAINTAIN SAFEGUARDS ALREADY INSTALLED TO INSURE COMPLIANCE Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: SSI WAS CENSURED BY THE SEC, PAID TO THE SEC A $200,000 CIVIL PENALTY, HAS AGREED TO MAINTAIN SAFEGUARDS TO INSURE COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS AND AGREED TO HIRE A CONSULTANT TO REVIEW ITS COMPLIANCE PROCEDURES 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). SSI HAS AGREED TO HIRE A CONSULTANT TO REVIEW ITS COMPLIANCE PROCEDURES AND MAINTAIN SAFEGUARDS TO INSURE COMPLIANCE WITH WITH APPLICABLE LAWS
regulatory · block 8PDF pages 50–52
- Regulator name — filed text
- NATIONAL ASSOCIATION OF SECURITIES DEALERS
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
FROM APPROXIMATELY FEBRUARY 1999 TO FEBRUARY 2002, A REGISTERED REPRESENTATIVE OF SSI PERPETRATED A SCHEME WHERE IN HE CONVERTED AT LEAST $477,000 TO HIS OWN USE & BENEFIT FROM FOUR CUSTOMER ACCOUNTS. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES IN EFFECT DURING THIS TIME PERIOD OUTLINED CERTAIN REQUIREMENTS FOR CHANGING CUSTOMER ADDRESSES BUT DID NOT CALL FOR THE FIRM TO MONITOR REPORTS OF ADDRESS CHANGES OR FOR REVIEWING A CONCENTRATION OF UNRELATED ACCOUNTS LISTING THE SAME ADDRESS. LIKEWISE, THE FIRM'S PROCEDURES PROVIDED REQUIREMENTS FOR WIRE TRANSFERS FROM CUSTOMER ACCOUNTS, BUT DID NOT REQUIRE CUSTOMER SIGNATURES OR OTHER CONTROLS TO EFFECT WIRE TRANSFERS OR THE ISSUANCE OF CHECKS FROM A CLIENT ACCOUNT.
Other filed details
Description of allegations — filed text
THE NASD ALLEGED THAT SSI FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE ADEQUATE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED WITH A VIEW TOWARDS PREVENTING CONVERSION OR MISUSE OF FUNDS.
Sanction detail — filed text
ON JANUARY 26,2004, SSI SIGNED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT FROM THE NASD. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS THAT SSI FAILED TO ESTABLISH, MAINTAIN, & ENFORCE ADEQUATE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED WITH A VIEW TOWARDS PREVENTING CONVERSION OR MISUSE OF FUNDS. SSI AGREED TO CENSURE & A $10,000 FINE.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) NATIONAL ASSOCIATION OF SECURITIES DEALERS 2. Principal Sanction: Censure Other Sanctions: $10,000 FINE 3. Date Initiated (MM/DD/YYYY): 01/26/2004 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: C07040013 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE NASD ALLEGED THAT SSI FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE ADEQUATE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED WITH A VIEW TOWARDS PREVENTING CONVERSION OR MISUSE OF FUNDS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 02/06/2004 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 10,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: N/A Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ON JANUARY 26,2004, SSI SIGNED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT FROM THE NASD. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS THAT SSI FAILED TO ESTABLISH, MAINTAIN, & ENFORCE ADEQUATE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED WITH A VIEW TOWARDS PREVENTING CONVERSION OR MISUSE OF FUNDS. SSI AGREED TO CENSURE & A $10,000 FINE. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). FROM APPROXIMATELY FEBRUARY 1999 TO FEBRUARY 2002, A REGISTERED REPRESENTATIVE OF SSI PERPETRATED A SCHEME WHERE IN HE CONVERTED AT LEAST $477,000 TO HIS OWN USE & BENEFIT FROM FOUR CUSTOMER ACCOUNTS. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES IN EFFECT DURING THIS TIME PERIOD OUTLINED CERTAIN REQUIREMENTS FOR CHANGING CUSTOMER ADDRESSES BUT DID NOT CALL FOR THE FIRM TO MONITOR REPORTS OF ADDRESS CHANGES OR FOR REVIEWING A CONCENTRATION OF UNRELATED ACCOUNTS LISTING THE SAME ADDRESS. LIKEWISE, THE FIRM'S PROCEDURES PROVIDED REQUIREMENTS FOR WIRE TRANSFERS FROM CUSTOMER ACCOUNTS, BUT DID NOT REQUIRE CUSTOMER SIGNATURES OR OTHER CONTROLS TO EFFECT WIRE TRANSFERS OR THE ISSUANCE OF CHECKS FROM A CLIENT ACCOUNT.
