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 Raymond James Financial Services Advisors, 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 Raymond James Financial Services Advisors, Inc..
No indirect ownership information reported in the source’s Schedule B.
Reported ownership and control details
Form ADV · Filing date 2026-09-21 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | RAYMOND JAMES FINANCIAL, INC.CORPORATIONDomestic entity | RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC | 75% or moreCode E | Yes | CORPORATION09/1973 | Schedule APDF page 56 |
| 2 | SCOTT CURTISDIRECTORIndividual | RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC | Less than 5%Code NA | Yes | DIRECTOR01/2012 | Schedule APDF page 56 |
| 3 | JONATHAN SANTELLIGENERAL COUNSELIndividual | RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC | Less than 5%Code NA | No | GENERAL COUNSEL05/2016 | Schedule APDF page 56 |
| 4 | Philip Roger MartinRIA CHIEF COMPLIANCE OFFICERIndividual | RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC | Less than 5%Code NA | Yes | RIA CHIEF COMPLIANCE OFFICER08/2019 | Schedule APDF page 56 |
| 5 | KEITH GREGORY RUSTDIRECTORIndividual | RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC | Less than 5%Code NA | Yes | DIRECTOR11/2019 | Schedule APDF page 56 |
| 6 | BROCK AARON GUICESECRETARYIndividual | RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC | Less than 5%Code NA | Yes | SECRETARY11/2019 | Schedule APDF page 56 |
| 7 | TASHTEGO SPRING ELWYNDIRECTOR; CHAIRMAN OF THE BOARD; PRESIDENT; CHIEF EXECUTIVE OFFICERIndividual | RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC | Less than 5%Code NA | Yes | DIRECTOR; CHAIRMAN OF THE BOARD; PRESIDENT; CHIEF EXECUTIVE OFFICER08/2022 | Schedule APDF page 56 |
| 8 | STEPHEN EDWARD KRUCHTENDIRECTORIndividual | RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC | Less than 5%Code NA | Yes | DIRECTOR02/2024 | Schedule APDF page 56 |
| 9 | RONICE L. BARLOWCHIEF OPERATING OFFICERIndividual | RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC | Less than 5%Code NA | Yes | CHIEF OPERATING OFFICER03/2025 | Schedule APDF page 56 |
| 10 | DOUGLAS CLARK BRIGMANDIRECTORIndividual | RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC | Less than 5%Code NA | Yes | DIRECTOR11/2025 | Schedule APDF page 56 |
| 11 | Kirk Edward BellDIRECTOR; PRESIDENT, ICDIndividual | RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC | Less than 5%Code NA | Yes | DIRECTOR; PRESIDENT, ICD04/2026 | Schedule APDF page 56 |
| 12 | WILLIAM CHRISTIAN GEISDIRECTORIndividual | RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC | Less than 5%Code NA | Yes | DIRECTOR08/2026 | Schedule APDF page 56 |
| 13 | ANDREW CANNING ZOLPERDIRECTORIndividual | RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC | Less than 5%Code NA | Yes | DIRECTOR08/2026 | Schedule APDF page 56 |
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 9/21/2026 9:55:53 AM
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 actions4 Yes1 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?Yes
- 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?Yes
- 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 actions3 Yes2 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?Yes
- 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?Yes
- 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 actions3 Yes1 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?Yes
- 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?Yes
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 Yes
- 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?Yes
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 25 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 1RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 57–59
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
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 CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 2RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 59–60
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
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 CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 3RAYMOND JAMES & ASSOCIATES, INC.PDF pages 60–62
- Advisory affiliate name — filed text
- RAYMOND JAMES & ASSOCIATES, INC.
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 CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 4PDF pages 62–65
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 17,000,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
C
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, AND ITS AMLCO, FAILED TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES TO REASONABLY DETECT AND CAUSE THE REPORTING OF SUSPICIOUS TRANSACTIONS. THE FINDINGS STATED THAT AS THE FIRM'S AMLCO, THE REPRESENTATIVE WAS RESPONSIBLE FOR ENSURING THAT THE FIRM'S AML PROGRAM WAS ADEQUATELY TAILORED TO THE FIRM'S BUSINESS AND FOR APPROPRIATELY MONITORING, DETECTING AND REPORTING SUSPICIOUS ACTIVITY. DESPITE THE SEPARATE AML DEPARTMENTS AND PROGRAMS, THE FIRM AS A CLEARING FIRM, ITS AMLCO, AND THE FIRM FOR WHICH THE FIRM SERVED AS CLEARING FIRM CREATED A SYSTEM UNDER WHICH THIS FIRM HEAVILY RELIED UPON ITS CLEARING FIRM TO PROVIDE CERTAIN SYSTEMS AND TOOLS AS PART OF THE FIRM'S AML PROGRAM. THE FIRM FAILED TO COMMIT ADEQUATE RESOURCES TO THE FIRM'S AML PROGRAMS. THE FIRM'S STAFFING OF ITS AML DEPARTMENTS WAS INADEQUATE IN LIGHT OF THE EXTENSIVE RESPONSIBILITIES ASSIGNED TO THE FEW INDIVIDUALS, INCLUDING THE LABOR-INTENSIVE MANUAL REVIEWS, PARTICULARLY IN LIGHT OF THE FIRM'S GROWTH. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND IMPLEMENT AML PROCEDURES AND SYSTEMS REASONABLY EXPECTED TO DETECT SUSPICIOUS ACTIVITY. THE FIRM FAILED TO ESTABLISH REASONABLE WRITTEN PROCEDURES FOR CERTAIN ASPECTS OF THE FIRM'S AML PROGRAMS. THE FIRM FAILED TO ESTABLISH REASONABLE AML SYSTEMS TAILORED TO ITS BUSINESS. THE AML PROCEDURES THAT WERE IN PLACE REQUIRED THE FIRM TO REVIEW ACCOUNTS FOR POTENTIAL SUSPICIOUS ACTIVITY. THE FIRM, HOWEVER, FAILED TO DEVELOP AND IMPLEMENT SURVEILLANCE REPORTS TAILORED TO DETECT CERTAIN TYPES OF POTENTIALLY SUSPICIOUS TRANSACTIONS. FOR EXAMPLE, THE FIRM HAD NO WRITTEN PROCEDURES REQUIRING REVIEW OF, OR SURVEILLANCE REPORTS MONITORING FOR, THE FOLLOWING HIGH-RISK ACTIVITIES: TRANSFERS OF FUNDS TO UNRELATED ACCOUNTS WITHOUT ANY APPARENT BUSINESS PURPOSE; JOURNALING SECURITIES AND CASH BETWEEN UNRELATED ACCOUNTS FOR NO APPARENT BUSINESS PURPOSE, PARTICULARLY INTERNAL TRANSFERS OF CASH FROM CUSTOMER ACCOUNTS TO EMPLOYEE OR EMPLOYEE-RELATED ACCOUNTS; AND MOVEMENT OF FUNDS, BY WIRE TRANSFER OR OTHERWISE, FROM MULTIPLE ACCOUNTS TO THE SAME THIRD PARTY ACCOUNT. THE FIRM'S SURVEILLANCE REPORTS FAILED TO REASONABLY MONITOR FOR SUSPICIOUS ACTIVITY. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO REASONABLY INVESTIGATE RED FLAGS. AS A RESULT OF THE FIRM'S AML PROCEDURES, THE FIRM HAD GAPS IN ITS SURVEILLANCE OF ACTIVITY FOR AML RED FLAGS. EVEN WHEN THE EXCEPTION REPORTS OR OTHER SURVEILLANCE IDENTIFIED RED FLAGS, THE FIRM FAILED TO REASONABLY INVESTIGATE MANY INSTANCES IN ORDER TO DETERMINE WHETHER A SAR SHOULD BE FILED. ALSO, ALTHOUGH THE FIRM AML ANALYSTS IDENTIFIED SOME RED FLAGS AND OPENED INVESTIGATIONS, THE INVESTIGATIONS WERE DEFICIENT. FINRA FOUND THAT THE FIRM FAILED TO REASONABLY ENFORCE ITS DUE DILIGENCE PROCEDURES FOR CERTAIN CORRESPONDENT ACCOUNTS OF CERTAIN FOREIGN FINANCIAL INSTITUTIONS (FFIS). MOREOVER, THE FIRM ALSO HAD NO RELIABLE PERIODIC REVIEW PROCESS IN PLACE TO ENSURE THAT THE ACTIVITY IN THE FFIS' ACCOUNTS WAS CONSISTENT WITH REPRESENTATIONS MADE BY FFIS AT THE TIME OF ACCOUNT OPENING. THIS FAILURE RESULTED IN THE FIRM PERFORMING NO PERIODIC RISK REVIEWS OF A PORTUGUESE FFI ACCOUNT, EVEN THOUGH THE FFI WAS ASSIGNED A HIGH-RISK RATING BY THE FIRM. FINRA ALSO FOUND THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECTION 5 OF THE SECURITIES ACT THROUGH INCOMPLETE RISK REVIEWS, DUE DILIGENCE FAILURES, AND FAILURES TO IMPLEMENT EXISTING PROCEDURES RELEVANT TO LOW PRICED SECURITIES.
