R. F. Lafferty & Co.., Inc..

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:
2498
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
R. F. LAFFERTY & CO., 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:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
04/01/2016
 Exact
 Explanation
If not exact, provide explanation:
THE DATE ON THE AWC DOES NOT SPECIFY, BUT WAS BASED ON APRIL 2016 ROUTINE EXAM OF RFL.
4.
Docket/Case Number:
2016047634501
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE FIRM ALLEGATIONS OF VIOLATIONS OF FINRA RULE 3110 WITH REGARDS TO RECORDKEEPING IN THE PROPERLY MARKETED ORDER TICKETS.
DURING JULY 2014 THRU JULY 2017, 56033 OF THE FIRMS ORDER MEMORANDA AND OTHER BOOKS AND RECORDS LACKED INFORMATION INDICATING
WHETHER THE TRADE WERE SOLICITED OR UNSOLICITED. FROM JULY 2014 TO JULY 2017, R.F. LAFFERTY'S WSPS REQUIRED THE FIRM TO MAINTAIN
ACCURATE ORDER MEMORANDA IN COMPLIANCE WITH THE RECORDKEEPING REQUIREMENTS IMPOSED BY FINRA RULE 451 1 AND THE EXCHANGE ACT
AND RULES THEREUNDER. THE FIRM, HOWEVER, FAILED TO ESTABLISH AND MAINTAIN A REASONABLY DESIGNED SUPERVISORY SYSTEM OR ENFORCE
ITS WSPS CONCERNING THE ACCURACY OF INFORMATION APPEARING ON ORDER MEMORANDA. THE FIRM ALLOWED INDIVIDUAL REPRESENTATIVES,
WHEN ENTERING CUSTOMER TRADES IN THE ORDER MANAGEMENT SYSTEMS MAINTAINED BY THE FIRM'S CLEARING FIRMS, TO SELECT WHETHER OR
NOT THEY HAD SOLICITED THE TRADES. R.F. LAFFERTY THEN RETAINED JUST THE INFORMATION IT RECEIVED FROM ITS CLEARING FIRMS AS THE ORDER
MEMORANDA IN THE FIRM'S OWN BOOKS AND RECORDS. BUT THE FIRM MAINTAINED NO SUPERVISORY SYSTEM TO ENSURE THE ACCURACY OF ITS
ORDER MEMORANDA, AND NO FIRM PRINCIPAL TOOK SUPERVISORY STEPS TO ENSURE THE ACCURACY OF THE FIRM'S ORDER MEMORANDA. TO THE
CONTRARY, WHEN FIRM SUPERVISORY PERSONNEL BECAME AWARE OF INACCURATE BLANK OR "N/A" SOLICITATION INFORMATION IN THE FIRM'S
BOOKS AND RECORDS, THEY TREATED THE TRADES AS UNSOLICITED FOR PURPOSES OF SUPERVISORY REVIEW. THE LIMITED STEPS THAT THE FIRM
TOOK TO CORRECT THE PROBLEM WERE NOT REASONABLE. DURING THE RELEVANT PERIOD, FIRM OPERATIONS PERSONNEL OCCASIONALLY ASKED
REGISTERED REPRESENTATIVES ABOUT TRADES IN CUSTOMER ACCOUNTS WITH "N/A" AS THE SOLICITATION INDICATOR; WHEN THAT HAPPENED,
OPERATIONS PERSONNEL ON AN AD HOC BASIS WOULD CORRECT THE ORDER MEMORANDA OR ADD A COMMENT TO THE BLOTTER TO SHOW THE
TRADES AS EITHER SOLICITED OR UNSOLICITED. THE FIRM DID NOT, HOWEVER, CORRECT ALL OR EVEN MOST TRADES SHOWING "N/A" AS THE
SOLICITATION INDICATOR AND TOOK NO OTHER STEPS TO REMEDY THE PROBLEM. AS DESCRIBED ABOVE, BECAUSE OF THE FIRM'S FAILURE TO
ESTABLISH AND MAINTAIN A REASONABLY DESIGNED SUPERVISORY SYSTEM OR ENFORCE ITS EXISTING WSPS, THE FIRM'S BOOKS AND RECORDS
CONTAINED TENS OF THOUSANDS OF INACCURACIES WITH RESPECT TO WHETHER TRADES WERE SOLICITED OR NOT. R.F. LAFFERTY VIOLATED NASD
RULE 3010 (FOR CONDUCT BEFORE DECEMBER L, 2014), FINRA RULE 3110 (FOR CONDUCT ON OR AFTER DECEMBER I, 2014), AND FINRA RULE 2010.
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):
12/11/2020
 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: $ 55,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
CENSURE AND MONETARY FINE
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 AND FINED $55000.00
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 FIRM WAS CENSURED AND FINED $55000.00

