Deutsche Bank Securities 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
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) 
NEW YORK STOCK EXCHANGE, INC.
2.
Principal Sanction:
Censure
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/09/2001
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
01-148
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
VIOLATED SEC REG. 240.15C2-8(C) BY FAILING TO PROVIDE PRELIMINARY PROSPECTUSES TO CUSTOMERS WHO INDICATED INTEREST IN PURCHASING
INITIAL PUBLIC OFFERINGS; VIOLATED EXCHANGE RULE 410 BY FAILING TO INCLUDE TERMS OF THE ORDER ON TICKETS TRANSMITTED TO THE FLOOR;
VIOLATED EXCHANGE RULE 440 AND SEC REG. 240.17A-3(A)(6) BY FAILING TO MAINTAIN A MEMORANDUM OF ORDERS; VIOLATED EXCHANGE RULE 440
AND SEC REGS. 240.17A-3 AND 17A-4 BY FAILING TO MAKE A PRESERVE REQUIRED BOOKS AND RECORDS; VIOLATED EXCHANGE RULE 342.16 IN THAT
A BRANCH FAILED TO PROPERLY SUPERVISE AND APPROVE OUTGOING CORRESPONDENCE; AND VIOLATED EXCHANGE RULE 342 BY FAILING TO
REASONABLY SUPERVISE AND PROVIDE APPROPRIATE SUPERVISORY PROCEDURES TO DETERMINE THAT DELEGATED AUTHORITY IS BEING PROPERLY
EXERCISED.
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):
09/26/2001
 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: $ 100,000.00
 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 FINE OF $100,000.00 WAS PAID ON SEPTEMBER 25, 2001.
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 ALLEGATIONS THE FIRM CONSENTED TO THE FINDINGS. THIS SETTLEMENT AND THE PAYMENT OF $100,000.00
CONCLUDES THIS MATTER. PLEASE DELETE DRP PUT ON ADV IN ERROR.

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) 
NEW YORK STOCK EXCHANGE, INC.
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
11/04/2003
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
HPD#:03-221
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
OTHER
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NEW YORK STOCK EXCHANGE, INC. ("NYSE") ALLEGED AND DEUTSCHE BANK SECURITIES INC. ("DBSI") WITHOUT ADMITTING OR DENYING GUILT
CONSENTED TO FINDINGS: THAT THE FIRM VIOLATED SUBSTANTIVE PROVISIONS, FAILED TO REASONABLY SUPERVISE AND CONTROL THE ACTIONS OF
ITS EMPLOYEES, AND FAILED TO ESTABLISH A SEPARATE SYSTEM OF FOLLOW UP AND REVIEW, TO ENSURE COMPLIANCE WITH EXCHANGE RULES,
WITH RESPECT TO (A) THE CALCULATION AND REPORTING OF SHORT INTEREST: (B) COMPLIANCE BY ITS REGISTERED EMPLOYEES WITH REGISTRATION
AND CONTINUING EDUCATION REQUIREMENTS; (C) THE ISSUANCE OF ACCURATE MONTHLY ACCOUNTS STATEMENTS TO INSTITUTIONAL CUSTOMERS
OF THE FIRM; AND (D) ITS FINANCIAL OPERATIONS, SPECIFICALLY RELATING TO RECONCILIATION OF LEDGERS SANCTION: THE HEARING PANEL
IMPOSED (A) A CENSURE (B) FINE OF $725,000, AND (C) AN UNDERTAKING.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
03/09/2004
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 725,000.00
 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 FINE OF $725,000.00 WAS PAID ON MARCH 4, 2004.
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 OF THE NYSE'S HEARING PANEL, DBSI CONSENTED TO THE PENALTY.

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE BANK AG
(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) 
NEW YORK MERCANTILE EXCHANGE ("NYMEX")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/20/2009
 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
Other Product Types: 
POSITION LIMIT VIOLATION
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NYMEX ALLEGED THAT DBAG VIOLATED RULE 9A.36, IN THAT DBAG HAD A SECOND POSITION LIMIT VIOLATION WITHIN A 12 MONTH PERIOD. DBAG WAS
SUMMARILY FINED IN THE AMOUNT OF $5,000.00, AND INFORMED THAT ANY FURTHER VIOLATION IN ACCORDANCE WITH THIS RULE WILL
AUTOMATICALLY RESULT IN A HEARING BEFORE THE PROBABLE CAUSE COMMITTEE ("PCC").
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:
Other
11. Resolution Date (MM/DD/YYYY):
04/20/2009
 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: 
DBAG CONSENTED TO A FINE OF $5,000.00. THE FINE WAS PAID ON MAY 8, 2009.
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 ALLEGATIONS DBAG PAID THE FINE OF $5,000.00.

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) 
DEPARTMENT OF INSURANCE, SECURITIES AND BANKING OF THE DISTRICT OF COLUMBIA ("THE DEPARTMENT").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/11/2011
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
ORDER NO. SB-CO-10-11
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
05/11/2011
 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: $ 125,399.43
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE ADMINISTRATIVE CONSENT ORDER ENTERED BY THE DEPARTMENT ON MAY 11, 2011, DBSI AGREED TO PAY A PENALTY OF
$125,399.43 TO THE DC DEPARTMENT OF INSURANCE, SECURITIES AND BANKING AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT
AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 ADMINISTRATIVE CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S
PARENT AND NASAA AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000
TO NASAA MEMBER JURISDICTIONS, AND THE $125,399.43 PENALTY IMPOSED BY THE DEPARTMENT IS ITS PRO-RATA SHARE OF THE TOTAL
PENALTY AMOUNT. THE ADMINISTRATIVE CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE
INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR
CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT
PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS DESCRIBED IN THE ADMINISTRATIVE CONSENT ORDER.
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 ALLEGATIONS IN THE ADMINISTRATIVE CONSENT ORDER, DBSI CONSENTED TO THE DEPARTMENT MAKING THE
FOLLOWING CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY
DISCLOSE TO CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS
TO ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST
AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. D.C. CODE § 31­5602.07(A)(9) ALLOWS THE DEPARTMENT, THROUGH ITS ADMINISTRATOR,
TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION
WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. D.C. CODE § 31­5602.07(A)(12) ALLOWS THE
DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR
EMPLOYEES.

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE SECURITIES KOREA
CO.
(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) 
KOREAN FINANCIAL SERVICES COMMISSION
2.
Principal Sanction:
Suspension

Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/01/2011
 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
Other Product Types: 
INDEX ARBITRAGE TRADING
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FOLLOWING THE DECLINE OF THE KOREA COMPOSITE STOCK PRICE INDEX 200 ("KOSPI 200") IN THE CLOSING AUCTION ON NOVEMBER 11, 2010, BY
APPROXIMATELY 2.7%, THE KOREAN FINANCIAL SUPERVISORY SERVICE ("FSS") COMMENCED AN INVESTIGATION AND EXPRESSED CONCERNS THAT THE
FALL IN THE KOSPI 200 WAS ATTRIBUTABLE TO A SALE BY DEUTSCHE BANK AG ("DEUTSCHE BANK")OF A BASKET OF STOCKS, WORTH APPROXIMATELY
"EUR 1.6 BILLION", THAT WAS HELD AS PART OF AN INDEX ARBITRAGE POSITION ON THE KOSPI 200. ON FEBRUARY 23, 2011, THE KOREAN FINANCIAL
SERVICES COMMISSION, WHICH OVERSEES THE WORK OF THE FSS, REVIEWED THE FSS' FINDINGS AND RECOMMENDATIONS AND RESOLVED TO TAKE
THE FOLLOWING ACTION: (I) TO FILE A CRIMINAL COMPLAINT TO THE KOREAN PROSECUTOR'S OFFICE FOR ALLEGED MARKET MANIPULATION AGAINST
FIVE EMPLOYEES OF THE DEUTSCHE BANK GROUP AND DEUTSCHE BANK'S SUBSIDIARY DEUTSCHE SECURITIES KOREA CO. ("DSK") FOR VICARIOUS
LIABILITY; AND (II) TO IMPOSE A SUSPENSION OF SIX MONTHS, COMMENCING APRIL 1, 2011, OF DSK'S BUSINESS FOR PROPRIETARY TRADING OF
CASH EQUITIES AND LISTED DERIVATIVES AND DMA (DIRECT MARKET ACCESS) CASH EQUITIES TRADING, AND THE REQUIREMENT THAT DSK SUSPENDS
THE EMPLOYMENT OF ONE NAMED EMPLOYEE FOR SIX MONTHS. THERE IS AN EXEMPTION TO THE BUSINESS SUSPENSION TO PERMIT DSK TO
CONTINUE ACTING AS LIQUIDITY PROVIDER FOR EXISTING DERIVATIVES LINKED SECURITIES. THE KOREAN PROSECUTOR'S OFFICE WILL NOW
UNDERTAKE ITS OWN INVESTIGATION TO DETERMINE WHETHER TO INDICT DSK AND/OR THE RELEVANT EMPLOYEES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
04/01/2011
 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: 
KOREAN FINANCIAL SERVICES COMMISSION IMPOSED A SUSPENSION OF SIX MONTHS, COMMENCING APRIL 1, 2011, OF DSK'S BUSINESS FOR
PROPRIETARY TRADING OF CASH EQUITIES AND LISTED DERIVATIVES AND DMA (DIRECT MARKET ACCESS) CASH EQUITIES TRADING, AND THE
REQUIREMENT THAT DSK SUSPENDS THE EMPLOYMENT OF ONE NAMED EMPLOYEE FOR SIX MONTHS. THERE IS AN EXEMPTION TO THE BUSINESS
SUSPENSION TO PERMIT DSK TO CONTINUE ACTING AS LIQUIDITY PROVIDER FOR EXISTING DERIVATIVES LINKED SECURITIES.
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).
KOREAN FINANCIAL SERVICES COMMISSION IMPOSED A SUSPENSION OF SIX MONTHS, COMMENCING APRIL 1, 2011, OF DSK'S BUSINESS FOR
PROPRIETARY TRADING OF CASH EQUITIES AND LISTED DERIVATIVES AND DMA (DIRECT MARKET ACCESS) CASH EQUITIES TRADING, AND THE

REQUIREMENT THAT DSK SUSPENDS THE EMPLOYMENT OF ONE NAMED EMPLOYEE FOR SIX MONTHS. THERE IS AN EXEMPTION TO THE BUSINESS
SUSPENSION TO PERMIT DSK TO CONTINUE ACTING AS LIQUIDITY PROVIDER FOR EXISTING DERIVATIVES LINKED SECURITIES.

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE SECURITIES KOREA
CO. ("DSK")
(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) 
KOREA EXCHANGE (MARKET OVERSIGHT COMMISSION OF KRX) ("KRX")

2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
REQUEST FOR DISCIPLINARY MEASURE AGAINST RELEVANT EMPLOYEES.
3.
Date Initiated (MM/DD/YYYY): 
02/25/2011
 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
Other Product Types: 
INDEX ARBITRAGE
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
RECEIVING AND PLACING LARGE QUANTITY OF QUOTATIONS AND ORDERS LINKED TO LISTED DERIVATIVES TRADES THAT UNDERMINED THE FAIR
MARKET TRADE SYSTEM; AND FAILURE TO COMPLY WITH REPORTING REQUIREMENTS INCLUDING THE DELAY OF REPORTING BY 1 MINUTE.
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):
03/25/2011
 Exact
 Explanation
If not exact, provide explanation:
DSK DID NOT FILE AN APPEAL AND PAID THE FINE.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 947,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
THE ACTUAL AMOUNT OF THE FINE WAS 1 BILLION KOREAN WON (KRW), THE APPROXIMATE CONVERSION TO U.S. DOLLARS USING THE
CONVERSION DATE OF 7/21/2011 IS $947,000. ADMINISTRATIVE FINE OF KRW 1 BILLION AS KRX MEMBER REQUIRED DSK TO DISCIPLINE
RELEVANT EMPLOYEES
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: 
1) FINE (AS EXPLAINED ABOVE) 2) KRX REQUIREMENT TO DISCIPLINE RELEVANT EMPLOYEES: (1) CENSURE (REPRIMAND) OF DEALERS WHO
PLACED THE ORDERS (2) 6 MONTH SUSPENSION OF DUTY OF INDEX ARB TRADER AT DSK
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).
1. DSK PAID THE FINE BY DUE DATE OF MARCH 25, 2011 2. DSK SANCTIONED THE RELEVANT EMPLOYEES AS REQUIRED BY KRX: (1) REPRIMANDED
RELEVANT DEALERS (2) WHO PLACED RELEVANT ORDERS OF THE CLIENT (DB LONDON) (MARCH 30, 2011) (2) PLACE INDEX ARB TRADER ON SIX (6)
MONTH SUSPENSION FROM APRIL 1, 2011 TO SEPTEMBER 30, 2011.

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE BANK AG
(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) 
NEW YORK MERCANTILE EXCHANGE ("NYMEX")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/23/2011
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
NYMEX CASE 11-08386-BC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NYMEX ALLEGED THAT DBAG VIOLATED NYMEX RULE 562 (POSITION LIMIT VIOLATIONS). IN THAT ON JUNE 23, 2011, DEUTSCHE BANK HELD A POSITION
OF 5,761.25 SHORT JULY 2011 HENRY HUB NATURAL GAS LOOK-ALIKE LAST DAY FINANCIAL FUTURES ("JUL11 NATGAS") CONTRACTS, WHICH WAS
1,261.25 CONTRACTS OR 28.0% OVER ITS EXCHANGE APPROVED EXPIRATION MONTH HEDGE EXEMPTION LEVEL OF 4,500 CONTRACTS IN JUL11
NATGAS. FURTHERMORE, ON JUNE 24, 2011, DEUTSCHE BANK INCREASED ITS JUL11 NATGAS POSITION TO 6,011.25 SHORT JUL11 NATGAS CONTRACTS
OR 33.6% OVER ITS EXCHANGE APPROVED EXPIRATION MONTH HEDGE EXEMPTION LEVEL.
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):
05/22/2012
 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: $ 40,000.00
 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 FINE OF $40,000.00 WAS PAID ON JUNE 1, 2012.
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 ALLEGATIONS, DBAG AGREED TO THE SETTLEMENT AND FINE OF $40,000.00.

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
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE BANK AG ("DBAG")
(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) 
SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY ("FINMA")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/03/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 

7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINMA ALLEGED DBAG FILED LATE DISCLOSURES ON SHAREHOLDINGS IN ADECCO SA ON MARCH 26, MARCH 30, AND APRIL 13, 2010, AND LATE
DISCLOSURE OF SHAREHOLDINGS IN PEACH PROPERTY GROUP ON NOVEMBER 25, 2010, IN VIOLATION OF ART. 20 OF STOCK EXCHANGE 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):
05/02/2012
 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:
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: 
NOTE: THE ABOVE MONETARY FINE IS IN SWISS FRANCS.
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 FINE OF 50,000 SWISS FRANCS WAS PAID.

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:
5832043
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
RINALDI, CHARLES J
(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).

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, INC.
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE
3.
Date Initiated (MM/DD/YYYY): 
04/15/1992
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CMS 920065 AWC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ALLEGED FAILURE TO REPORT "0" TRADING VOLUME ON THREE (3) NASDAQ SECURITIES, BY DEUTSCHE BANK CAPITAL CORPORATION THE
PREDECESSOR FIRM OF THE APPLICANT.
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):
08/17/1992
 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 FINE OF $5,000.00 WAS PAID ON OR ABOUT AUGUST 7, 1992.
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 NASD'S ALLEGATION, THE APPLICANTS'S PREDECESSOR AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND
CONSENT AND TO PAY $5,000.00.

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) 
NASD, INC. MARKET REGULATION COMMITTEE.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
01/10/1997
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
CMS960225
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 COMPLAINT ALLEGED VIOLATION OF NASD MARKETPLACE RULES 4632,4642, & 6130(D)(7) IN THAT APPLICANT FAILED TO TIMELY AND
ACCURATELY REPORT NASDAQ NMS AND NASDAQ SMALLCAP TRANSACTIONS, RULE 6620 FOR APPLICANTS'S FAILURE TO TIMELY AND ACCURATELY
REPORT OTC EQUITY SECURITIES TRANSACTIONS; AND VIOLATION OF NASD CONDUCT RULE 2110 AND 3110 FOR APPLIANT'S FAILURE TO SUPERVISE.
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):
02/06/1998
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 12,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE FINE WAS PAID ON OR ABOUT 2/6/98.
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 ALLEGATIONS OF THE COMPLAINT, APPLICANT HAS CONSENTED, FOR THE PURPOSES OF THIS PROCEEDING
ONLY, TO THE ENTRY OF FINDINGS OF FACTS AND VIOLATIONS CONSISTENT WITH THE ALLEGATIONS OF THE COMPLAINT. APPLICANT WAS CENSURED
AND FINED $12,500.00.

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 ASSOCIATIONS OF SECURITIES DEALERS, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/11/1991
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
MS-999 AND MS-1031
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD ALLEGED VIOLATIONS BY PREDECESSOR OF APPLICANT OF ARTICLE III, SECTIONS 1 AND 41 OF THE RULE OF FAIR PRACTICE, REGARDING
THE REPORTING TRANSACTION IN CERTAIN NON-NASDAQ OVER-THE-COUNTER SECURITES.
8.
Current Status?      
 Pending
 On Appeal
 Final

9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
09/11/1991
 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: $ 1,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
ORDER MAKING FINDINGS AND IMPOSING SANCTIONS.
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: 
A FINE OF $1,000.00 WAS PAID ON OR ABOUT 9/11/91.
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 TO OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO THE ENTRY OF AN ORDER MAKING FINDINGS AND
IMPOSINGS SANCTIONS, AND PAID A FINE OF $1,000.00

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, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
10/03/1997
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CMS990004AWC
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 NASDR ALLEDGED THAT APPLICANT FAILED TO ESTABLISH WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE
COMPLIANCE WITH THE SEC RULE 11AC1(C)(5) AND NASD CONDUCT RULE 2110. IN ADDITION AS A RESULT, NASD ALLEGED THAT APPLICANTS FAILURE
TO ENFORCE ITS SUPERVISORY PROCEDURES RELATING TO BOOKS AND RECORDS VIOLATED NASD CONDUCT RULE 3010.
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):
02/25/1999
 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: $ 7,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE FINE WAS PAID ON OR ABOUT 2/25/99.
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 ALLEGATIONS, THE APPLICANT AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT AND TO PAY
$7,500.

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:
Other
Other Sanctions: 
ORDER MAKING FINDINGS AND IMPOSING SANTIONS.
3.
Date Initiated (MM/DD/YYYY): 
01/16/1992
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NOT APPLICABLE.
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Government
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC ALLEGED VIOLATIONS BY PREDECESSOR OF APPLICANT OF RULE 15C OF THE SECURITIES AND EXCHANGE ACT OF 1934 AND 17 C.F.R. PART
404. WITH RESPECT TO CERTAIN RECORDS TO ITS DISTRIBUTION OF CERTAIN UNSECURED DEBT SECURITIES RELATING TO ITS DISTRIBUTION OF
CERTAIN UNSECURED DEBT SECURITIES OF ONE OR MORE GOVERNMENT SPONSORED ENTERPRISES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/16/1992
 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:
ORDER MAKING FINDINGS AND IMPOSING SANCTIONS WITH RESPECT TO CERTAIN RECORDS RELATING TO ITS DISTRIBUTION OF CERTAIN
UNSECURED DEBT SECURITIES OF ONE OR MORE GOVERNMENT SPONSORED ENTERPRISES.
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: 
NONE.
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 TO OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO THE ENTRY OF AN ORDER MAKING FINDINGAND
IMPOSING SANCTIONS.

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 SECURITES DEALERS, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 

10/28/1971
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NASD-NY 1533
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD ALLEGED VIOLATIONS BY PREDECESSOR OF APPLICANT OF ARTICLE III, SECTION 1 OF THE RULES OF FAIR PRACTICE, FR&W, REGARDING
THE SALE OF 100 SHARES OF HOT ISSUES TO RESTRICTED ACCOUNTS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
09/14/1972
 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: $ 1,000.00
 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 FINE WAS PAID ON 10/10/72.
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 AGREED TO SETTLE THIS MATTER WITHOUT ADMITTING OR DENYING THE NASD'S ALLEGATION AND PAID THE $1,000.00 FINE.

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 ASSOICIATION OF SECURITIES DEALERS, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
10/28/1971
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NASD-NY 1531
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD ALLEGED VIOLATIONS BY PREDECESSOR OF APPLICANT OF ARTICLE III, SECTION 1 OF THE RULES OF FAIR PRACTICE, REGARDING THE
RESTRICTION OF USE OF INTERMEDIARY BROKERS.
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):
07/08/1972
 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: $ 5,184.00
 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 FINE WAS PAID ON JULY 17, 1972.
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 AGREED TO SETTLE THIS MATTER WITHOUT ADMITTING OR DENYING THE NASD'S ALLEGATIONS AND PAID THE $5,184.00 FINE.

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) 
FLORIDA DEPARTMENT OF BANKING AND FINANCING, DIV. OF SEC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/31/1995
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2267-S-12/96
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):
ALLEGED VIOLATION BY APPLICANT OF SECTION 517.12(5) IN THAT APPLICANT'S FLORIDA BRANCH OFFICE WAS NOT REGISTERED WITH THE FLORIDA
DEPARTMENT OF BANKING AND FINANCING, DIVISION OF SECURITIES AND INVESTOR PROTECTION BECAUSE OF FAILURE TO TIMELY RENEW ITS
FLORIDA BRANCH OFFICE APPLICATION BEFORE MARCH 31,1995 ACCOUNTS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
04/02/1996
 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: $ 16,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution

 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE FINE WAS PAID ON OR ABOUT 4/2/1996.
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 VIOLATION OF SECTION 517.12(5) OF THE FLORIDA STATUTES, APPLICANT AGREED TO PAY A FINE OF $16,500.00.

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) 
NASD, INC. MARKET REGULATION DEPARTMENT STAFF
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
01/10/1997
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CMS970066AWC
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):
AS THE RESULT OF ROUTINE EXAMINATION OF APPLICANT, THE NASDR ALLEGED VIOLATIONS OF SEC RULE 17A-3 AND NASD CONDUCT RULE 3110(E)
FOR APPLICANTS FAILURE TO CORRECTLY PREPARE ORDER MEMORANDUM.
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):
01/12/1998
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 2,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE FINE WAS PAID ON 2/4/98.
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 ALLEGATIONS, THE APPLICANT AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT AND TO PAY
$2,500.00. IN ADDITION, APPLICANT AGREED TO IMPLEMENT AND PROVIDE THE NASD STAFF WITHIN 60 DAYS OF THE ACCEPTANCE OF THE AWC
REVISED WRITTEN SUPERVISORY PROCEDURES CONCERNING RECORDKEEPING.

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) 
NEW YORK STOCK EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
06/23/1999
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:

EXCHANGE HEARING PANEL DECISION 99-490
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Asset Backed
Other Product Types: 
DEBT-GOVERNMENT
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DBSI VIOLATED SEC REG.240.15C3-1, SEC REG.240.17A-11(B), AND SEC REG.240.17A-11(D)IN ADDITION, VIOLATED SEC REG.240.17A-5, SEC
REG.240.8(C)1 AND 240.15C3-3, SEC REG.240.17A-3 AND 240.17A-4 THE ABOVE-MENTIONED RELATE TO FINANCIAL REPORTING BOOKS AND RECORDS
VIOLATIONS. DBSI WAS ALSO IN VIOLATION OF NYSE RULES 325, 440 AND 342.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
08/13/1999
 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: $ 175,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
NONE
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 FINE OF $175,000.00 WAS PAID ON AUGUST 19, 1999.
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 SETTLEMENT CONCLUDES THE MATTER HAVING PAID THE FINE NO FURTHER ACTION IS REQUIRED.

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, INC.
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE
3.
Date Initiated (MM/DD/YYYY): 
06/06/2000
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CMS000104
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD ALLEGED FAILURE TO ACCEPT OR DECLINE IN ACT TRANSACTIONS IN ELIGIBLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION OF SUCH
TRANSACTIONS; FAILURE TO DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS, WHEN THE ORDERS WERE AT A PRICE THAT WOULD HAVE IMPROVED
ITS BID OR OFFER IN EACH SUCH SECURITY RELATED TO THOSE ORDERS, OR WHEN THE FULL SIZE OF EACH SUCH ORDER WERE PRICED EQUAL TO ITS
BID OR OFFER AND THE NATIONAL BEST BID OR OFFER AND THE ORDERS REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE
ASSOCIATED WITH ITS BID OR OFFER IN EACH SECURITY; AND, FAILURE TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN SUPERVISORY
PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE
NASD CONCERNING TRADE REPORTING, ACT COMPLIANCE, BEST EXECTION, LIMIT ORDER PROTECTION INTERPRETATION, LOCKED AND CROSSED
MARKETS, BOOKS AND RECORDS, SEC ORDER EXECUTION RULES AND 21(A) REPORT ISSUES.

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):
06/06/2000
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 25,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
REVISE WRITTEN SUPERVISORY PROCEDURES WITHIN 60 DAYS OF AWC'S ACCEPTANCE.
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 FINE OF $25,000.00 WAS PAID ON AUGUST 18, 2000.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE APPLICANT AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT AND TO PAY
$25,000.00.

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, INC.
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE
3.
Date Initiated (MM/DD/YYYY): 
06/06/2000
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CMS000105
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD ALLEGED THAT DBSI, A MARKET MAKER IN SECURITIES, WITHOUT MAKING REASONABLE EFFORTS TO AVOID A LOCKED OR CROSSED MARKET
BY EXECUTING TRANSACTIONS WITH ALL MARKET MAKERS WHOSE QUOTATIONS WOULD BE LOCKED OR CROSSED, ENTERED A BID OR ASK QUOTATION
IN THE NASDAQ STOCK MARKET WHICH CAUSED A LOCKED OR CROSSED MARKET CONDITION TO OCCUR.
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):
06/06/2000
 Exact
 Explanation
If not exact, provide explanation:

12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 3,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
NONE
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 FINE OF $3,000.00 WAS PAID ON AUGUST 18, 2000.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE APPLICANT AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT AND TO PAY
$3,000.00.

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.

p
 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) 
NEW YORK STOCK EXCHANGE, INC.
2.
Principal Sanction:
Censure
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/09/2001
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
01-148
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
VIOLATED SEC REG. 240.15C2-8(C) BY FAILING TO PROVIDE PRELIMINARY PROSPECTUSES TO CUSTOMERS WHO INDICATED INTEREST IN PURCHASING
INITIAL PUBLIC OFFERINGS; VIOLATED EXCHANGE RULE 410 BY FAILING TO INCLUDE TERMS OF THE ORDER ON TICKETS TRANSMITTED TO THE FLOOR;
VIOLATED EXCHANGE RULE 440 AND SEC REG. 240.17A-3(A)(6) BY FAILING TO MAINTAIN A MEMORANDUM OF ORDERS; VIOLATED EXCHANGE RULE 440
AND SEC REGS. 240.17A-3 AND 17A-4 BY FAILING TO MAKE A PRESERVE REQUIRED BOOKS AND RECORDS; VIOLATED EXCHANGE RULE 342.16 IN THAT
A BRANCH FAILED TO PROPERLY SUPERVISE AND APPROVE OUTGOING CORRESPONDENCE; AND VIOLATED EXCHANGE RULE 342 BY FAILING TO
REASONABLY SUPERVISE AND PROVIDE APPROPRIATE SUPERVISORY PROCEDURES TO DETERMINE THAT DELEGATED AUTHORITY IS BEING PROPERLY
EXERCISED.
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):
09/26/2001
 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: $ 100,000.00
 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 FINE OF $100,000.00 WAS PAID ON SEPTEMBER 25, 2001.

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 ALLEGATIONS THE FIRM CONSENTED TO THE FINDINGS. THIS SETTLEMENT AND THE PAYMENT OF $100,000.00
CONCLUDES THIS MATTER.

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) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 

CIVIL PENALTIES, CENSURE, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
12/03/2002
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 3-10957
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT 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 SEC ALLEGES THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") FAILED TO COMPLY WITH CERTAIN ASPECTS OF THE RECORD-KEEPING
REQUIREMENTS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 DURING THE PERIOD FROM 1999 TO (AT LEAST) 2001, IN THAT IT FAILED IN
PRESERVING FOR THREE YEARS, AND/OR TO PRESERVE IN AN ACCESSIBLE PLACE FOR TWO YEARS, ALL ELECTRONIC MAIL COMMUNICATIONS
(INCLUDING INTER-OFFICE MEMORANDA) RECEIVED AND SENT BY ITS AGENTS AND EMPLOYEES THAT RELATED TO ITS BUSINESS AS A MEMBER OF AN
EXCHANGE OR AS A BROKER OR DEALER.
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:
NOT APPLICABLE
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):
12/03/2002
 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: $ 1,650,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
WITHIN 90 DAYS OF THE ISSUANCE OF THE ORDER, UNLESS OTHERWISE EXTENDED BY THE STAFF OF THE COMMISSION FOR GOOD CAUSE
SHOWN, DBSI UNDERTAKES AND AGREES TO INFORM THE COMMISSION IN WRITING THAT IT HAS COMPLETED ITS REVIEW AND THAT IT HAS
ESTABLISHED SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THOSE LAWS, REGULATIONS, AND RULES
CONCERNING THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS.
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: 
DBSI PURSUANT TO SECTION 21C OF THE EXCHANGE ACT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY
FUTURE VIOLATIONS OF SECTION 17(A) AND RULE 17A-4. IN ADDITION, DBSI PAID THE CIVIL MONETARY PENALTY OF $1,650,000 ON DECEMBER
11, 2002, IN THE MANNER AND TO THE PARTIES DESCRIBED IN THE FINAL ORDER .
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 OF THE SEC'S ADMINISTRATIVE PROCEEDING, DBSI CONSENTED TO PAY THE FINE AND COMPLY WITH
THE FINAL ORDER.