Sanction detail — filed text
THE FIRMS WERE CENSURED, FINED $8,000,000 (RJA) AND $9,000,000 (RJFS) AND REQUIRED TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF ITS AML AND SUPERVISORY POLICIES, SYSTEMS, PROCEDURES, AND TRAINING. AT THE CONCLUSION OF THE REVIEW, WHICH SHALL BE NO MORE THAN 180 DAYS AFTER THE DATE OF THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALL CERTIFY THAT ITS PROCEDURES ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 3310. THE CERTIFICATION SHALL BE PROVIDED IN A WRITTEN LETTER TO FINRA. THE LETTER SHALL BE ACCOMPANIED BY A WRITTEN REPORT, AT A MINIMUM, STATING (I) THE ADEQUACY OF THE FIRM'S POLICIES, SYSTEMS, PROCEDURES AND TRAINING RELATING TO AML AND SUPERVISION; (II) A DESCRIPTION OF THE REVIEW PERFORMED AND THE CONCLUSIONS REACHED; AND (III) RECOMMENDATIONS FOR MODIFICATIONS AND ADDITIONS TO THE FIRM'S POLICIES, SYSTEMS, PROCEDURES AND TRAINING. THE $17,000,000 FINE WAS PAID ON 5/26/16.
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 CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) 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: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 05/18/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2014043592001 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Annuity(ies) - Variable Other Product Types: LOW PRICED SECURITIES 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 THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, AND ITS AMLCO, FAILED TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES TO REASONABLY DETECT AND CAUSE THE REPORTING OF SUSPICIOUS TRANSACTIONS. THE FINDINGS STATED THAT AS THE FIRM'S AMLCO, THE REPRESENTATIVE WAS RESPONSIBLE FOR ENSURING THAT THE FIRM'S AML PROGRAM WAS ADEQUATELY TAILORED TO THE FIRM'S BUSINESS AND FOR APPROPRIATELY MONITORING, DETECTING AND REPORTING SUSPICIOUS ACTIVITY. DESPITE THE SEPARATE AML DEPARTMENTS AND PROGRAMS, THE FIRM AS A CLEARING FIRM, ITS AMLCO, AND THE FIRM FOR WHICH THE FIRM SERVED AS CLEARING FIRM CREATED A SYSTEM UNDER WHICH THIS FIRM HEAVILY RELIED UPON ITS CLEARING FIRM TO PROVIDE CERTAIN SYSTEMS AND TOOLS AS PART OF THE FIRM'S AML PROGRAM. THE FIRM FAILED TO COMMIT ADEQUATE RESOURCES TO THE FIRM'S AML PROGRAMS. THE FIRM'S STAFFING OF ITS AML DEPARTMENTS WAS INADEQUATE IN LIGHT OF THE EXTENSIVE RESPONSIBILITIES ASSIGNED TO THE FEW INDIVIDUALS, INCLUDING THE LABOR-INTENSIVE MANUAL REVIEWS, PARTICULARLY IN LIGHT OF THE FIRM'S GROWTH. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND IMPLEMENT AML PROCEDURES AND SYSTEMS REASONABLY EXPECTED TO DETECT SUSPICIOUS ACTIVITY. THE FIRM FAILED TO ESTABLISH REASONABLE WRITTEN PROCEDURES FOR CERTAIN ASPECTS OF THE FIRM'S AML PROGRAMS. THE FIRM FAILED TO ESTABLISH REASONABLE AML SYSTEMS TAILORED TO ITS BUSINESS. THE AML PROCEDURES THAT WERE IN PLACE REQUIRED THE FIRM TO REVIEW ACCOUNTS FOR POTENTIAL SUSPICIOUS ACTIVITY. THE FIRM, HOWEVER, FAILED TO DEVELOP AND IMPLEMENT SURVEILLANCE REPORTS TAILORED TO DETECT CERTAIN TYPES OF POTENTIALLY SUSPICIOUS TRANSACTIONS. FOR EXAMPLE, THE FIRM HAD NO WRITTEN PROCEDURES REQUIRING REVIEW OF, OR SURVEILLANCE REPORTS MONITORING FOR, THE FOLLOWING HIGH-RISK ACTIVITIES: TRANSFERS OF FUNDS TO UNRELATED ACCOUNTS WITHOUT ANY APPARENT BUSINESS PURPOSE; JOURNALING SECURITIES AND CASH BETWEEN UNRELATED ACCOUNTS FOR NO APPARENT BUSINESS PURPOSE, PARTICULARLY INTERNAL TRANSFERS OF CASH FROM CUSTOMER ACCOUNTS TO EMPLOYEE OR EMPLOYEE-RELATED ACCOUNTS; AND MOVEMENT OF FUNDS, BY WIRE TRANSFER OR OTHERWISE, FROM MULTIPLE ACCOUNTS TO THE SAME THIRD PARTY ACCOUNT. THE FIRM'S SURVEILLANCE REPORTS FAILED TO REASONABLY MONITOR FOR SUSPICIOUS ACTIVITY. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO REASONABLY INVESTIGATE RED FLAGS. AS A RESULT OF THE FIRM'S AML PROCEDURES, THE FIRM HAD GAPS IN ITS SURVEILLANCE OF ACTIVITY FOR AML RED FLAGS. EVEN WHEN THE EXCEPTION REPORTS OR OTHER SURVEILLANCE IDENTIFIED RED FLAGS, THE FIRM FAILED TO REASONABLY INVESTIGATE MANY INSTANCES IN ORDER TO DETERMINE WHETHER A SAR SHOULD BE FILED. ALSO, ALTHOUGH THE FIRM AML ANALYSTS IDENTIFIED SOME RED FLAGS AND OPENED INVESTIGATIONS, THE INVESTIGATIONS WERE DEFICIENT. FINRA FOUND THAT THE FIRM FAILED TO REASONABLY ENFORCE ITS DUE DILIGENCE PROCEDURES FOR CERTAIN CORRESPONDENT ACCOUNTS OF CERTAIN FOREIGN FINANCIAL INSTITUTIONS (FFIS). MOREOVER, THE FIRM ALSO HAD NO RELIABLE PERIODIC REVIEW PROCESS IN PLACE TO ENSURE THAT THE ACTIVITY IN THE FFIS' ACCOUNTS WAS CONSISTENT WITH REPRESENTATIONS MADE BY FFIS AT THE TIME OF ACCOUNT OPENING. THIS FAILURE RESULTED IN THE FIRM PERFORMING NO PERIODIC RISK REVIEWS OF A PORTUGUESE FFI ACCOUNT, EVEN THOUGH THE FFI WAS ASSIGNED A HIGH-RISK RATING BY THE FIRM. FINRA ALSO FOUND THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECTION 5 OF THE SECURITIES ACT THROUGH INCOMPLETE RISK REVIEWS, DUE DILIGENCE FAILURES, AND FAILURES TO IMPLEMENT EXISTING PROCEDURES RELEVANT TO LOW PRICED SECURITIES. 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): 05/18/2016 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: $ 17,000,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKING 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: THE FIRMS WERE CENSURED, FINED $8,000,000 (RJA) AND $9,000,000 (RJFS) AND REQUIRED TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF ITS AML AND SUPERVISORY POLICIES, SYSTEMS, PROCEDURES, AND TRAINING. AT THE CONCLUSION OF THE REVIEW, WHICH SHALL BE NO MORE THAN 180 DAYS AFTER THE DATE OF THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALL CERTIFY THAT ITS PROCEDURES ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 3310. THE CERTIFICATION SHALL BE PROVIDED IN A WRITTEN LETTER TO FINRA. THE LETTER SHALL BE ACCOMPANIED BY A WRITTEN REPORT, AT A MINIMUM, STATING (I) THE ADEQUACY OF THE FIRM'S POLICIES, SYSTEMS, PROCEDURES AND TRAINING RELATING TO AML AND SUPERVISION; (II) A DESCRIPTION OF THE REVIEW PERFORMED AND THE CONCLUSIONS REACHED; AND (III) RECOMMENDATIONS FOR MODIFICATIONS AND ADDITIONS TO THE FIRM'S POLICIES, SYSTEMS, PROCEDURES AND TRAINING. THE $17,000,000 FINE WAS PAID ON 5/26/16. 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). C
regulatory · block 5RAYMOND JAMES & ASSOCIATES, INC.PDF pages 65–67
- Advisory affiliate name — filed text
- RAYMOND JAMES & ASSOCIATES, INC.