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NATIONAL ASSOCIATION OF SECURITIES DEALERS
2.
Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
02/17/1999
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
C11990004
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):
SUPERVISION VIOLATIONS
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
02/19/1999
 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: $ 5,000.00
 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: 
$5,000.00 PAID ON 3/25/1999 BY R. F. LAFFERTY & CO., INC.
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).
SUPERVISION VIOLATIONS

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/09/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2013038999301
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Corporate
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 REPORTED
SECONDARY MARKET (S1) TRANSACTIONS IN TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)-ELIGIBLE CORPORATE DEBT SECURITIES TO TRACE
THAT IT WAS NOT REQUIRED TO REPORT, FAILED TO REPORT S1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES TO TRACE THAT IT

WAS REQUIRED TO REPORT, FAILED TO REPORT TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES TO TRACE WITHIN 15 MINUTES OF
THE TIME OF EXECUTION, AND REPORTED TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES TO TRACE THAT IT WAS NOT REQUIRED
TO REPORT.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
10/09/2015
 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: $ 5,000.00
 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: 
THE FIRM WAS FINED $5000.00.
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).
NO CLIENT AND/OR MARKET IMPACT. FIRM HAS TAKEN CORRECTIVE ACTION TO INSURE COMPLIANCE.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 

If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/11/2013
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2009020281601
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Penny Stock(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA RULE 3310(A) AND NASD RULE 3011(A): THE FIRM'S ANTI-MONEY LAUNDERING (AML) POLICIES, PROCEDURES, AND INTERNAL CONTROLS WERE
NOT REASONABLY DESIGNED TO MONITOR FOR, DETECT, AND CAUSE THE REPORTING OF SUSPICIOUS TRANSACTIONS, AS REQUIRED BY NASD RULE
3011(A) AND FINRA RULE 3310(A). THE FIRM'S AML SYSTEMS AND PROCEDURES FAILED TO ADDRESS THE INHERENT RISKS ASSOCIATED WITH TRADING
IN OTC BULLETIN BOARD AND PINK SHEET SECURITIES. BASED ON THE NATURE AND TYPE OF SECURITIES ITS CUSTOMERS TRADED, THE FIRM SHOULD
HAVE HAD PROCEDURES TO ADEQUATELY MONITOR FOR, DETECT, AND REPORT SUSPICIOUS TRADING ACTIVITY, BUT DID NOT. THE FIRM FAILED TO
IMPLEMENT ITS EXISTING AML POLICIES AND PROCEDURES, WHICH INCLUDED RELYING ON EXCEPTION REPORTS PRODUCED BY ITS CLEARING FIRM
AND MONITORING CUSTOMER ACCOUNT ACTIVITY FOR UNUSUAL SIZE, VOLUME, PATTERN OR TYPE OF TRANSACTIONS WHILE TAKING INTO ACCOUNT
RISK FACTORS AND RED FLAGS APPROPRIATE TO THE FIRM'S BUSINESS. THE FIRM DID NOT CONDUCT REVIEWS OF CUSTOMER TRADING ACTIVITIES TO
REASONABLY DETECT ANY OF THE RED FLAGS OF SUSPICIOUS ACTIVITY INCLUDED IN ITS PROCEDURES. IN ADDITION, THE FIRM DID NOT HAVE A
MEANINGFUL PROCESS FOR INVESTIGATING SUSPICIOUS ACTIVITY AND FILING APPROPRIATE SAR-SFS (SUSPICIOUS ACTIVITY REPORTS FOR THE
SECURITIES AND FUTURES INDUSTRY), AS THE FACTS AND CIRCUMSTANCES REQUIRED. TWO CUSTOMERS OPENED APPROXIMATELY 27 PERSONAL AND
BUSINESS ACCOUNTS AT THE FIRM. THE TWO CUSTOMERS WERE CONSULTANTS AND ADVISERS TO COMPANIES ENCOMPASSING A NUMBER OF
DIFFERENT BUSINESS AREAS, INCLUDING INITIAL PUBLIC OFFERINGS AND CAPITAL STRUCTURE. AFTER THE ACCOUNTS WERE OPENED AT THE FIRM,
THE TWO CUSTOMERS PROMPTLY TRANSFERRED INTO THEIR ACCOUNTS MILLIONS OF SHARES OF PENNY STOCKS OF ISSUERS WITH QUESTIONABLE
OPERATING HISTORIES. THEY LIQUIDATED THEIR POSITIONS AND WIRED THE PROCEEDS FROM THE ACCOUNTS. THE TWO CUSTOMERS LIQUIDATED
APPROXIMATELY $7.3 MILLION OF PENNY STOCKS AS A RESULT OF THESE SALES. FURTHER, WHILE THE CUSTOMERS WERE LIQUIDATING THE STOCKS,
SUSPICIOUS INTERNET PROMOTIONAL CAMPAIGNS TOUTED THE SAME SECURITIES. DESPITE THE EXISTENCE OF SPECIFIC RED FLAGS NOTED IN THE
FIRM'S AML PROCEDURES, DUE TO THE FIRM'S FAILURE TO IMPLEMENT ITS AML POLICIES AND PROCEDURES, IT DID NOT DETECT THE SUSPICIOUS
ACTIVITIES AND CONSIDER WHETHER IT SHOULD HAVE BEEN INVESTIGATED FURTHER AND, IF APPROPRIATE, REPORTED AS SUSPICIOUS ACTIVITY.