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, INC
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
11/22/2002
 Exact
 Explanation
If not exact, provide explanation:
EXACT DATE AWC INITIATED UNKNOWN.
4.
Docket/Case Number:

CAF020064
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD ALLEGES THAT DBSI (A) FAILED TO KEEP ELECTRONIC COMMUNICATIONS FOR THREE YEARS AND/OR FAILED TO PRESERVE ELECTRONIC MAIL
COMMUNICATIONS FOR THE FIRST TWO YEARS, IN AN ACCESSIBLE PLACE IN VIOLATION OF SECTION 17(A) OF THE EXCHANGE ACT, RULE 17A-4
THEREUNDER, AND NASD RULE 3110, AND (B) HAD INADEQUATE SUPERVISORY SYSTEMS AND PROCEDURES THAT WERE NOT REASONABLY DESIGNED
TO ACHIEVE COMPLIANCE WITH SECTION 17(A), RULE 17A-4 THEREUNDER AND NASD RULE 3110 IN VIOLATION OF NASD RULE 3010.
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:
NOT APPLICABLE
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):
11/22/2002
 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: $ 1,650,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
DBSI UNDERTAKES TO REVIEW ITS PROCEDURES REGARDING THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FOR COMPLIANCE
WITH THE FEDERAL SECURITIES LAWS AND THE RULES OF NASD AND THE EXCHANGE. WITHIN 90 DAYS OF THE ISSUANCE OF THIS ORDER,
UNLESS OTHERWISE EXTENDED BY THE STAFF OF THE NASD FOR GOOD CAUSE SHOWN, DBSI UNDERTAKES AND AGREES TO INFORM THE NASD IN
WRITING THAT IT HAS COMPLETED ITS REVIEW AND THAT IT HAS ESTABLISHED SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE
COMPLIANCE WITH THOSE LAWS, REGULATIONS, AND RULES CONCERNING THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS.
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: 
DBSI PAID THE FINE OF $1,650,000 (REDUCED BY AMOUNTS PAID BY DBSI PURSUANT TO AGREEMENTS TO PAY A CIVIL MONETARY PENALTY OF
$550,000 TO THE U.S. TREASURY AND A FINE OF $550,000 TO THE NYSE IN RELATED PROCEEDINGS).
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 TO THE ALLEGATIONS OF THE NASD'S AWC, DBSI CONSENTED TO THE SANCTIONS.

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) 
NEW YORK STOCK EXCHANGE, INC
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
11/12/2002
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
02-223
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT 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 NYSE ALLEGES THAT DBSI VIOLATED RULE 440 AND SEA SECTION 17(A) AND SEC REG. 17A-4 BY FAILING TO PRESERVE FOR A PERIOD OF THREE
YEARS, AND/OR PRESERVE IN AN ACCESSIBLE PLACE FOR TWO YEARS, ELECTRONIC COMMUNICATIONS RELATING TO THE BUSINESS OF THE FIRM AND
VIOLATED EXCHANGE RULE 342 BY FAILING TO REASONABLY SUPERVISE AND CONTROL THE ACTIVITIES OF ITS EMPLOYEES TO ASSURE COMPLIANCE
WITH EXCHANGE RULES AND FEDERAL SECURITIES LAWS RELATING TO RETENTION OF ELECTRONIC COMMUNICATIONS.
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:
NOT APPLICABLE
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
11/15/2002
 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: $ 1,650,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
WITHIN 90 DAYS OF THE EXECUTION OF THE STIPULATION AND CONSENT, DBSI UNDERTAKES AND AGREES TO INFORM THE EXCHANGE IN
WRITING THAT IT HAS COMPLETED ITS REVIEW AND THAT IT HAS SYSTEMS AND PROCEDURES IN PLACE REASONABLY DESIGNED TO ENSURE
COMPLIANCE WITH THOSE LAWS AND RULES CONCERNING THE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS. THE NYSE'S DIVISION
OF ENFORCEMENT SHALL HAVE THE DISCRETION, UPON SHOWING OF GOOD CAUSE, TO EXTEND THE DEADLINE FOR COMPLIANCE WITH THIS
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: 
DBSI PAID THE FINE OF $1,650,000 (REDUCED BY AMOUNTS PAID PURSUANT TO AGREEMENTS TO PAY A CIVIL PENALTY OF $550,000 TO THE U.S.
TREASURY AND A FINE OF $550,000 TO THE NASD).
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 OF THE NYSE'S HEARING PANEL, DBSI CONSENTED TO THE PENALTY.

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, INC.
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE
3.
Date Initiated (MM/DD/YYYY): 
07/17/2000
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CMS010156AWC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN CONNECTION WITH MRD REVIEW#2000271404613, THE NASDR ALLEGED THAT DEUTSCHE BANC ALEX. BROWN INC. ("DBAB") VIOLATED NASD RULE
4613. NASDR ALLEGED THAT ON 10 OCCASIONS FROM JULY 1, 2000 TO SEPTEMBER 30, 2000, DBAB A MARKET MAKER IN THE SUBJECT SECURITIES,
WITHOUT MAKING REASONABLE EFFORTS TO AVOID A LOCKED OR CROSSED MARKET BY EXECUTING TRANSACTIONS WITH ALL MARKET PARTICIPANTS
WHOSE QUOTATIONS WOULD BE LOCKED OR CROSSED, ENTERED A BID OR ASKED QUOTATION IN THE NASDAQ STOCK MARKET WHICH CAUSED A
LOCKED OR CROSSED MARKET CONDITION TO OCCUR IN EACH INSTANCE.
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):
10/01/2001
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 3,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE FINE OF $3,000.00 WAS PAID ON OCTOBER 30, 2001.
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 ALLEGATIONS, THE APPLICANT AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT AND TO PAY
$3,000.00.

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, INC.
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE
3.
Date Initiated (MM/DD/YYYY): 
08/09/2001
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CMS020072
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN CONNECTION WITH MRD REVIEW#200130290, THE NASDR ALLEGED THAT DEUTSCHE BANC ALEX. BROWN INC. ("DBAB") VIOLATED NASD RULE 4613
(E)(1)(C). NASDR ALLEGED THAT ON 62 OCCASIONS FROM APRIL 1, 2001 TO JUNE 30, 2001, DBAB A MARKET MAKER IN THE RELEVANT SECURITIES,
CAUSED A LOCKED/CROSSED MARKET CONDITION PRIOR TO THE MARKET OPENING BY ENTERING A BID (ASK)QUOTATION THAT LOCKED/CROSSED
ANOTHER MARKET MAKER'S QUOTATIONS WITHOUT IMMEDIATELY THEREAFTER SENDING THROUGH SELECTNET TO THE MARKET MAKER(S)WHOSE
QUOTE(S) IT LOCKED OR CROSSED A TRADE-OR-MOVE MESSSAGE(S) THAT WAS AT THE RECEIVING MARKET MAKER'S QUOTED PRICE AND WHOSE
AGGREGATE SIZE WAS AT LEAST 5000 SHARES.
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):
04/29/2002
 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: $ 20,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
THE FINE OF $20,000.00 WAS PAID ON MAY 17, 2002.
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 ALLEGATIONS, THE APPLICANT AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT AND TO
PAY A $20,000.00 FINE.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

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) 
CHICAGO BOARD OF TRADE ("CBOT")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/28/2003
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
02-RFT-110
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") (F/K/A DEUTSCHE BANK FUTURES INC. "DBFI")
VIOLATED CBT REGULATION 332.08. IN 12 INSTANCES, FAILED TO KEYPUNCH THE UPDATED ORDER ENTRY TIME FOR A CANCEL/REPLACE ORDER INTO
THE "TIME STAMP IN" FIELD. IN 5 INSTANCES, THE INCORRECT ORDER TYPE WAS KEYPUNCHED INTO THE TRADE ENTRY SYSTEM. IN 4 INSTANCES, THE
INCORRECT CONFIRMATION TIME WAS KEYPUNCHED INTO THE TRADE ENTRY SYSTEM. IN 1 INSTANCE, THE INCORRECT ORDER ENTRY TIME WAS
KEYPUNCHED INTO THE TRADE ENTRY SYSTEM. PLEASE NOTE DBFI MERGED WITH DBSI ON 11-01-02.
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):
04/10/2003
 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: $ 1,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE FINE OF $1,500.00 WAS PAID ON APRIL 10, 2003.
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 ANY VIOLATION OF CBT REGULATION 332.08, DBSI AGREED TO PAY A FINE OF $1,500.00.

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) 
CHICAGO BOARD OF TRADE ("CBOT")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/19/2003
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
02-EX-26
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHICAGO BOARD OF TRADE ("CBOT") ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED REGULATIONS 285.05 AND 545.02, IN
THAT THE FIRM DID NOT ACCURATELY CALCULATE AND/OR REFLECT CERTAIN ASSETS, LIABILITIES, CAPITAL CHARGES, MARGIN REQUIREMENTS, AND
SEGREGATED AND SECURED AMOUNTS ON ITS JULY 31, 2002 FINANCIAL STATEMENT, AND REGULATIONS 431.02 AND 545.02, AND IN THAT THE FIRM
DID NOT MEET THE EXCHANGE'S REQUIREMENTS FOR MAINTAINING A SYSTEM FOR RECORDING AND AGING OUTSTANDING MARGIN CALLS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
04/15/2003
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 10,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
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 FINE OF $10,000.00 WAS PAID ON MAY 2, 2003.
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 ANY VIOLATIONS OF CBT REGULATIONS 285.05, 431.02 OR 545.02, DBSI AGREED TO PAY A FINE OF $10,000.00.

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
CRD
Number:
105006
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE ASSET
MANAGEMENT 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) 
US SECURITIES AND EXCHANGE COMMISSION ("SEC")
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURE, CIVIL MONETARY PENALTY
3.
Date Initiated (MM/DD/YYYY): 
08/19/2003
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-11226
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 SEC ALLEGED THAT DEUTSCHE ASSET MANAGEMENT INC. ("DEAM") INC., AN ENTITY UNDER COMMON CONTROL WITH DBSI, VIOLATED SECTION
206(2) OF THE INVESTMENT ADVISERS ACT OF 1940. THE SEC ALLEGED THAT DEAM INC. VOTED CLIENT PROXIES IN CONNECTION WITH A CONTESTED
MERGER WITHOUT FIRST DISCLOSING THE CIRCUMSTANCES OF ITS INVESTMENT BANKING AFFILIATE'S WORK ON THE PROPOSED MERGER AND THE
FACT THAT THIS AFFILIATE HAD INTERVENED IN THE VOTING PROCESS.
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):
08/19/2003
 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: $ 750,000.00
 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: 
DEAM INC. AGREED TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $750,000, WHICH WAS PAID TO THE U.S. TREASURY ON AUGUST 22,
2003.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON JULY 1, 2003, DEAM INC., AN ENTITY UNDER COMMON CONTROL WITH DBSI, SUBMITTED AN OFFER OF SETTLEMENT TO THE SEC, WHICH WAS
ACCEPTED BY THE SEC ON AUGUST 19, 2003. IN THE OFFER OF SETTLEMENT, SOLELY FOR THE PURPOSE OF THE PROCEEDING AND ANY OTHER ACTION
IN WHICH THE SEC IS A PARTY AND WITHOUT ADMITTING OR DENYING THE FINDINGS SET FORTH IN THE ADMINISTRATIVE ORDER, DEAM INC.
CONSENTED TO THE FINDING OF A VIOLATION DESCRIBED IN 7, ABOVE. AS A RESULT OF THE FINDING, DEAM INC. CONSENTED TO AN ENTRY OF A
CEASE AND DESIST ORDER, A CENSURE, AND THE PAYMENT OF A $750,000 CIVIL MONETARY PENALTY.

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE INVESTMENT
MANAGEMENT AMERICAS INC.
(FKA SCUDDER KEMPER
INVESTEMENTS, 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:
Censure
Other Sanctions: 
CEASE AND DESIST, CIVIL AND ADMINISTRATIVE PENALTIES, OTHER: SCUDDER KEMPER INVESTMENTS, INC. ("SCUDDER KEMPER") UNDERTOOK TO
MAINTAIN ENHANCED SUPERVISORY POLICES AND PROCEDURES RELATING TO FIXED-INCOME DERIVATIVES AND TO INFORM AFFECTED CLIENT
ACCOUNTS OF THE SEC ORDER.
3.
Date Initiated (MM/DD/YYYY): 
12/21/1999
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-10121
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
SCUDDER KEMPER INVESTMENTS, INC.
6.
Principal Product Type:
Derivative(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC ALLEGED THAT THE ACTIONS GIVING RISE TO THE ADMINISTRATIVE PROCEEDING AROSE FROM THE ACTIONS OF A FORMER TRADER AT
SCUDDER KEMPER'S BOSTON DERIVATIVES TRADING DESK, WHO VIOLATED APPLICABLE TRADING LIMITS ESTABLISHED BY PORTFOLIO MANAGERS IN

CERTAIN INSTITUTIONAL ACCOUNTS, INCLUDING REGISTERED INVESTMENTS COMPANIES, MANAGED BY SCUDDER KEMPER DURING A PERIOD FROM
JULY 1997 THROUGH OCTOBER 9, 1998. THE ORDER ALLEGES THAT AS A RESULT OF THE TRADER'S MISCONDUCT, LOSSES OF MORE THAN $16 MILLION
WERE INCURRED. SCUDDER KEMPER FULLY REIMBURSED THE LOSSES. THE SEC ALLEGED THAT THE TRADER'S SUPERVISOR AND SCUDDER KEMPER
FAILED TO SUPERVISE THE TRADER AND, THROUGH THE TRADER'S ACTIONS, SCUDDER KEMPER FAILED ACCURATELY TO MAINTAIN CERTAIN REQUIRED
BOOKS AND RECORDS UNDER THE INVESTMENT ADVISERS ACT OF 1940 AND THE INVESTMENT COMPANY ACT OF 1940.
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):
12/21/1999
 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: $ 250,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
SCUDDER KEMPER INVESTMENTS, INC. UNDERTOOK TO MAINTAIN ENHANCED SUPERVISORY POLICES AND PROCEDURES WITH RESPECT TO
FIXED-INCOME DERIVATIVES AND TO INFORM AFFECTED CLIENT ACCOUNTS ABOUT THE SEC ORDER.
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: 
SCUDDER KEMPER INVESTMENTS, INC. WAS FINED A CIVIL MONEY PENALTY OF $250,000, WHICH IT WAS OBLIGATED TO PAY TO THE UNITED
STATES TREASURY WITHIN 30 DAYS OF 12/21/99.
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 DELETE DRP ALREADY REPORTED ON FORM B/D.

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE INVESTMENT
MANAGEMENT AMERICAS INC.
("FKA SCUDDER KEMPER
INVESTMENTS, 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:
Censure
Other Sanctions: 
CEASE AND DESIST, CIVIL AND ADMINISTRATIVE PENALTIES, OTHER: SCUDDER KEMPER INVESTMENTS, INC. ("SCUDDER KEMPER")UNDERTOOK TO
MAINTAIN ENHANCED SUPERVISORY POLICIES AND PROCEDURES RELATING TO FIXED-INCOME DERIVATIVES AND TO INFORM AFFECTED CLIENT
ACCOUNTS OF THE SEC ORDER.
3.
Date Initiated (MM/DD/YYYY): 
12/21/1999
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-10121
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
SCUDDER KEMPER INVESTMENTS, INC.
6.
Principal Product Type:
Derivative(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC ALLEGED THAT THE ACTIONS GIVING RISE TO THE ADMINISTRATIVE PROCEEDING AROSE FROM THE ACTIONS OF A FORMER TRADER AT
SCUDDER KEMPER'S BOSTON DERIVATIVES TRADING DESK, WHO VIOLATED APPLICABLE TRADING LIMITS ESTABLISHED BY PORTFOLIO MANAGERS IN
CERTAIN INSTITUTIONAL ACCOUNTS, INCLUDING REGISTERED INVESTMENT COMPANIES, MANAGED BY SCUDDER KEMPER DURING A PERIOD FROM JULY

1997 THROUGH OCTOBER 9, 1998. THE ORDER ALLEGES THAT AS A RESULT OF THE TRADER'S MISCONDUCT, LOSSES OF MORE THAT $16 MILLION
WERE INCURRED. SCUDDER KEMPER FULLY REIMBURSED THE LOSSES. THE SEC ALLEGED THAT THE TRADER'S SUPERVISOR AND SCUDDER KEMPER
FAILED TO SUPERVISE THE TRADER AND, THROUGH THE TRADER'S ACTIONS, SCUDDER KEMPER FAILED ACCURATELY TO MAINTAIN CERTAIN REQUIRED
BOOKS AND RECORDS UNDER THE INVESTMENT ADVISERS ACT OF 1940 AND THE INVESTMENT COMPANY ACT OF 1940.
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):
12/21/1999
 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: $ 250,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
SCUDDER KEMPER INVESTMENTS, INC. UNDERTOOK TO MAINTAIN ENHANCED SUPERVISORY POLICES AND PROCEDURES WITH RESPECT TO
FIXED-INCOME DERIVATIVES AND TO INFORM AFFECTED CLIENT ACCOUNTS ABOUT THE SEC ORDER.
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: 
SCUDDER KEMPER INVESTMENTS, INC. WAS FINED A CIVIL MONEY PENALTY OF $250,000.00, WHICH IT WAS OBLIGATED TO PAY TO THE UNITED
STATES TREASURY WITHIN 30 DAYS OF 12/21/1999.
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).

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

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

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NASD
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
12/31/2003
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CMS030303
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI")VIOLATED NASD CONDUCT RULE 2110 AND NASD MARKETPLACE RULES 4632 AND
6620(A)- DBSI INCORRECTLY DESIGNATED AS "PRP" THROUGH ACT ONE LAST SALE REPORT OF A TRANSACTION IN A NASDAQ NATIONAL
MARKET("NNM")SECURITY; FAILED TO REPORT THE CORRECT NUMBER OF SHARES THROUGH ACT IN LAST SALE REPORTS OF RISKLESS PRINCIPAL
TRANSACTIONS IN NNM SECURITIES; FAILED TO REPORT THE CORRECT PRICE THROUGH ACT IN LAST SALE REPORTS OF RISKLESS PRINCIPAL
TRANSACTIONS IN NNM SECURITIES; DOUBLE REPORTED TO ACT ONE LAST SALE REPORT OF A TRANSACTION IN A NNM SECURITY; FAILED TO SUBMIT,
FOR THE OFFSETTING, RISKLESS PORTION OF TRANSACTIONS IN NNM SECURITIES EITHER: (A) A CLEARING ONLY REPORT WITH A CAPACITY INDICATOR
OF RISKLESS PRINCIPAL,IF A CLEARING REPORT IS NECESSARY TO CLEAR THE TRANSACTION; OR(B)A NON-TAPE, NON-CLEARING REPORT WITH A
CAPACITY INDICATOR OF RISKLESS PRINCIPAL, IF A CLEARING REPORT IS NOT NECESSARY TO CLEAR THE TRANSACTION; FAILED WITHIN 90 SECONDS
AFTER EXECUTION, TO TRANSMIT TO ACT LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES; AND, FAILED WITHIN 90 SECONDS
AFTER EXECUTION, TO TRANSMIT TO ACT LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES AND FAILED TO DESIGNATE THROUGH
ACT SUCH LAST SALE REPORTS AS LATE.
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):
01/15/2004
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 9,000.00
 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 FINE OF $9,000.00 WAS PAID ON JANUARY 15, 2004.
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 ALLEGATIONS, THE APPLICANT AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT AND TO PAY
$9,000.00.

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) 
NEW YORK STOCK EXCHANGE, INC.
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
11/04/2003
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
HPD#: 03-221
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NEW YORK STOCK EXCHANGE, INC. ("NYSE") ALLEGED AND DEUTSCHE BANK SECURITIES INC. ("DBSI") WITHOUT ADMITTING OR DENYING GUILT
CONSENTED TO FINDINGS: THAT THE FIRM VIOLATED SUBSTANTIVE PROVISIONS, FAILED TO REASONABLY SUPERVISE AND CONTROL THE ACTIONS OF
ITS EMPLOYEES, AND FAILED TO ESTABLISH A SEPARATE SYSTEM OF FOLLOW UP AND REVIEW, TO ENSURE COMPLIANCE WITH EXCHANGE RULES,
WITH RESPECT TO (A) THE CALCULATION AND REPORTING OF SHORT INTEREST; (B) COMPLIANCE BY ITS REGISTERED EMPLOYEES WITH THE
REGISTRATION AND CONTINUING EDUCATION REQUIREMENTS; (C) THE ISSUANCE OF ACCURATE MONTHLY ACCOUNTS STATEMENTS TO INSTITUTIONAL
CUSTOMERS OF THE FIRM; AND (D) ITS FINANCIAL OPERATIONS, SPECIFICALLY RELATING TO RECONCILIATION OF LEDGERS SANCTION: THE HEARING
PANEL IMPOSED (A) A CENSURE (B) A FINE OF $725,000, AND (C) AN UNDERTAKING.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
03/09/2004
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?

 Monetary/Fine Amount: $ 725,000.00
 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 FINE OF $725,000.00 WAS PAID ON MARCH 9, 2004.
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 OF THE NYSE'S HEARING PANEL, DBSI CONSENTED TO THE PENALTY.

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE BANK AG
(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) 
OSLO POLICE DISTRICT, SECTION OF FINANCE AND ENVIRONMENTAL CRIME.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
SEE NUMBER 13 BELOW.
3.
Date Initiated (MM/DD/YYYY): 
01/07/2004
 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):
N/A
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
OPTIONS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DEUTSCHE BANK AG, AN AFFILIATE OF THE FILER OF THIS FORM B/D FAILED TO FILE APPROPRIATE NOTICES WITH THE OSLO STOCK EXCHANGE WITHIN
THE TIME PERIOD REQUIRED AFTER STOCK AND OPTION PURCHASES THAT CAUSED HOLDINGS BY DEUTSCHE BANK AG TO EXCEED LEVELS SPECIFIED
BY NORWEGIAN REGULATION.
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:
N/A
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
02/20/2004
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 4,300.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of

penalty was waived: 
TOTAL AMOUNT OF FINE: US $4300 PORTION LEVIED AGAINST CONTROL AFFILIATE: 100% DATE PAID: TO BE DETERMINED PORTION OF PENALTY
WAIVED: 0
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 ACTION AGAINST DEUTSCHE BANK AG IS FINAL. THE FINANCIAL SUPERVISORY AUTHORITY OF NORWAY, A FINANCIAL REGULATORY AUTHORITY, DID
NOT MAKE A FINAL CONCLUSION THAT A VIOLATION HAD OCCURRED. INSTEAD, AS REQUIRED BY NORWEGIAN LAW, ANY SUCH FINDING MUST BE MADE
BY THE RELEVANT POLICE AUTHORITY, IN THIS CASE THE OSLO POLICE DISTRICT WHICH IS NOT A FINANCIAL REGULATOR. THE POLICE DISTRICT
DETERMINED TO RESOLVE THIS MATTER BY ACCEPTING A FINE IN LIEU OF PROSECUTION. ACCEPTING SUCH A FINE IS NOT DEEMED AS A CONVICTION
BY A COURT UNDER NORWEGIAN LAW. *THIS DRP SHOULD BE ARCHIVED FROM THIS RECORD AS THE APPROPRIATE RESPONSE SHOULD HAVE BEEN
MADE TO QUESTION 11B (2) IN LIEU OF QUESTION 11D(2)*.

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

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

SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NASD
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE
3.
Date Initiated (MM/DD/YYYY): 
04/27/2004
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CMS040065
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN CONNECTION WITH MRD REVIEW#200022250, THE NASD ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED NASD CONDUCT
RULES 2110, 3010, AND 3360. DBSI SUBMITTED TO THE NASD ITS SHORT INTEREST POSITION REPORT WHICH INCLUDED A SHORT INTEREST POSITION
OF 105,440,517 SHARES FOR 285 SECURITIES WHEN THE FIRM'S ACTUAL SHORT INTEREST FOR THE MONTH WAS 53,867,000 SHARES IN 306
SECURITIES; AND, DBSI'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH
RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS CONCERNING SHORT INTEREST REPORTING.
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):
04/27/2004
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 10,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
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 FINE OF $10,000.00 WAS PAID ON MAY 17, 2004.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT, CONSENTING TO A
CENSURE AND FINE OF $10,000.00.

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) 
NASD
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE, DISGORGEMENT
3.
Date Initiated (MM/DD/YYYY): 
05/18/2004
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:

CAF040037
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
INITIAL PUBLIC OFFERINGS ("IPOS")
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED NASD CONDUCT RULE 2110 IN CONNECTION WITH THE FIRM'S
ALLOCATION AND SALE OF INITIAL PUBLIC OFFERINGS ("IPOS") FROM SEPTEMEBER 1999 THROUGH MARCH 2000. THE NASD FOUND THAT DBSI
RECEIVED WITHOUT INQUIRY $4.81 MILLION IN UNUSUALLY HIGH AGENCY COMMISSIONS ON LISTED AGENCY TRADES FROM 10 CUSTOMERS WITHIN
ONE DAY OF ALLOCATING IPO SHARES TO SUCH CUSTOMERS. THE FIRM RECEIVED COMMISSIONS SET BY THESE CUSTOMERS OF UP TO $1 PER SHARE
TO EXECUTE INSTITUTIONAL SIZED AGENCY TRADES IN LISTED SECURITIES. BY RECEIVING THESE PAYMENTS FROM CERTAIN CUSTOMERS WITHOUT
INQUIRY WHILE PROVIDING THE CUSTOMERS WITH IPO ALLOCATIONS THE NASD FOUND THAT, THE FIRM FAILED TO OBSERVE HIGH STANDARDS OF
COMMERICAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE, IN VIOLATION OF NASD CONDUCT RULE 2110. DBSI NEITHER ADMITTED NOR
DENIED THE NASD'S FINDINGS.
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):
05/18/2004
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 5,291,000.00
 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 FINE OF $481,000 AND THE DISGOREGEMENT OF $4,810,000 WAS PAID ON MAY 20, 2004.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT, CONSENTING TO A
CENSURE, A FINE IN THE AMOUNT OF $481,000 AND DISGOREMENT OF $4,810,000.

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) 
AMERICAN STOCK EXCHANGE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE AND UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
04/01/2004
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
02-12
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Derivative(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE AMERICAN STOCK EXCHANGE ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED EXCHANGE RULE 30 AND ARTICLE V, SECTION
4(H) OF THE EXCHANGE CONSTITUTION, IN THAT DURING THE PERIOD FEBRUARY 1998 THROUGH MAY 2003, THE FIRM FILED WITH THE EXCHANGE

INACCURATE REPORTS OF SHORT INTEREST POSITIONS IN SECURITIES ON THE EXCHANGE; DBSI VIOLATED EXCHANGE RULE 320 AND ARTICLE V,
SECTION 4(H) OF THE EXCHANGE CONSTITUTION IN THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN APPROPRIATE POLICIES, SYSTEMS, AND
PROCEDURES OF SUPERVISION AND CONTROL, INCLUDING WRITTEN SUPERVISORY PROCEDURES, DESIGNED TO ENSURE COMPLIANCE WITH SHORT
INTEREST REQUIREMENTS OF THE EXCHANGE.
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):
06/18/2004
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 112,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
DBSI WAS REQUIRED TO SUBMIT TO THE EXCHANGE REVISED SUPERVISORY PROCEDURES TO ADDRESS DEFICIENCES ALONG WITH THE DATE
THE REVISED PROCEDURES WERE IMPLEMENTED.
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 FINE OF $112,500 TO BE PAID TO THE AMEX (AS PART OF A FINE OF $225,000 IN TOTAL TO BE PAID TO THE AMEX AND THE NASD) AT THEIR
INSTRUCTION WAS PAID ON JULY 9, 2004.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT, CONSENTING TO A
CENSURE AND FINED $225,000 IN TOTAL.

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

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

One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is Yes, no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NASD
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE AND UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
04/27/2004
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CMS040066
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Derivative(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED NASD CONDUCT RULES 2110, 3010, AND 3360. DBSI'S SHORT
INTEREST REPORTED TO THE NASD WAS INACCURATE AND SHORT POSITIONS WERE INCORRECTLY CLASSIFIED AS TYPE 1 OR 2 ACCOUNTS, RATHER
THAN AS TYPE 5 ACCOUNTS; FAILED TO MAKE CORRECTIONS IN A TIMELY AND EFFECTIVE MANNER SUCH THAT SHORT INTEREST POSITIONS WERE
REPORTED TO NASD PRIOR TO COMPLETION OF PROCEDURES TO REVIEW AFFILIATE ACCOUNTS AND WERE REPORTED TO NASD INACCURATE;
INCORRECTLY NETTED SHORT POSITIONS AGAINST LONG POSITIONS AND SHORT INTEREST REPORTED TO THE NASD WERE INACCURATE; AND, ITS
SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO APPLICABLE
SECURITIES LAWS AND REGULATIONS CONCERNING SHORT INTEREST REPORTING.
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):
04/27/2004
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 112,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO THE SHORT INTEREST REPORTING.
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 FINE OF $112,500 TO BE PAID TO THE NASD (AS PART OF A FINE OF $225,000 IN TOTAL TO BE PAID TO THE NASD AND THE AMEX) AT THEIR
INSTRUCTION WAS PAID ON JULY 9, 2004.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT, CONSENTING TO A
CENSURE AND FINED $225,000 IN TOTAL.

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

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the

adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NASD REGULATION, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE; RESTITUTION; UNDERTAKING TO REVISE WRITTEN SUPERVISORY PROCEDURES
3.
Date Initiated (MM/DD/YYYY): 
07/15/2004
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CMS040105 AWC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
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):
THE NASD ALLEGED VIOLATIONS OF RULES 2440, RULE 2110, AND IM-2440 IN CONNECTION WITH DBSI'S PRICING OF HIGH YIELD AND DISTRESSED
CORPORATE DEBT SECURITIES IN 7 IDENTIFIED TRANSACTIONS. THE NASD ALSO ALLEGED VIOLATIONS OF RULE 6420 FOR REPORTING INACCURATE
EXECUTION TIMES FOR CERTAIN TRANSACTIONS IN CORPORATE DEBT SECURITIES, VIOLATIONS OF RULE 3110 AND THE RECORDKEEPING PROVISIONS
OF THE FEDERAL SECURITIES LAWS FOR FAILING TO CREATE AND MAINTAIN REQUIRED RECORDS ASSOCIATED WITH CUSTOMER ORDERS AND TRADE
EXECUTIONS FOR CERTAIN TRANSACTIONS IN CORPORATE DEBT SECURITIES, VIOLATIONS OF NASD RULE 1022 FOR REGISTRATION FAILURES, AND
VIOLATIONS OF RULE 3010 FOR SUPERVISORY FAILURES ASSOCIATED WITH EACH OF THE ALLEGED UNDERLYING 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):
07/15/2004
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?