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 500,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
C
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT CAUSED CERTAIN NEWLY-RECRUITED REGISTERED REPRESENTATIVES FROM OTHER BROKERAGE FIRMS TO DISCLOSE CUSTOMER NONPUBLIC PERSONAL INFORMATION TO IT IN VIOLATION OF REGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934. THE FINDINGS STATED THAT THE FIRM USED THE NONPUBLIC PERSONAL INFORMATION PROVIDED TO PRE-POPULATE NEW ACCOUNT FORMS WITH CERTAIN CUSTOMER INFORMATION. THE FIRM, HOWEVER, FAILED TO MAKE ANY DETERMINATION AS TO WHETHER THE RECRUITS, OR THE CURRENT BROKER-DEALERS WITH WHICH THE RECRUITS WERE ASSOCIATED, HAD OBTAINED THE CUSTOMERS' CONSENT TO PROVIDE THE FIRM WITH THE CUSTOMERS' NONPUBLIC PERSONAL INFORMATION OR PROVIDED CUSTOMERS WITH NOTICE OF, AND AN OPPORTUNITY TO OPT-OUT OF, THE DISCLOSURE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN REASONABLE SUPERVISORY SYSTEMS, INCLUDING WSPS AND TRAINING, TO ENSURE COMPLIANCE WITH REGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934. THE FIRM FAILED TO PREVENT THE IMPROPER SOLICITATION OF NONPUBLIC PERSONAL INFORMATION FROM RECRUITS, FAILED TO ADEQUATELY TRAIN AND EDUCATE ITS STAFF ON WHAT CONSTITUTED NONPUBLIC PERSONAL INFORMATION AND THE APPROPRIATE CIRCUMSTANCES IN WHICH SUCH INFORMATION COULD BE SHARED, AND WITH RESPECT TO REGISTERED REPRESENTATIVES WHO WERE TRANSITIONING FROM THE FIRM TO ANOTHER BROKER-DEALER. IT WAS UNABLE TO DEMONSTRATE THAT ITS WSPS WERE SYSTEMATICALLY FOLLOWED AND ENFORCED.
Sanction detail — filed text
THE FIRM WAS CENSURED, FINED $500,000.00, AND REQUIRED TO REVIEW AND REVISE, AS NECESSARY, ITS POLICIES, PROCEDURES, AND INTERNAL CONTROLS. WITHIN 45 BUSINESS DAYS OF THE ISSUANCE OF THE NOTICE OF ACCEPTANCE OF THIS AWC, THE CHIEF EXECUTIVE OFFICER AND CHIEF COMPLIANCE OFFICER AT THE FIRM SHALL CERTIFY IN WRITING TO FINRA THAT, WITH RESPECT TO THE AREAS DESCRIBED IN THE AWC, (1) THE FIRM HAS ENGAGED IN THE REVIEW DESCRIBED ABOVE; AND (II) AS OF THE DATE OF THIS CERTIFICATION, THE FIRM HAS ESTABLISHED AND IMPLEMENTED POLICIES, PROCEDURES AND INTERNAL CONTROLS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934.
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 CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) 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: Other Other Sanctions: N/A 3. Date Initiated (MM/DD/YYYY): 03/08/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2013035599201 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 THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT CAUSED CERTAIN NEWLY-RECRUITED REGISTERED REPRESENTATIVES FROM OTHER BROKERAGE FIRMS TO DISCLOSE CUSTOMER NONPUBLIC PERSONAL INFORMATION TO IT IN VIOLATION OF REGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934. THE FINDINGS STATED THAT THE FIRM USED THE NONPUBLIC PERSONAL INFORMATION PROVIDED TO PRE-POPULATE NEW ACCOUNT FORMS WITH CERTAIN CUSTOMER INFORMATION. THE FIRM, HOWEVER, FAILED TO MAKE ANY DETERMINATION AS TO WHETHER THE RECRUITS, OR THE CURRENT BROKER-DEALERS WITH WHICH THE RECRUITS WERE ASSOCIATED, HAD OBTAINED THE CUSTOMERS' CONSENT TO PROVIDE THE FIRM WITH THE CUSTOMERS' NONPUBLIC PERSONAL INFORMATION OR PROVIDED CUSTOMERS WITH NOTICE OF, AND AN OPPORTUNITY TO OPT-OUT OF, THE DISCLOSURE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN REASONABLE SUPERVISORY SYSTEMS, INCLUDING WSPS AND TRAINING, TO ENSURE COMPLIANCE WITH REGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934. THE FIRM FAILED TO PREVENT THE IMPROPER SOLICITATION OF NONPUBLIC PERSONAL INFORMATION FROM RECRUITS, FAILED TO ADEQUATELY TRAIN AND EDUCATE ITS STAFF ON WHAT CONSTITUTED NONPUBLIC PERSONAL INFORMATION AND THE APPROPRIATE CIRCUMSTANCES IN WHICH SUCH INFORMATION COULD BE SHARED, AND WITH RESPECT TO REGISTERED REPRESENTATIVES WHO WERE TRANSITIONING FROM THE FIRM TO ANOTHER BROKER-DEALER. IT WAS UNABLE TO DEMONSTRATE THAT ITS WSPS WERE SYSTEMATICALLY FOLLOWED AND ENFORCED. 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): 03/08/2016 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: $ 500,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKING 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: THE FIRM WAS CENSURED, FINED $500,000.00, AND REQUIRED TO REVIEW AND REVISE, AS NECESSARY, ITS POLICIES, PROCEDURES, AND INTERNAL CONTROLS. WITHIN 45 BUSINESS DAYS OF THE ISSUANCE OF THE NOTICE OF ACCEPTANCE OF THIS AWC, THE CHIEF EXECUTIVE OFFICER AND CHIEF COMPLIANCE OFFICER AT THE FIRM SHALL CERTIFY IN WRITING TO FINRA THAT, WITH RESPECT TO THE AREAS DESCRIBED IN THE AWC, (1) THE FIRM HAS ENGAGED IN THE REVIEW DESCRIBED ABOVE; AND (II) AS OF THE DATE OF THIS CERTIFICATION, THE FIRM HAS ESTABLISHED AND IMPLEMENTED POLICIES, PROCEDURES AND INTERNAL CONTROLS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934. 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). C
regulatory · block 6RAYMOND JAMES & ASSOCIATES, INC.PDF pages 67–69
- Advisory affiliate name — filed text
- RAYMOND JAMES & ASSOCIATES, INC.