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):
03/11/2013
 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: $ 50,000.00
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,
THEREFORE THE FIRM IS CENSURED, FINED $50,000 AND REQUIRED TO REVIEW AND REVISE, AS NECESSARY, THE FIRM'S AML POLICIES,
PROCEDURE, AND INTERNAL CONTROLS IN ORDER TO TAILOR THEM TO ITS BUSINESS MODEL. WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF
THIS AWC BY THE NATIONAL ADJUDICATORY COUNCIL (NAC), THE FIRM'S PRESIDENT SHALL CERTIFY THAT THE FIRM HAS ESTABLISHED AND
IMPLEMENTED AML POLICIES, PROCEDURES, AND INTERNAL CONTROLS WITH RESPECT TO MONITORING FOR SUSPICIOUS SECURITIES
TRANSACTIONS THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE REQUIREMENTS OF THE BANK SECRECY ACT AND THE
IMPLEMENTING REGULATIONS PROMULGATED THEREUNDER BY THE DEPARTMENT OF THE TREASURY. FINE PAID IN FULL 3/25/13.
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).
A REGISTERED REPRESENTATIVE WHO JOINED R.F. LAFFERTY IN FEBRUARY 2009 TRANSFERRED IN OVER 75 ACCOUNTS INTO THE FIRM. OVER A PERIOD
OF 18 MONTHS, THE CLIENTS AT ISSUE IN THE AWC SOLD SHARES IN THE EQUITIES IN QUESTION. IN TOTAL, THE ACCOUNTS' MARKET AND CASH
VALUES WERE IN EXCESS OF $50,000,000 AND THESE CLIENTS TRANSACTED OTHER BUSINESS IN NYSE, AMEX AND NASDAQ SECURITIES. THESE
CLIENTS ARE UNITED STATES CITIZENS AND ALL MONIES WERE WIRED TO ACCOUNTS IN THEIR NAMEPLATE IN UNITED STATES BANKS DOMICILED IN
THE UNITED STATES. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE AWC. SINCE THE PERIOD IN QUESTION, THE
FIRM HAS ENHANCED ITS AML POLICIES, PROCEDURES AND INTERNAL CONTROLS AS TAILORED TO ITS BUSINESS MODEL. THE REGISTERED
REPRESENTATIVE AND THE ACCOUNTS IN QUESTION ARE NO LONGER WITH THE FIRM.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):

You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/25/2013
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2011026111301
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):
SEC RULE 10B-10, SEC RULES 606, 611(A)(B) AND (C) OF REGULATION NMS, FINRA RULE 2010, NASD RULE 3010 - R.F. LAFFERTY & CO., INC. FAILED TO
PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THAT THE TRANSACTIONS WERE EXECUTED AT AN AVERAGE PRICE, OR
ERRONEOUSLY DISCLOSED THAT THE TRANSACTIONS WERE EXECUTED AT AN AVERAGE PRICE. THE FIRM MADE AVAILABLE PUBLICLY A REPORT OF ITS
ROUTING OF NON-DIRECTED ORDERED IN COVERED SECURITIES THAT FAILED TO IDENTIFY ACCURATELY AND COMPLETELY THE MARKET CENTERS TO
WHICH THE FIRM ROUTED NON-DIRECTED ORDERS IN COVERED SECURITIES, AND FAILED TO DISCLOSE CORRECTLY THE PERCENTAGE OF TOTAL NON-
DIRECTED ORDERS ROUTED TO EACH MARKET CENTER. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY
DESIGNED TO ACHIEVE COMPLIANCE WITH RULE 611(A), (B), AND (C) OF REGULATION NMS. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR
SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND/OR FINRA AND SEC RULES
ADDRESSING TRADING AND MARKET MAKING TOPICS. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) FAILED TO PROVIDE FOR MINIMUM
REQUIREMENTS FOR ADEQUATE WSPS IN ORDER HANDLING -DISCLOSURE OF ORDER EXECUTION INFORMATION; BEST EXECUTION -CUSTOMER BLOCK-
SIZED ORDERS, NOT HELD ORDERS AND ORDERS WITH SPECIAL PRICING TERMS/CONDITIONS, EXECUTION OF ORDERS ROUTED AS AGENT, REGULAR
AND RIGOROUS REVIEW OF ORDERS EXECUTED BY OTHER PARTIES, THREE-QUOTE RULE; TRADE REPORTING - GENERAL TRADE REPORTING, USE OF
TRADE MODIFIERS, REPORTING RISKLESS PRINCIPAL TRADES, ACCEPTING/MATCHING TRADES ON THE FIRM'S BEHALF; SALE TRANSACTIONS - RULE 204