 Monetary/Fine Amount: $ 5,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING TO REVISE WRITTEN SUPERVISORY PROCEDURES
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: 
DBSI CONSENTED TO MAKE PAYMENTS TOTALING $5 MILLION, REFLECTING RESTITUTION PAYMENTS TO CUSTOMERS OF $421,575 AND THE
REMAINDER AS A FINE PAID TO THE NASD (REPRESENTING A $1,578,425 FINE FOR THE MARKUP/MARKDOWN, REGISTRATION AND FIPS
REPORTING VIOLATIONS, A FINE OF $1,500,000 FOR THE SUPERVISION VIOLATIONS, AND A FINE OF $1,500,000 FOR THE BOOKS AND RECORDS
VIOLATIONS). DBSI MADE RESTITUTION PAYMENTS TO CUSTOMERS BETWEEN JULY 12, 2004 AND JULY 23, 2004 AND MADE PAYMENT TO THE
NASD ON JULY 23, 2004. DBSI ALSO CONSENTED TO A CENSURE AND AGREED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES TO ADDRESS
THE FINDINGS IN THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON JULY 12, 2004, DBSI SUBMITTED AN AWC TO THE NASD, WHICH WAS REVIEWED AND ACCEPTED BY THE NASD ON JULY 15, 2004. IN THE AWC,
SOLELY FOR THE PURPOSE OF THE PROCEEDING ANY OTHER ACTION IN WHICH THE NASD IS A PARTY AND WITHOUT ADMITTING OR DENYING THE
FINDINGS SET FORTH IN THE AWC, DBSI CONSENTED TO FINDINGS THAT DBSI VIOLATED CERTAIN NASD RULES AND THE RECORDKEEPING PROVISIONS
OF THE FEDERAL SECURITIES LAWS AS SET FORTH IN 7, ABOVE. IN ADDITION TO THE PAYMENT OF THE FINE AND RESTITUTION, DBSI AGREED TO A
CENSURE AND TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES.

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) 
CALIFORNIA DEPARTMENT OF CORPORATIONS
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
08/30/2004
 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
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CALIFORNIA DEPARTMENT OF CORPORATIONS CHARGED VIOLATIONS OF CORPORATIONS CODE SECTION 25218 AND TITLE 10 OF THE CODE OF
REGULATIONS SECTION 260.218 FOR ALLEGEDLY NOT ADEQUATELY INSULATING RESEARCH ANALYSTS FROM THE INFLUENCES OF COVERED
COMPANIES AND INVESTMENT BANKING; VIOLATIONS OF CORPORATIONS CODE SECTIONS 25212(G) AND 25218 AND TITLE 10 OF THE CALIFORNIA
CODE OF REGULATIONS SECTION 260.218.4 FOR ALLEGEDLY NOT PROPERLY SUPERVISING ITS EMPLOYEES TO PREVENT SUCH INFLUENCES; AND
VIOLATIONS OF CALIFORNIA CORPORATIONS CODE SECTION 25241 AND SECTION 260.241.1(B) OF TITLE 10 OF THE CALIFORNIA CODE OF
REGULATIONS FOR ALLEGEDLY NOT PROMPTLY PRODUCING E-MAIL DATA.
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):
08/31/2004
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN

RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $3,001,328 PAID TO CALIFORNIA ON AUGUST 26, 2004); (II) $25 MILLION TO FUND THE PROVISION OF
INDEPENDENT RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE
OVER THE NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE CALIFORNIA
DEPARTMENT OF CORPORATIONS, AND TO PAY $87.5 MILLION. THE CALIFORNIA DEPARTMENT OF CORPORATIONS CHARGED VIOLATIONS OF
CORPORATIONS CODE SECTION 25218 AND TITLE 10 OF THE CODE OF REGULATIONS SECTION 260.218 FOR ALLEGEDLY NOT ADEQUATELY INSULATING
RESEARCH ANALYSTS FROM THE INFLUENCES OF COVERED COMPANIES AND INVESTMENT BANKING; VIOLATIONS OF CORPORATIONS CODE SECTIONS
25212(G) AND 25218 AND TITLE 10 OF THE CALIFORNIA CODE OF REGULATIONS SECTION 260.218.4 FOR ALLEGEDLY NOT PROPERLY SUPERVISING ITS
EMPLOYEES TO PREVENT SUCH INFLUENCES; AND VIOLATIONS OF CALIFORNIA CORPORATIONS CODE SECTION 25241 AND SECTION 260.241.1(B) OF
TITLE 10 OF THE CALIFORNIA CODE OF REGULATIONS FOR ALLEGEDLY NOT PROMPTLY PRODUCING E-MAIL DATA.

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

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

the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NASD
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE, DISGORGEMENT AND UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
08/20/2004
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CAF040062
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD CHARGED VIOLATIONS OF NASD RULES 2110, 2210(D)(1), AND 2210(D)(2) IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST
RESULTING FROM INVESTMENT BANKING INFLUENCE OVER RESEARCH ANALYSTS; THE ISSUANCE OF RESEARCH REPORTS AFFECTED BY THOSE
CONFLICTS OF INTEREST; PAYMENTS TO AND FROM OTHER SECURITIES FIRMS AND THE RECEIPT OF PAYMENTS FROM ISSUERS FOR RESEARCH; AND
THE NON-DISCLOSURE OF SUCH PAYMENTS. THE NASD ALSO CHARGED VIOLATIONS OF NASD RULE 3010 FOR ALLEGEDLY NOT ADEQUATELY
SUPERVISING ITS RESEARCH ANALYSTS IN ORDER TO PREVENT CONFLICTS OF INTERESTS, AS WELL AS NASD RULE 2110 FOR ALLEGEDLY NOT
PROMPTLY PRODUCING E-MAIL.
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):
08/20/2004
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI HAS AGREED TO PAY: (I) $50 MILLION, OFFSET IN THE AMOUNT OF $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE
REGULATORS IN RELATED PROCEEDINGS; (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH TO INVESTORS (PAYABLE
OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE YEARS); AND (IV) $7.5
MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT WITH THE NASD
AND TO PAY $87.5 MILLION. THE NASD CHARGED VIOLATIONS OF NASD RULES 2110, 2210(D)(1), AND 2210(D)(2) IN CONNECTION WITH ALLEGED
CONFLICTS OF INTEREST RESULTING FROM INVESTMENT BANKING INFLUENCE OVER RESEARCH ANALYSTS; THE ISSUANCE OF RESEARCH REPORTS
AFFECTED BY THOSE CONFLICTS OF INTEREST; PAYMENTS TO AND FROM OTHER SECURITIES FIRMS AND THE RECEIPT OF PAYMENTS FROM ISSUERS
FOR RESEARCH; AND THE NON-DISCLOSURE OF SUCH PAYMENTS. THE NASD ALSO CHARGED VIOLATIONS OF NASD RULE 3010 FOR ALLEGEDLY NOT
ADEQUATELY SUPERVISING ITS RESEARCH ANALYSTS IN ORDER TO PREVENT CONFLICTS OF INTEREST, AS WELL AS NASD RULE 2110 FOR ALLEGEDLY
NOT PROMPTLY PRODUCING E-MAIL.

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) 
NEW YORK STOCK EXCHANGE INC.("NYSE")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
08/02/2004
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NYSE DEC. 04-128
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NYSE CHARGED VIOLATIONS OF NYSE RULES 401, 472, AND 476(A)(6) IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST RESULTING FROM
INVESTMENT BANKING INFLUENCE OVER RESEARCH ANALYSTS; THE ISSUANCE OF RESEARCH REPORTS AFFECTED BY THOSE CONFLICTS OF INTEREST;
PAYMENTS TO AND FROM OTHER SECURITIES FIRMS AND THE RECEIPT OF PAYMENTS FROM ISSUERS FOR RESEARCH; AND THE NON-DISCLOSURE OF
SUCH PAYMENTS. THE NYSE ALSO CHARGED VIOLATIONS OF NYSE RULE 342 FOR ALLEGEDLY NOT ADEQUATELY SUPERVISING ITS RESEARCH ANALYSTS
IN ORDER TO PREVENT CONFLICTS OF INTEREST, AS WELL AS NYSE RULE 476(A)(11) FOR ALLEGEDLY NOT PROMPTLY PRODUCING E-MAIL.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
08/27/2004
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI HAS AGREED TO PAY: (I) $50 MILLION, OFFSET IN THE AMOUNT OF $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE
REGULATORS IN RELATED PROCEEDINGS; (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH TO INVESTORS (PAYABLE

OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE YEARS); AND (IV) $7.5
MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO A STIPULATION AND CONSENT WITH THE NYSE, AND TO PAY $87.5
MILLION. THE NYSE CHARGED VIOLATIONS OF NYSE RULE 401, 472, AND 476(A)(6) IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST
RESULTING FROM INVESTMENT BANKING INFLUENCE OVER RESEARCH ANALYSTS; THE ISSUANCE OF RESEARCH REPORTS AFFECTED BY THOSE
CONFLICTS OF INTEREST; PAYMENTS TO AND FROM OTHER SECURITIES FIRMS AND THE RECEIPT OF PAYMENTS FROM ISSUERS FOR RESEARCH; AND
THE NON-DISCLOSURE OF SUCH PAYMENTS. THE NYSE ALSO CHARGED VIOLATIONS OF NYSE RULE 342 FOR ALLEGEDLY NOT ADEQUATELY
SUPERVISING ITS RESEARCH ANALYSTS IN ORDER TO PREVENT CONFLICTS OF INTEREST, AS WELL AS NYSE RULE 476(A)(11) FOR ALLEGEDLY NOT
PROMPTLY PRODUCING E-MAIL.

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

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

SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NASD
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
07/23/2004
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CMS040137
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
TRADING & MARKET MAKING
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NASD ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED NASD MARKETPLACE RULE 4632 IN CONNECTION WITH DBSI'S FAILURE TO
REPORT REQUIRED INFORMATION FOR "AT RISK" AND "RISKLESS" PRINCIPAL TRANSACTIONS. THE NASD ALSO ALLEGED VIOLATIONS BY DBSI OF SEC
RULE 10B-10 FOR FAILURE TO PROVIDE WRITTEN NOTIFICATION TO CUSTOMERS THAT TRANSACTIONS WERE EXECUTED AT AN AVERAGE PRICE AND
INCORRECTLY DOCUMENTING THE AVERAGE PRICE DISCLOSURE.
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):
08/25/2004
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 10,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
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: 
DBSI CONSENTED TO A CENSURE AND A FINE TOTALING $10,000, (COMPRISED OF A $5,000 FINE FOR THE TRADE REPORTING VIOLATIONS AND A
$5,000 FINE FOR THE SEC RULE 10B-10 VIOLATIONS), PAYABLE TO THE NASD. DBSI REMITTED SAID SUM ON SEPTEMBER 23, 2004.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER & CONSENT ("AWC"), CONSENTING TO A
CENSURE AND FINE OF $10,000.

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

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NASD
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
06/22/2004
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
CMS040117
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
EQUITY
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NASD ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED NASD MARKETPLACE RULE 6955(A) AND NASD CONDUCT RULE 2110 IN
CONNECTION WITH DBSI'S FAILURE TO COMPLY WITH THE REPORTING RULES APPLICABLE TO THE ORDER AUDIT TRAIL SYSTEM ("OATS"). THE NASD
ALSO ALLEGED VIOLATIONS BY DBSI OF NASD CONDUCT RULES 2110 AND 3010 FOR FAILURE TO DESIGNATE AN APPROPRIATE REGISTERED
PRINCIPAL(S) WITH AUTHORITY TO CARRY OUT THE SUPERVISORY RESPONSIBILITIES IN RELATION TO OATS REPORTING.
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):
08/19/2004
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 15,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND A FINE TOTALING $15,000, (COMPRISED OF A $10,000 FINE FOR THE OATS VIOLATIONS AND A $5,000
FINE FOR THE SUPERVISORY PROCEDURES VIOLATIONS), PAYABLE TO THE NASD. DBSI REMITTED SAID SUM ON SEPTEMBER 7, 2004.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER & CONSENT ("AWC"), CONSENTING TO A
CENSURE AND FINE OF $15,000.

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:
1531022
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GOLDSMITH, RICHARD ALAN
(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).

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) 
CHICAGO BOARD OF TRADE ("CBOT")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/23/2004
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2004-INV-12A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Financial
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CBOT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED CBOT REGULATION 9B.16, BY VIRTUE OF REGULATION 9B.07, IN THAT
CROSS TRADES EXECUTED BY DBSI WERE NOT ENTERED IN ACCORDANCE WITH PRESCRIBED TIME REQUIREMENTS AND PROCEDURES. THE CBOT ALSO
ALLEGED DBSI VIOLATED REGULATION 336.01, IN THAT DBSI DIRECTLY OR INDIRECTLY GUARANTEED THE EXECUTION OF ORDERS TO PURCHASE 10-
YEAR U.S. TREASURY NOTE OPTION CONTRACTS.
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):
09/29/2004
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 75,000.00
 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: 
DBSI CONSENTED TO A FINE TOTALING $75,000, PAYABLE TO THE CBOT. DBSI REMITTED SAID SUM ON OCTOBER 26, 2004.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON SEPTEMBER 29, 2004, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS SET FORTH BY CBOT IN THE SETTLEMENT, DBSI CONSENTED TO THE
ALLEGED FINDINGS AND FINE IN THE TOTAL AMOUNT OF $75,000.

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, INC. ("NASD")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE AND RESTITUTION
3.
Date Initiated (MM/DD/YYYY): 
02/06/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CLG050032 ("AWC")
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NASD ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED NASD CONDUCT RULES 2110 AND 2320, IN THAT DBSI FAILED TO USE
REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT
PRICE TO ITS CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS.
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):
03/22/2005
 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: $ 15,000.00
 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: 
DBSI CONSENTED TO A FINE OF $15,000, PAYABLE TO THE NASD, AND RESTITUTION PAYMENTS TO CUSTOMERS IN THE AMOUNT OF $323.87
PLUS ANY INTEREST DUE. DBSI REMITTED THE FINE ON APRIL 11, 2005, THE RESTITUTION PAYMENTS WILL BE PAID.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") CONSISTING OF A
CENSURE AND FINE OF $15,000.00, AND RESTITUTION PAYMENTS TO CUSTOMERS DUE.

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) 
ALABAMA SECURITIES COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
02/11/2005
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
CO-2005-0011
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE ALABAMA SECURITIES COMMISSION CHARGED VIOLATIONS OF ALABAMA SECURITIES ACT 830-X-3-.13(1) & (3) FOR ALLEGEDLY FAILING TO
ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS AND PROCEDURES FOR SUPERVISION AND CONTROL OF ITS EMPLOYEES; VIOLATIONS OF
ALABAMA SECURITIES ACT 8-6-3(I)7 FOR ALLEGEDLY (I) FAILING TO MANAGE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER AND (II) FAILING
TO MAKE ADEQUATE DISCLOSURE; VIOLATIONS OF ALABAMA SECURITIES ACT 830-X-2-.06(2) FOR ALLEGEDLY ISSUING RESEARCH REPORTS THAT
WERE NOT PROPERLY BALANCED, AND/OR CONTAINED EXAGGERATED OR UNWARRANTED CLAIMS AND OPINIONS.
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):
03/31/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANADATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF THIRD-PARTY RESEARCH
SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $394,052 PAID TO ALABAMA ON 3/29/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH
TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE
YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE ALABAMA
SECURITIES COMMISSION AND TO PAY $87.5 MILLION. THE ALABAMA SECURITIES COMMISSION CHARGED VIOLATIONS OF ALABAMA SECURITIES ACT
830-X-3-.13(1) & (3) FOR ALLEGEDLY FAILING TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS AND PROCEDURES FOR SUPERVISION AND
CONTROL OF THE RESEARCH AND INVESTMENT BANKING DEPARTMENTS; VIOLATIONS OF ALABAMA SECURITIES ACT 8-6-3(J)7 FOR ALLEGEDLY (I)
FAILING TO MANAGE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER AND (II) FAILING TO MAKE ADQUATE DISCLOSURE; VIOLATIONS OF
ALABAMA SECURITIES ACT 830-X-2-.06(2) FOR ALLEGEDLY ISSUING RESEARCH REPORTS THAT WERE NOT BASED ON PRINCIPLES OF FAIR DEALING AND
GOOD FAITH, DID NOT PROVIDE SOUND BASIS FOR EVALUATING FACTS, WERE NOT PROPERLY BALANCED, AND/OR CONTAINED EXAGGERATED OR
UNWARRANTED CLAIMS AND OPINIONS.

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

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,

11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
MAINE OFFICE OF SECURITIES
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT,UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
02/11/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NO. 05-045-CON
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE MAINE OFFICE OF SECURITIES CHARGED VIOLATIONS OF 10313(1)(G), 10313(1)(J) AND 10313(6) OF REVISED MAINE SECURITIES ACT IN
CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISON AND PRODUCTION OF EMAILS.
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):
03/16/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO MAINE ON 3/4/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH TO
INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE YEARS);
AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO A CONSENT ORDER WITH THE MAINE OFFICE OF SECURITIES AND TO
PAY $87.5 MILLION. THE MAINE OFFICE OF SECURITIES CHARGED VIOLATIONS OF 10313(1)(G), 10313(1)(J) AND 10313(6) OF THE REVISED MAINE
SECURITIES ACT IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.

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) 
VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
02/14/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5-004-S
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION CHARGED DBSI WITH VIOLATIONS OF 9 V.S.A.
131 4221A(A)(8) FOR ALLEGEDLY (I) PERMITTING ITS INVESTMENT BANKING DEPARTMENT TO EXERT IMPROPER INFLUENCE OVER ITS RESEARCH
ANALYSTS, (II) ISSUING RESEARCH THAT CONTAINED OPINIONS THAT LACKED A REASONABLE BASIS AND/OR CONTAINED EXAGGERATED OR
UNWARRANTED CLAIMS, AND (III) FAILING TO PROMPTLY PRODUCE REQUIRED BOOKS AND RECORDS; VIOLATIONS OF 9 V.S.A. 131 4221A(A)(11) FOR

ALLEGEDLY FAILING TO (I) REASONABLY SUPERVISE ITS EMPLOYEES TO ENSURE THAT ITS RESEARCH ANALYSTS WERE ADEQUATELY INSULATED FROM
PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING AND (II) ESTABLISH, MAINTAIN AND ENFORCE WRITTEN
SUPERVISORY PROCEDURES.
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):
03/05/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO VERMONT ON 3/18/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, DBSI AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE VERMONT DEPARTMENT OF
BANKING, INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION AND TO PAY $87.5 MILLION. THE VERMONT DEPARTMENT OF BANKING,
INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION CHARGED VIOLATIONS OF 9 V.S.A. 131 4221A(A)(8) FOR ALLEGEDLY (I) PERMITTING ITS
INVESTMENT BANKING DEPARTMENT TO EXERT IMPROPER INFLUENCE OVER ITS RESEARCH ANALYSTS, (II) ISSUING RESEARCH THAT CONTAINED
OPINIONS THAT LACKED A REASONABLE BASIS AND/OR CONTAINED EXAGGERATED OR UNWARRANTED CLAIMS, AND (III) FAILING TO PROMPTLY
PRODUCE REQUIRED BOOKS AND RECORDS; VIOLATIONS OF 9 V.S.A. 131 4221A(A)(11) FOR ALLEGEDLY FAILING TO (I) REASONABLY SUPERVISE ITS
EMPLOYEES TO ENSURE THAT ITS RESEARCH ANALYSTS WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED
COMPANIES AND INVESTMENT BANKING AND (II) ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES.

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) 
WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
02/16/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
S-04-251-04-CO01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS CHARGED VIOLATIONS OF RCW 21.20.110(1)(G) FOR ALLEGEDLY FAILING TO ENSURE
THAT RESEARCH ANALYSTS WHO ISSUE REPORTS WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES OF COVERED COMPANIES AND
INVESTMENT BANKERS; VIOLATIONS OF RCW 21.20.110(I) FOR ALLEGEDLY FAILING TO REASONABLY SUPERVISE ITS EMPLOYEES TO ENSURE THAT ITS
ANALYSTS WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING.

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):
03/25/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $522,271 PAID TO WASHINGTON ON 3/10/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO A CONSENT ORDER WITH THE WASHINGTON DEPARTMENT OF
FINANCIAL INSTITUTIONS. THE WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS CHARGED VIOLATIONS OF RCW 21.20.110(1)(G) FOR
ALLEGEDLY FAILING TO ENSURE THAT RESEARCH ANALYSTS WHO ISSUE REPORTS WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES
OF COVERED COMPANIES AND INVESTMENT BANKERS; VIOLATIONS OF RCW 21.20.110(J) FOR ALLEGEDLY FAILING TO REASONABLY SUPERVISE ITS
EMPLOYEES TO ENSURE THAT ITS ANALYSTS WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND
INVESTMENT BANKING.

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

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

You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION, SECURITIES DIVISION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
02/16/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
05-94
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION, SECURITIES DIVISION CHARGED VIOLATIONS OF THE RHODE ISLAND UNIFORM
SECURITIES ACT OF 1990 7-212(B)(8), 7-11-212(B)(11), AND 7-11-209(D)(1)IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISON AND
PRODUCTION OF EMAILS.
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):
03/22/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AN D PROJECTIONS; AND THE USE OF INDEPENDENT THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO RHODE ISLAND ON 3/16/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, DBSI AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE RHODE ISLAND DEPARTMENT
OF BUSINESS REGULATION, SECURITIES DIVISION AND TO PAY $87.5 MILLION. THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION,
SECURITIES DIVISION CHARGED VIOLATIONS OF THE RHODE ISLAND UNIFORM SECURITIES ACT OF 1990 7-212(B)(8), 7-11-212(B)(11), AND 7-11-
209(D)(1) IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.

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) 
OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES, DIVISION OF FINANCE AND CORPORATE SECURITIES
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
02/16/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
S-05-0003
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE OREGON DEPARTMENT OF CONSUMER AND BUSINESS SERVICES, DIVISION OF FINANCE AND CORPORATE SECURITIES CHARGED VIOLATIONS OF
ORS 59.135, ORS 59.195, ORS 59.205 AND OAR CHAPTER 441, DIVISION 205 CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISON AND
PRODUCTION OF EMAILS.
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):
03/17/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $303,166 PAID TO OREGON ON 3/2/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH
TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE
YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, DBSI AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE OREGON DEPARTMENT OF
CONSUMER AND BUSINESS SERVICES, DIVISION OF FINANCE AND CORPORATE SECURITIES AND TO PAY $87.5 MILLION. THE OREGON DEPARTMENT OF
CONSUMER AND BUSINESS SERVICES, DIVISION OF FINANCE AND CORPORATE SECURITIES CHARGED VIOLATIONS OF ORS 59.135, ORS 59.195, ORS
59.205 AND OAR CHAPTER 441, DIVISION 205 IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.

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) 
PENNSYLVANIA SECURITIES COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
02/23/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2003-04-50
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
PENNSYLVANIA ACCEPTED APPLICANT'S OFFER OF SETTLEMENT IN CONNECTION WITH THE PENNSYLVANIA SECURITIES COMMISSION'S CHARGE THAT
IF, IN A CONTESTED PROCEEDING UNDER THE PENNSYLVANIA SECURITIES ACT OF 1972 (70 P.S.1-510), IT WAS PROVEN THAT APPLICANT ENGAGED IN
CONDUCT RELATED TO RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS AS ALLEGED IN THE SEC COMPLAINT, THERE WOULD BE
A BASIS UNDER SECTION 305(A)(IX), 70 P.S.1-305(A)(IX), FOR THE PENNSYLVANIA SECURITIES COMMISSION TO SUSPEND, REVOKE OR CONDITION
THE BROKER-DEALER REGISTRATION OF APPLICANT IN THE COMMONWEALTH OF PENNSYLVANIA.
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):
02/23/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN

RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $1,088,210 PAID TO PENNSYLVANIA ON 3/11/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, DBSI AGREED TO AN ORDER WITH THE PENNSYLVANIA SECURITIES COMMISSION AND TO PAY
$87.5 MILLION. PENNSYLVANIA ACCEPTED APPLICANT'S OFFER OF SETTLEMENT IN CONNECTION WITH THE PENNSYLVANIA SECURITIES COMMISSION'S
CHARGE THAT IF, IN A CONTESTED PROCEEDING UNDER THE PENNSYLVANIA SECURITIES ACT OF 1972 (70 P.S. 1-510), IT WAS PROVEN THAT
APPLICANT ENGAGED IN CONDUCT RELATED TO RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS AS ALLEGED IN THE SEC
COMPLAINT (FILED ON OR ABOUT 8/26/2004 BY THE U.S. SECURITIES AND EXCHANGE COMMISSION IN THE UNITED STATES DISTRICT COURT FOR THE
SOUTHERN DISTRICT OF NEW YORK), THERE WOULD BE A BASIS UNDER SECTION 305(A)(IX), 70 P.S. 1-305(A)(IX), FOR THE PENNSYLVANIA SECURITIES
COMMISSION TO SUSPEND, REVOKE OR CONDITION THE BROKER-DEALER REGISTRATION OF APPLICANT IN THE COMMONWEALTH OF PENNSYLVANIA.

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) 
OHIO DEPARTMENT OF COMMERCE, DIVISION OF SECURITIES
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
02/24/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE OHIO DEPARTMENT OF COMMERCE, DIVISON OF SECURITIES CHARGED VIOLATIONS OF OHIO REVISED CODE CHAPTER 1707 AND THE RULES
PROMULGATED THEREUNDER IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.
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):
03/24/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED

PROCEEDINGS (INCLUDING $1,005,988 PAID TO OHIO ON 3/10/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH
TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE
YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, DBSI AGREED TO A SETTLEMENT AGREEMENT WITH THE OHIO DEPARTMENT OF COMMERCE,
DIVISION OF SECURITIES AND TO PAY $87.5 MILLION. THE OHIO DEPARTMENT OF COMMERCE, DIVISION OF SECURITIES CHARGED VIOLATIONS OF
OHIO REVISED CODE CHAPTER 1707 AND THE RULES PROMULGATED THEREUNDER IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION
AND PRODUCTION OF EMAILS.

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) 

KENTUCKY OFFICE OF FINANCIAL INSTITUTIONS
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESISIT, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
03/02/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE KENTUCKY OFFICE OF FINANCIAL INSTITUTIONS CHARGED VIOLATIONS OF KENTUCKY REVISED STATUTES 292.530, 292.330(13)(A)7 AND
292.330(A)9A IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.
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):
03/15/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF THIRD-PARTY RESEARCH
SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $358,136 PAID TO KENTUCKY ON 3/28/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE KENTUCKY OFFICE
OF FINANCIAL INSTITUTIONS AND TO PAY $87.5 MILLION. THE KENTUCKY OFFICE OF FINANCIAL INSTITUTIONS CHARGED VIOLATIONS OF KENTUCKY
REVISED STATUTES 292.530, 292.330(13)(A)7 AND 292.330(A)9.A IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION
OF EMAILS.

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) 
WISCONSIN DEPARTMENT OF FINANCIAL INSTITUTIONS
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
03/04/2005
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
FILE NO. S-05026(LX)
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE WISCONSIN DEPARTMENT OF FINANCIAL INSTITUTIONS CHARGED VIOLATIONS OF WIS. STATS. SEC.551.34(1)(G) IN CONNECTION WITH
RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS; VIOLATIONS OF WIS. STATS. SEC. 551.34(1)(I) FOR ALLEGEDLY FAILING TO
REASONABLE SUPERVISE ITS EMPLOYEES; AND VIOLATIONS OF WIS. STATS. 551.34(2) FOR ALLEGEDLY FAILING TO MAINTAIN AND TIMELY PRODUCE
DOCUMENTS AND MATERIALS (INCLUDING EMAILS).
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):
03/29/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $475,269 PAID TO WISCONSIN ON 3/11/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE WISCONSIN
DEPARTMENT OF FINANCIAL INSTITUTIONS AND TO PAY $87.5 MILLION. THE WISCONSIN DEPARTMENT OF FINANCIAL INSTITUTIONS CHARGED
VIOLATIONS OF WIS. STATS. SEC. 551.34(1)(G) IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS;
VIOLATIONS OF WIS. STATS. SEC. 551.34(1)(J) FOR ALLEGEDLY FAILING TO REASONABLY SUPERVISE ITS EMPLOYEES; AND VIOLATIONS OF WIS. STATS.
551.34(2) FOR ALLEGEDLY FAILING TO MAINTAIN AND TIMELY PRODUCE DOCUMENTS AND MATERIALS (INCLUDING EMAILS).

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) 
ARIZONA CORPORATION COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
02/04/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
S-03578A-05-0000
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:

Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE ARIZONA CORPORATION COMMISSION CHARGED VIOLATIONS OF ARIZONA REVISED STATUTE 44-1961(A)(13)IN CONNECTION WITH RESEARCH
ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.
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):
02/25/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $454,619 PAID TO ARIZONA ON 3/1/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH
TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE
YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, DBSI AGREED TO AN ORDER TO CEASE AND DESIST, AN ORDER FOR ADMINISTRATIVE PENALTIES
AND CONSENT TO SAME WITH THE ARIZONA CORPORATION COMMISSION, AND TO PAY $87.5 MILLION. THE ARIZONA CORPORATION COMMISSION
CHARGED VIOLATIONS OF ARIZONA REVISED STATUTE 44-1961(A)(13)IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND
PRODUCTION OF EMAILS.

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) 
NEBRASKA DEPARTMENT OF BANKING AND FINANCE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
02/11/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NEBRASKA DEPARTMENT OF BANKING AND FINANCE CHARGED VIOLATIONS OF NEBRASKA REVISED STATUTES 8-1103(9)(A)(VII)FOR ALLEGEDLY
FAILING TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED
COMPANIES AND INVESTMENT BANKING; VIOLATIONS OF NEBRASKA REVISED STATUTES 8-1103(9)(A)(XI) FOR ALLEGEDLY FAILING TO REASONABLY
SUPERVISE ITS AGENTS OR EMPLOYEES; AND VIOLATIONS OF NEBRASKA REVISED STATUTES 8-1103(7)(A) AND 48 NAC 4.010 FOR ALLEGEDLY FAILING
TO PRESERVE FOR A PERIOD OF THREE YEARS, AND/OR PRESERVE IN AN ACCESSIBLE PLACE FOR TWO YEARS, CERTAIN BOOKS AND RECORDS
RELATING TO ITS BUSINESS.