- Regulator name — filed text
- UNITED STATES SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 600,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THE FIRM HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THE FIRM CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING A CEASE-AND-DESIST ORDER. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, THE FIRM VIOLATED SECTION 206(4) OF THE ADVISERS ACT, AND RULE 206(4)-7 THEREUNDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE TO IMPOSE THE SANCTIONS AGREED TO IN THE FIRM'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THAT PURSUANT TO SECTION 203(K) OF THE ADVISERS ACT, THE FIRM SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, SHALL WITHIN TEN DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $600,000, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER.
Other filed details
Description of allegations — filed text
THIS MATTER ARISES FROM RAYMOND JAMES & ASSOCIATES, INC.'S ("RJA") FAILURE TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES RELATING TO TRADING COMMISSIONS CHARGED TO CLIENTS PARTICIPATING IN THE RAYMOND JAMES CONSULTING SERVICES ("RJCS") SEPARATELY MANAGED ACCOUNT PROGRAM. UNDER THE RJCS PROGRAM, CLIENTS SELECT AN AVAILABLE INVESTMENT MANAGER TO DEVELOP A MODEL PORTFOLIO IN THE CLIENT'S SEPARATELY MANAGED ACCOUNT. RJA CHARGES THE RJCS PROGRAM CLIENTS A NEGOTIABLE "WRAP FEE." IN ADDITION TO THE WRAP FEE, RJA CLIENTS ALSO WERE ASSESSED COMMISSIONS ON CERTAIN EQUITY TRANSACTIONS EXECUTED BY BROKER-DEALERS UNAFFILIATED WITH RJA. ALTHOUGH RJA'S FORM ADV PART 2A BROCHURES DISCLOSE THAT AN INVESTMENT MANAGER MAY DIRECT ITS TRADING TO FIRMS UNAFFILIATED WITH RJA AND THAT ANY COMMISSIONS ASSESSED BY THESE OTHER FIRMS WILL BE IN ADDITION TO THE WRAP FEE CHARGED BY RJA, RJA DID NOT OBTAIN INFORMATION REGARDING THE AMOUNT OF COMMISSIONS CHARGED FOR THESE TRANSACTIONS OR WHETHER THAT AMOUNT WAS MATERIAL. INSTEAD, RJA RECEIVED INFORMATION REGARDING THESE SECURITIES TRANSACTIONS ON A NET BASIS WITH ANY EQUITY COMMISSION COST INCLUDED IN THE PRICE OF THE SECURITY. RJCS PROGRAM CLIENTS ALSO WERE UNAWARE OF THE ACTUAL COMMISSIONS INCURRED FOR TRADING AWAY BECAUSE THEIR ACCOUNT STATEMENTS DISCLOSED ONLY NET PRICES CHARGED PER EQUITY TRADE AND THEY DID NOT RECEIVE INFORMATION ABOUT COMMISSIONS FROM ANY OTHER SOURCE. AS A RESULT, RJA FAILED TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO ALLOW IT TO DETERMINE WHETHER THE RJCS PROGRAM OR PARTICULAR INVESTMENT MANAGERS WERE SUITABLE FOR ITS PROSPECTIVE AND EXISTING RJCS CLIENTS, SUCH AS COLLECTING, TRACKING AND DISCLOSING INFORMATION REGARDING COMMISSIONS ASSOCIATED WITH TRADING AWAY. IN ADDITION, THE FIRM HAD NO POLICIES AND PROCEDURES TO COMMUNICATE TO RJCS PROGRAM CLIENTS THE INVESTMENT MANAGERS' TRADING AWAY PRACTICES AND ASSOCIATED COSTS, AND THEREFORE THOSE CLIENTS DID NOT NECESSARILY HAVE ADEQUATE INFORMATION: (I) TO NEGOTIATE MEANINGFULLY THE WRAP FEE WITH RJA; (II) TO ASSESS THE TOTAL COSTS OF THE RJCS PROGRAM; AND (III) TO DETERMINE WHICH RJCS PROGRAM INVESTMENT MANAGERS TO SELECT. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, THE FIRM VIOLATED SECTION 206(4) OF THE ADVISERS ACT, AND RULE 206(4)-7 THEREUNDER.
Sanction detail — filed text
THE FIRM WAS CENSURED, FINED $600,000 AND ORDERED TO COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER. THE FINE WAS PAID ON 10/12/16.
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
CRD
Number:
705
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
RAYMOND JAMES &
ASSOCIATES, INC.
(For individuals, Last, First,
Middle)
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)
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Other Sanctions:
N/A
3.
Date Initiated (MM/DD/YYYY):
09/08/2016
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-17531
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
UNSPECIFIED SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THIS MATTER ARISES FROM RAYMOND JAMES & ASSOCIATES, INC.'S ("RJA") FAILURE TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES RELATING
TO TRADING COMMISSIONS CHARGED TO CLIENTS PARTICIPATING IN THE RAYMOND JAMES CONSULTING SERVICES ("RJCS") SEPARATELY MANAGED
ACCOUNT PROGRAM. UNDER THE RJCS PROGRAM, CLIENTS SELECT AN AVAILABLE INVESTMENT MANAGER TO DEVELOP A MODEL PORTFOLIO IN THE
CLIENT'S SEPARATELY MANAGED ACCOUNT. RJA CHARGES THE RJCS PROGRAM CLIENTS A NEGOTIABLE "WRAP FEE." IN ADDITION TO THE WRAP FEE,
RJA CLIENTS ALSO WERE ASSESSED COMMISSIONS ON CERTAIN EQUITY TRANSACTIONS EXECUTED BY BROKER-DEALERS UNAFFILIATED WITH RJA.
ALTHOUGH RJA'S FORM ADV PART 2A BROCHURES DISCLOSE THAT AN INVESTMENT MANAGER MAY DIRECT ITS TRADING TO FIRMS UNAFFILIATED WITH
RJA AND THAT ANY COMMISSIONS ASSESSED BY THESE OTHER FIRMS WILL BE IN ADDITION TO THE WRAP FEE CHARGED BY RJA, RJA DID NOT OBTAIN
INFORMATION REGARDING THE AMOUNT OF COMMISSIONS CHARGED FOR THESE TRANSACTIONS OR WHETHER THAT AMOUNT WAS MATERIAL.
INSTEAD, RJA RECEIVED INFORMATION REGARDING THESE SECURITIES TRANSACTIONS ON A NET BASIS WITH ANY EQUITY COMMISSION COST
INCLUDED IN THE PRICE OF THE SECURITY. RJCS PROGRAM CLIENTS ALSO WERE UNAWARE OF THE ACTUAL COMMISSIONS INCURRED FOR TRADING
AWAY BECAUSE THEIR ACCOUNT STATEMENTS DISCLOSED ONLY NET PRICES CHARGED PER EQUITY TRADE AND THEY DID NOT RECEIVE INFORMATION
ABOUT COMMISSIONS FROM ANY OTHER SOURCE. AS A RESULT, RJA FAILED TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY
DESIGNED TO ALLOW IT TO DETERMINE WHETHER THE RJCS PROGRAM OR PARTICULAR INVESTMENT MANAGERS WERE SUITABLE FOR ITS
PROSPECTIVE AND EXISTING RJCS CLIENTS, SUCH AS COLLECTING, TRACKING AND DISCLOSING INFORMATION REGARDING COMMISSIONS
ASSOCIATED WITH TRADING AWAY. IN ADDITION, THE FIRM HAD NO POLICIES AND PROCEDURES TO COMMUNICATE TO RJCS PROGRAM CLIENTS THE
INVESTMENT MANAGERS' TRADING AWAY PRACTICES AND ASSOCIATED COSTS, AND THEREFORE THOSE CLIENTS DID NOT NECESSARILY HAVE
ADEQUATE INFORMATION: (I) TO NEGOTIATE MEANINGFULLY THE WRAP FEE WITH RJA; (II) TO ASSESS THE TOTAL COSTS OF THE RJCS PROGRAM; AND
(III) TO DETERMINE WHICH RJCS PROGRAM INVESTMENT MANAGERS TO SELECT. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, THE FIRM
VIOLATED SECTION 206(4) OF THE ADVISERS ACT, AND RULE 206(4)-7 THEREUNDER.