regulatory · block 9PDF pages 52–54
- Regulator name — filed text
- STATE OF FLORIDA, OFFICE OF FINANCIAL REGULATION
- Monetary/Fine Amount — filed text
- $ 37,500.00
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
OVER A PERIOD OF SEVERAL YEARS, SSI DESIGNATED 15 BRANCH OFFICES IN FLORIDA ON ITS SCHEDULE E WITH THE NASD AND CONDUCTED BUSINESS FROM THESE LOCATIONS. SSI WAS UNAWARE THAT FURTHER ACTION WOULD BE REQUIRED TO FILE THESE LOCATIONS WITH THE STATE OF FLORIDA AND HAD PREVIOUSLY INFORMED THE STATE OF FLORIDA THAT IT MAINTAINED BRANCH OFFICES IN THE STATE. THE STATE OF FLORIDA ALLEGED THE FAILURE TO REGISTER THE BRANCH OFFICES WITH THE STATE OF FLORIDA VIOLATED CHAPTER 517 OF THE FLORIDA STATUTES. ON JUNE 14, 2006, SSI, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AGREED TO A STIPULATION AND CONSENT AGREEMENT.
Other filed details
Description of allegations — filed text
OVER A PERIOD OF SEVERAL YEARS, SSI DESIGNATED 15 BRANCH OFFICES IN FLORIDA ON ITS SCHEDULE E WITH THE NASD AND CONDUCTED BUSINESS FROM THESE LOCATIONS. SSI WAS UNAWARE THAT FURTHER ACTION WOULD BE REQUIRED TO FILE THESE LOCATIONS WITH THE STATE OF FLORIDA AND HAD PREVIOUSLY INFORMED THE STATE OF FLORIDA THAT IT MAINTAINED BRANCH OFFICES IN THE STATE. THE STATE OF FLORIDA ALLEGED THE FAILURE TO REGISTER THE BRANCH OFFICES WITH THE STATE OF FLORIDA VIOLATED CHAPTER 517 OF THE FLORIDA STATUTES. ON JUNE 14, 2006, SSI, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AGREED TO A STIPULATION AND CONSENT AGREEMENT.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) STATE OF FLORIDA, OFFICE OF FINANCIAL REGULATION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: STIPULATION & CONSENT AGREEMENT 3. Date Initiated (MM/DD/YYYY): 06/01/2006 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 0273-S-6/06 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): OVER A PERIOD OF SEVERAL YEARS, SSI DESIGNATED 15 BRANCH OFFICES IN FLORIDA ON ITS SCHEDULE E WITH THE NASD AND CONDUCTED BUSINESS FROM THESE LOCATIONS. SSI WAS UNAWARE THAT FURTHER ACTION WOULD BE REQUIRED TO FILE THESE LOCATIONS WITH THE STATE OF FLORIDA AND HAD PREVIOUSLY INFORMED THE STATE OF FLORIDA THAT IT MAINTAINED BRANCH OFFICES IN THE STATE. THE STATE OF FLORIDA ALLEGED THE FAILURE TO REGISTER THE BRANCH OFFICES WITH THE STATE OF FLORIDA VIOLATED CHAPTER 517 OF THE FLORIDA STATUTES. ON JUNE 14, 2006, SSI, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AGREED TO A STIPULATION AND CONSENT AGREEMENT. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 06/26/2006 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 37,500.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, p j p g p ( p Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE STIPULATION AND CONSENT AGREEMENT WAS SIGNED BY SSI ON 06/14/2006 AND SENT TO THE STATE OF FLORIDA, OFFICE OF FINANCIAL REGULATION. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). OVER A PERIOD OF SEVERAL YEARS, SSI DESIGNATED 15 BRANCH OFFICES IN FLORIDA ON ITS SCHEDULE E WITH THE NASD AND CONDUCTED BUSINESS FROM THESE LOCATIONS. SSI WAS UNAWARE THAT FURTHER ACTION WOULD BE REQUIRED TO FILE THESE LOCATIONS WITH THE STATE OF FLORIDA AND HAD PREVIOUSLY INFORMED THE STATE OF FLORIDA THAT IT MAINTAINED BRANCH OFFICES IN THE STATE. THE STATE OF FLORIDA ALLEGED THE FAILURE TO REGISTER THE BRANCH OFFICES WITH THE STATE OF FLORIDA VIOLATED CHAPTER 517 OF THE FLORIDA STATUTES. ON JUNE 14, 2006, SSI, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AGREED TO A STIPULATION AND CONSENT AGREEMENT.
regulatory · block 10PDF pages 54–56
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 315,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
FIRM REMEDIATED AND ADOPTED ADDITIONAL WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO SUPERVISE PROPER COMPLETION OF ELECTRONIC SIGNATURES.
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO SANCTIONS AND FINDINGS THAT, FROM JANUARY 2022 TO SEPTEMBER 2025, SYNOVUS FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ADDRESS FORGERY AND FALSIFICATION OF ELECTRONIC SIGNATURES. AS A RESULT, THE FIRM DID NOT DETECT THAT ASSOCIATED PERSONS AT ONE BRANCH COLLECTIVELY FORGED OR FALSIFIED CUSTOMER SIGNATURES ON OVER 150 DOCUMENTS AND THAT FIRM PERSONNEL FORGED OR FALSIFIED REGISTERED REPRESENTATIVES' SIGNATURES ON MORE THAN 500 DOCUMENTS. THESE ACTIONS CAUSED THE FIRM TO MAINTAIN INACCURATE BOOKS AND RECORDS, VIOLATING FINRA RULES 3110, 4511, AND 2010, SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934, AND EXCHANGE ACT RULE 13A-3.
Sanction detail — filed text
FIRM WAS CENSURED AND FINED $315,000.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FINRA 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CENSURE 3. Date Initiated (MM/DD/YYYY): 10/02/2025 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2023080354703 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO SANCTIONS AND FINDINGS THAT, FROM JANUARY 2022 TO SEPTEMBER 2025, SYNOVUS FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ADDRESS FORGERY AND FALSIFICATION OF ELECTRONIC SIGNATURES. AS A RESULT, THE FIRM DID NOT DETECT THAT ASSOCIATED PERSONS AT ONE BRANCH COLLECTIVELY FORGED OR FALSIFIED CUSTOMER SIGNATURES ON OVER 150 DOCUMENTS AND THAT FIRM PERSONNEL FORGED OR FALSIFIED REGISTERED REPRESENTATIVES' SIGNATURES ON MORE THAN 500 DOCUMENTS. THESE ACTIONS CAUSED THE FIRM TO MAINTAIN INACCURATE BOOKS AND RECORDS, VIOLATING FINRA RULES 3110, 4511, AND 2010, SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934, AND EXCHANGE ACT RULE 13A-3. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 10/03/2025 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 315,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: FIRM WAS CENSURED AND FINED $315,000. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). FIRM REMEDIATED AND ADOPTED ADDITIONAL WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO SUPERVISE PROPER COMPLETION OF ELECTRONIC SIGNATURES.
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