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):
02/17/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO NEBRASKA ON 3/4/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH
TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE
YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO A CONSENT ORDER WITH THE NEBRASKA DEPARTMENT OF BANKING
AND FINANCE AND TO PAY $87.5 MILLION. THE NEBRASKA DEPARTMENT OF BANKING AND FINANCE CHARGED VIOLATIONS OF NEBRASKA REVISED
STATUTES 8-1103(9)(A)(VII) FOR ALLEGEDLY FAILING TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM
PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING; VIOLATIONS OF NEBRASKA REVISED STATUTES 8-1103(9)(A)
(XI) FOR ALLEGEDLY FAILING TO REASONABLY SUPERVISE ITS AGENTS OR EMPLOYEES; AND VIOLATIONS OF NEBRASKA REVISED STATUTES 8-1103(7)
(A) AND 48 NAC 4.010 FOR ALLEGEDLY FAILING TO PRESERVE FOR A PERIOD OF THREE YEARS,AND/OR PRESERVE IN AN ACCESSIBLE PLACE FOR TWO
YEARS, CERTAIN BOOKS AND RECORDS RELATING TO ITS BUSINESS.

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

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

A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
03/04/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 04-050-IG
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION CHARGED VIOLATIONS OF N.C.G.S. 78A-39(A)(2)(G) WITHIN
THE MEANING OF 18 NCAC 06.1414(A) AND 18 NCAC 06.1414(B)(33) FOR ALLEGEDLY FAILING TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH
WERE ADEQUATELY INSULATED; VIOLATIONS OF N.C.G.S. 78A-39(A)(2)(G) WITHIN THE MEANING OF 18 NCAC 06.1414(A) AND 18 NCAC 06.1414(B)(33)
FOR ALLEGEDLY FAILING TO REASONABLY SUPERVISE ITS EMPLOYEES; VIOLATIONS OF N.C.G.S. 78A-38 FOR ALLEGEDLY BREACHING ITS OBLIGATION
TO COMPLY WITH A REASONABLE REGULATORY REQUEST FOR DOCUMENTS.
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):
03/31/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $713,240 PAID TO NORTH CAROLINA ON 3/23/05); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO A CONSENT ORDER WITH THE NORTH CAROLINA DEPARTMENT OF
THE SECRETARY OF STATE, SECURITIES DIVISION AND TO PAY $87.5 MILLION. THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE,
SECURITIES DIVISION CHARGED VIOLATIONS OF N.C.G.S. 78A-39(A)(2)(G) WITHIN THE MEANING OF 18 NCAC 06 .1414(A) AND 18 NCAC 06 .1414(B)
(33) FOR ALLEGEDLY FAILING TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED; VIOLATIONS OF N.C.G.S. 78A-39(A)
(2)(G) WITHIN THE MEANING OF 18 NCAC 06 .1414(A) AND 18 NCAC 06 .1414(B)(33) FOR ALLEGEDLY FAILING TO REASONABLY SUPERVISE ITS
EMPLOYEES; VIOLATIONS OF N.C.G.S. 78A-38 FOR ALLEGEDLY BREACHING ITS OBLIGATION TO COMPLY WITH A REASONABLE REGULATORY REQUEST
FOR DOCUMENTS.

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
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) 
KANSAS OFFICE OF THE SECURITIES COMMISSIONER
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
03/04/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2003EO52
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE KANSAS OFFICE OF THE SECURITIES COMMISSIONER CHARGED VIOLATIONS OF K.S.A. 17-1254(M)(7), K.S.A. 17-1254(M)(12) AND K.A.R. 81-3-1(D)
(3) IN CONNECTION WITH RESEARCH WORK, SUPERVISION AND PRODUCTION OF EMAILS.
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):

(
)
03/28/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS, AND THE USE OF THIRD-PARTY RESEARCH
SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO KANSAS ON 3/15/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH
TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE
YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO A CONSENT ORDER WITH KANSAS OFFICE OF THE SECURITIES
COMMISSIONER AND TO PAY $87.5 MILLION. THE KANSAS OFFICE OF THE SECURITIES COMMISSION CHARGED VIOLATIONS OF K.S.A. 17-1254(M)(7),
K.S.A. 17-1254(M)(12) AND K.A.R. 81-3-1(D)(3) IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.

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) 
MINNESOTA DEPARTMENT OF COMMERCE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
03/05/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE MINNESOTA DEPARTMENT OF COMMERCE CHARGED VIOLATIONS OF MINN. STAT. 80A.07, SUBD.1(7) AND (10) (2004) AND MINN. R. CH. 2875.0910
(2003) IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.
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):
04/01/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension

B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF THIRD-PARTY RESEARCH
SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $435,909 PAID TO MINNESOTA ON 3/10/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO A CONSENT ORDER WITH THE MINNESOTA DEPARTMENT OF
COMMERCE AND TO PAY $87.5 MILLION. THE MINNESOTA DEPARTMENT OF COMMERCE CHARGED VIOLATIONS OF MINN. STAT. 80A.07, SUBD. 1(7) AND
(10) (2004) AND MINN. R. CH. 2875.0910 (2003) IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.

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) 
COMMISSION OF SECURITIES, STATE OF GEORGIA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
03/15/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
EN-10522
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMISSIONER OF SECURITIES OF THE STATE OF GEORGIA CHARGED VIOLATIONS OF O.C.G.A. 10-5-4(A)(8) AND 10-5-12(A)(1)AND RULE AND
REGULATION OF THE STATE OF GEORGIA 590-4-2-.14 IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS;
VIOLATIONS OF 10-5-4(A)(11) AND 10-5-12(A)(1) AND RULE 590-4-2-.07 FOR ALLEGEDLY FAILING TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES,
SYSTEMS, AND PROCEDURES FOR SUPERVISION AND CONTROL OF THE RESEARCH AND INVESTMENT BANKING DEPARTMENTS.
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):
03/28/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANADATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 

DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $394,052 PAID TO GEORGIA ON 3/25/2005; (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH
TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE
YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO A CONSENT ORDER WITH THE COMMISSIONER OF SECURITIES OF
THE STATE OF GEORGIA. THE COMMISSIONER OF SECURITIES OF THE STATE OF GEORGIA CHARGED VIOLATIONS OF O.C.G.A. 10-5-4(A)(8) AND 10-5-
12(A)(1) AND RULE AND REGULATION OF THE STATE OF GEORGIA 590-4-2-.14 IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND
PRODUCTION OF EMAILS; VIOLATIONS OF 10-5-4(A)(11) AND 10-5-12(A)(1) AND RULE 590-4-2-.07 FOR ALLEGEDLY FAILING TO ESTABLISH AND
MAINTAIN ADEQUATE POLICIES, SYSTEMS, AND PROCEDURES FOR SUPERVISION AND CONTROL OF THE RESEARCH AND INVESTMENT BANKING
DEPARTMENTS.

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) 
COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
02/11/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
SEC-2003-00023
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION CHARGED VIOLATIONS OF VIRGINIA SECURITIES RULE 21 VAC 5-20-260,
SECURITIES RULE 21 VAC 5-20-270 AND SECURITIES RULE 21 VAC 5-20-28(E)(12) IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION
AND PRODUCTION OF EMAILS.
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):
03/30/2005
 Exact
 Explanation
If not exact, provide explanation:
FINAL ORDER RECEIVED FROM VIRGINIA BY DBSI'S OUTSIDE COUNSEL ON MAY 4, 2005.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $627,219 PAID TO VIRGINIA ON 3/1/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH
TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE
YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE FIRM AGREED TO A CONSENT ORDER WITH THE COMMONWEALTH OF VIRGINIA STATE
CORPORATION COMMISSION AND TO PAY $87.5 MILLION. THE COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION CHARGED
VIOLATIONS OF VIRGINIA SECURITIES RULE 21 VAC 5-20-260, SECURITIES RULE 21 VAC 5-20-270 AND SECURITIES RULE 21 VAC 5-20-28(E)(12) IN
CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.

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) 
THE STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING

3.
Date Initiated (MM/DD/YYYY): 
04/21/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ADMINISTRATIVE PROCEEDING NO.0152-S-8/04
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION CHARGED VIOLATIONS OF SECTIONS 517.161(1)(A), 517.121, FLORIDA STATUTES AND
RULE 69W-600.013(1)(P), FLORIDA ADMINISTRATIVE CODE IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF
EMAILS.
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):
05/23/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $1,416,180 PAID TO FLORIDA ON 5/10/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION AND TO PAY $87.5 MILLION. THE STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION CHARGED VIOLATIONS OF
SECTIONS 517.161(1)(A), 517.121, FLORIDA STATUTES AND RULE 69W-600.013(1)(P), FLORIDA ADMINISTRATIVE CODE IN CONNECTION WITH
RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.

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

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,

11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
STATE OF IOWA INSURANCE DIVISION, SECURITIES BUREAU
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
04/21/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
MATTER NO. 1000048
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF IOWA INSURANCE DIVISION, SECURITIES BUREAU CHARGED VIOLATIONS OF IOWA CODE SECTION 502.412(4)(I)(2005), IOWA CODE
SECTION 502.412(M)(2005) AND IOWA ADMINISTRATIVE CODE SECTION 191-50.3 IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION
AND PRODUCTION OF EMAILS.
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):
05/16/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO IOWA ON 5/11/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH TO
INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE YEARS);
AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE STATE OF IOWA
INSURANCE DIVISION, SECURITIES BUREAU AND TO PAY $87.5 MILLION. THE STATE OF IOWA INSURANCE DIVISION, SECURITIES BUREAU CHARGED
VIOLATIONS OF IOWA CODE SECTION 502.412(4)(I)(2005), IOWA CODE SECTION 502.412(M)(2005) AND IOWA ADMINISTRATIVE CODE SECTION 191-
50.3 IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.

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) 
THE COMMONWEALTH OF MASSACHUSETTS OFFICE OF THE SECRETARY OF THE COMMONWEALTH SECURITIES DIVISION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
03/04/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
MATTER NO. 2005-0008
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMONWEALTH OF MASSACHUSETTS OFFICE OF THE SECRETARY OF THE COMMONWEALTH SECURITIES DIVISION CHARGED VIOLATIONS OF
MASSACHUSETTS GENERAL LAWS CHAPTER 110A, THE MASSACHUSETTS UNIFORM SECURITIES ACT, 203A AND 204 IN CONNECTION WITH RESEARCH

ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.
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):
05/23/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $562,586 PAID TO MASSACHUSETTS ON 3/7/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE COMMONWEALTH
OF MASSACHUSETTS OFFICE OF THE SECRETARY OF THE COMMONWEALTH SECURITIES DIVISION AND TO PAY $87.5 MILLION. THE COMMONWEALTH
OF MASSACHUSETTS OFFICE OF THE SECRETARY OF THE COMMONWEALTH SECURITIES DIVISION CHARGED VIOLATIONS OF MASSACHUSETTS GENERAL
LAWS CHAPTER 110A, THE MASSACHUSETTS UNIFORM SECURITIES ACT, 203A AND 204 IN CONNECTION WITH RESEARCH ANALYST WORK,
SUPERVISION AND PRODUCTION OF EMAILS.

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) 
COLORADO DIVISION OF SECURITIES, DEPARTMENT OF REGULATORY AGENCIES
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
05/05/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
05-H-16
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COLORADO DIVISION OF SECURITIES, DEPARTMENT OF REGULATORY AGENCIES CHARGED VIOLATIONS OF CRS (2004) 11-51-407, 11-51-410(1)
(G), AND 11-51-410(1)(I) IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.
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):
06/14/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $381,129 PAID TO COLORADO ON 6/10/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO A CONSENT ORDER WITH THE COLORADO DIVISION OF SECURITIES,
DEPARTMENT OF REGULATORY AGENCIES AND TO PAY $87.5 MILLION. THE COLORADO DIVISION OF SECURITIES, DEPARTMENT OF REGULATORY
AGENCIES CHARGED VIOLATIONS OF CRS (2004) 11-51-407, 11-51-410(1)(G), AND 11-51-410(1)(I) IN CONNECTION WITH RESEARCH ANALYST WORK,
SUPERVISION AND PRODUCTION OF EMAILS.

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) 
ARKANSAS SECURITIES DEPARTMENT
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
05/25/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
S-05-023-05-C001
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE ARKANSAS SECURITIES DEPARTMENT CHARGED VIOLATIONS OF ARK CODE ANN 23-42-308(A)(2)(G) AND 23-42-308(A)(2)(J) IN CONNECTION WITH
RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.
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):
06/23/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO ARKANSAS ON 6/16/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE ARKANSAS
SECURITIES DEPARTMENT AND TO PAY $87.5 MILLION. THE ARKANSAS SECURITIES DEPARTMENT CHARGED VIOLATIONS OF ARK CODE ANN 23-42-
308(A)(2)(G) AND 23-42-308(A)(2)(J) IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.

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) 
COMMONWEALTH OF PUERTO RICO COMMISSIONER OF FINANCIAL INSTITUTIONS
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
06/24/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
MATTER NO. C05-V-005
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMONWEALTH OF PUERTO RICO COMMISSIONER OF FINANCIAL INSTITUTIONS CHARGED VIOLATIONS OF SECTION 864 (A)(G) OF ACT. NO. 60
AND SECTION 26.1 OF REGULATION 6078 IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISON AND PRODUCTION OF EMAILS.
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):
07/01/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $337,476 PAID TO PUERTO RICO ON 7/6/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE COMMONWEALTH
OF PUERTO RICO COMMISSIONER OF FINANCIAL INSTITUTIONS AND TO PAY $87.5 MILLION. THE COMMONWEALTH OF PUERTO RICO COMMISSIONER
OF FINANCIAL INSTITUTIONS CHARGED VIOLATIONS OF SECTION 864 (A)(G) OF ACT NO. 60 AND SECTION 26.1 OF REGULATION 6078 IN CONNECTION
WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.

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) 
NEW JERSEY OFFICE OF THE ATTORNEY GENERAL, DIVISION OF CONSUMER AFFAIRS, BUREAU OF SECURITIES
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
06/21/2005
 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
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NEW JERSEY OFFICE OF THE ATTORNEY GENERAL, DIVISION OF CONSUMER AFFAIRS, BUREAU OF SECURITIES CHARGED VIOLATIONS OF N.J.S.A.
49:3-58(A)(2)(XI) FOR ALLEGEDLY FAILING TO ADEQUATELY SUPERVISE ITS EMPLOYEES; N.J.S.A. 49:3-58(A)(2)(VII) FOR ALLEGEDLY FAILING TO (I)
MANAGE CONFLICTS OF INTEREST APPROPRIATELY, (II) DISCLOSE PAYMENTS MADE AND RECEIVED FOR RESEARCH COVERAGE, AND (IV) PUBLISHING
EXAGGERATED OR UNWARRANTED RESEARCH ON INVESTMENT BANKING CLIENTS; AND N.J.S.A. 49:3-68 FOR ALLEGEDLY FAILING TO PRODUCE EMAIL
DOCUMENTS
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):
07/11/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $745,585 PAID TO NEW JERSEY ON 6/27/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.

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 ALLEGATIONS, THE APPLICANT AGREED TO A CONSENT ORDER WITH THE NEW JERSEY OFFICE OF THE
ATTORNEY GENERAL, DIVISION OF CONSUMER AFFAIRS, BUREAU OF SECURITIES AND TO PAY $87.5 MILLION. THE NEW JERSEY OFFICE OF THE
ATTORNEY GENERAL, DIVISION OF CONSUMER AFFAIRS, BUREAU OF SECURITIES CHARGED VIOLATIONS OF N.J.S.A. 49:3-58(A)(2)(XI) FOR ALLEGEDLY
FAILING TO ADEQUATELY SUPERVISE ITS EMPLOYEES; N.J.S.A. 49:3-58(A)(2)(VII) FOR ALLEGEDLY FAILING TO (I) MANAGE CONFLICTS OF INTEREST
APPROPRIATELY, (II) DISCLOSE PAYMENTS MADE AND RECEIVED FOR RESEARCH COVERAGE, AND (IV) PUBLISHING EXAGGERATED OR UNWARRANTED
RESEARCH ON INVESTMENT BANKING CLIENTS; AND N.J.S.A. 49:3-68 FOR ALLEGEDLY FAILING TO PRODUCE EMAIL DOCUMENTS.

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) 
IDAHO DEPARTMENT OF FINANCE

2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
05/25/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2005-7-11
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE IDAHO DEPARTMENT OF FINANCE CHARGED VIOLATIONS OF IDAHO CODE 30-1413(7) AND IDAPA 12.01.08.119 AND 12.01.08.124 IN CONNECTION
WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.
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):
07/15/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO IDAHO ON 7/14/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH
TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE
YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE IDAHO
DEPARTMENT OF FINANCE AND TO PAY $87.5 MILLION. THE IDAHO DEPARTMENT OF FINANCE CHARGED VIOLATIONS OF IDAHO CODE 30-1413(7) AND
IDAPA 12.01.08.119 AND 12.01.08.124 IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.

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) 
THE DISTRICT OF COLUMBIA DEPARTMENT OF INSURANCE, SECURITIES AND BANKING
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
03/04/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
SEC.CO 05-02

5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DISTRICT OF COLUMBIA DEPARTMENT OF INSURANCE, SECURITIES AND BANKING CHARGED VIOLATIONS OF D.C. OFFICIAL CODE 31-5602.07(A)(9)
FOR ALLEGEDLY ENABLING THE INVESTMENT BANKING DEPARTMENT TO EXERT INFLUENCE OVER RESEARCH ANALYSTS, ISSUING RESEARCH REPORTS
AFFECTED BY CONFLICTS OF INTEREST, MAKING PAYMENTS FOR RESEARCH COVERAGE, AND RECEIVING PAYMENTS FOR RESEARCH WITHOUT
DISCLOSING RECEIPT OF THOSE PAYMENTS; VIOLATIONS OF D.C. OFFICIAL CODE 31-5602.07(A)(12) FOR ALLEGEDLY FAILING TO ESTABLISH AND
MAINTAIN ADEQUATE POLICIES AND PROCEDURES TO DETECT IMPROPER INFLUENCES AND MANAGE CONFLICTS OF INTEREST.
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):
06/21/2005
 Exact
 Explanation
If not exact, provide explanation:
FINAL ORDER RECEIVED FROM THE DISTRICT OF COLUMBIA OF INSURANCE, SECURITIES AND BANKING BY DBSI'S OUTSIDE COUNSEL ON AUGUST 9,
2005.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO THE DISTRICT OF COLUMBIA ON 4/11/2005); (II) $25 MILLION TO FUND THE PROVISION OF
INDEPENDENT RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE
OVER THE NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE DISTRICT OF
COLUMBIA DEPARTMENT OF INSURANCE, SECURITIES AND BANKING, AND TO PAY $87.5 MILLION. THE DISTRICT OF COLUMBIA DEPARTMENT OF
INSURANCE, SECURITIES AND BANKING CHARGED VIOLATIONS OF D.C. OFFICIAL CODE 31-5602.07(A)(9) FOR ALLEGEDLY ENABLING THE INVESTMENT
BANKING DEPARTMENT TO EXERT INFLUENCE OVER RESEARCH ANALYSTS, ISSUING RESEARCH REPORTS AFFECTED BY CONFLICTS OF INTEREST,
MAKING PAYMENTS FOR RESEARCH COVERAGE, AND RECEIVING PAYMENTS FOR RESEARCH WITHOUT DISCLOSING RECEIPT OF THOSE PAYMENTS;
VIOLATIONS OF D.C. OFFICIAL CODE 31-5602.07(A)(12) FOR ALLEGEDLY FAILING TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES AND
PROCEDURES TO DETECT IMPROPER INFLUENCES AND MANAGE CONFLICTS OF INTEREST.

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

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.

Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
STATE OF WYOMING SECRETARY OF STATE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
07/01/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
05-02
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF WYOMING SECRETARY OF STATE CHARGED VIOLATIONS OF WYO. STAT. 17-4-106(A)(II)(G) AND 17-4-106(B)(II)(A) IN CONNECTION WITH
RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.
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):
07/26/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO WYOMING ON 7/14/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE STATE OF
WYOMING SECRETARY OF STATE AND TO PAY $87.5 MILLION. THE STATE OF WYOMING SECRETARY OF STATE CHARGED VIOLATIONS OF WYO. STAT. 17-
4-106(A)(II)(G) AND 17-4-106(B)(II)(A) IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.

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) 
INDIANA OFFICE OF THE SECRETARY OF STATE, SECURITIES DIVISION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
08/01/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
05-0021 CO
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE INDIANA OFFICE OF THE SECRETARY OF STATE, SECURITIES DIVISION CHARGED VIOLATIONS OF INDIANA CODE 23-2-1-11(A)(6) AND 710 IND.
ADMIN. CODE 1-17-1(W) FOR ALLEGEDLY FAILING TO ENSURE THAT RESEARCH ANALYSTS WERE INSULATED FROM COVERED COMPANIES AND
INVESTMENT BANKING AND INDIANA CODE 23-2-1-11(A)(14) AND 710 INDIANA ADMINISTRATIVE CODE 1-17-1(V) FOR ALLEGEDLY FAILING TO
SUPERVISE ITS EMPLOYEES.

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):
08/11/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $538,784 PAID TO INDIANA ON 8/16/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH
TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE
YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO A CONSENT AGREEMENT AND ORDER WITH THE INDIANA OFFICE OF
THE SECRETARY OF STATE, SECURITIES DIVISION AND TO PAY $87.5 MILLION. THE INDIANA OFFICE OF THE SECRETARY OF STATE, SECURITIES
DIVISION CHARGED VIOLATIONS OF INDIANA CODE 23-2-1-11(A)(6) AND 710 IND. ADMIN. CODE 1-17-1(W) FOR ALLEGEDLY FAILING TO ENSURE THAT
RESEARCH ANALYSTS WERE INSULATED FROM COVERED COMPANIES AND INVESTMENT BANKING AND INDIANA CODE 23-2-1-11(A)(14) AND 710
INDIANA ADMINISTRATIVE CODE 1-17-1(V) FOR ALLEGEDLY FAILING TO SUPERVISE ITS EMPLOYEES.

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) 
NEVADA SECRETARY OF STATE, SECURITIES DIVISION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
08/01/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. I05-185-JN
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NEVADA SECRETARY OF STATE, SECURITIES DIVISION CHARGED VIOLATIONS OF NRS 90.420(1)(H), NRS 90.420(1)(K), NAC 90.342, NAC 90.321
AND NASD CONDUCT RULE 3010 IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.
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):
08/11/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO NEVADA ON 8/9/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH
TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE
YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO A CONSENT AGREEMENT AND ORDER WITH THE NEVADA SECRETARY
OF STATE, SECURITIES DIVISION AND TO PAY $87.5 MILLION. THE NEVADA SECRETARY OF STATE, SECURITIES DIVISION CHARGED VIOLATIONS OF NRS
90.420(1)(H), NRS 90.420(1)(K), NAC 90.342, NAC 90.321 AND NASD CONDUCT RULE 3010 IN CONNECTION WITH RESEARCH ANALYST WORK,
SUPERVISION AND PRODUCTION OF EMAILS.

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) 
NEW YORK STOCK EXCHANGE, INC. ("NYSE")
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE
3.
Date Initiated (MM/DD/YYYY): 
04/04/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
HPD# 05-045
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
EQUITY LISTED (COMMON & PREFERRED STOCK)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NYSE ALLEGED, AND DEUTSCHE BANK SECURITIES INC. ("DBSI"), WITHOUT ADMITTING OR DENYING GUILT CONSENTED TO FINDINGS THAT DBSI
VIOLATED EXCHANGE RULE 451 IN THAT THE FIRM, ON NUMEROUS OCCASIONS, FAILED TO TRANSMIT TO ITS CUSTOMERS WHO WERE BENEFICIAL
OWNERS OF STOCK, VIA ITS SERVICE PROVIDER, ACCURATE INFORMATION IN CONNECTION WITH PROXY SOLICITATIONS; THAT THE FIRM VIOLATED
SECURITIES AND EXCHANGE COMMISSION RULE 240.17A-4, EXCHANGE RULE 440, AND EXCHANGE RULE 452.20, IN THAT THE FIRM FAILED TO RETAIN
ALL PROXY SOLICITATION RECORDS FOR PERIOD OF NOT LESS THAN THREE YEARS, THE FIRST TWO IN AN EASILY ACCESSIBLE LOCATION; THAT THE
FIRM ENGAGED IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE, IN THAT THE FIRM; (A) FAILED TO IMPLEMENT
ADEQUATE POLICIES AND PROCEDURES TO ADJUST ITS RECORD OF STOCK OWNERSHIP SO THAT VOTES OF ITS CUSTOMERS WHO WERE BENEFICIAL
OWNERS OF STOCK WERE ACCURATELY TALLIED BY THE TABULATOR FOR PROXY VOTING PURPOSES;(B) ON NUMEROUS OCCASIONS, VOTED MORE
SHARES THAN IT WAS ENTITLED TO VOTE IN PROXY MATTERS; (C) FAILED TO ASSURE THAT ITS SYSTEMS AND PROCEDURES PROVIDED FOR THE
ACCURATE SUBMISSION OF PROXY DATA TO THE PROXY TABULATORS; THAT THE FIRM VIOLATED EXCHANGE RULE 401 BY FAILING TO ADHERE TO THE
PRINCIPLES OF GOOD BUSINESS PRACTICE IN THAT THE FIRM, ON NUMEROUS OCCASIONS, FAILED TO RECONCILE ITS RECORD OF STOCK OWNERSHIP
SO THAT VOTES OF BENEFICIAL OWNERS WERE ACCURATELY TALLIED BY THE TABULATOR FOR PROXY VOTING PURPOSES; AND THAT THE FIRM
VIOLATED EXCHANGE RULE 342 IN THAT THE FIRM FAILED TO (A) SUPERVISE PROXY OPERATIONS TO PREVENT OVERVOTING; PROVIDE FOR AND
IMPLEMENT WRITTEN PROCEDURES FOR PROXY OPERATIONS AND SUPERVISON OF THE PROXY FUNCTION; AND (C) PROVIDE FOR AND IMPLEMENT
WRITTEN PROCEDURES FOR SUPERVISON OF ITS PROXY SERVICE PROVIDER.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:

Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
02/02/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 1,000,000.00
 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: 
THE ENTIRE $1 MILLION DOLLAR FINE WAS LEVIED AGAINST DBSI. DBSI HAS NOT YET PAID THE FINE.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE BOARD IMPOSED THE PENALTY CONSENTED TO BY THE PARTIES, THAT OF A CENSURE AND A $1 MILLION DOLLAR FINE. WITHOUT ADMITTING OR
DENYING THE ALLEGATIONS, DBSI AGREED TO THE CENSURE AND $1 MILLION DOLLAR FINE.

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) 
OFFICE OF THE MISSISSIPPI SECRETARY OF STATE, BUSINESS REGULATION AND ENFORCEMENT DIVISION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
06/23/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
02-11-06-S
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE OFFICE OF THE MISSISSIPPI SECRETARY OF STATE, BUSINESS REGULATION AND ENFORCEMENT DIVISION CHARGED VIOLATIONS OF MISS. CODE
ANN. 75-71-321(A)(F) (REV. 2000) IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS AND MISS. CODE
ANN. 75-71-321(B)(A) (REV. 2000) FOR ALLEGEDLY FAILING TO REASONABLY SUPERVISE ITS EMPLOYEES.
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):
07/01/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:

UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO MISSISSIPPI ON 7/16/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO A CONSENT ORDER WITH THE OFFICE OF THE MISSISSIPPI
SECRETARY OF STATE, BUSINESS REGULATION AND ENFORCEMENT DIVISION AND TO PAY $87.5 MILLION. THE OFFICE OF THE MISSISSIPPI SECRETARY
OF STATE, BUSINESS REGULATION AND ENFORCEMENT DIVISION CHARGED VIOLATIONS OF MISS. CODE ANN. 75-71-321(A)(F) (REV. 2000) IN
CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS AND MISS. CODE ANN. 75-71-321(B)(A) (REV. 2000) FOR
ALLEGEDLY FAILING TO REASONABLY SUPERVISE ITS EMPLOYEES.

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) 
THE STATE OF DELAWARE, DEPARTMENT OF JUSTICE, SECURITIES DIVISION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
08/01/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE. NO. 05-3-1
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF DELAWARE, DEPARTMENT OF JUSTICE, SECURITIES DIVISION CHARGED VIOLATIONS OF 6 DEL. C. SECS. 7315(A), 7316(A)(7) AND
7316(A)(10) IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.
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):
08/22/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO DELAWARE ON 8/16/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT

RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE STATE OF
DELAWARE, DEPARTMENT OF JUSTICE, SECURITIES DIVISION AND TO PAY $87.5 MILLION. THE STATE OF DELAWARE, DEPARTMENT OF JUSTICE,
SECURITIES DIVISION CHARGED VIOLATIONS OF 6 DEL. C. SECS. 7315(A), 7316(A)(7) AND 7316(A)(10) IN CONNECTION WITH RESEARCH ANALYST
WORK, SUPERVISION AND PRODUCTION OF EMAILS.

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

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

2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
08/04/2005
 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
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF NORTH DAKOTA SECURITIES DEPARTMENT CHARGED VIOLATIONS OF SECTION 10-04-11(C) N.D.C.C. IN CONNECTION WITH RESEARCH
ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.
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):
08/26/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO NORTH DAKOTA ON 8/23/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE STATE OF NORTH
DAKOTA SECURITIES DEPARTMENT AND TO PAY $87.5 MILLION. THE STATE OF NORTH DAKOTA SECURITIES DEPARTMENT CHARGED VIOLATIONS OF
SECTION 10-04-11(C) N.D.C.C. IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.