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:
Order
11. Resolution Date (MM/DD/YYYY):
09/08/2016
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: $ 600,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
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:
THE FIRM WAS CENSURED, FINED $600,000 AND ORDERED TO COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER. THE FINE WAS
PAID ON 10/12/16.
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).
IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THE FIRM HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS
DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE
COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THE
COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THE FIRM CONSENTS TO THE
ENTRY OF THIS ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940,
MAKING FINDINGS, AND IMPOSING A CEASE-AND-DESIST ORDER. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, THE FIRM VIOLATED SECTION
206(4) OF THE ADVISERS ACT, AND RULE 206(4)-7 THEREUNDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE TO IMPOSE
THE SANCTIONS AGREED TO IN THE FIRM'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THAT PURSUANT TO SECTION 203(K) OF THE ADVISERS ACT,
THE FIRM SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THE
ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, SHALL WITHIN TEN DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE
AMOUNT OF $600,000, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER.Show 19 more source blocks
regulatory · block 7PDF pages 69–71
- Regulator name — filed text
- MASSACHUSETTS
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
MONETARY FINE OF $75,000 PAID AND MASSACHUSETTS INVESTMENT ADVISER REPRESENTATIVE REGISTRATION PROCEDURES REVIEWED TO ENSURE COMPLIANCE WITH REGISTRATION REQUIREMENTS.
Other filed details
Description of allegations — filed text
COMMONWEALTH OF MASSACHUSETTS ALLEGED FAILURE TO REGISTER INVESTMENT ADVISER REPRESENTATIVE WHO HAD A PLACE OF BUSINESS IN MASSACHUSETTS AND TO ENSURE INVESTMENT ADVISER REPRESENTATIVE WAS PROPERLY REGISTERED WITH THE COMMONWEALTH.
Sanction detail — filed text
MONETARY FINE OF $75,000 PAID ON 06/14/2017
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) MASSACHUSETTS 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: ADMINISTRATIVE FINE, RETURN OF ADVISORY FEES 3. Date Initiated (MM/DD/YYYY): 06/09/2017 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2017-0016 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): COMMONWEALTH OF MASSACHUSETTS ALLEGED FAILURE TO REGISTER INVESTMENT ADVISER REPRESENTATIVE WHO HAD A PLACE OF BUSINESS IN MASSACHUSETTS AND TO ENSURE INVESTMENT ADVISER REPRESENTATIVE WAS PROPERLY REGISTERED WITH THE COMMONWEALTH. 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): 06/09/2017 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: RESPONDENT RETURNED ALL ADVISORY FEES RECEIVED PURSUANT TO THE ALLEGED UNREGISTERED ACTIVITY. RESPONDENT REVIEWED ITS POLICIES AND PROCEDURES TO ENSURE COMPLIANCE WITH REGISTRATION REQUIREMENTS 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: MONETARY FINE OF $75,000 PAID ON 06/14/2017 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). MONETARY FINE OF $75,000 PAID AND MASSACHUSETTS INVESTMENT ADVISER REPRESENTATIVE REGISTRATION PROCEDURES REVIEWED TO ENSURE COMPLIANCE WITH REGISTRATION REQUIREMENTS.
regulatory · block 8RAYMOND JAMES & ASSOCIATES, INC.PDF pages 71–72
- Advisory affiliate name — filed text
- RAYMOND JAMES & ASSOCIATES, INC.
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 CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 9RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 72–74
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 2,000,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") ENTERED FINDINGS THAT RAYMOND JAMES FINANCIAL SERVICES, INC., FAILED TO ESTABLISH, MAINTAIN, AND SUPERVISE A SUPERVISORY SYSTEM IN CONNECTION WITH REVIEW OF EMAIL COMMUNICATIONS. WITHOUT ADMITTING OR DENYING THE FINDINGS, ON DECEMBER 21, 2017, THE FIRM CONSENTED TO A CENSURE AND FINE OF $2,000,000 AND IS ADOPTING AND IMPLEMENTING SUPERVISORY POLICIES TO ADDRESS THE DEFICIENCIES.
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING FINRA'S FINDINGS, RAYMOND JAMES FINANCIAL SERVICES ("RJFS" OR "FIRM") CONSENTED TO THE SANCTIONS IMPOSED BY FINRA AND TO THE ENTRY OF FINDINGS THAT, BETWEEN DECEMBER 2007 AND SEPTEMBER 2017, RJFS DID NOT HAVE SUPERVISORY SYSTEMS AND PROCESS FOR REVIEWING EMAIL COMMUNICATIONS THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE LEGAL REQUIREMENTS OR APPROPRIATE FOR THE FIRM'S BUSINESS, SIZE, STRUCTURE AND CUSTOMERS, AS A RESULT, FINRA FOUND THAT RJFS VIOLATED NASD RULES 3010 AND 2110 AND FINRA RULES 3110 AND 2010. IN PARTICULAR, FINRA FOUND THAT (1) THE FIRMS' AUTOMATED LEXICON- BASED SYSTEM TO SURVEIL THE E-MAILS OF ITS PERSONNEL WAS FLAWED IN SIGNIFICANT RESPECTS, (2) THE FIRM FAILED TO DEVOTE ADEQUATE PERSONNEL AND RESOURCES TO THE TEAM THAT REVIEWED E-MAILS, (3) THE FIRM FAILED TO APPLY ALL OF ITS POLICIES IN ITS PRIMARY LEXICON TO BRANCH OFFICES THAT HAD THEIR OWN EMAIL SERVERS, AND (4) THE FIRM DID NOT PERIODICALLY TEST THE CONFIGURATION AND EFFECTIVENESS OF ITS EMAIL SURVEILLANCE SYSTEM. THE FIRM WAS CENSURED, FINED $2 MILLION, AND AGREED TO CERTAIN UNDERTAKINGS TO ADDRESS THE IDENTIFIED DEFICIENCIES.
Sanction detail — filed text
THE FIRM WAS CENSURED, FINED $2 MILLION AND UNDERTAKES TO CERTIFY IN WRITING TO FINRA THAT IT HAS ADOPTED AND IMPLEMENTED WRITTEN SUPERVISORY POLICIES, PROCEDURES, AND SYSTEMS INCLUDING, IF UTILIZED, AN APPROPRIATE EMAIL REVIEW LEXICON, THAT ARE REASONABLY DESIGNED TO ADDRESS EACH OF THE DEFICIENCIES IDENTIFIED IN THIS AWC AND THAT IT HAS (I) COMPLETED A RISK-BASED RETROSPECTIVE REVIEW, WHICH MAY INCLUDE THE USE OF SAMPLING, REASONABLY DESIGNED TO DETECT POTENTIAL VIOLATIONS OF THE SECURITIES LAWS AND FINRA RULES EVIDENCED IN EMAILS SENT OR RECEIVED BY ITS REGISTERED REPRESENTATIVES THAT WERE IMPACTED BY THE SYSTEMIC FAILURES DESCRIBED ABOVE; AND HAS (II) COMPLIED WITH ITS FORM U4, FORM U5, AND RULE 4530 REPORTING OBLIGATIONS AS A RESULT OF ITS FINDINGS ARISING OUT OF THAT REVIEW.
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
CRD
Number:
6694
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
RAYMOND JAMES FINANCIAL
SERVICES, INC.