OF REGULATION SHO CLOSE-OUT AND PRE-BORROW REQUIREMENTS OF THE SECURITIES EXCHANGE ACT OF 1934; TRADE REPORTING FACILITY SALE
REPORTING REQUIREMENTS; OTHER TRADING RULES - ENTERING QUOTES FOR OVER-THE-COUNTER SECURITIES INTO MULTIPLE REAL-TIME QUOTE
SYSTEMS; ORDER AUDIT TRAIL SYSTEM (OATS)- DETECTION AND REPAIR OF OATS REJECTIONS; OATS/TRADE REPORTING FACILITY DATA MATCHING;
OTHER RULES - GENERAL HOUSEKEEPING; MONITORING OF ELECTRONIC COMMUNICATIONS; AND USE OF MULTIPLE MARKET PARTICIPANT
IDENTIFIERS (MPIDS). THE FIRM FAILED TO PROVIDE DOCUMENTARY EVIDENCE IT PERFORMED THE SUPERVISORY REVIEWS SET FORTH IN ITS WSPS
CONCERNING: ANTI-INTIMIDATION/COORDINATION; OTHER TRADING RULES - ACTIVITY DURING A TRADING HALT; OATS - CLOCK SYNCHRONIZATION,
OATS DATA ACCURACY AND TIMELINESS; AND OTHER RULES - INFORMATION BARRIERS, AND ACCEPTANCE/DISPLAY OF SUB-PENNY ORDERS.
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):
11/25/2013
 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: $ 22,000.00
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;
THEREFORE, THE FIRM IS CENSURED, FINED $22,000 AND REQUIRED TO REVISE ITS WSPS REGARDING SUPERVISION REASONABLY DESIGNED TO
ACHIEVE COMPLIANCE WITH RULE 611(A), (B), AND (C) OF REGULATION NMS;ORDER HANDLING -DISCLOSURE OF ORDER EXECUTION
INFORMATION; BEST EXECUTION -CUSTOMER BLOCK-SIZED ORDERS, NOT HELD ORDERS AND ORDERS WITH SPECIAL PRICING
TERMS/CONDITIONS, EXECUTION OF ORDERS ROUTED AS AGENT, REGULAR AND RIGOROUS REVIEW OF ORDERS EXECUTED BY OTHER PARTIES,
THREE-QUOTE RULE; TRADE REPORTING - GENERAL TRADE REPORTING, USE OF TRADE MODIFIERS, REPORTING RISKLESS PRINCIPAL TRADES,
ACCEPTING/MATCHING TRADES ON THE FIRM'S BEHALF; SALE TRANSACTIONS - RULE 204 OF REGULATION SHO CLOSE-OUT AND PRE-BORROW
REQUIREMENTS OF THE SECURITIES EXCHANGE ACT OF 1934; TRADE REPORTING FACILITY SALE REPORTING REQUIREMENTS; OTHER TRADING
RULES - ENTERING QUOTES FOR OVER-THE-COUNTER SECURITIES INTO MULTIPLE REAL-TIME QUOTE SYSTEMS; ORDER AUDIT TRAIL SYSTEM
(OATS)- DETECTION AND REPAIR OF OATS REJECTIONS; OATS/TRADE REPORTING FACILITY DATA MATCHING; OTHER RULES - GENERAL
HOUSEKEEPING; MONITORING OF ELECTRONIC COMMUNICATIONS; AND USE OF MULTIPLE MARKET PARTICIPANT IDENTIFIERS (MPIDS) WITHIN
30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC.
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 NOTICE OF ACCEPTANCE OF THE LETTER OF ACCEPTANCE,WAIVER AND CONSENT NO# 2011026111301 HAS BEEN APPROVED ON 11 25 2013. IN
ACCORDANCE WITH THE AWC, THE FIRM HAS ISSUED PAYMENT OF THE FINE AND REVISED THE FIRM'S WRITTEN SUPERVISORY PROCEDURES.