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

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NATIONAL ASSOCIATION OF SECURITIES DEALERS
2.
Principal Sanction:
Censure
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
02/08/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
MRD# 20050004547-01

5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
FIXED INCOME
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NASD ALLEGES THAT DEUTSCHE BANK SECURITIES INC.("DBSI"), FAILED TO REPORT 4,749 TRACE TRANSACTIONS WITHIN THIRTY MINUTES AS
REQUIRED BY NASD RULE 6230(A). THE NASD ALSO ALLEGES PURSUANT TO NASD RULE 2110 & 3010, THAT WRITTEN SUPERVISORY PROCEDURES
REGARDING TRACE REPORTING IN PLACE AT DBSI, WERE NOT ADEQUATELY 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):
09/09/2005
 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: $ 15,000.00
 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 FINE OF 15000.00 WILL BE PAID TO THE NASD.
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 ALLEGATIONS, THE APPLICANT AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT, AND A FINE OF
$15,000 (COMPRISED OF A $10,000 FINE FOR THE TRACE LATE REPORTING VIOLATIONS AND A $5,000 FINE FOR THE 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) 
UTAH DIVISION OF SECURITIES, DEPARTMENT OF COMMERCE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST,DISGORGEMENT,UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
07/12/2005
 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
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE UTAH DIVISION OF SECURITIES, DEPARTMENT OF COMMERCE CHARGED VIOLATIONS OF UTAH CODE ANN. 61-1-6(2)(G) FOR ALLEGEDLY ENABLING
CONFLICTS OF INTEREST TO DEVELOP AND FAILING TO MANAGE SUCH CONFLICTS, ISSUING REPORTS AFFECTED BY SUCH CONFLICTS, MAKING
PAYMENTS FOR RESEARCH, AND RECEIVING PAYMENT FOR RESEARCH AND VIOLATIONS OF UTAH CODE ANN. 61-1-6(2)(J) FOR ALLEGEDLY FAILING TO
ESTABLISH AND MAINTAIN ADEQUATE POLICIES AND PROCEDURES FOR AVOIDING AND MANAGING CONFLICTS OF INTEREST; VIOLATIONS OF 61-1-5(5)
AND R164-6-1G(C)(30) OF THE UTAH ADMINISTRATIVE CODE FOR ALLEGEDLY FAILING TO PRODUCE EMAILS.
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):
08/25/2005
 Exact
 Explanation
If not exact, provide explanation:
FINAL ORDER RECEIVED FROM UTAH STATE DEPARTMENT OF SECURITIES BY DEUTSCHE BANK SECURITIES INC'S OUTSIDE COUNSEL ON 09/22/05.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO UTAH ON 8/9/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH TO
INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE YEARS);
AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE FIRM AGREED TO A CONSENT ORDER WITH THE UTAH DIVISION OF SECURITIES,
DEPARTMENT OF COMMERCE AND TO PAY $87.5 MILLION. THE UTAH DIVISION OF SECURITIES, DEPARTMENT OF COMMERCE CHARGED VIOLATIONS OF
UTAH CODE ANN. 61-1-6(2)(G) FOR ALLEGEDLY ENABLING CONFLICTS OF INTEREST TO DEVELOP AND FAILING TO MANAGE SUCH CONFLICTS, ISSUING
REPORTS AFFECTED BY SUCH CONFLICTS, MAKING PAYMENTS FOR RESEARCH, AND RECEIVING PAYMENT FOR RESEARCH AND VIOLATIONS OF UTAH
CODE ANN. 61-1-6(2)(J) FOR ALLEGEDLY FAILING TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES AND PROCEDURES FOR AVOIDING AND MANAGING
CONFLICTS OF INTEREST; VIOLATIONS OF 61-1-5(5) AND R164-6-1G(C)(30) OF THE UTAH ADMINISTRATIVE CODE FOR ALLEGEDLY FAILING TO
PRODUCE EMAILS.

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

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

You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NATIONAL ASSOCIATION OF SECURITIES DEALERS
2.
Principal Sanction:
Censure
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/22/2004
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
MRD20050002625-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
EQUITY
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FOLLOWING EXAMINATION MRD200447866 ON 07/22/04 (SUBSEQUENTLY DESIGNATED AS MRD20050002625-01), THE NASD ALLEGED THAT DEUTSCHE
BANK SECURITIES INC.("DBSI" OR THE "FIRM") VIOLATED: (1) NASD CONDUCT RULE 3370 BECAUSE IT EFFECTED FIVE SHORT SALES FOR THE FIRM'S
PROPRIETARY ACCOUNT AND FAILED TO MAKE AN AFFIRMATIVE DETERMINATION THAT DBSI COULD BORROW OR DELIVER THE SECURITIES BY
SETTLEMENT DATE; (2) NASD MARKETPLACE RULE 6130(D), BECAUSE A THIRD PARTY ACTING ON DBSI'S BEHALF FAILED TO REPORT TO THE NASDAQ
MARKET CENTER THE CORRECT SYMBOL INDICATING WHETHER, IN 291 TRANSACTIONS, DBSI ACTED IN A PRINCIPAL OR AGENCY CAPACITY; AND (3)
SEC RULE 10B-10 BECAUSE DBSI'S FAILURE TO PROVIDE WRITTEN NOTIFICATION TO ITS CUSTOMERS ON SEVEN OCCASIONS THAT TRANSACTIONS
WERE EXECUTED AT AVERAGE PRICE , AND FAILED TO PROVIDE WRITTEN NOTIFICATION TO ITS CUSTOMERS ON THIRTEEN OCCASIONS THE CORRECT
CAPACITY IN WHICH IT WAS ACTING. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER &
CONSENT AND A FINE OF $15,000 (COMPRISED OF A $5,000 FINE FOR THE AFFIRMATIVE DETERMINATION VIOLATIONS, $5,000 FINE FOR THE TRADE
REPORTING VIOLATIONS, AND A $5,000 FINE FOR THE SEC RULE 10B-10 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):
09/09/2005
 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: $ 15,000.00
 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 FINE OF $15,000.00 WILL BE PAID TO THE NASD.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT, AND A FINE OF $15,000
(COMPRISED OF A $5,000 FINE FOR THE AFFIRMATIVE DETERMINATION VIOLATIONS, $5,000 FINE FOR THE TRADE REPORTING VIOLATIONS, AND A
$5,000 FINE FOR SEC RULE 10B-10 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) 
WEST VIRGINIA SECURITIES DIVISION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
08/31/2005
 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
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE WEST VIRGINIA SECURITIES DIVISION CHARGED VIOLATIONS OF WEST VIRGINIA CODE 32-2-204 FOR (1) ALLEGEDLY FAILING TO REASONABLY
SUPERVISE ITS AGENTS OR EMPLOYEES AND (2) FOR ALLEGEDLY FAILING TO ENSURE THAT ANALYSTS WERE ADEQUATELY INSULATED FROM
INFLUENCES OF COVERED COMPANIES AND INVESTMENT BANKING.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
09/30/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO WEST VIRGINIA ON 10/10/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE WEST VIRGINIA
SECURITIES DIVISION AND TO PAY $87.5 MILLION. THE WEST VIRGINIA SECURITIES DIVISION CHARGED VIOLATIONS OF WEST VIRGINIA CODE 32-2-
204 FOR (1) ALLEGEDLY FAILING TO REASONABLY SUPERVISE ITS AGENTS OR EMPLOYEES AND (2) FOR ALLEGEDLY FAILING TO ENSURE THAT ANALYSTS
WERE ADEQUATELY INSULATED FROM INFLUENCES OF COVERED COMPANIES AND INVESTMENT BANKING.

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

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

circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
STATE OF HAWAII DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
09/06/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
SEU-2005-036-B
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF HAWAII DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS CHARGED VIOLATION OF: H.R.S. 485-15(7) FOR ALLEGEDLY FAILING TO
ENSURE ANALYSTS WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING; 485-
16 FOR ALLEGEDLY FAILING TO PROMPTLY PRODUCE COPIES OF EMAIL COMMUNICATIONS REQUESTED BY REGULATORS; AND 485-15(10) FOR
ALLEGEDLY FAILING TO REASONABLY SUPERVISE ITS EMPLOYEES TO ENSURE THAT ANALYSTS WERE ADEQUATELY INSULATED FROM PRESSURES AND
INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING.
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):
10/17/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY

RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO HAWAII ON 10/10/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH
TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE
YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, DBSI AGREED TO A CONSENT ORDER AND CONSENT TO ENTRY OF ADMINISTRATIVE ORDER WITH
THE STATE OF HAWAII DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS AND TO PAY $87.5 MILLION. THE STATE OF HAWAII DEPARTMENT OF
COMMERCE AND CONSUMER AFFAIRS CHARGED VIOLATION OF: H.R.S. 485-15(7) FOR ALLEGEDLY FAILING TO ENSURE ANALYSTS WERE ADEQUATELY
INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING; 485-16 FOR ALLEGEDLY FAILING TO
PROMPTLY PRODUCE COPIES OF EMAIL COMMUNICATIONS REQUESTED BY REGULATORS; AND 485-15(10) FOR ALLEGEDLY FAILING TO REASONABLY
SUPERVISE ITS EMPLOYEES TO ENSURE THAT ANALYSTS WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED
COMPANIES AND INVESTMENT BANKING.

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) 
MONTANTA STATE AUDITOR'S OFFICE SECURITIES DEPARTMENT
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING.
3.
Date Initiated (MM/DD/YYYY): 
09/06/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
05-17-05-144I
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE MONTANA STATE AUDITOR'S OFFICE SECURITIES DEPARTMENT CHARGED DBSI WITH VIOLATIONS OF MCA 30-10-201(13)(K) FOR ALLEGEDLY
FAILING TO REASONABLY SUPERVISE ITS EMPLOYEES, MCA 30-10-201(12) FOR ALLEGEDLY FAILING TO KEEP REQUIRED BOOKS AND RECORDS, MCA 30-
10-201(13)(G) FOR ALLEGEDLY FAILING TO ENSURE ANALYSTS WERE ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED
COMPANIES AND INVESTMENT BANKING, AND MCA 30-10-201(13)(G) IN CONNECTION WITH THE FOREGOING.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
11/02/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 

DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO MONTANA ON 10/1/05); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT RESEARCH
TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE NEXT FIVE
YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, THE APPLICANT AGREED TO A CONSENT AGREEMENT AND ORDER WITH THE MONTANA STATE
AUDITOR'S OFFICE SECURITIES DEPARTMENT AND TO PAY $87.5 MILLION. THE MONTANA STATE AUDITOR'S OFFICE SECURITIES DEPARTMENT CHARGED
DBSI WITH VIOLATIONS OF MCA 30-10-201(13)(K) FOR ALLEGEDLY FAILING TO REASONABLY SUPERVISE ITS EMPLOYEES, MCA 30-10-201(12) FOR
ALLEGEDLY FAILING TO KEEP REQUIRED BOOKS AND RECORDS, MCA 30-10-201(13)(G) FOR ALLEGEDLY FAILING TO ENSURE ANALYSTS WERE
ADEQUATELY INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING, AND MCA 30-10-201(13)(G) IN
CONNECTION WITH THE FOREGOING.

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) 
THE STATE OF MICHIGAN OFFICE OF FINANCIAL AND INSURANCE SERVICES
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
10/19/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ORDER NO. 05-010-M
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF MICHIGAN OFFICE OF FINANCIAL AND INSURANCE SERVICES CHARGED DBSI WITH VIOLATIONS OF MCL 451.604(A)(1)(G) AND (A)(2) FOR
ALLEGED FAILURES RELATING TO JUST AND EQUITABLE PRINCIPLES OF TRADE; THE REASONABLE SUPERVISION OF ITS EMPLOYEES TO ENSURE
ADEQUATE INSULATION BETWEEN ITS RESEARCH ANALYSTS AND INVESTMENT BANKING; THE ESTABLISHMENT, MAINTENANCE, AND ENFORCEMENT OF
WRITTEN PROCEDURES; AND THE KEEPING OF REQUIRED BOOKS AND RECORDS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
11/04/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $880,634 PAID TO MICHIGAN ON 10/24/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, DBSI AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE STATE OF MICHIGAN OFFICE
OF FINANCIAL AND INSURANCE SERVICES AND TO PAY $87.5 MILLION. THE STATE OF MICHIGAN OFFICE OF FINANCIAL AND INSURANCE SERVICES
CHARGED DBSI WITH VIOLATIONS OF MCL 451.604(A)(1)(G)AND (A)(2) FOR ALLEGED FAILURES RELATING TO JUST AND EQUITABLE PRINCIPLES OF
TRADE; THE REASONABLE SUPERVISION OF ITS EMPLOYEES TO ENSURE ADEQUATE INSULATION BETWEEN ITS RESEARCH ANALYSTS AND INVESTMENT
BANKING; THE ESTABLISHMENT, MAINTENANCE, AND ENFORCEMENT OF WRITTEN PROCEDURES; AND THE KEEPING OF REQUIRED BOOKS AND
RECORDS.

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

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

CEASE AND DESIST,DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
11/29/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CO-2005-7083-S
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF CONNECTICUT DEPARTMENT OF BANKING CHARGED DBSI WITH VIOLATIONS OF SECTION 36B-4(B) OF THE CONNECTICUT UNIFORM
SECURITIES ACT (THE "ACT") FOR ALLOWING CONFLICTS OF INTEREST TO DEVELOP AND FAILING TO MANAGE THESE CONFLICTS, ISSUING RESEARCH
REPORTS THAT WERE AFFECTED BY CONFLICTS, AND MAKING AND RECEIVING PAYMENTS IN CONNECTION WITH CERTAIN TRANSACTIONS AND FAILING
TO DISCLOSE SUCH PAYMENTS; VIOLATIONS OF SECTION 36B-31-6F(B) OF THE REGULATIONS OF CONNECTICUT STATE AGENCIES PROMULGATED
UNDER THE ACT (THE "REGULATIONS") FOR FAILING TO ESTABLISH AND MAINTAIN SYSTEMS TO DETECT AND PREVENT AND MANAGE CONFLICTS; AND
VIOLATIONS OF SECTION 36B-14 OF THE ACT AND SECTION 36B-31-14F OF THE REGULATIONS FOR FAILING TO PRODUCE ELECTRONIC MAIL IN A
TIMELY MANNER.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
12/07/2005
 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: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $301,763 PAID TO CONNECTICUT ON 11/16/2005); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, DBSI AGREED TO A CONSENT ORDER WITH THE STATE OF CONNECTICUT DEPARTMENT OF
BANKING AND TO PAY $87.5 MILLION. THE STATE OF CONNECTICUT DEPARTMENT OF BANKING CHARGED DBSI WITH VIOLATIONS OF SECTION 36B-4(B)
OF THE CONNECTICUT UNIFORM SECURITIES ACT (THE "ACT") FOR ALLOWING CONFLICTS OF INTEREST TO DEVELOP AND FAILING TO MANAGE THESE
CONFLICTS, ISSUING RESEARCH REPORTS THAT WERE AFFECTED BY CONFLICTS, AND MAKING AND RECEIVING PAYMENTS IN CONNECTION WITH

CERTAIN TRANSACTIONS AND FAILING TO DISCLOSE SUCH PAYMENTS; VIOLATIONS OF SECTION 36B-31-6F(B) OF THE REGULATIONS OF CONNECTICUT
STATE AGENCIES PROMULGATED UNDER THE ACT (THE "REGULATIONS") FOR FAILING TO ESTABLISH AND MAINTAIN SYSTEMS TO DETECT AND PREVENT
AND MANAGE CONFLICTS; AND VIOLATIONS OF SECTION 36B-14 OF THE ACT AND SECTION 36B-31-14F OF THE REGULATIONS FOR FAILING TO
PRODUCE ELECTRONIC MAIL IN A TIMELY MANNER.

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

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

3.
Date Initiated (MM/DD/YYYY): 
01/23/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
04CV06909
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF SOUTH DAKOTA DIVISION OF SECURITIES CHARGED DBSI WITH VIOLATIONS OF CHAPTER 47-31B UNDER 47-31B-412(D)(9) AND 47-31B-
412(13) IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/31/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI AGREED TO PAY: (I) $50 MILLION, OFFSET BY $25 MILLION TO BE PAID PURSUANT TO AGREEMENTS WITH STATE REGULATORS IN RELATED
PROCEEDINGS (INCLUDING $287,500 PAID TO SOUTH DAKOTA ON 1/27/2006); (II) $25 MILLION TO FUND THE PROVISION OF INDEPENDENT
RESEARCH TO INVESTORS (PAYABLE OVER THE NEXT FIVE YEARS); (III) $5 MILLION TO PROMOTE INVESTOR EDUCATION (PAYABLE OVER THE
NEXT FIVE YEARS); AND (IV) $7.5 MILLION IN CONNECTION WITH ALLEGATIONS CONCERNING SECTION 17(B) OF THE EXCHANGE ACT.
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 ALLEGATIONS, DBSI AGREED TO AN ADMINISTRATIVE CONSENT ORDER WITH THE STATE OF SOUTH DAKOTA
DIVISION OF SECURITIES AND TO PAY $87.5 MILLION. THE STATE OF SOUTH DAKOTA DIVISION OF SECURITIES CHARGED DBSI WITH VIOLATIONS OF
CHAPTER 47-31B UNDER 47-31B-412(D)(9) AND 47-31B-412(13) IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION
OF EMAILS.

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: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
01/03/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20050004905
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NASD ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED NASD MARKETPLACE RULE 6620(A) AND NASD CONDUCT RULES 2110 AND
3010 WHEN, ON A NUMBER OF OCCASIONS FROM SEPTEMBER 1, 2004 THROUGH DECEMBER 31, 2004, DBSI (I) FAILED TO TRANSMIT THROUGH
NASDAQ MARKET CENTER WITHIN 90 SECONDS AFTER EXECUTION CERTAIN LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES; (II)
FAILED TO TRANSMIT THROUGH NASDAQ MARKET CENTER WITHIN 90 SECONDS AFTER EXECUTION CERTAIN LAST SALE REPORTS OF TRANSACTIONS IN
OTC EQUITY SECURITIES AND FAILED TO DESIGNATE THROUGH NASDAQ MARKET CENTER SUCH LAST SALES REPORTS AS LATE; (III) INCORRECTLY
DESIGNATED AS ".SLD" CERTAIN LAST SALES REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES EXECUTED OUTSIDE NORMAL MARKET HOURS;
AND (IV) FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES FOR TRADE REPORTING.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
02/06/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 15,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND A FINE TOTALING $15,000.00 (COMPRISED OF A $10,000 FINE FOR TRADE REPORTING VIOLATIONS, AND A
$5,000 FINE FOR SUPERVISION VIOLATIONS). THE FINE OF $15,000 WAS PAID ON MARCH 3, 2006.
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 ADMITTIG OR DENYING THE ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT TO A CENSURE AND A FINE
OF $15,000 (COMPRISED OF A $10,000 FINE FOR TRADE REPORTING VIOLATIONS AND A $5,000 FINE FOR SUPERVSIORY 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) 
INTERNATIONAL SECURITIES EXCHANGE, INC. ("ISE")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
09/15/2005
 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:
Derivative(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE ISE ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI")VIOLATED ISE RULES 713(B), 713(C), 713(E), 803(A), 804(D)AND SEC 11AC1-1,
WHEN ON A NUMBER OF OCCASIONS IN THE PERIOD OCTOBER 2003 THROUGH OCTOBER 2004, DBSI FAILED TO PROPERLY HANDLE PUBLIC CUSTOMER
ORDERS THAT IT HELD FOR MANUAL HANDLING, INCLUDING FAILING TO ALLOCATE PUBLIC CUSTOMER ORDERS TO THE MARKET PARTICIPANT
REPRESENTING THE BEST QUOTATION ON THE EXCHANGE. THE ISE FURTHER ALLEGED THAT DBSI VIOLATED ISE RULES 803(A), 803(C)(2), AND 804(A),
WHEN ON A NUMBER OF OCCASIONS IN THE PERIOD JANUARY 2004 THROUGH JUNE 2004, DBSI FAILED TO PROPERLY HANDLE PUBLIC CUSTOMER
ORDERS THAT IT HELD FOR MANUAL HANDLING, INCLUDING FAILING TO PROVIDE PUBLIC CUSTOMER ORDERS WITH THE BEST PRICE AS REPRESENTED
AT ANOTHER EXCHANGE.

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):
12/20/2005
 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:
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 ENTIRE $75,000.00 FINE WAS LEVIED AGAINST DBSI. THE FINE WAS PAID ON FEBRUARY 14, 2006.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER, & CONSENT TO A CENSURE AND A FINE OF
$75,000.00 (COMPRISED OF $50,000 FOR THE TRADE REPORTING VIOLATIONS AND $25,000 FOR THE FIRM QUOTE 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) 
INTERNATIONAL SECURITIES EXCHANGE, INC. ("ISE")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
01/10/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2005-60, 112, 59
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ISE ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI" OR THE "FIRM") VIOLATED ISE RULE 1901(C)(2) WHEN: (1) ON A NUMBER OF INSTANCES
BETWEEN JANUARY 1, 2005 AND JUNE 30, 2005, WHEN SENDING P/A ORDERS THAT WERE LARGER THAN THE FIRM CUSTOMER QUOTE SIZE, THE FIRM
SENT AN INITIAL P/A ORDER THAT WAS NOT FOR THE FIRM CUSTOMER QUOTE SIZE; AND (2) IN SOME INSTANCES WHEN SENDING A P/A ORDER THAT
WAS LARGER THAN THE FIRM CUSTOMER QUOTE SIZE, DBSI SENT AN ADDITIONAL P/A ORDER WHEN SUCH ORDER WAS NOT FOR AT LEAST THE LESSER
OF THE SIZE OF THE DISSEMINATED QUOTATION, 100 CONTRACTS, OR THE ENTIRE REMAINDER OF THE PUBLIC CUSTOMER ORDER; AND ISE FURTHER
ALLEGED THAT DBSI VIOLATED RULE 400 WHEN: (1) ON CERTAIN INSTANCES BETWEEN JANUARY 2005 AND MARCH 2005, THE FIRM SENT P/A ORDERS
THROUGH THE LINKAGE THAT DID NOT REFLECT AN UNEXECUTED PUBLIC CUSTOMER ORDER; AND (2) IN SOME INSTANCES, THE FIRM FAILED TO PASS
THE EXECUTION OF THE P/A ORDERS TO THE PUBLIC CUSTOMER.
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):
03/08/2006
 Exact
 Explanation

p
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 15,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
CENSURE
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: 
DBSI AGREED TO A CENSURE AND A FINE TOTALING $15,000 (COMPRISED OF A $5,000 FINE FOR VIOLATIONS IN ISE NO. 2005-60, $5,000 FOR
THE VIOLATION IN ISE NO. 2005-112, AND $5,000 FOR THE VIOLATIONS IN ISE NO. 2005-59). THE FINE WAS PAID ON MARCH 14,2006.
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 ALLEGATIONS, THE APPLICANT AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT, AND A FINE OF
$15,000 (COMPRISED OF A $5,000 FINE FOR VIOLATIONS IN ISE NO. 2005-60, $5,000 FOR THE VIOLATION IN ISE NO. 2005-112, AND $5,000 FOR THE
VIOLATIONS IN ISE NO. 2005-59).

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE BANK AG (LONDON
BRANCH) ("DBL")
(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) 
UK FINANCIAL SERVICES AUTHORITY ("FSA")
2.
Principal Sanction:
Other Sanctions: 
BREACHES OF FSA PRINCIPLE 5,2
3.
Date Initiated (MM/DD/YYYY): 
08/06/2004
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FSA/PN/036/2006
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
EQUITY CAPITAL MARKETS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE FINANCIAL SERVICES AUTHORITY, ("FSA"), FINED DEUTSCHE BANK AG, LONDON BRANCH, ("DBL"), FOR BREACHES OF FSA PRINCIPLE 5, (DUTY TO
OBSERVE PROPER STANDARDS OF MARKET CONDUCT), AND BREACHES OF PRINCIPLE 2, (DUTY TO ACT WITH DUE SKILL, CARE AND DILIGENCE),
REGARDING TWO SEPARATE EQUITY CAPITAL MARKET TRANSACTIONS CONDUCTED BY DBL IN MARCH 2004. DBL INTERNALLY IDENTIFIED AND SELF
REPORTED TO THE FSA ISSUES RELATING TO BOTH TRANSACTIONS. DBL APPOINTED EXTERNAL ADVISORS TO UNDERTAKE A DETAILED INVESTIGATION
INTO THE TRANSACTIONS, THE RESULTS OF WHICH WERE PROVIDED TO THE FSA IN MAY 2004. THE FIRST TRANSACTION INVOLVED A BOOK BUILD IN
SCANIA AB, B SHARES. FOR THE PURPOSES OF THE SETTLEMENT WITH FSA, DBL HAS ADMITTED BREACHES OF FSA PRINCIPLE 5, IN THAT DBL HAD
PURCHASED HIGH VOLUMES OF SCANIA AB, B SHARES USING EXTERNAL BROKERS, RATHER THAN TRADING IN DBL'S OWN NAME, THEREBY INCREASING
AND STABILIZING THE SHARE PRICE. FOR THE PURPOSES OF A SETTLEMENT, DBL HAS ADMITTED BREACHES OF FSA PRINCIPLE 2, IN THAT (1) DBL
ALLOWED THE PURCHASE OF SHARES BY AN EMPLOYEE WITHOUT PRE-NOTIFICATION (2) DBL ISSUED THREE COVERAGE STATEMENTS THAT WERE
INCOMPLETE OR INACCURATE WITH RESPECT TO THE ACTUAL DEGREE OF COVERAGE, AND (3) DBL ISSUED AN INTERNAL STATEMENT ON THE DAY
FOLLOWING THE TRANSACTION THAT DBL WOULD BE REPORTING TO THE STOCKHOLM STOCK EXCHANGE THAT IT CURRENTLY HELD A 9.6% STAKE IN
SCANIA AB. THIS INFORMATION WAS NOT PROPERLY EMBARGOED, AS A NUMBER OF DBL EMPLOYEES DISCLOSED IT TO CLIENTS, PRIOR TO THE
INFORMATION BEING MADE PUBLIC. THE SECOND TRANSACTION INVOLVED THE STABILIZATION OF CYTOS BIOTECHNOLOGY AG SHARES. FOR THE
PURPOSES OF THE SETTLEMENT WITH FSA DBL HAS ADMITTED BREACHES OF FSA PRINCIPLE 2 BECAUSE (1) DBL FAILED TO ENSURE THAT THE
STABILIZATION TRADER FOLLOWED DBL'S INTERNAL PROCEDURES ON STABILIZATION AND ; (2) DBL FAILED TO ENSURE THAT THE LONDON STAFF
ESCALATED TRADING ISSUES TO COMPLIANCE IN A TIMELY MANNER.
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):
04/11/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 6,363,643.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PLEASE NOTE: THE ABOVE AMOUNT IS IN GBP.
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: 
DBL AGREED TO PAY: (I) A FINE OF GBP 3,500,000 AND A "LOSS AVOIDANCE" FIGURE OF GBP 2,363,643 WITH RESPECT TO THE SCANIA
TRANSACTION DUE TO THE DBL PURCHASES AND THE INACCURATE COVERAGE STATEMENTS (II) A FINE OF 500,000 WITH RESPECT TO THE CYTOS
BIOTECHNOLGY TRANSACTION FOR FAILURE TO FOLLOW INTERNAL PROCEDURES ON STABILIZATION, AND FAILURE TO ESCALATE ISSUE TO
COMPLIANCE IN A TIMELY MANNER.
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).
FOR THE PURPOSES OF THE SETTLEMENT, DBL AGREED TO A TOTAL FINANCIAL PENALTY OF GBP 6,363,643 FOR BREACHES OF FSA PRINCIPLE 5 IN
RESPECT TO ONE OF THE TRANSACTIONS, AND FSA PRINCIPLE 2 IN RESPECT OF BOTH TRANSACTIONS. THE FINE WAS PAID TO THE FSA ON APRIL 13,
2006.

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) 
TEXAS STATE SECURITIES BOARD
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
05/24/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
IC06-CD0-07
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE TEXAS STATE SECURITIES BOARD CHARGED DBSI WITH VIOLATIONS OF 115.5 AND 115.10 OF THE RULES AND REGULATIONS OF THE TEXAS STATE
SECURITIES BOARD FOR ALLEGEDLY ENGAGING IN INEQUITABLE PRACTICES IN THE SALE OF SECURITIES AS SPECIFIED IN SECTION 14.A(3) OF THE
TEXAS SECURITIES ACT, IN CONNECTION WITH RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.
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):
05/31/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 87,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution

 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI PAID $1,847,656 TO TEXAS ON 5/30/06. THIS AMOUNT IS PART OF A GLOBAL SETTLEMENT PREVIOSULY DISCLOSED BY DBSI ON 10/13/04.
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 ALLEGATIONS, DBSI AGREED TO THE ENTRY OF AN ORDER AND FINDINGS OF FACT AND CONCLUSIONS OF LAW
BY THE TEXAS STATE SECURITIES BOARD. DBSI WAS SUBJECT TO A CEASE AND DESIST ORDER, AND PAID $1,847,656 TO TEXAS ON 5/30/06.THIS
AMOUNT IS PART OF A GLOBAL SETTLEMENT PREVIOUSLY DISCLOSED BY DBSI ON 10/13/04. THE TEXAS STATE SECURITIES BOARD CHARGED DBSI
WITH VIOLATIONS OF 115.5 AND 115.10 OF THE RULES AND REGULATIONS OF THE TEXAS STATE SECURITIES BOARD FOR ALLEGEDLY ENGAGING IN
INEQUITABLE PRACTICES IN THE SALE OF SECURITIES AS SPECIFIED IN SECTION 14.A(3) OF THE TEXAS SECURITIES ACT, IN CONNECTION WITH
RESEARCH ANALYST WORK, SUPERVISION AND PRODUCTION OF EMAILS.