(For individuals, Last, First,
Middle)
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:
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
12/21/2017
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2013036343601
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
RAYMOND JAMES FINANCIAL SERVICES, INC
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 FINRA'S FINDINGS, RAYMOND JAMES FINANCIAL SERVICES ("RJFS" OR "FIRM") CONSENTED TO THE SANCTIONS
IMPOSED BY FINRA AND TO THE ENTRY OF FINDINGS THAT, BETWEEN DECEMBER 2007 AND SEPTEMBER 2017, RJFS DID NOT HAVE SUPERVISORY
SYSTEMS AND PROCESS FOR REVIEWING EMAIL COMMUNICATIONS THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE
LEGAL REQUIREMENTS OR APPROPRIATE FOR THE FIRM'S BUSINESS, SIZE, STRUCTURE AND CUSTOMERS, AS A RESULT, FINRA FOUND THAT RJFS
VIOLATED NASD RULES 3010 AND 2110 AND FINRA RULES 3110 AND 2010. IN PARTICULAR, FINRA FOUND THAT (1) THE FIRMS' AUTOMATED LEXICON-
BASED SYSTEM TO SURVEIL THE E-MAILS OF ITS PERSONNEL WAS FLAWED IN SIGNIFICANT RESPECTS, (2) THE FIRM FAILED TO DEVOTE ADEQUATE
PERSONNEL AND RESOURCES TO THE TEAM THAT REVIEWED E-MAILS, (3) THE FIRM FAILED TO APPLY ALL OF ITS POLICIES IN ITS PRIMARY LEXICON
TO BRANCH OFFICES THAT HAD THEIR OWN EMAIL SERVERS, AND (4) THE FIRM DID NOT PERIODICALLY TEST THE CONFIGURATION AND
EFFECTIVENESS OF ITS EMAIL SURVEILLANCE SYSTEM. THE FIRM WAS CENSURED, FINED $2 MILLION, AND AGREED TO CERTAIN UNDERTAKINGS TO
ADDRESS THE IDENTIFIED DEFICIENCIES.
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):
12/21/2017
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: $ 2,000,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
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:
THE FIRM WAS CENSURED, FINED $2 MILLION AND UNDERTAKES TO CERTIFY IN WRITING TO FINRA THAT IT HAS ADOPTED AND IMPLEMENTED
WRITTEN SUPERVISORY POLICIES, PROCEDURES, AND SYSTEMS INCLUDING, IF UTILIZED, AN APPROPRIATE EMAIL REVIEW LEXICON, THAT ARE
REASONABLY DESIGNED TO ADDRESS EACH OF THE DEFICIENCIES IDENTIFIED IN THIS AWC AND THAT IT HAS (I) COMPLETED A RISK-BASED
RETROSPECTIVE REVIEW, WHICH MAY INCLUDE THE USE OF SAMPLING, REASONABLY DESIGNED TO DETECT POTENTIAL VIOLATIONS OF THE
SECURITIES LAWS AND FINRA RULES EVIDENCED IN EMAILS SENT OR RECEIVED BY ITS REGISTERED REPRESENTATIVES THAT WERE IMPACTED BY
THE SYSTEMIC FAILURES DESCRIBED ABOVE; AND HAS (II) COMPLIED WITH ITS FORM U4, FORM U5, AND RULE 4530 REPORTING OBLIGATIONS
AS A RESULT OF ITS FINDINGS ARISING OUT OF THAT REVIEW.
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).
THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") ENTERED FINDINGS THAT RAYMOND JAMES FINANCIAL SERVICES, INC., FAILED TO
ESTABLISH, MAINTAIN, AND SUPERVISE A SUPERVISORY SYSTEM IN CONNECTION WITH REVIEW OF EMAIL COMMUNICATIONS. WITHOUT ADMITTING
OR DENYING THE FINDINGS, ON DECEMBER 21, 2017, THE FIRM CONSENTED TO A CENSURE AND FINE OF $2,000,000 AND IS ADOPTING AND
IMPLEMENTING SUPERVISORY POLICIES TO ADDRESS THE DEFICIENCIES.regulatory · block 10RAYMOND JAMES & ASSOCIATES, INC.PDF pages 74–76
- Advisory affiliate name — filed text
- RAYMOND JAMES & ASSOCIATES, INC.
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 CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 11RAYMOND JAMES & ASSOCIATES, INC.PDF pages 76–78
- Advisory affiliate name — filed text
- RAYMOND JAMES & ASSOCIATES, INC.
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 CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 12RAYMOND JAMES & ASSOCIATES, INC.PDF pages 78–79
- Advisory affiliate name — filed text
- RAYMOND JAMES & ASSOCIATES, INC.
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 CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 13PDF pages 79–81
- Regulator name — filed text
- SECURITIES AND EXCHANGE COMMISSION
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
RJFSA SELF-REPORTED THE CONDUCT DISCUSSED IN THE ORDER PURSUANT TO THE SEC'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE. WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, RJFSA SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE SEC ACCEPTED, THAT CONSENTED TO THE ENTRY OF THE ORDER. IN DETERMINING TO ACCEPT RJFSA'S SETTLEMENT OFFER, THE SEC CONSIDERED THAT RJFSA HAD SELF-REPORTED ITS CONDUCT TO THE SEC. THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE ORDER ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.
Other filed details
Description of allegations — filed text
RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC. ("RJFSA") ENTERED INTO A SETTLEMENT WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC") PURSUANT TO THE SEC'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE. PURSUANT TO THE SEC'S ORDER DATED MARCH 11, 2019, THE SEC FOUND THAT AT TIMES BETWEEN JANUARY 1, 2014, TO FEBRUARY 16, 2018, RJFSA PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE, AND DID NOT DISCLOSE ADEQUATELY IN ITS FORM ADV OR OTHERWISE THE CONFLICTS OF INTEREST RELATED TO (A) ITS ASSOCIATED PERSONS' RECEIPT OF 12B-1 FEES, AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. AS A RESULT OF THAT CONDUCT, THE SEC FOUND THAT RJFSA WILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT.
Sanction detail — filed text
THE ORDER REQUIRES RJFSA TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. IN ADDITION, THE ORDER CENSURED RJFSA AND ORDERED IT TO PAY TO AFFECTED INVESTORS DISGORGEMENT OF $6,181,028.07 AND PREJUDGMENT INTEREST OF $696,020.04, WHICH HAD ALREADY BEEN PAID BY FEBRUARY 12, 2019. LASTLY, THE ORDER CAUSED RJFSA TO REVIEW AND CORRECT AS NECESSARY ALL RELEVANT DISCLOSURE DOCUMENTS, EVALUATE WHETHER CLIENTS SHOULD BE MOVED TO A LOWER-COST SHARE CLASS AND MOVE CLIENT AS NECESSARY, EVALUATE, UPDATE, AND REVIEW POLICIES AND PROCEDURES, AND NOTIFY AFFECTED INVESTORS OF THE SETTLEMENT TERMS.
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)
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions:
CENSURE, DISGORGEMENT, PREJUDGMENT INTEREST, AND UNDERTAKINGS
3.
Date Initiated (MM/DD/YYYY):
03/11/2019
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ADMIN. PROCEEDING FILE NO. 3-19029
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):
RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC. ("RJFSA") ENTERED INTO A SETTLEMENT WITH THE U.S. SECURITIES AND EXCHANGE
COMMISSION ("SEC") PURSUANT TO THE SEC'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE. PURSUANT TO THE SEC'S ORDER DATED MARCH 11,
2019, THE SEC FOUND THAT AT TIMES BETWEEN JANUARY 1, 2014, TO FEBRUARY 16, 2018, RJFSA PURCHASED, RECOMMENDED, OR HELD FOR
ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR
WHICH THE CLIENTS WERE ELIGIBLE, AND DID NOT DISCLOSE ADEQUATELY IN ITS FORM ADV OR OTHERWISE THE CONFLICTS OF INTEREST RELATED
TO (A) ITS ASSOCIATED PERSONS' RECEIPT OF 12B-1 FEES, AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. AS A
RESULT OF THAT CONDUCT, THE SEC FOUND THAT RJFSA WILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT.
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:
Settled
11. Resolution Date (MM/DD/YYYY):
03/11/2019
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: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
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:
THE ORDER REQUIRES RJFSA TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF
SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. IN ADDITION, THE ORDER CENSURED RJFSA AND ORDERED IT TO PAY TO AFFECTED
INVESTORS DISGORGEMENT OF $6,181,028.07 AND PREJUDGMENT INTEREST OF $696,020.04, WHICH HAD ALREADY BEEN PAID BY FEBRUARY 12,
2019. LASTLY, THE ORDER CAUSED RJFSA TO REVIEW AND CORRECT AS NECESSARY ALL RELEVANT DISCLOSURE DOCUMENTS, EVALUATE
WHETHER CLIENTS SHOULD BE MOVED TO A LOWER-COST SHARE CLASS AND MOVE CLIENT AS NECESSARY, EVALUATE, UPDATE, AND REVIEW
POLICIES AND PROCEDURES, AND NOTIFY AFFECTED INVESTORS OF THE SETTLEMENT TERMS.
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).
RJFSA SELF-REPORTED THE CONDUCT DISCUSSED IN THE ORDER PURSUANT TO THE SEC'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE.
WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, RJFSA SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE SEC ACCEPTED, THAT CONSENTED
TO THE ENTRY OF THE ORDER. IN DETERMINING TO ACCEPT RJFSA'S SETTLEMENT OFFER, THE SEC CONSIDERED THAT RJFSA HAD SELF-REPORTED ITS
CONDUCT TO THE SEC. THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE ORDER ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.regulatory · block 14RAYMOND JAMES & ASSOCIATES, INC.PDF pages 81–83
- Advisory affiliate name — filed text
- RAYMOND JAMES & ASSOCIATES, INC.
- Regulator name — filed text
- SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 3,000,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, RJA, RJFS, AND RJFSA CONSENTED TO THE ENTRY BY THE SEC OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTION 8A OF THE SECURITIES ACT, SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, AND SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ("ORDER") (RELEASE NO. 86985, SEPT. 17, 2019). PURSUANT TO THE ORDER RJA AND RJFS MUST CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT; RJA AND RJFSA MUST CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. ALSO PURSUANT TO THE ORDER, RJA, RJFS, AND RJFSA WERE CENSURED AND REQUIRED TO PAY DISGORGEMENT, PREJUDMENT INTEREST AND A CIVIL MONEY PENALTY TOTALING $15,171,113.81. IN DETERMINING TO ACCEPT RAYMOND JAMES' OFFER OF A SETTLEMENT, THE SEC TOOK INTO CONSIDERATION CERTAIN REMEDIAL EFFORTS PROMPTLY TAKEN BY, AND THE COOPERATION OF, RAYMOND JAMES.
Other filed details
Description of allegations — filed text
THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT RAYMOND JAMES & ASSOCIATES, INC. ("RJA") AND RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC. ("RJFSA") VIOLATED SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT"), AND RULE 206(4)-7 THEREUNDER, BY FAILING TO CONDUCT PROMISED SUITABILITY REVIEWS FOR CERTAIN ADVISORY ACCOUNTS, FAILING TO ADOPT POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS CONCERNING THE SUITABILITY OF FEE-BASED ADVISORY ACCOUNTS, AND OVERVALUING CERTAIN ASSETS THAT RESULTED IN CHARGING EXCESS ADVISORY FEES. THE SEC ALSO ALLEGED THAT RJA AND RAYMOND JAMES FINANCIAL SERVICES, INC. ("RJFS") VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT") BY FAILING TO HAVE A REASONABLE BASIS FOR RECOMMENDING CERTAIN UNIT INVESTMENT TRUST TRANSACTIONS TO BROKERAGE CUSTOMERS, AND FAILING TO DISCLOSE THE CONFLICT OF INTEREST ASSOCIATED WITH EARNING GREATER COMPENSATION WHEN RECOMMENDING CERTAIN SECURITIES WITHOUT PROVIDING APPLICABLE SALES-LOAD DISCOUNTS TO BROKERAGE CUSTOMERS.
Sanction detail — filed text
IN THE ORDER, RJA, RJFS, AND RJFSA WERE CENSURED, REQUIRED TO PAY A CIVIL MONETARY PENALTY OF $3,000,000, WHICH WAS PAID ON 09/25/2019, AND REQUIRED TO PAY DISGORGEMENT OF $11,098,349.01. DISGORGEMENT PAID TO OPEN ACCOUNTS ON 9/9 AND CLOSED ACCOUNTS ON 9/16.
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
CRD
Number:
705
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
RAYMOND JAMES &
ASSOCIATES, INC.
(For individuals, Last, First,
Middle)
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)
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions:
CENSURED, DISGORGEMENT, AND CIVIL MONEY PENALTY.
3.
Date Initiated (MM/DD/YYYY):
09/17/2019
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-19464
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC.
6.
Principal Product Type:
Unit Investment Trust(s)
Other Product Types:
FEE-BASED ADVISORY ACCOUNTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT RAYMOND JAMES & ASSOCIATES, INC. ("RJA") AND RAYMOND JAMES FINANCIAL
SERVICES ADVISORS, INC. ("RJFSA") VIOLATED SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT"), AND
RULE 206(4)-7 THEREUNDER, BY FAILING TO CONDUCT PROMISED SUITABILITY REVIEWS FOR CERTAIN ADVISORY ACCOUNTS, FAILING TO ADOPT
POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS CONCERNING THE SUITABILITY OF FEE-BASED ADVISORY ACCOUNTS,
AND OVERVALUING CERTAIN ASSETS THAT RESULTED IN CHARGING EXCESS ADVISORY FEES. THE SEC ALSO ALLEGED THAT RJA AND RAYMOND JAMES
FINANCIAL SERVICES, INC. ("RJFS") VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT") BY FAILING TO
HAVE A REASONABLE BASIS FOR RECOMMENDING CERTAIN UNIT INVESTMENT TRUST TRANSACTIONS TO BROKERAGE CUSTOMERS, AND FAILING TO
DISCLOSE THE CONFLICT OF INTEREST ASSOCIATED WITH EARNING GREATER COMPENSATION WHEN RECOMMENDING CERTAIN SECURITIES WITHOUT
PROVIDING APPLICABLE SALES-LOAD DISCOUNTS TO BROKERAGE CUSTOMERS.
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:
Order
11. Resolution Date (MM/DD/YYYY):
09/17/2019
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: $ 3,000,000.00
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:
IN THE ORDER, RJA, RJFS, AND RJFSA WERE CENSURED, REQUIRED TO PAY A CIVIL MONETARY PENALTY OF $3,000,000, WHICH WAS PAID ON
09/25/2019, AND REQUIRED TO PAY DISGORGEMENT OF $11,098,349.01. DISGORGEMENT PAID TO OPEN ACCOUNTS ON 9/9 AND CLOSED
ACCOUNTS ON 9/16.
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).
WITHOUT ADMITTING OR DENYING THE FINDINGS, RJA, RJFS, AND RJFSA CONSENTED TO THE ENTRY BY THE SEC OF AN ORDER INSTITUTING
ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTION 8A OF THE SECURITIES ACT, SECTION 15(B) OF THE SECURITIES
EXCHANGE ACT OF 1934, AND SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A
CEASE-AND-DESIST ORDER ("ORDER") (RELEASE NO. 86985, SEPT. 17, 2019). PURSUANT TO THE ORDER RJA AND RJFS MUST CEASE AND DESIST FROM
COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT; RJA AND
RJFSA MUST CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE
ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. ALSO PURSUANT TO THE ORDER, RJA, RJFS, AND RJFSA WERE CENSURED AND
REQUIRED TO PAY DISGORGEMENT, PREJUDMENT INTEREST AND A CIVIL MONEY PENALTY TOTALING $15,171,113.81. IN DETERMINING TO ACCEPT
RAYMOND JAMES' OFFER OF A SETTLEMENT, THE SEC TOOK INTO CONSIDERATION CERTAIN REMEDIAL EFFORTS PROMPTLY TAKEN BY, AND THE
COOPERATION OF, RAYMOND JAMES.regulatory · block 15RAYMOND JAMES & ASSOCIATES, INC.PDF pages 83–85
- Advisory affiliate name — filed text
- RAYMOND JAMES & ASSOCIATES, INC.