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 DIVISION OF THE ATTORNEY GENERAL OF THE STATE OF SOUTH CAROLINA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
06/08/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 06025
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SECURITIES DIVISION OF THE ATTORNEY GENERAL OF THE STATE OF SOUTH CAROLINA CHARGED DEUTSCHE BANK SECURITIES INC. ("DBSI") WITH
VIOLATIONS OF SOUTH CAROLINA ACT 35-1-412(D)(13), 35-1-412(D)(9), AND 35-1-411(D) IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST
WITH RESPECT TO ITS RESEARCH ANALYSTS, ISSUANCE OF RESEARCH REPORTS AFFECTED BY CONFLICTS OF INTEREST, MAKING PAYMENTS FOR
RESEARCH, FAILURE TO DISCLOSE RECEIPT OF PAYMENTS FOR RESEARCH, AND FAILURE TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS
AND PROCEDURES FOR SUPERVISION AND CONTROL TO DETECT AND PREVENT SUCH 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:
Consent
11. Resolution Date (MM/DD/YYYY):
06/16/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 355,499.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI PAID $355,499 TO SOUTH CAROLINA ON 6/13/2006. THIS AMOUNT IS PART OF A GLOBAL SETTLEMENT PREVIOUSLY DISCLOSED BY DBSI ON
10/13/04.
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 ALLEGATIONS, DBSI AGREED TO THE ENTRY OF AN ADMINISTRATIVE CONSENT ORDER WITH THE SECURITIES
DIVISION OF THE ATTORNEY GENERAL OF THE STATE OF SOUTH CAROLINA. DBSI WAS SUBJECT TO A CEASE AND DESIST ORDER, AND PAID $355,499
TO SOUTH CAROLINA ON 6/13/2006. THIS AMOUNT IS PART OF A GLOBAL SETTLEMENT PREVIOUSLY DISCLOSED BY DBSI ON 10/13/04. THE SECURITIES
DIVISION OF THE ATTORNEY GENERAL OF THE STATE OF SOUTH CAROLINA CHARGED DBSI WITH VIOLATIONS OF SOUTH CAROLINA ACT 35-1-412(D)
(13), 35-1-412(D)(9), AND 35-1-411(D) IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST WITH RESPECT TO ITS RESEARCH ANALYSTS,
ISSUANCE OF RESEARCH REPORTS AFFECTED BY CONFLICTS OF INTEREST, MAKING PAYMENTS FOR RESEARCH, FAILURE TO DISCLOSE RECEIPT OF
PAYMENTS FOR RESEARCH, AND FAILURE TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS AND PROCEDURES FOR SUPERVISION AND
CONTROL TO DETECT AND PREVENT SUCH 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) 
TENNESSEE SECURITIES DIVISION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
05/24/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 05-005
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE TENNESSEE SECURITIES DIVISION CHARGED DBSI WITH VIOLATIONS OF TENNESSEE CODE ANNOTATED 48-2-112(A)(2)(G), 48-2-112(A)92)(J), AND
48-2-111 IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST WITH RESPECT TO ITS RESEARCH ANALYSTS AND INVESTMENT BANKING BUSINESS,
THE ALLEGED FAILURE TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES AND PROCEDURES TO MANAGE THESE CONFLICTS OF INTEREST, AND THE
ALLEGED FAILURE TO PROMPTLY PRODUCE E-MAIL COMMUNICATIONS.
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):
06/26/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 504,120.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI PAID $504,120 TO TENNESSEE ON 5/30/06. THIS AMOUNT IS PART OF A GLOBAL SETTLEMENT PREVIOUSLY DISCLOSED BY DBSI ON
10/13/04.
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 ALLEGATIONS, DBSI AGREED TO THE ENTRY OF AN ADMINISTRATIVE CONSENT ORDER WITH THE TENNESEEE
SECURITIES DIVISION. DBSI WAS SUBJECT TO A CEASE AND DESIST ORDER, AND PAID $504,120 TO TENNESSEE ON 5/30/06. THIS AMOUNT IS PART OF
A GLOBAL SETTLEMENT PREVIOUSLY DISCLOSED BY DBSI ON 10/13/04. ADDITIONALLY, UNDER THE GLOBAL SETTLEMENT, DBSI AGREED TO
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES. THE TENNESSEE SECURITIES DIVISION CHARGED DBSI WITH VIOLATIONS OF TENNESSEE CODE ANNOTATED 48-2-112(A)(2)(G),
48-2-112(A)92)(J), AND 48-2-111 IN CONNECTION WITH ALLEGED CONFLICTS OF INTEREST WITH RESPECT TO ITS RESEARCH ANALYSTS AND
INVESTMENT BANKING BUSINESS, THE ALLEGED FAILURE TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES AND PROCEDURES TO MANAGE THESE
CONFLICTS OF INTEREST, AND THE ALLEGED FAILURE TO PROMPTLY PRODUCE E-MAIL COMMUNICATIONS.

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) 
CHICAGO BOARD OF TRADE ("CBOT")

2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/02/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2006-INV-12E
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
U.S. TREASURY NOTES FUTURES CONTRACTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JULY 20, 2006, THE CHICAGO BOARD OF TRADE ("CBOT") FLOOR GOVERNORS COMMITTEE CHARGED DBSI WITH HAVING VIOLATED CBOT
REGULATION 9B.13 IN THAT ITS EMPLOYEES ENGAGED IN PREEXECUTION CONVERSATIONS AND FAILED TO ENTER CROSS TRADES IN ACCORDANCE
WITH REQUIRED TIME PARAMETERS AND PROCEDURES. THE CBOT SIMULTANEOUSLY ACCEPTED DBSI'S OFFER OF SETTLEMENT IN WHICH, WITHOUT
ADMITTING OR DENYING THE ALLEGATIONS SET FORTH IN THE COMPLAINT, DBSI AGREED TO PAY A FINE OF $25,000.
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):
07/20/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 25,000.00
 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 FINE OF $25,000.00 WAS PAID ON 8/7/06.
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).

DRP Pages

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) 
ILLINOIS SECURITIES DEPARTMENT
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 

07/20/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE NO. 0600247
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE ILLINOIS SECURITIES DEPARTMENT CHARGED DBSI WITH VIOLATIONS OF 8.E(1)(B) OF THE ILLINOIS SECURITIES LAW OF 1953, AS AMENDED,
(THE "ACT") IN CONNECTION WITH ALLEGED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, FAILURE TO MANAGE
SUCH CONFLICTS, PUBLICATION OF EXAGGERATED, UNWARRANTED, AND UNREASONABLE RATINGS ON CERTAIN STOCKS, RECEIPT AND MAKING OF
PAYMENTS THAT INCLUDED RESEARCH COVERAGE AND THE FAILURE TO DISCLOSE THOSE PAYMENTS. DBSI ALSO WAS CHARGED WITH VIOLATIONS OF
8.E(1)(E)(IV) OF THE ACT IN CONNECTION WITH THE ALLEGED FAILURE TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES AND PROCEDURES, AND
THE ALLEGED FAILURE TO FULLY AND COMPLETELY RESPOND TO E-MAIL PRODUCTION REQUESTS.
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):
07/20/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 1,100,459.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI PAID $1,100,459 TO ILLINOIS ON 7/12/06. THIS AMOUNT IS PART OF A GLOBAL SETTLEMENT PREVIOUSLY DISCLOSED BY DBSI ON
10/13/04.
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 ALLEGATIONS, DBSI AGREED TO THE ENTRY OF AN ADMINISTRATIVE CONSENT ORDER WITH THE STATE OF
ILLINOIS SECRETARY OF STATE, SECURITIES DEPARTMENT. DBSI WAS SUBJECT TO A CEASE AND DESIST ORDER, AND PAID $1,100,459 TO ILLINOIS ON
7/12/06. THIS AMOUNT IS PART OF A GLOBAL SETTLEMENT PREVIOUSLY DISCLOSED BY DBSI ON 10/13/04. ADDITIONALLY, UNDER THE GLOBAL
SETTLEMENT, DBSI AGREED TO UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY
DISCLOSURES TO BE INCLUDED IN RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF
INDEPENDENT, THIRD-PARTY RESEARCH SERVICES. THE ILLINOIS SECURITIES DEPARTMENT CHARGED DBSI WITH VIOLATIONS OF 8.E(1)(B) OF THE
ILLINOIS SECURITIES LAW OF 1953, AS AMENDED, (THE "ACT") IN CONNECTION WITH ALLEGED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING
OVER RESEARCH ANALYSTS, FAILURE TO MANAGE SUCH CONFLICTS, PUBLICATION OF EXAGGERATED, UNWARRANTED, AND UNREASONABLE RATINGS
ON CERTAIN STOCKS, RECEIPT AND MAKING OF PAYMENTS THAT INCLUDED RESEARCH COVERAGE AND THE FAILURE TO DISCLOSE THOSE PAYMENTS.
DBSI ALSO WAS CHARGED WITH VIOLATIONS OF 8.E(1)(E)(IV) OF THE ACT IN CONNECTION WITH THE ALLEGED FAILURE TO ESTABLISH AND MAINTAIN
ADEQUATE POLICIES AND PROCEDURES, AND THE ALLEGED FAILURE TO FULLY AND COMPLETELY RESPOND TO E-MAIL PRODUCTION REQUESTS.

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

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
STATE OF OKLAHOMA DEPARTMENT OF SECURITIES
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
07/31/2006
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
ODS FILE NO.05-058
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF OKLAHOMA DEPARTMENT OF SECURITIES CHARGED DBSI WITH VIOLATIONS OF PREDECESSOR ACT AND/OR THE RULES OF THE
OKLAHOMA SECURITIES COMMISSION AND THE ADMINISTRATOR OF THE DEPARTMENT OF SECURITIES IN CONNECTION WITH ALLEGED INAPPROPRIATE
INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, FAILURE TO MANAGE SUCH CONFLICTS, FAILURE TO ESTABLISH AND MAINTAIN
ADEQUATE POLICIES AND PROCEDURES, AND FAILURE TO PROMPTLY PRODUCE REQUESTED E-MAIL COMMUNICATIONS.
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):
10/12/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 305,758.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI PAID $305,758 TO OKLAHOMA ON 8/02/06. THIS AMOUNT IS PART OF A GLOBAL SETTLEMENT PREVIOUSLY DISCLOSED BY DBSI ON
10/13/04.
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 ALLEGATIONS, DBSI AGREED TO THE ENTRY OF AN ADMINISTRATIVE CONSENT ORDER WITH STATE OF
OKLAHOMA DEPARTMENT OF SECURITIES. DBSI WAS SUBJECT TO A CEASE AND DESIST ORDER, AND PAID $305,758 TO OKLAHOMA ON 8/02/06. THIS
AMOUNT IS PART OF A GLOBAL SETTLEMENT PREVIOUSLY DISCLOSED BY DBSI ON 10/13/04. ADDITIONALLY, UNDER THE GLOBAL SETTLEMENT, DBSI
AGREED TO UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE
INCLUDED IN RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-
PARTY RESEARCH SERVICES. THE STATE OF OKLAHOMA DEPARTMENT OF SECURITIES CHARGED DBSI WITH VIOLATIONS OF PREDECESSOR ACT AND/OR
THE RULES OF THE OKLAHOMA SECURITIES COMMISSION AND THE ADMINISTRATOR OF THE DEPARTMENT OF SECURITIES IN CONNECTION WITH
ALLEGED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, FAILURE TO MANAGE SUCH CONFLICTS, FAILURE TO
ESTABLISH AND MAINTAIN ADEQUATE POLICIES AND PROCEDURES, FAILURE TO PROMPTLY PRODUCE REQUESTED E-MAIL COMMUNICATIONS.

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

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.

Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
STATE OF LOUISIANA OFFICE OF FINANCIAL INSTITUTIONS SECURITIES DIVISION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
07/31/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF LOUISIANA OFFICE OF FINANCIAL INSTITUTIONS SECURITIES DIVISION CHARGED DBSI WITH VIOLATIONS OF THE LOUISIANA
SECURITIES LAW IN CONNECTION WITH ALLEGED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS, FAILURE TO
MANAGE SUCH CONFLICTS, FAILURE TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES AND PROCEDURES, AND FAILURE TO PROMPTLY PRODUCE
REQUESTED E-MAIL COMMUNICATIONS.
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):
10/19/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 395,990.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI PAID $395,990 TO LOUISIANA ON 8/02/06. THIS AMOUNT IS PART OF A GLOBAL SETTLEMENT PREVIOUSLY DISCLOSED BY DBSI ON
10/13/04.
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 ALLEGATIONS, DBSI AGREED TO THE ENTRY OF AN ADMINISTRATIVE ORDER BY THE OFFICE OF FINANCIAL
INSTITUTIONS SECURITIES DIVISION. DBSI WAS SUBJECT TO A CEASE AND DESIST ORDER, AND PAID $395,990 TO LOUISIANA ON 8/02/06. THIS
AMOUNT IS PART OF A GLOBAL SETTLEMENT PREVIOUSLY DISCLOSED BY DBSI ON 10/13/04. ADDITIONALLY, UNDER THE GLOBAL SETTLEMENT, DBSI
AGREED TO UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE
INCLUDED IN RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-
PARTY RESEARCH SERVICES.

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

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

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NASD
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
12/15/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2005001465501
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
EQUITY TRADE REPORTING (OATS)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NASD ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED NASD MARKETPLACE RULE 6955(A) IN THAT DBSI SUBMITTED TO OATS
INCORRECT "ORDER SENT" TIMESTAMPS FOR ORDERS ROUTED TO ITS AFFILIATES, DBPR AND DBPT. AS A RESULT OF THE INACCURATE TIMESTAMPS,

THE ROUTE REPORTS FAILED TO MATCH DBPR'S OR DBPT'S NEW ORDER REPORTS.
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):
12/15/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 25,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND A FINE OF $25,000.00 (THE FINE WAS PAID ON 1/5/2007).
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), CONSENTING TO A
CENSURE AND FINE OF $25,000.00

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) 
NYSE ARCA, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
12/07/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE NO. 06-17
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBSI SETTLED A DISCIPLINARY ACTION BY NYSE ARCA ALLEGING THAT BETWEEN APRIL 4, 2005
AND JUNE 16, 2005, DBSI FAILED TO AGGREGATE ODD LOT ORDERS INTO ROUND LOTS AS REQUIRED BY NYSE ARCA EQUITIES RULES 7.38(C) AND
6.2(B), FAILED TO EXERCISE SUFFICIENT DUE DILIGENCE TO LEARN ESSENTIAL FACTS RELATING TO SUCH ORDERS AS REQUIRED BY NYSE ARCA
EQUITIES RULE 9.2(A), FAILED TO DILIGENTLY SUPERVISE A CUSTOMER ACCOUNT IN CONNECTION WITH SUCH ORDERS AS REQUIRED BY NYSE ARCA
EQUITIES RULE 9.2(B), AND FAILED TO SUPERVISE ITS BUSINESS OPERATIONS AND ASSOCIATED PERSONS IN CONNECTION WITH SUCH ORDERS AND
ACCOUNT AS REQUIRED BY NYSE ARCA EQUITIES RULE 6.18(A). DBSI WAS CENSURED AND FINED $200,000. NYSE ARCA INFORMED DBSI OF THE
DECEMBER 7, 2006 FINAL DECISION IN THIS MATTER ON DECEMBER 12, 2006.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision & Order of Offer of Settlement

11. Resolution Date (MM/DD/YYYY):
12/07/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 200,000.00
 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: 
DBSI CONSENTED TO A DECISION AND ORDER OF OFFER OF SETTLEMENT, A CENSURE AND A FINE OF $200,000.00 (THE FINE WAS PAID ON
1/5/07).
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 ALLEGATIONS, DBSI SETTLED A DISCIPLINARY ACTION BY NYSE ARCA ALLEGING THAT BETWEEN APRIL 4, 2005
AND JUNE 16, 2005, DBSI FAILED TO AGGREGATE ODD LOT ORDERS INTO ROUND LOTS AS REQUIRED BY NYSE ARCA EQUITIES RULES 7.38(C) AND
6.2(B), FAILED TO EXERCISE SUFFICIENT DUE DILIGENCE TO LEARN ESSENTIAL FACTS RELATING TO SUCH ORDERS AS REQUIRED BY NYSE ARCA
EQUITIES RULE 9.2(A), FAILED TO DILIGENTLY SUPERVISE A CUSTOMER ACCOUNT IN CONNECTION WITH SUCH ORDERS AS REQUIRED BY NYSE ARCA
EQUITIES RULE 9.2(B), AND FAILED TO SUPERVISE ITS BUSINESS OPERATIONS AND ASSOCIATED PERSONS IN CONNECTION WITH SUCH ORDERS AND
ACCOUNT AS REQUIRED BY NYSE ARCA EQUITIES RULE 6.18(A). DBSI WAS CENSURED AND FINED $200,000. NYSE ARCA INFORMED DBSI OF THE FINAL
DECEMBER 7, 2006 DECISION IN THIS MATTER ON DECEMBER 12, 2006.

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) 
CHICAGO BOARD OF TRADE ("CBOT")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/14/2006
 Exact
 Explanation
If not exact, provide explanation:
DATE OF FAX RECEIVED FROM CBOT
4.
Docket/Case Number:
06-RFT-024
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DBSI PAID A $2,000 FINE TO RESOLVE THE CHICAGO BOARD OF TRADE'S PRELIMINARY CONCLUSION THAT DBSI HAD VIOLATED REGULATION 465.01 BY
FAILING TO ENTER ORDER ENTRY TIME STAMPS ON 21 CUSTOMER ORDERS DURING THE PERIOD FROM JUNE 1, 2006 AND JUNE 8, 2006. CBOT
ATTEMPTED TO INFORM DBSI OF THIS PRELIMINARY CONCLUSION BY AN INCORRECTLY ADDRESSED LETTER DATED NOVEMBER 2, 2006. DBSI DID NOT
RECEIVE CBOT'S NOVEMBER 2, 2006 LETTER UNTIL DECEMBER 14, 2006. DBSI PAID THE $2,000 FINE ON JANUARY 8, 2007.
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):
12/14/2006
 Exact
 Explanation
If not exact, provide explanation:
DATE OF FAX RECEIVED FROM CBOT
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 2,000.00

 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: 
DBSI CONSENTED TO A FINE OF $2,000 (THE FINE WAS PAID ON JANUARY 8, 2007).
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, DBSI PAID A $2,000 FINE TO RESOLVE THE CHICAGO BOARD OF TRADE'S PRELIMINARY CONCLUSION THAT DBSI
HAD VIOLATED REGULATION 465.01 BY FAILING TO ENTER ORDER ENTRY TIME STAMPS ON 21 CUSTOMER ORDERS DURING THE PERIOD FROM JUNE 1,
2006 AND JUNE 8, 2006. CBOT ATTEMPTED TO INFORM DBSI OF THIS PRELIMINARY CONCLUSION BY AN INCORRECTLY ADDRESSED LETTER DATED
NOVEMBER 2, 2006. DBSI DID NOT RECEIVE CBOT'S NOVEMBER 2, 2006 LETTER UNTIL DECEMBER 14, 2006.

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE INVESTMENT
MANAGEMENT AMERICAS INC.
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE ASSET
MANAGEMENT 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 EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURE, DISGORGEMENT AND PENALTY
3.
Date Initiated (MM/DD/YYYY): 
12/21/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 3-12514
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):
ON DECEMBER 21, 2006 THE SEC INSTITUTED AND SETTLED AN ADMINISTRATIVE PROCEEDING AGAINST DEUTSCHE BANK SECURITIES INC. ("DBSI") IN
CONNECTION WITH DBSI'S ALLEGED FAILURE TO PROPERLY SUPERVISE ONE OF ITS FORMER REGISTERED REPRESENTATIVES WHO HAD ENGAGED IN
DECEPTIVE MARKET TIMING OF MUTUAL FUND SHARES IN CLIENT ACCOUNTS. THE SEC FURTHER ALLEGED THAT DBSI, THROUGH THE CONDUCT OF THE
FORMER REGISTERED REPRESENTATIVE, VIOLATED RULE 22C-1(A), AS ADOPTED UNDER SECTION 22(C) OF THE INVESTMENT COMPANY ACT OF 1940 BY
THE CONDUCT OF THE FORMER REGISTERED REPRESENTATIVE ENTERING LATE TRADES FOR AT LEAST ONE CUSTOMER. THE SEC ALLEGED THAT THE
FORMER REGISTERED REPRESENTATIVE RECEIVED AND ENTERED ORDERS TO PURCHASE, REDEEM OR EXCHANGE MUTUAL FUND SHARES AFTER THE
4:00 P.M. EASTERN TIME MARKET CLOSE ON CERTAIN OCCASIONS WHERE CUSTOMER ORDERS RECEIVED BEFORE 4:00 P.M. WERE BLOCKED BY FUND
COMPANIES AS MARKET TIMING TRADES. THE CUSTOMER ORDERS ENTERED INTO AFTER 4:00 P.M. SERVED AS SUBSTITUTE ORDERS FOR THOSE THAT
HAD BEEN PREVIOUSLY RECEIVED AND BLOCKED BEFORE 4:00 P.M. THE SEC ALSO ALLEGED THAT DBSI VIOLATED SECTION 15(B)(4)(E) OF THE
EXCHANGE ACT BECAUSE IT ALLEGEDLY FAILED TO PROPERLY SUPERVISE THE FORMER REGISTERED REPRESENTATIVE WHO HAD ENGAGED IN THE
CONDUCT. ON DECEMBER 21, 2006 THE SEC ALSO ISSUED AN ORDER UNDER RULE 602(E) OF THE SECURITIES ACT OF 1933 ON BEHALF OF DEUTSCHE
ASSET MANAGEMENT, INC., DEUTSCHE INVESTMENT MANAGEMENT AMERICAS, INC., AND DEUTSCHE BANK SECURITIES INC., GRANTING A WAIVER OF
THE DISQUALIFICATION PROVISION OF RULE 602(C)(3).
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled

11. Resolution Date (MM/DD/YYYY):
12/21/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 442,954.00
 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 FINE OF $442,954 WAS PAID ON JANUARY 19, 2007
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 SEC'S ALLEGATIONS OR FINDINGS, DBSI AGREED TO TOTAL PAYMENT OF $442,954, CONSISTING OF $202,835
IN DISGORGEMENT, $202,835 IN CIVIL PENALTY, AND $37,284 IN PREJUDGMENT INTEREST.

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE INVESTMENT
MANAGEMENT AMERICAS INC.
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual

Registered:
Yes
No
Name:
DEUTSCHE ASSET
MANAGEMENT, 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) 
ATTORNEY GENERAL OF THE STATE OF NEW YORK BUREAU OF INVESTMENT PROTECTION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
12/21/2006
 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:
Mutual Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DEUTSCHE INVESTMENT MANAGEMENT AMERICAS INC. ("DIMA"), AND DEUTSCHE ASSET MANAGEMENT, INC. ("DAMI") SERVE AS INVESTMENT ADVISORS
TO THE DWS SCUDDER FUNDS. THE NYAG ALLEGED DIMA AND DAMI BREACHED THEIR FIDUCIARY DUTY TO CERTAIN DWS SCUDDER FUNDS BY FAILING
TO EFFECTIVELY LIMIT TRADING ACTIVITY IN DWS SCUDDER FUNDS. THE NYAG ALSO ALLEGED THAT DIMA AND DAMI BREACHED THEIR FIDUCIARY DUTY
TO CERTAIN DWS SCUDDER FUNDS BY ENTERING INTO MARKET TIMING ARRANGEMENTS WITH INVESTORS. THE NYAG ALLEGED THAT DEUTSCHE BANK
SECURITIES INC. ("DBSI"), THROUGH THE ACTIVITY OF ONE OF ITS REGISTERED REPRESENTATIVES, FACILITATED MARKET TIMING AND A FORM OF LATE
TRADING BY A CLIENT. THE NYAG ALLEGED THAT THE FORMER REGISTERED REPRESENTATIVE RECEIVED AND ENTERED ORDERS TO PURCHASE, REDEEM
OR EXCHANGE MUTUAL FUND SHARES AFTER THE 4:00PM EASTERN TIME MARKET CLOSE ON CERTAIN OCCASIONS WHERE CUSTOMER ORDERS
RECEIVED BEFORE 4:00PM WERE BLOCKED BY FUND COMPANIES AS MARKET TIMING TRADES. THE CUSTOMER ORDERS ENTERED INTO AFTER 4:00PM
SERVED AS SUBSTITUTE ORDERS FOR THOSE THAT HAD BEEN PREVIOUSLY RECEIVED AND BLOCKED BEFORE 4:00PM.
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):
12/21/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 20,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
DIMA AND DAMI ARE SUBJECT TO CERTAIN UNDERTAKINGS REGARDING THE CONDUCT OF THEIR BUSINESS IN THE FUTURE, INCLUDING:
FORMATION OF A CODE OF ETHICS OVERSIGHT COMMITTEE TO OVERSEE ALL MATTERS RELATING TO ISSUES ARISING UNDER DIMA'S AND DAMI'S
CODE OF ETHICS; ESTABLISHMENT OF AN INTERNAL COMPLIANCE CONTROLS COMMITTEE HAVING OVERALL COMPLIANCE OVERSIGHT
RESPONSIBILITY OF DIMA AND DAMI; ENGAGEMENT OF AN INDEPENDENT COMPLIANCE CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW
OF DIMA AND DAMI'S SUPERVISORY, COMPLIANCE, AND OTHER POLICIES AND PROCEDURES DESIGNED TO PREVENT AND DETECT BREACHES OF
FIDUCIARY DUTY, BREACHES OF THE CODE OF ETHICS, AND FEDERAL SECURITIES LAW VIOLATIONS BY DIMA AND DAMI AND THEIR EMPLOYEES;
AND COMMENCING IN 2008, DIMA AND DAMI SHALL UNDERGO A COMPLIANCE REVIEW BY AN INDEPENDENT THIRD PARTY.
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 FINE WILL BE PLACED INTO ESCROW ON OR ABOUT JANUARY 31, 2007.
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 ALLEGATIONS, DIMA, DAMI, AND DBSI AGREED TO PAY, JOINTLY AND SEVERALLY, $102.3 MILLION IN
DISGORGEMENT. DIMA AND DAMI ALSO AGREED TO PAY $20 MILLION IN A CIVIL PENALTY. THE ENTIRE AMOUNT OF $123.3 MILLION IS TO BE
DISTRIBUTED FOR THE BENEFIT OF THE SHAREHOLDERS OF THE AFFECTED DWS SCUDDER FUNDS.

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) 
NEW YORK STOCK EXCHANGE
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURE, DISGORGEMENT AND PENALTY
3.
Date Initiated (MM/DD/YYYY): 
12/18/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
DECISION 06-157
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):
ON DECEMBER 21, 2006 THE NYSE INSTITUTED AND SETTLED A DISCIPLINARY PROCEEDING AGAINST DEUTSCHE BANK SECURITIES INC. ("DBSI") IN
CONNECTION WITH DBSI'S ALLEGED VIOLATIONS OF NYSE RULES 401 AND 476(A)(6) FOR FAILURE TO ADHERE TO PRINCIPLES OF GOOD BUSINESS
PRACTICE AND ENGAGING IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE IN CONNECTION WITH HAVING VIOLATED
RULE 22C-1, AS ADOPTED UNDER SECTION 22(C) OF THE INVESTMENT COMPANY ACT OF 1940. THE NYSE ALLEGED THAT DBSI VIOLATED THE ABOVE
CITED RULES BY THE CONDUCT OF A DBSI FORMER REGISTERED REPRESENTATIVE WHO ENTERED LATE TRADES FOR AT LEAST ONE CUSTOMER. MORE
SPECIFICALLY, THE NYSE ALLEGED THAT THE REGISTERED REPRESENTATIVE RECEIVED AND ENTERED ORDERS TO PURCHASE, REDEEM OR EXCHANGE
MUTUAL FUND SHARES AFTER THE 4:00 P.M. EASTERN TIME MARKET CLOSE ON CERTAIN OCCASIONS WHERE CUSTOMER ORDERS RECEIVED BEFORE
4:00 P.M. WERE BLOCKED BY FUND COMPANIES AS MARKET TIMING TRADES. THE CUSTOMER ORDERS ENTERED INTO AFTER 4:00 P.M. SERVED AS
SUBSTITUTE ORDERS FOR THOSE THAT HAD BEEN PREVIOUSLY RECEIVED AND BLOCKED BEFORE 4:00 P.M. THE NYSE FURTHER ALLEGED THAT DBSI
VIOLATED NYSE RULE 342 BY FAILING TO REASONABLY SUPERVISE THE REGISTERED REPRESENTATIVE AND FAILING TO ESTABLISH AND MAINTAIN
APPROPRIATE PROCEDURES FOR SUPERVISION AND CONTROL EFFECTIVE TO DETECT AND PREVENT THE REGISTERED REPRESENTATIVE'S DECEPTIVE
CUSTOMER TRADING OF MUTUAL FUNDS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled

11. Resolution Date (MM/DD/YYYY):
12/18/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 442,954.00
 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 VIEW OF THE ABOVE FINDINGS, THE NYSE IMPOSED THE PENALTY CONSENTED TO BY DBSI OF A CENSURE AND A TOTAL PAYMENT IN THE
AMOUNT OF $442,954. PAYMENT OF THE $442,954 BY DBSI PURSUANT TO AN ORDER ISSUED IN A RELATED SEC PROCEEDING AGAINST DBSI
SHALL BE DEEMED PAYMENT IN SATISFACTION OF THE NYSE STIPULATION AND CONSENT.
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).
DBSI, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, CONSENTED TO CENSURE AND TOTAL PAYMENT OF $442,954.

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

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any

event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
STATE OF NEW YORK, OFFICE OF THE ATTORNEY GENERAL
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
10/26/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE ATTORNEY GENERAL OF THE STATE OF NEW YORK CHARGED DBSI WITH VIOLATIONS OF THE GENERAL BUSINESS LAW OF THE STATE OF NEW YORK
(THE "MARTIN ACT") IN CONNECTION WITH ALLEGED CREATION OF CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS AS A RESULT OF ITS
RESEARCH STRUCTURE, ALLEGED FAILURE TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES AND PROCEDURES REASONABLY DESIGNED TO MANAGE
THESE CONFLICTS OF INTEREST, ALLEGED PUBLICATION OF EXAGGERATED OR UNWARRANTED RESEARCH, AND ALLEGED FAILURE TO PROMPTLY
PRODUCE COPIES OF E-MAIL COMMUNICATIONS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
12/01/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 1,681,482.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension

B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI PAID $1,681,482 TO THE NEW YORK STATE DEPARTMENT OF LAW ON 11/16/06. THIS AMOUNT IS PART OF A GLOBAL SETTLEMENT
PREVIOUSLY DISCLOSED BY DBSI ON 10/13/04.
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 ALLEGATIONS, DBSI AGREED TO ENTER INTO AN ASSURANCE OF DISCONTINUANCE WITH THE ATTORNEY
GENERAL OF THE STATE OF NEW YORK. DBSI WAS SUBJECT TO A CEASE AND DESIST ORDER, AND PAID $1,681,482 TO THE NEW YORK STATE
DEPARTMENT OF LAW ON 11/16/2006. THIS AMOUNT IS PART OF A GLOBAL SETTLEMENT PREVIOUSLY DISCLOSED BY DBSI ON 10/13/04.
ADDITIONALLY, UNDER THE GLOBAL SETTLEMENT, DBSI AGREED TO UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND
INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS
AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY RESEARCH SERVICES.

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

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

 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
STATE OF MISSOURI, OFFICE OF THE SECRETARY OF STATE, COMMISSIONER OF SECURITIES
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
10/26/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE NO. AP-06-49
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF MISSOURI COMMISSIONER OF SECURITIES CHARGED DBSI WITH VIOLATIONS OF SECTIONS 409.204(A)(2)(G) AND 409.204(A)(2)(J) OF
THE MISSOURI REVISED STATUTES IN CONNECTION WITH ALLEGED FAILURE TO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY
INSULATED FROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING AND ALLEGED FAILURE TO REASONABLY
SUPERVISE ITS EMPLOYEES TO ENSURE THAT ITS ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELY INSULATED FROM PRESSURES AND
INFLUENCES FROM COVERED COMPANIES AND INVESTMENT BANKING.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
11/03/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 495,785.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI PAID $495,785 TO THE SECRETARY OF THE STATE OF MISSOURI ON 10/27/06. THIS AMOUNT IS PART OF A GLOBAL SETTLEMENT DISCLOSED
BY DBSI ON 10/13/04.
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 ALLEGATIONS, DBSI AGREED TO THE ENTRY OF AN ADMINISTRATIVE ORDER BY THE COMMISSIONER OF
SECURITIES. DBSI WAS SUBJECT TO A CEASE AND DESIST ORDER, AND PAID $495,785 TO THE SECRETARY OF STATE OF THE STATE OF MISSOURI ON
10/27/06. THIS AMOUNT IS PART OF A GLOBAL SETTLEMENT PREVIOUSLY DISCLOSED BY DBSI ON 10/13/04. ADDITIONALLY, UNDER THE GLOBAL
SETTLEMENT, DBSI AGREED TO UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY
DISCLOSURES TO BE INCLUDED IN RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF
INDEPENDENT, THIRD-PARTY RESEARCH SERVICES.

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 COMMISSIONER OF MARYLAND
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
10/26/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
SECURITIES DIVISION NO. 2002-0894
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SECURITIES COMMISSIONER OF MARYLAND CHARGED DBSI WITH VIOLATIONS OF SECTION 11-412(A)(7) OF THE MARYLAND SECURITIES ACT IN
CONNECTION WITH ALLEGED CREATION AND/OR MAINTENANCE OF INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCH ANALYSTS,
THE IMPOSITION OF AND FAILURE TO MANAGE CONFLICTS OF INTEREST FOR ITS RESEARCH ANALYSTS, ISSUANCE OF EXAGGERATED OR UNWARRANTED
RESEARCH, INAPPROPRIATE USE OF RESEARCH COVERAGE, AND FAILURE TO DISCLOSE COMPENSATION FOR INAPPROPRIATELY ISSUING AND
RECEIVING RESEARCH REPORTS. DBSI WAS ALSO CHARGED WITH VIOLATIONS OF SECTION 11-412(A)(10) FOR ALLEGEDLY FAILING TO ESTABLISH AND
ENFORCE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ENSURE THAT ANALYSTS WERE NOT UNDUELY INFLUENCED BY
INVESTMENT BANKING.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/30/2007
 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: $ 469,315.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN
RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY
RESEARCH SERVICES.
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: 
DBSI PAID $469,315 TO THE SECURITIES DIVISION OF THE OFFICE OF THE ATTORNEY GENERAL OF THE STATE OF MARYLAND ON 12/8/06. THIS
AMOUNT IS PART OF A GLOBAL SETTLEMENT PREVIOUSLY DISCLOSED BY DBSI ON 10/13/04.
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 ALLEGATIONS, DBSI CONSENTED TO THE ENTRY OF AN ADMINISTRATIVE CONSENT ORDER BY THE SECURITIES
COMMISSIONER. DBSI WAS SUBJECT TO A CEASE AND DESIST ORDER, AND PAID $469,315 TO THE SECURITIES DIVISION OF THE OFFICE OF THE
ATTORNEY GENERAL OF THE STATE OF MARYLAND ON 12/8/06. THIS AMOUNT IS PART OF A GLOBAL SETTLEMENT PREVIOUSLY DISCLOSED BY DBSI ON
10/13/04. ADDITIONALLY, UNDER THE GLOBAL SETTLEMENT, DBSI AGREED TO UNDERTAKINGS WITH RESPECT TO THE SEPARATION OF RESEARCH AND
INVESTMENT BANKING; MANDATORY DISCLOSURES TO BE INCLUDED IN RESEARCH REPORTS AND TRANSPARENCY OF RESEARCH ANALYSTS' RATINGS
AND PROJECTIONS; AND THE USE OF INDEPENDENT, THIRD-PARTY RESEARCH SERVICES.

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) 
NEW YORK STOCK EXCHANGE ("NYSE")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)

(
)
( )
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/03/2004
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
06-218
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
BOND INDICES, PRIME BROKERAGE
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DBSI VIOLATED NYSE RULE 342 BY FAILING TO SUPERVISE AN EMPLOYEE WHO USED AND DISTRIBUTED CONFIDENTIAL AND PROPRIETARY
INFORMATION OF A FORMER EMPLOYER. DBSI VIOLATED NYSE RULE123C BY FAILING TO REASONABLY SUPERVISE MOC/LOC AND AUDIT TRAIL
ACTIVITIES, NYSE RULE 401 REGARDING THE REQUIREMENTS FOR MAINTAINING PRIME BROKERAGE ACCOUNTS AND FAILING TO TIMELY NOTIFY NYSE
OF TERMINATION OF FLOOR EMPLOYEES AND TIMELY RETURN FLOOR BADGES OF TERMINATED FLOOR EMPLOYEES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/15/2007
 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: $ 325,000.00
 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 FINE OF $325,000.00 WILL BE PAID.
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).
WEI WU WAS EMPLOYED BY DBSI IN ITS INDEX DEVELOPMENT GROUP FROM ON OR ABOUT AUGUST 20, 2001 THROUGH ON OR ABOUT APRIL 11, 2003.
IT IS ALLEGED THAT DBSI FAILED TO REASONABLY SUPERVISE WU'S ACCESSING AND USING HIS FORMER MEMBER FIRM EMPLOYER'S PASSWORD
PROTECTED INFORMATION. WU UTILIZED HIS FORMER EMPLOYER'S RESEARCH REPORTS AND BOND INDICES DATA ON MORE THAN 200 OCCASIONS.
WU WAS SUPERVISED BY AN INDIVIDUAL WORKING OUT OF LONDON EMPLOYED BY A NON-MEMBER FIRM, DEUTSCHE BANK AG. DBSI FAILED TO
REASONABLY SUPERVISE WU IN VIOLATION OF NYSE RULE 342. RULE 342. DBSI ALSO VIOLATED NYSE RULE 342 BY FAILING TO REASONABLY
SUPERVISE AND CONTROL ITS COMPLIANCE WITH MARKET ON CLOSE (" MOC"), LIMIT ON CLOSE("LOC"), AUDIT TRAIL AND PRIME BROKERAGE
REPORTING REQUIREMENTS. AT VARIOUS TIMES IN 2003, 2004 AND 2006, DBSI FAILED TO COMPLY WITH NYSE REQUIREMENTS GOVERNING THE ENTRY
AND CANCELLATION OF CERTAIN MOC/LOC ORDERS AND VIOLATED NYSE RULE 132 BY ALLOWING A CLIENT TO SUBMIT, THROUGH THE FIRM OR USING
MACHINERY IDENTIFIED WITH THE FIRM, NUMEROUS ORDERS THROUGH SUPERDOT WITHOUT ACCOUNT TYPE INDICATOR AND INACCURATE ACCOUNT
TYPE INDICATORS, BY FAILING TO BY FAILING TO OBTAIN AND MAINTAIN CERTAIN CUSTOMER AGREEMENTS IN ITS CAPACITY AS PRIME BROKER AND BY
FAILING TO REQUIRE CUSTOMERS TO MAINTAIN MINIMUM NET EQUITY IN SIX PRIME BROKERAGE ACCOUNTS. THE FIRM ALSO FAILED TO NOTIFY NYSE'S
SECURITY OFFICE OF THE TERMINATION OF NINE FLOOR PERSONNEL WITHIN THE REQUIRED TIME AND FAILED TO RETURN FLOOR BADGES FOR EIGHT

FLOOR PERSONNEL WITHIN THE REQUIRED TIMEFRAME IN VIOLATION OF NYSE RULE 401 AND NYSE INFORMATION MEMO 99-20.

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) 
NEW YORK STOCK EXCHANGE INC. ("NYSE")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/18/2004
 Exact
 Explanation
If not exact, provide explanation:

MATTER SELF REPORTED - ON OR ABOUT JULY 26, 2004 FOLLOW-UP SEC MEETING - JULY 29, 2004 AND AUGUST 10, 2004 AUGUST 18, 2004 - LETTER
FROM ENFORCEMENT ANNOUNCING INVESTIGATION OF REPORTED MATTERS.
4.
Docket/Case Number:
DECISION NO. 06-217
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
ISSUES WITH COLLECTION AND PROCESSING OF RESEARCH REPORT DFISCLOSURES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIOD OF JULY 2002 THROUGH JUNE 2004, DBSI FAILED TO INCLUDE REQUIRED CONFLICT DISCLOSURES ON ITS PUBLISHED REPORTS
IN VIOLATION OF NYSE RULE 472(K). DBSI ALSO VIOLATED NYSE RULE 476(A)(6) BY ENGAGING IN CONDUCT INCONSISTENT WITH JUST AND
EQUITABLE PRINCIPLES OF TRADE BY PUBLISHING RESEARCH REPORTS WITHOUT REQUIRED CONFLICT OF INTEREST DISCLOSURES AND VIOLATED
NYSE RULE 342 IN FAILING TO ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURES AND SYSTEMS AND ESTABLISH SEPARATE SYSTEMS OF FOLLOW-
UP AND REVIEW TO ADEQUATELY SUPERVISE THE INCLUSION OF REQUIRED CONFLICT OF INTEREST DISCLOSURES ON PUBLISHED RESEARCH REPORTS
AND IN CONNECTION WITH RESEARCH ANALYSTS' PUBLIC APPEARANCES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
01/15/2007
 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: $ 950,000.00
 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 $950,000.00 FINE WAS PAID ON FEBRUARY 7, 2007.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON OR ABOUT JULY 26, 2004, DBSI REPORTED TO THE SEC, THE NYSE AND THE NASD THAT IT HAD EXPERIENCED PROBLEMS WITH ITS COLLECTIONS
AND PROCESSING OF RESEARCH REPORT CONFLICT DISCLOSURES. A SUBSEQUENT MEETING WAS HELD WITH THE SEC ON JULY 29, 2004.
THEREAFTER, NYSE ENFORCEMENT NOTIFIED THE FIRM OF ITS INVESTIGATION OF THE REPORTED MATTERS, WHICH WERE COMBINED WITH FINDINGS
RESULTING FROM A SALES PRACTICE EXAMINATION CONDUCTED BY THE NYSE IN APRIL AND MAY 2004. PURSUANT TO NYSE RULE 472 DBSI WAS
REQUIRED TO IMPLEMENT SYSTEMS TO MAINTAIN AND UPDATE CONFLICT OF INTEREST DISCLOSURE INFORMATION FOR INCLUSION IN PUBLISHED
RESEARCH REPORTS AND IN CONNECTION WITH FIRM RESEARCH ANALYSTS' PUBLIC APPEARANCES.

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE BANK AG (LONDON)
(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) 
AUTORITE DES MARCHES FINANCIERS ("AMF")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/18/2006
 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
Other Product Types: 
MANDATORY CONVERTIBLE BOND
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE AMF ALLEGED CERTAIN ABUSES ARISING OUT OF THE CONVERTIBLE BOND OFFER FOR FRENCH TELELCOMMUNICATIONS EQUIPMENT MAKER
ALCATEL WHICH TOOK PLACE IN DECEMBER 2002. THE ALLEGATIONS CENTERED ON WHETHER HEDGE FUNDS ACTED ON THE BASIS OF INFORMATION
COMMUNICATED BY DB LONDON BEFORE THE ISSUANCE OF THE BONDS WAS PUBLICLY ANNOUNCED, DURING ITS MARKET SOUNDING ACTIVITIES. THE
AMF CONCLUDED THAT DB HAD NO CULPABILITY IN RELATION TO ALLEGED INSIDER DEALING ACTIVITIES, BUT ALLEGED PROCEDURAL, RECORD
KEEPING OMISSIONS BY DB, IN RELATION TO THE RECORDS IT MAINTAINED OF THE MARKET SOUNDINGS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
11/23/2007
 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: $ 300,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PLEASE NOTE: THE ABOVE AMOUNT IS IN EUROS.
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: 
AMF IMPOSED A MONETARY SANCTION OF 300,000 EUROS, WHICH HAS BEEN PAID IN FULL.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON DECEMBER 22, 2006, THE AMF NOTIFIED DB LONDON THAT IT WOULD BE SANCTIONED FOR TECHNICAL AND PROCEDURAL VIOLATIONS IN
CONNECTION WITH A CONVERTIBLE BOND OFFERING BY ALCATEL, DB LEAD MANAGED THE TRANSACTION. THERE WAS NO CASE TO ANSWER FOR
INSIDER TRADING. DB LONDON CONDUCTED MARKET SOUNDINGS WITH SEVERAL HEDGE FUNDS AHEAD OF THE OFFERING IN DECEMBER 2002. DB
LONDON WAS ABLE TO PRODUCE DOCUMENTATION SUFFICIENT TO ATTEST THAT IT WAS ENGAGED IN MARKET SOUNDING WHICH IS PERMITTED UNDER
AMF RULES. HOWEVER, SINCE THE TIMES THE TELEPHONE CONTACTS WITH THE HEDGE FUNDS WERE MADE WERE NOT EVIDENCED IN THE
DOCUMENTATION AND THE NAMES OF CERTAIN THIRD PARTIES WERE MISSING FROM THE FIRM'S RECORDS, AMF FOUND THAT DB LONDON ACTED
CONTRARY TO FRENCH MARKET SOUNDING REGULATIONS.

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE BANK AG (LONDON)
(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) 
COMISION NACIONAL DEL MERCADO ("CNMV")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
SUSPENSION
3.
Date Initiated (MM/DD/YYYY): 
02/03/2006
 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:
Equity Listed (Common & Preferred Stock)

Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CNMV ALLEGED DB LONDON ENGAGED IN A BREACH OF ITS OBLIGATION NOT TO CARRY OUT MARKET SOUNDING OR WALL CROSSING ACTIVITIES
UNTIL THE CLOSE OF THE MARDRID MARKET AND APPROVAL OF A SHORT PROSPECTUS FOR AN EQUITY PLACEMENT (BLOCK TRADE) EXECUTED IN
SPARES OF SPANISH COMPANY EBRO PULEVA ON FEBRUARY 26, 2004.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
12/19/2006
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 1,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
NOTE RE AMOUNT: AMOUNT IN EUROS (1,000,000 EUROS)
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: 
SUSPENDED FROM ACCELERATED BOOK BUILT DEALS IN SPANISH SECURITES FOR A PERIOD OF THREE MONTHS FROM 19 DECEMBER 2006
THROUGH 19 MARCH 2007.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON DECEMBER 19, 2006, DB LONDON RECEIVED NOTICE THAT THE CNMV RECEIVED APPROVAL TO SANCTION DB LONDON IN RESPECT OF AN EQUITY
PLACEMENT (BLOCK TRADE) EXECUTED IN SHARES OF SPANISH COMPANY EBRO PULEVA IN FEBRUARY 2004. THE CNMV ALLEGED THAT, PURSUANT, TO
PROSPECTUS DESCRIBING THE PLACEMENT, DB LONDON IMPOSED UPON ITSELF AN OBLIGATION NOT TO CARRY OUT ANY MARKET SOUNDING OR WALL
CROSSING ACTIVITIES PRIOR TO THE CLOSE OF THE MADRID MARKET AND APPROVAL OF THE SHORT PROSPECTUS BY THE CNMV ON THE DATE OF THE
TRANSACTION. THE CNMV ARGUED THAT DB LONDON BREACHED THIS OBLIGATION BY APPROACHING THREE INVESTORS TO DETERMINE MARKET
INTEREST PRIOR TO THE MARKET CLOSE.

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

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

PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NASD
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
ACCEPTANCE, WAIVER AND CONSENT ("AWC")
3.
Date Initiated (MM/DD/YYYY): 
03/12/2007
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20041000088-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
MUNICIPAL SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NASD ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED NASD CONDUCT RULES 2110, 3010, AND 3370, IN THAT DBSI ACCEPTED
523 CUSTOMER SHORT SALE ORDERS FROM MULTIPLE ACCOUNTS AND, FOR EACH ORDER, FAILED TO MAKE/ANNOTATE AN AFFIRMATIVE
DETERMINATION THAT THE FIRM WOULD RECEIVE DELIVERY OF THE SECURITY ON BEHALF OF THE CUSTOMER OR THAT THE FIRM COULD BORROW THE
SECURITY ON BEHALF OF THE CUSTOMER FOR DELIVERY BY SETTLEMENT DATE. DBSI FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES
WHICH SPECIFIED THAT THE DESIGNATED SUPERVISOR WAS RESPONSIBLE FOR THE DAILY REVIEW OF ALL EXCEPTIONS GENERATED FOR INSTANCES
IN WHICH THE SECURITIES LENDING DEPARTMENT DID NOT HAVE A CORRESPONDING LOCATE OR THE NUMBER OF SHARES EXCEEDED THE LOCATE.
NASD ALSO ALLEGED THAT DBSI FAILED TO REPORT, PURSUANT TO MSRB RULE G-14, 102 CUSTOMER TRANSACTIONS IN MUNICIPAL SECURITIES
WITHIN 15 MINUTES OF THE TIME OF EXECUTION.

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):
03/12/2007
 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: $ 45,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND A FINE OF $45,000.00. THE FINE WILL BE PAID.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), CONSENTING TO A
CENSURE AND FINE OF $45,000.00.

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

CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE SECURITIES
AUSTRALIA LIMITED
(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) 
AUSTRALIAN SECURITIES EXCHANGE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/01/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE AUSTRALIAN SECURITIES EXCHANGE ("ASX") DETERMINED THAT DEUTSCHE SECURITIES AUSTRALIA LIMITED CONTRAVENED ASX MARKET RULE
20.8.3 AS A RESULT OF EXECUTING FIVE SPECIAL CROSSINGS IN DERIVATIVE MARKET CONTRACTS OVER A CASH MARKET PRODUCT FOR WHICH THERE
WAS A CURRENT OFFER PERIOD FOR A TAKEOVER BID AND CONTRAVENED ASX MARKET RULE 20.8.4 BY EXECUTING ONE SPECIAL CROSSING IN A
COMBINATION WHEN A COMPONENT PART OF THE COMBINATION WAS A DERIVIATIVES MARKET CONTRACT OVER A CASH MARKET PRODUCT FOR
WHICH THERE WAS A CURRENT OFFER PERIOD FOR A TAKEOVER BID.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision

11. Resolution Date (MM/DD/YYYY):
01/24/2007
 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: $ 45,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PLEASE NOTE: THE ABOVE AMOUNT IS IN AUSTRALIAN DOLLARS.
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: 
A FINE OF A$45,000 WAS IMPOSED UPON DEUTSCHE SECURITIES AUSTRALIA LIMITED.
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 AUSTRALIAN SECURITIES EXCHANGE ("ASX") RULES PROHIBIT SPECIAL SIZE CROSSINGS BEING EXECUTED IN SECURITIES THAT ARE PARTY TO A
TAKEOVER SITUATION. THE ASX CONTACTED DEUTSCHE SECURITIES AUSTRALIA LIMITED ("DSAL") ON MAY 1, 2006 REGARDING SIX SEPARATE SPECIAL
CROSSINGS IN THE STOCK OF PATRICK CORPORATION THAT HAD BEEN EXECUTED AT A TIME WHEN PATRICK WAS A SUBJECT OF A TAKEOVER BID. THE
SPECIAL CROSSINGS OCCURRED DURING A PERIOD BEGINNING IN DECEMBER 2005 THROUGH MID MARCH 2006. DSAL RESPONDED THAT THE
INCORRECT EXECUTION OF SPECIAL CROSSINGS WAS A RESULT OF GENUINE CONFUSION REGARDING THE STATUS OF THE TAKEOVER BID. ASX
ENFORCEMENT DIVISION REFERRED THE MATTER TO ASX DISCIPLINARY TRIBUNAL FOR CONSIDERATION. THE TRIBUNAL IMPOSED A MONETARY
SANCTION OF A$50,000 WHICH WAS APPEALED BY BOTH DSAL AND ASX ENFORCEMENT AS BEING OVERLY SEVERE. IN LIGHT OF DSAL'S CO-OPERATION
WITH THE INITIAL INVESTIGATION, ITS PRIOR UNBLEMISHED HISTORY AND THE ACTION THAT DSAL HAD TAKEN SINCE THE CONTRAVENTIONS
OCCURRED, THE TRIBUNAL REDUCED THE SANCTION TO A$45,000 ON JANUARY 24, 2007. ON MARCH 7, 2007, THE ASX ISSUED A DISCIPLINARY
CIRCULAR NAMING DSAL AND PROVIDING DETAILS OF THE OFFENSE AND PENALTY IMPOSED.

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) 
CHICAGO BOARD OF TRADE ("CBOT")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/22/2007
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
06-RFT-055
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHICAGO BOARD OF TRADE ("CBOT") DURING A ROUTINE COMPUTERIZED TRADING RECONSTRUCTION SYSTEM ("CTR") EXAMINATION ALLEGED
THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED REGULATIONS 332.08 AND 465.01 IN THAT TRADE DATA FOR CERTAIN TRADE DATES
REFLECTED A CTR ERROR RATE HIGHER THAN THE CBOT'S ACCEPTABLE THRESHOLD.
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):
05/22/2007
 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: $ 2,100.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution

p
g
g
 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: 
DEUTSCHE BANK SECURITIES INC. ("DBSI") CONSENTED TO A FINE OF $2,100.00. THE FINE WAS PAID ON JUNE 13, 2007.
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 ALLEGATIONS, DBSI AGREED TO PAY THE FINE OF $2,100.00.

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) 
NASD
2.
Principal Sanction:
Censure
Other Sanctions: 
ACCEPTANCE, WAIVER AND CONSENT ("AWC")
3.
Date Initiated (MM/DD/YYYY): 
06/12/2007
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20060054835-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
EQUITY LISTED (COMMON & PREFERRED)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NASD ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED NASD MARKET PLACE RULES 4632, 6130(D) AND 6955(A), IN THAT DBSI
FAILED TO SUBMIT TO THE TRADE REPORTING FACILITY FOR THE OFFSETTING "RISKLESS" PORTION OF 476 "RISKLESS" PRINCIPAL TRANSACTIONS IN
DESIGNATED SECURITIES, EITHER A CLEARING-ONLY REPORT WITH THE CAPACITY INDICATOR OR A NON-TAPE, NON-CLEARING REPORT WITH A
CAPACITY INDICATOR OF "RISKLESS PRINCIPAL." DBSI IS ALSO ALLEGED TO HAVE FAILED TO REPORT TO THE TRADE REPORTING FACILITY, TWO LAST
SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES. NASD ALLEGED THAT DBSI FAILED TO REPORT TO THE TRADE REPORTING FACILITY, THE
CORRECT SYMBOL INDICATING WHETHER A TRANSACTION WAS A BUY, SELL SHORT, SELL SHORT EXEMPT OR CROSS FOR 55 TRANSACTIONS IN
REPORTABLE SECURITIES IN VIOLATION OF NASD MARKETPLACE RULE 6130(D). NASD ALLEGED THAT DBSI FAILED TO SUBMIT REQUIRED INFORMATION
TO OATS IN CONNECTION WITH NINE ORDERS REPRESENTING APPROXIMATELY 12 PERCENT OF THE SAMPLE OF REPORTS REVIEWED IN THE TMMS
EXAMINATION IN VIOLATION OF NASD MARKETPLACE RULE 6955(A). NASD ALLEGED THAT DBSI FAILED TO MARK THE FIRM'S LEDGER AS SHORT OR
SHORT EXEMPT IN THE EXECUTION OF 64 LONG SALE TRANSACTIONS IN VIOLATION OF SEC RULE 200(G) OF REGULATION SHO AND FAILED, ON 16
OCCASIONS, TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER ITS CORRECT CAPACITY IN THE TRANSACTION AND ON ONE
OCCASION, FAILED TO PROVIDE TO ITS CUSTOMER THE CORRECT AVERAGE PRICE IN VIOLATION OF SEC RULE 10B-10.
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):
06/12/2007
 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: $ 30,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND A FINE OF $30,000.00. THE FINE WILL BE PAID.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), CONSENTING TO A
CENSURE AND FINE OF $30,000.00 (COMPRISED OF A $5,000.00 FOR TRADE VIOLATIONS, A $5,000.00 FOR SEC RULE 200(G) VIOLATIONS, A
$10,000.00 FINE FOR OATS VIOLATIONS, AND A $10,000.00 FOR SEC RULE 10B-10 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
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE BANK AG (LONDON)
(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) 
AUTORITE DES MARCHES FINANCIERS ("AMF")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
REPRIMAND
3.
Date Initiated (MM/DD/YYYY): 
12/13/2002
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Corporate
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
AMF ALLEGED CERTAIN ABUSES ARISING OUT OF A CONVERTIBLE OFFER BY VIVENDI WHICH TOOK PLACE IN NOVEMBER 2002. THE ALLEGATIONS
CENTERED ON WHETHER HEDGE FUNDS ACTED ON INFORMATION OFFERED BY DBAG LONDON BEFORE THE ISSUANCE OF THE BOND WAS PUBLICLY
ANNOUNCED.
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):
06/07/2007
 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: $ 750,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PLEASE NOTE THE FINE OF $750,000.00 IS IN EUROS.
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 SANCTION AND REPRIMAND ONLY. THE FINE WILL BE PAID.
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 AMF ALLEGED THAT DBAG LONDON, WHICH HANDLED A 1 BILLION EURO CONVERTIBLE BOND ISSUE FOR VIVENDI IN NOVEMEBER 2002, DID NOT
FULLY RESPECT THE RULES OF GOOD CONDUCT WHICH APPLY TO MARKET TESTING IN PASSING ON INFORMATION ABOUT THE ISSUE TO FOUR HEDGE
FUNDS PRIOR TO THE INFORMATION BECOMING PUBLICLY KNOWN. THE AMF FOUND THAT THE FUNDS USED THIS INFORMATION TO TRADE VIVENDI
SHARES. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBAG LONDON WAS SANCTIONED FOR TECHNICAL AND PROCEDURAL REASONS AND
THERE WERE NO FINDINGS THAT DBAG LONDON VIOLATED INSIDER TRADING RULES. LIKEWISE, DBAG LONDON WAS NOT SANCTIONED FOR PASSING
INFORMATION TO THE HEDGE FUNDS. THE AMF ALLEGED THAT THERE WERE ALSO MATERIAL INACCURACIES IN THE PROSPECTUS. HOWEVER, THIS WAS

VIEWED BY THE AMF AS A FORMAL BREACH, WHICH ON ITS OWN, WOULD NOT WARRANT A HIGH PENALTY. THE AMF ALLEGED THAT DBAG LONDON
FAILED TO RETAIN PROPER RECORDS OF ITS "MARKET SOUNDING" COMMUNICATIONS AND FAILED TO RETAIN REVELANT TAPE RECORDINGS. THE AMF
DID NOT ALLEGE THAT THE MISTAKEN ERASURE OF THE TAPES WAS INTENTIONAL.

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

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

3.
Date Initiated (MM/DD/YYYY): 
09/27/2007
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2006006015001
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
TRACE-ELIGIBLE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") FAILED TO REPORT TO TRACE, 2,429 TRANSACTIONS IN TRACE ELIGIBLE SECURITIES
EXECUTED ON A BUSINESS DAY DURING TRACE SYSTEM HOURS WITHIN THE REQUIRED 15 MINUTES OF THE TIME OF EXECUTION IN VIOLATION OF
NASD MARKETPLACE RULE 6230(A). THE LATE TRANSACTIONS CONSTITUTED APPROXIMATELY 8% OF ALL TRANSACTIONS IN TRACE ELIGIBLE
SECURITIES THAT THE FIRM WAS REQUIRED TO REPORT TO TRACE DURING THE PERIOD APRIL 1, 2006 THROUGH JUNE 20, 2006. THE CONDUCT
CONSTITUTED SEPARATE AND DISTINCT VIOLATION OF 6230(A) AND A PATTERN OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN
VIOLATION OF NASD CONDUCT RULE 2110.
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):
09/27/2007
 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: $ 20,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND A FINE OF $20,000.00. THE FINE WAS PAID ON 10/19/2007.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT, CONSENTING TO A $20,000
FINE AND CENSURE

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

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

11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
ACCEPTANCE, WAIVER AND CONSENT
3.
Date Initiated (MM/DD/YYYY): 
09/27/2007
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20060047177-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
EQUITY TRADE REPORTING (OATS)

7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN CONNECTION WITH REVIEW 20060047177, THE NASD CONDUCTED A REVIEW OF DEUTSCHE BANK SECURITIES INC.'S ("DBSI'S") COMPLIANCE WITH
RULES APPLICABLE TO THE ORDER AUDIT TRAIL SYSTEM ("OATS") DURING THE PERIOD OF OCTOBER 1, 2005 THROUGH DECEMBER 31, 2005. THE NASD
ALLEGED DURING THE REVIEW PERIOD, DBSI SUBMITTED TO OATS 2,144 REPORTABLE ORDER EVENTS ("ROES") THAT WERE REJECTED BY OATS FOR
CONTEXT SYNTAX ERRORS. DBSI DID NOT REPAIR 1,412 OF THE REJECTED ROE'S, REPRESENTING APPROXIMATELY 66 PERCENT OF ALL REJECTED ROES.
THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD MARKETPLACE RULE 6955(A).
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):
09/27/2007
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 10,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
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: 
DBSI CONSENTED TO A CENSURE AND A FINE OF $10,000.00. THE FINE WAS PAID ON 10/19/2007.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), CONSENTING TO A
CENSURE AND FINE OF $10,000.00.