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 g y 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 CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 16PDF pages 85–87
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 CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 17RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 87–89
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
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 CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: S-19-0019 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 18RAYMOND JAMES & ASSOCIATES, INC.PDF pages 89–90
- Advisory affiliate name — filed text
- RAYMOND JAMES & ASSOCIATES, INC.
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 CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 19RAYMOND JAMES & ASSOCIATES, INC.PDF pages 90–92
- Advisory affiliate name — filed text
- RAYMOND JAMES & ASSOCIATES, INC.
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: ( ) g p 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 CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2018057742301 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 20RAYMOND JAMES & ASSOCIATES, INC.PDF pages 92–94
- Advisory affiliate name — filed text
- RAYMOND JAMES & ASSOCIATES, INC.
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 CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 20186982 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 21RAYMOND JAMES & ASSOCIATES, INC.PDF pages 94–96
- Advisory affiliate name — filed text
- RAYMOND JAMES & ASSOCIATES, INC.
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 CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 3-21133 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 22PDF pages 96–97
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 CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2018058633501 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 23RAYMOND JAMES & ASSOCIATES, INC.PDF pages 97–99
- Advisory affiliate name — filed text
- RAYMOND JAMES & ASSOCIATES, INC.
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 CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) 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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2021-02-23-00034 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 24RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 99–101
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION
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 y 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 CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) 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 AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 07/10/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: E-2023-00041 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
regulatory · block 25PDF pages 101–103
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 1,825,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
PLEASE SEE NUMBERS 7 THROUGH 12 FOR A SUMMARY OF THE MATTER AND RESOLUTION.
Other filed details
Description of allegations — filed text
ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT (AWC) WITH FINRA FOR NOT REASONABLY SUPERVISING THE FIRM'S REPORTING, INCLUDING TIMELINESS OF REPORTING, OF CUSTOMER COMPLAINTS VIA FINRA RULE 4530 FILINGS AND AMENDMENTS TO REGISTERED REPRESENTATIVES' FORMS U4 AND U5 SINCE AT LEAST JANUARY 2018. ADDITIONALLY, FROM JANUARY 2012 TO AT LEAST DECEMBER 2017, THE FIRM, WHICH SELF-REPORTED THE ISSUE, DID NOT REASONABLY SUPERVISE MUTUAL FUND PURCHASES THAT THE FIRMS' REPRESENTATIVES MADE DIRECTLY WITH MUTUAL FUND COMPANIES ON BEHALF OF FIRM CUSTOMERS; SUCH TRANSACTIONS IN MANY CASES HAPPENED OUTSIDE THE FIRM'S AUTOMATED SURVEILLANCE SYSTEMS WHICH WERE NOT CONFIGURED TO SUBJECT THEM TO REVIEW. THE FIRM AND FINRA CONDUCTED RETROSPECTIVE REVIEWS OF THE DIRECT BUSINESS IDENTIFIED AND THE FIRM AGREED TO THE ENTRY OF FINDINGS AND SANCTIONS, INCLUDING A CENSURE, FINE, AND RESTITUTION.
Sanction detail — filed text
THE FIRMS WERE CENSURED, FINED IN THE AMOUNT OF $525,000 (RJA) AND $1,300,000 (RJFS), AND REQUIRED TO PAY RESTITUTION IN THE AMOUNT OF $26,169.04 PLUS INTEREST (RJA) AND $85,554.94 PLUS INTEREST RJFS. FURTHER, WITHIN 180 DAYS OF THE DATE OF THE NOTICE OF ACCEPTANCE OF THIS AWC, A MEMBER OF EACH RESPONDENT'S SENIOR MANAGEMENT WHO IS A REGISTERED PRINCIPAL OF EACH FIRM SHALL CERTIFY IN WRITING THAT, AS OF THE DATE OF THE CERTIFICATION, THE FIRMS HAVE REMEDIATED THE CUSTOMER COMPLAINT AND DIRECT BUSINESS SYSTEM CONFIGURATION ISSUES IDENTIFIED IN THIS AWC AND IMPLEMENTED A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ARTICLE V, SECTIONS 2 AND 3 OF FINRA'S BY-LAWS, AND FINRA RULES 3110, 1122, AND 4530 REGARDING THE ISSUES IDENTIFIED IN THIS AWC.
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 CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) CRD Number: 705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES & ASSOCIATES, INC. (For individuals, Last, First, Middle) 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: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 08/29/2024 Exact Explanation If not exact, provide explanation: THE DATE OF INITIATION IS NOT STATED IN THE AWC, ONLY THAT THE MATTER ORIGINATED FROM A FINRA EXAMINATION OF RJA AND FINRA'S REVIEW OF SELF-DISCLOSURES MADE BY RJA AND RJFS. THE ENTRY OF CONSENT WAS AUGUST 29, 2024. 4. Docket/Case Number: 2018059564801 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT (AWC) WITH FINRA FOR NOT REASONABLY SUPERVISING THE FIRM'S REPORTING, INCLUDING TIMELINESS OF REPORTING, OF CUSTOMER COMPLAINTS VIA FINRA RULE 4530 FILINGS AND AMENDMENTS TO REGISTERED REPRESENTATIVES' FORMS U4 AND U5 SINCE AT LEAST JANUARY 2018. ADDITIONALLY, FROM JANUARY 2012 TO AT LEAST DECEMBER 2017, THE FIRM, WHICH SELF-REPORTED THE ISSUE, DID NOT REASONABLY SUPERVISE MUTUAL FUND PURCHASES THAT THE FIRMS' REPRESENTATIVES MADE DIRECTLY WITH MUTUAL FUND COMPANIES ON BEHALF OF FIRM CUSTOMERS; SUCH TRANSACTIONS IN MANY CASES HAPPENED OUTSIDE THE FIRM'S AUTOMATED SURVEILLANCE SYSTEMS WHICH WERE NOT CONFIGURED TO SUBJECT THEM TO REVIEW. THE FIRM AND FINRA CONDUCTED RETROSPECTIVE REVIEWS OF THE DIRECT BUSINESS IDENTIFIED AND THE FIRM AGREED TO THE ENTRY OF FINDINGS AND SANCTIONS, INCLUDING A CENSURE, FINE, AND RESTITUTION. 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): 08/29/2024 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: $ 1,825,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKING. 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: THE FIRMS WERE CENSURED, FINED IN THE AMOUNT OF $525,000 (RJA) AND $1,300,000 (RJFS), AND REQUIRED TO PAY RESTITUTION IN THE AMOUNT OF $26,169.04 PLUS INTEREST (RJA) AND $85,554.94 PLUS INTEREST RJFS. FURTHER, WITHIN 180 DAYS OF THE DATE OF THE NOTICE OF ACCEPTANCE OF THIS AWC, A MEMBER OF EACH RESPONDENT'S SENIOR MANAGEMENT WHO IS A REGISTERED PRINCIPAL OF EACH FIRM SHALL CERTIFY IN WRITING THAT, AS OF THE DATE OF THE CERTIFICATION, THE FIRMS HAVE REMEDIATED THE CUSTOMER COMPLAINT AND DIRECT BUSINESS SYSTEM CONFIGURATION ISSUES IDENTIFIED IN THIS AWC AND IMPLEMENTED A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ARTICLE V, SECTIONS 2 AND 3 OF FINRA'S BY-LAWS, AND FINRA RULES 3110, 1122, AND 4530 REGARDING THE ISSUES IDENTIFIED IN THIS AWC. 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). PLEASE SEE NUMBERS 7 THROUGH 12 FOR A SUMMARY OF THE MATTER AND RESOLUTION.
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