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) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
ACCEPTANCE, WAIVER AND CONSENT
3.
Date Initiated (MM/DD/YYYY): 
12/18/2007
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20060067543-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT NINETEEN FIRMS INCLUDING DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED NASD CONDUCT RULES 2110, 3010, 3310 IN
THAT THE FIRMS DID NOT DETERMINE WHETHER THE AGGREGATE TRADE VOLUMES IN CERTAIN SECURITIES THAT THEY ADVERTISED IN AUTEX,
BLOOMBERG AND/OR REUTERS IN AUGUST 2006 ACCURATELY REFLECTED THEIR EXECUTED TRADE VOLUMES. IN DBSI'S CASE, FINRA ALLEGED THAT
THE ADVERTISED AGGREGATE TRADE VOLUME FOR TWO EQUITY SECURITIES EXCEEDED THE FIRM'S EXECUTED TRADE VOLUME FOR THOSE SECURITIES.
FINRA FURTHER ALLEGED THAT THE FIRM'S SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE
ADVERTISING RULES.
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):
12/18/2007
 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: $ 150,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND A FINE OF $150,000.00. THE FINE WAS PAID ON JANUARY 9, 2008. DBSI WAS ALSO REQUIRED TO REVISE
ITS WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO COMPLIANCE WITH NASD RULE 3310 WITHIN 30 DAYS OF ACCEPTANCE OF THIS
AWC. DBSI HAS COMPLETED THE REQUIRED REVISIONS.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT, CONSENTING TO A
$150,000.00 FINE AND CENSURE.

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) 
BOURSE DE MONTREAL
2.
Principal Sanction:
Other
Other Sanctions: 
ELECTRONIC TRADING ACCESS APPROVAL FOR DESIGNATED PERSONNEL HAD TO BE OBTAINED.
3.
Date Initiated (MM/DD/YYYY): 
01/25/2008
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
N/A
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIOD FROM JUNE 16, 2006 TO MAY 8, 2007, DEUTSCHE BANK SECURITIES INC. ("DBSI") WAS ALLEGED TO HAVE CONTRAVENED
PARAGRAPH A) OF ARTICLE 6366 OF THE RULES OF BOURSE DE MONTREAL INC.(THE BOURSE), BY PROVIDING ACCESS TO ITS DESIGNATED PERSONNEL
TO THE ELECTRONIC TRADING SYSTEM OF THE BOURSE WITHOUT HAVING OBTAINED THE PRIOR APPROVAL OF THE BOURSE THEREOF, RENDERING DBSI
SUBJECT TO A DISCIPLINARY COMPLAINT AND TO THE PENALTIES LISTED IN ARTICLE 4101 AND FOLLOWING OF THE RULES OF THE BOURSE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
11/18/2008
 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: $ 53,759.60
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
THE AMOUNT ABOVE INCLUDES COSTS OF THE INVESTIGATION OF $3,759.60
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: 
DBSI CONSENTED TO A FINE OF $53,759.60. THIS AMOUNT INCLUDES COSTS OF THE INVESTIGATION. THE FINE WAS PAID ON 12/8/08.
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 ALLEGATIONS, DBSI CONSENTED TO THE BOURSE DE MONTREAL DECISION, AND TO A FINE OF $53,759.60.

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) 
AMERICAN STOCK EXCHANGE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
01/14/2008
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AMEX CASE NO. 06-338
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
AMEX ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED EXCHANGE RULE 208 ON APRIL 19, 2005, BY ACCEPTING FROM A
CUSTOMER MULTIPLE ODD-LOT ORDERS, RATHER THAN ROUND LOT ORDERS AND PLACING SUCH MULTIPLE ORDERS INTO THE FIRM'S ELECTRONIC
ORDER ENTRY SYSTEM, THEREBY VIOLATING EXCHANGE RULES 320(B) AND (C) IT WAS FURTHER ALLEGED THAT DURING THE RELEVANT PERIOD, DBSI
FAILED TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES, SYSTEMS AND PROCEDURES OF SUPERVISION AND CONTROL, INCLUDING WRITTEN
SUPERVISORY PROCEDURES, AND FAILED TO ESTABLISH A SEPARATE SYSTEM TO FOLLOW UP AND REVIEW, TO ENSURE COMPLIANCE WITH EXCHANGE
RULE 208, IN PARTICULAR, ODD-LOT TRADING PRACTICES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
03/19/2008
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 10,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
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: 
DBSI CONSENTED TO A CENSURE AND A FINE OF $10,000.00. THE FINE WAS PAID ON APRIL 9, 2008.
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 ALLEGATIONS, DBSI ENTERED INTO A STIPULATION AND CONSENT TO PENALTY, CONSENTING TO A $10,000.00
FINE AND CENSURE.

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) 
NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT
2.
Principal Sanction:
Other
Other Sanctions: 
CENSURE

3.
Date Initiated (MM/DD/YYYY): 
05/15/2008
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NYSE HBD# 08-27
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
INDEX ARBITRAGE ORDERS AND DAILY PROGRAM TRADE REPORTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NYSE ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED RULES 80A AND 476(A)(10). WITHOUT ADMITTING OR DENYING ANY
ALLEGATIONS OR FINDINGS, AND FOR THE SOLE PURPOSE OF SETTLING THIS PROCEEDING, DBSI AND THE NYSE ENTERED A STIPULATION OF FACTS
AND CONSENT TO PENALTY THAT DURING THE PERIOD OF JUNE AND JULY 2006, 1) DBSI VIOLATED NYSE RULE 80A BY INTRODUCING FOR EXECUTION
ON THE NYSE NINETY-THREE BASKETS OF INDEX ARBITRAGE ORDERS WITHOUT THE APPROPRIATE TICK RESTRICTIONS WHEN AN NYSE RULE 80A
COLLAR WAS IN PLACE AND; 2) VIOLATED NYSE RULE 476(A)(10), ON SIX TRADE DATES, BY FAILING TO SUBMIT TO THE NYSE ACCURATE DAILY
PROGRAM TRADE REPORTS RELATING TO AFOREMENTIONED INDEX ARBITRAGE ORDERS. ON MAY 15, 2008, THE NYSE HEARING OFFICER ACCEPTED THE
STIPULATION.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
06/09/2008
 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: $ 35,000.00
 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 FINE OF $35,000.00 WILL BE PAID.
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 ALLEGATIONS, DBSI AGREED TO A STIPULATION AND CENSURE, CONSENTING TO A FINE OF $35,000.00.

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) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
ACCEPTANCE, WAIVER AND CONSENT
3.
Date Initiated (MM/DD/YYYY): 
06/16/2008
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2007007241401
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):
FINRA ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED SEC RULE 17A-3(A)(6)AND NASD RULES 2110 AND 3110, IN CONNECTION
WITH CORPORATE DEBT TRANSACTIONS EFFECTED BY THE FIRM ON APRIL 2ND AND 3RD 2007, BY FAILING TO RECORD THE TIME OF RECEIPT OF THE
ORDER ON THE ORDER MEMORANDA.
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):
06/16/2008
 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: $ 7,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
DBSI CONSENTED TO A CENSURE AND A FINE OF $7,500.00. THE FINE WAS PAID ON JULY 9, 2008.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT, CONSENTING TO A
$7,500.00 FINE AND CENSURE.

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
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
ACCEPTANCE, WAIVER AND CONSENT
3.
Date Initiated (MM/DD/YYYY): 
06/26/2008
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FINRA 20050018280-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
OATS AND TRF REPORTING
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IT WAS ALLEGED THAT: THE FIRM, IN MAY 2006, HAD A FAIL TO DELIVER POSITION IN A THRESHOLD SECURITY FOR THIRTEEN CONSECUTIVE
SETTLEMENT DAYS AND FAILED TO IMMEDIATELY THEREAFTER CLOSE IT OUT, THEREBY ALLEGEDLY VIOLATING RULE 203(B)(3). DURING THE PERIODS
JULY 1, 2005 THROUGH DECEMBER 31, 2005, THE FIRM REPORTED TO OATS ROUTE OR COMBINED ORDER/ROUTE REPORTS THAT THE OATS SYSTEM
WAS UNABLE TO LINK TO THE RELATED ORDERS ROUTED TO OATS ALLEGEDLY DUE TO INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA.
THE CONDUCT ALLEGEDLY VIOLATED NASD MARKETPLACE RULE 6955(A). THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO
THE TRADE REPORTING FACILITY ("TRF'), FORMERLY THE NASDAQ MARKET CENTER ("NMC"), LAST SALE REPORTS OF TRANSACTIONS DURING THE
PERIOD DECEMBER 1, 2005 THROUGH APRIL 30, 2006. THE CONDUCT ALLEGEDLY VIOLATED NASD MARKETPLACE 4632(A). THE FIRM TRANSMITTED TO
THE TRF TEN LAST SALE REPORTS OF TRANSACTIONS AND FAILED TO APPEND AS REQUIRED THE ".W" MODIFIER. THE CONDUCT ALLEGEDLY VIOLATED
NASD MARKETPLACE RULE 4632(A)(6). THE FIRM, DURING THE PERIOD MAY 1, 2006 THROUGH AUGUST 31, 2006, FAILED TO ACCEPT OR DECLINE AS
REQUIRED IN THE TRF TRANSACTIONS WITHIN TWENTY MINUTES AFTER EXECUTION . THE CONDUCT ALLEGEDLY VIOLATED NASD MARKETPLACE RULE
6130(B) AND NASD CONDUCT RULE 2110. THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE TRF LAST SALE REPORTS OF
TRANSACTIONS AND FAILED TO DESIGNATE TO THE TRF CERTAIN OF THOSE REPORTS AS LATE. THE CONDUCT ALLEGEDLY VIOLATED OF NASD CONDUCT
RULE 2110 AND NASD MARKETPLACE RULE 6420(A).
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):
06/26/2008
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 37,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
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: 
DBSI CONSENTED TO A CENSURE AND A FINE OF $37,500.00. THE FINE WAS PAID ON JULY 22, 2008.
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, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE OF $37,500 (COMPRISED
OF A $7,500 FINE FOR THE REG. SHO VIOLATIONS; A $15,000 FNE FOR THE OATS VIOLATIONS; AND A $15,000 FINE FOR THE TRADE REPORTING
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) 
NYSE ARCA EQUITIES, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
08/28/2008
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ENFORCEMENT DECISION NO. 08-AE-02
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
SHORT SALES IN LISTED AND UNLISTED EQUITY SECURITIES.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NYSE ARCA EQUITIES, INC. ALLEGED THAT BETWEEN JANUARY 2005 THROUGH APPROXIMATELY OCTOBER 2006 (THE "RELEVANT PERIOD"), DEUTSCHE
BANK SECURITIES INC. ("DBSI"), WITH RESPECT TO AT LEAST FIVE OF ITS 19 PROPRIETARY TRADING DESKS (THE "FIVE DESKS"), FAILED TO COMPLY
WITH CERTAIN NYSE ARCA EQUITIES RULES AND REGULATION SHO ("REG SHO') REQUIREMENTS WITH RESPECT TO ITS EXECUTION AND SUPERVISION
OF THE SHORT SALE ORDERS DESCRIBED BELOW. SPECIFICALLY, NYSE ARCA EQUITIES, INC. ALLEGED THE FIRM EFFECTED AN UNQUANTIFIED BUT
SIGNIFICANT NUMBER OF SHORT SALES ON AT LEAST THE FIVE DESKS IN SECURITIES THAT WERE NOT ON THE FIRM EASY-TO-BORROW LIST WITHOUT
HAVING BORROWED THE SECURITIES OR ENTERED INTO BONA-FIDE ARRANGEMENTS TO BORROW THE SECURITIES, OR HAVING REASONABLE GROUNDS
TO BELIEVE THAT THE SECURITIES COULD BE BORROWED FOR DELIVERY WHEN DUE, AND WITHOUT THE PROPER DOCUMENTATION OF SUCH.
FURTHER, NYSE ARCA EQUITIES, INC. ALLEGED AT LEAST TWO OF SUCH DESKS DID NOT PROPERLY ADHERE TO THE INDEPENDENT TRADING UNIT
AGGREGATION REQUIREMENTS AND ONE TRADER ON EACH OF THE TWO DESKS DID NOT CORRECTLY MARK AN UNQUANTIFIED BUT SIGNIFICANT
NUMBER OF PROPRIETARY SELL ORDERS. AS A RESULT, CERTAIN SHORT SALES ALLEGEDLY WERE INCORRECTLY MARKED LONG, AND SOME OF THOSE
ORDERS ALLEGEDLY WERE IMPROPERLY EXECUTED. NYSE ARCA EQUITIES, INC. ALSO ALLEGED THE FIRM FAILED TO ADEQUATELY SUPERVISE CERTAIN
TRADERS ON AT LEAST THE FIVE DESKS AND FAILED TO MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES CONCERNING PROPRIETARY
SHORT SALES IN A MANNER REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RELEVANT PROVISIONS OF REG SHO AND NYSE ARCA
EQUITIES RULES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
08/28/2008
 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: $ 575,000.00
 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: 
DBSI CONSENTED TO A DECISION AND ORDER OF OFFER OF SETTLEMENT, A CENSURE AND A FINE OF $575,000.00 (THE FINE WAS PAID ON
9/12/08).
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 ALLEGATIONS, DBSI CONSENTED TO A DECISION AND ORDER OF OFFER OF SETTLEMENT, A CENSURE AND A
FINE OF $575,000.00.

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) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
ACCEPTANCE, WAIVER AND CONSENT ("AWC")
3.
Date Initiated (MM/DD/YYYY): 
02/05/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2006005064401
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
DEBT-MUNICIPAL SECURITIES, TRACE-ELIGIBLE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) SUBMITTED CERTAIN INACCURATE OATS REPORTS IN DECEMBER 2005 IN
VIOLATION OF NASD RULE 6995(A); (2) FAILED TO TIMELY REPORT CERTAIN TRANSACTIONS TO TRACE DURING THE PERIOD FROM JANUARY 1, 2007
THROUGH MARCH 31, 2007 IN VIOLATION OF NASD RULES 6230(A) AND 2110; (3) FAILED TO TIMELY REPORT CERTAIN INFORMATION CONCERNING
CERTAIN MUNICIPAL SECURITIES TRANSACTIONS TO RTRS DURING THE PERIOD FROM JULY 1, 2007 THROUGH SEPTEMBER 30, 2007 IN VIOLATION OF
MSRB RULE G-14; (4) FAILED TO TIMELY REPORT CERTAIN TRANSACTIONS TO THE NNTRF DURING THE PERIOD FROM JANUARY 1, 2007 THROUGH APRIL
30, 2007 IN VIOLATION OF NASD RULE 6130(G); (5) FAILED TO PROVIDE WRITTEN NOTIFICATION TO CERTAIN CUSTOMERS OF INFORMATION RELATING
TO CERTAIN TRANSACTIONS DURING THE PERIOD FROM JANUARY 4-7, 2008 IN VIOLATION OF SEC RULE 10B-10; AND (6) FAILED TO TIMELY REPORT
CERTAIN TRANSACTIONS TO THE NNTRF DURING THE PERIOD FROM JANUARY 1, 2008 THROUGH APRIL 30, 2008 IN VIOLATION OF NASD RULE 6130(G).
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):
02/05/2009
 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: $ 43,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND A FINE OF $43,000.00. THE FINE WAS PAID ON 2/19/2009.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), CONSENTING TO A
CENSURE AND FINE OF $43,000.00. THE FINE WAS (COMPRISED OF A $10,000 FINE FOR OATS VIOLATIONS, A $10,000 FINE FOR TRACE VIOLATIONS, A
$10,000 FINE FOR MSRB VIOLATIONS, A $10,000 FINE FOR VIOLATIONS OF NASD RULE 6130, AND $3,000 FINE FOR SEC RULE 10-B10 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) 
ATTORNEY GENERAL OF THE STATE OF NEW YORK, INVESTOR PROTECTION BUREAU ("NYAG")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/03/2009
 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
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE ASSURANCE OF DISCONTINUANCE ("AOD") ENTERED INTO BETWEEN DBSI AND THE NYAG ON JUNE 3, 2009 ALLEGED THAT DBSI MISLED CERTAIN
INVESTORS AS TO THE RISKS RELATED TO, AND THE LIQUIDITY OF, AUCTION RATE SECURITIES ("ARS").
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):
06/03/2009
 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: $ 678,282.50
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE AOD, DBSI AGREED TO PAY A PENALTY OF $678,282.50 TO NEW YORK AND TO TAKE CERTAIN MEASURES WITH RESPECT TO
CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 AOD FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND THE NYAG AND THAT
RESULTED IN A TERM SHEET (THE "AUGUST 31 TERM SHEET"). THE AUGUST 31 TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000, AND
THE $678,282.50 PENALTY IMPOSED BY THE NYAG IS NEW YORK'S PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE AOD REQUIRES THAT
DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT SOLD ARS BELOW PAR;
PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS; WORK TO PROVIDE

LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS DESCRIBED IN THE
AOD.
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 ALLEGATIONS OF THE NYAG, DBSI AGREED TO CERTAIN RELIEF AS DESCRIBED ABOVE. THE AOD STATED THAT
THE ACTS AND PRACTICES OF DBSI AS DESCRIBED IN THE AOD VIOLATED: (1) THE MARTIN ACT, ARTICLE 23-A OF THE NY GENERAL BUSINESS LAW, (2)
SECTION 349 OF THE NY GENERAL BUSINESS LAW, AND (3) SECTION 63(12) OF THE NY EXECUTIVE LAW.

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE BANK AG (LONDON)
(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) 
LONDON STOCK EXCHANGE ("LSE")
2.
Principal Sanction:
Other
Other Sanctions: 
LSE, A FOREIGN SRO, ISSUED A FINE OF $25,000 GBP
3.
Date Initiated (MM/DD/YYYY): 
04/22/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
ETF
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
LSE ALLEGED THAT DEUTSCHE BANK AG QUOTED PRICES ON AN ETF THAT WERE HALF THE VALUE OF THAT LAST TRADED. AS A RESULT THE ETF WAS
SUSPENDED AND THE CLOSING AUCTION DELAYED.
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):
06/01/2009
 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: $ 40,000.00
 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 FINE IMPOSED WAS 25,000 GBP. THE ABOVE REPRESENTS AN APPROXIMATE DOLLAR/POUND CONVERSION. THE FINE WILL BE PAID.
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).
DB LONDON ACCEPTED THE FINE AND HAS PROACTIVELY DEVELOPED AND IMPLEMENTED A NEW QUOTING SYSTEM WITH MORE SOPHISTICATED LOGIC
TO PREVENT SIMILAR 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) 
BUREAU OF SECURITIES, STATE OF NEW JERSEY ("NJ BUREAU OF SECURITIES")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/03/2009
 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):

y
p
y
g
y
g
y
(
pp
)
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NJ BUREAU OF SECURITIES ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN
THE SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
06/03/2009
 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: $ 1,057,350.69
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO A CONSENT ORDER EXECUTED ON JUNE 3, 2009, DBSI AGREED TO PAY A PENALTY OF $1,057,350.69 TO NEW JERSEY AND TO TAKE
CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008. DBSI ALSO AGREED
TO PAY $15,000 TO THE NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION ("NASAA") AS REIMBURSEMENT FOR COSTS ASSOCIATED
WITH NASAA'S ASSISTANCE ON NJ'S INVESTIGATION.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "AUGUST 31 TERM SHEET"). THE AUGUST 31 TERM SHEET REQUIRED A TOTAL PENALTY OF
$15,000,000 TO NASAA MEMBER JURISDICTIONS, AND THE $1,057,350.69 PENALTY IMPOSED BY NEW JERSEY IS ITS PRO-RATA SHARE OF THE
TOTAL PENALTY AMOUNT. THE CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS;
REIMBURSE ELIGIBLE INVESTORS THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL
DAMAGES CLAIMS BY ELIGIBLE INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS
BUY BACK; AND PROVIDE OTHER RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE BUREAU CHIEF MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS IN VIOLATION OF N.J.S.A 49:3-58(A)(2)(VII); AND (2) IN CONNECTION WITH THE FAILURE TO (I)
PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES
CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE ADEQUATE
DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND ESTABLISH
AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT, IN VIOLATION OF ITS DUTIES UNDER N.J.S.A. 49:3-58(A)(2)(XI).

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE BANK AG ("DBAG")
(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) 
NEW YORK MERCANTILE EXCHANGE ("NYMEX")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/20/2009
 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
Other Product Types: 
POSITION LIMIT VIOLATION
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NYMEX ALLEGED THAT DBAG VIOLATED RULE 9A.36, IN THAT DBAG HAD A SECOND POSITION LIMIT VIOLATION WITHIN A 12 MONTH PERIOD. DBAG WAS
SUMMARILY FINED IN THE AMOUNT OF $5,000.00, AND INFORMED THAT ANY FURTHER VIOLATION IN ACCORDANCE WITH THIS RULE WILL
AUTOMATICALLY RESULT IN A HEARING BEFORE THE PROBABLE CAUSE COMMITTEE ("PCC").
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:
Other
11. Resolution Date (MM/DD/YYYY):
04/20/2009
 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: 
DBAG CONSENTED TO A FINE OF $5,000.00. THE FINE WAS PAID ON MAY 8, 2009.
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 ALLEGATIONS DBAG PAID THE FINE OF $5,000.00.

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) 
CHICAGO BOARD OF TRADE (CBOT")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/29/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
09-05550-CTRA
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHICAGO BOARD OF TRADE ("CBOT") DURING A ROUTINE COMPUTERIZED TRADING RECONSTRUCTION SYSTEM ("CTR") EXAMINATION ALLEGED
THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED CBOT RULE 536.F IN THAT TRADE DATA FOR CERTAIN TRADE DATES REFLECTED A CTR
ERROR RATE HIGHER THAN THE CBOT'S ACCEPTABLE THRESHOLD.
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):
05/29/2009
 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: $ 2,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
DEUTSCHE BANK SECURITIES INC. ("DBSI") CONSENTED TO A FINE OF $2,500.00. THE FINE WILL BE DEBITED FROM DBSI'S CBOT ACCOUNT.
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 ALLEGATIONS, DBSI AGREED TO PAY THE FINE OF $2,500.00.

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) 
MONTANA SECURITIES DEPARTMENT ("DEPARTMENT")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/03/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
SEC-2009-39
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
08/03/2009
 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: $ 30,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension

B.
Other Sanctions Ordered:
PURSUANT TO A CONSENT AGREEMENT AND FINAL ORDER ("ORDER") ENTERED BY THE COMMISSIONER OF SECURITIES AND INSURANCE ON
AUGUST 3, 2009, DBSI AGREED TO PAY A PENALTY OF $30,000.00 TO THE INVESTOR PROTECTION TRUST ON BEHALF OF THE STATE OF MONTANA
AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA AND THAT
RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $30,000.00 PENALTY IMPOSED BY THE DEPARTMENT IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT
SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS;
WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS
DESCRIBED IN THE ORDER.
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 ALLEGATIONS IN THE ORDER, DBSI CONSENTED TO THE DEPARTMENT MAKING THE FOLLOWING CONCLUSIONS
OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO CLIENTS THE
EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO ARTIFICIALLY PREVENT
FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND UNETHICAL CONDUCT
IN THE SECURITIES BUSINESS IN VIOLATION OF MONT. CODE ANN. SECTION 30-10-201(13)(G); AND (2) IN CONNECTION WITH THE FAILURE TO (I)
PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES
CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE ADEQUATE
DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND ESTABLISH
AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT, IN VIOLATION OF ITS DUTIES UNDER MONT. CODE ANN. SECTION
30-10-201(13)(K).

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 DIVISION OF THE OFFICE OF THE SECRETARY OF STATE, STATE OF NEVADA ("THE DIVISION")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/03/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
I09-181
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
08/03/2009
 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: $ 199,478.53
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:

PURSUANT TO A CONSENT ORDER ENTERED BY THE DIVISION ON AUGUST 3, 2009, DBSI AGREED TO PAY A PENALTY OF $199,478.53 TO THE
NEVADA STATE GENERAL FUND FOR CREDIT TO THE SECRETARY OF STATE'S OPERATING GENERAL FUND BUDGET ACCOUNT AND TO TAKE CERTAIN
MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $199,478.53 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. NRS 90.420(1)(H) ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION
AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH THE
FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. NRS 90.420(1)(1) ALLOWS THE DIVISION, THROUGH
ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
ARIZONA CORPORATION COMMISSION ("COMMISSION")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/20/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
S-03578A-09-0314
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMISSION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
08/20/2009
 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: $ 115,823.35
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO AN ORDER FOR ADMINISTRATIVE PENALTIES AND CONSENT TO SAME ("ORDER") ENTERED BY THE COMMISSION ON AUGUST 20,

2009, DBSI AGREED TO PAY A PENALTY OF $115,823.35 TO THE STATE OF ARIZONA AND TO TAKE CERTAIN MEASURES WITH RESPECT TO
CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA AND THAT
RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $115,823.35 PENALTY IMPOSED BY THE STATE OF ARIZONA IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT.
THE ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT
SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS;
WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS
DESCRIBED IN THE ORDER.
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 ALLEGATIONS IN THE ORDER, DBSI CONSENTED TO THE COMMISSION MAKING THE FOLLOWING CONCLUSIONS
OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO CLIENTS THE
EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO ARTIFICIALLY PREVENT
FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND UNETHICAL CONDUCT
IN THE SECURITIES BUSINESS IN VIOLATION OF A.R.S. SECTION 44-1961(A)(13); AND (2) IN CONNECTION WITH THE FAILURE TO (I) PROVIDE
ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS,
(III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS
OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES
NECESSARY TO DETECT AND PREVENT SUCH CONDUCT, IN VIOLATION OF ITS DUTIES UNDER A.R.S. SECTION 44-1961(A)(12).

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 DIVISION OF THE DEPARTMENT OF BUSINESS REGULATION, STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/21/2009
 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
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
08/21/2009
 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: $ 31,987.49
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO A CONSENT ORDER ENTERED BY THE DIVISION ON AUGUST 21, 2009, DBSI AGREED TO PAY A PENALTY OF $31,987.49 TO THE
GENERAL TREASURER, STATE OF RHODE ISLAND TO BE DEPOSITED IN THE GENERAL FUND, AND TO TAKE CERTAIN MEASURES WITH RESPECT TO
CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $31,987.49 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. SECTION 7-11-212(8) OF RISA ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE
ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH
THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. SECTION 7-11-212(11) OF RISA ALLOWS THE
DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR
EMPLOYEES.

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) 
DEPARTMENT OF BANKING, INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION OF THE STATE OF VERMONT ("THE DEPARTMENT").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/27/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
09-073-S
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
08/27/2009
 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: $ 500,854.01
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO A CONSENT ORDER ENTERED BY THE DEPARTMENT ON AUGUST 27, 2009, DBSI AGREED TO PAY A PENALTY OF $500,854.01 TO THE
DEPARTMENT, OF WHICH $488,354.01 IS AN ADMINISTRATIVE PENALTY AND $12,500 REPRESENTS A PAYMENT TO THE SECURITIES INVESTOR
EDUCATION AND TRAINING FUND, AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS
BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $500,854.01 PENALTY IMPOSED BY THE DEPARTMENT IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DEPARTMENT MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. 9 V.S.A. SECTION 5412(D)(13) ALLOWS THE DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO
TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION
WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. 9 V.S.A. SECTION 5412(D)(9) ALLOWS THE
DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR
EMPLOYEES.

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) 
DIVISION OF SECURITIES OF THE DEPARTMENT OF REVENUE AND REGULATION, STATE OF SOUTH DAKOTA ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/20/2009
 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
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
08/20/2009
 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: $ 30,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO A CONSENT ORDER ENTERED BY THE DIVISION ON AUGUST 20, 2009, DBSI AGREED TO PAY A PENALTY OF $30,000 TO THE SOUTH
DAKOTA DIVISION OF SECURITIES AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS
BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $30,000 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE CONSENT
ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT
SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS;
WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS
DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. SDCL 47-31B-412(D)(13) ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE
ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH
THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. SDCL 47-31B-412(D)(9) ALLOWS THE DIVISION,
THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
DEPARTMENT OF CORPORATIONS, STATE OF CALIFORNIA ("THE DEPARTMENT").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/10/2009
 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
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) FAILED TO OBSERVE HIGH STANDARDS OF COMMERCIAL HONOR AND
JUST AND EQUITABLE PRINCIPLES OF FAIR TRADE IN THE SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE
SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
09/10/2009
 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: $ 2,295,375.13
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO A CONSENT ORDER ENTERED BY THE DEPARTMENT ON SEPTEMBER 10, 2009, DBSI AGREED TO PAY A PENALTY OF $2,295,375.13
TO THE CALIFORNIA STATE CORPORATIONS FUND AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT
PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $2,295,375.13 PENALTY IMPOSED BY THE DEPARTMENT IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DEPARTMENT MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI FAILED TO OBSERVE HIGH
STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF FAIR TRADE IN THE SECURITIES BUSINESS. TITLE 10, CH. 3, SECTION
260.218 OF THE CALIFORNIA CODE OF REGULATIONS ALLOWS THE DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT
HAS FAILED TO OBSERVE HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF FAIR TRADE IN THE SECURITIES
BUSINESS; AND (2) IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND
MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO
CLIENTS BY ITS AGENTS, AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI
FAILED TO REASONABLY SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. TITLE 10,
CH. 3, SECTION 260.218.4(A) OF THE CALIFORNIA CODE OF REGULATIONS ALLOWS THE DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION
AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
NYSE ARCA, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/04/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
09-ARCA-8
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DEUTSCHE BANK SECURITIES INC. ("DBSI") SETTLED THE ALLEGED VIOLATIONS OF NYSE ARCA
EQUITIES RULES 6.18(B) AND (C), WHICH WERE THE RESULT OF A PROGRAMMING GLITCH IN DBSI'S NTRADE ALGORITHMIC ORDER ROUTING AND
TRADING PLATFORM AND AN INADVERTENT FILTERING MISTAKE IN CONNECTION WITH AN EXCEPTION REPORT RELATING TO ITS ARINA TRADING
PLATFORM. DBSI PROMPTLY CORRECTED THESE ISSUES WHEN IT BECAME AWARE OF THEM. THE $50,000 FINE WAS PAID ON SEPTEMBER 29, 2009.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
09/04/2009
 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:
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: 

CENSURE AND FINE OF $50,000 AGAINST DBSI PAID ON SEPTEMBER 29, 2009.
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 ALLEGATIONS, DBSI SETTLED THE ALLEGED VIOLATIONS OF NYSE ARCA EQUITIES RULES 6.18(B) AND (C),
WHICH WERE THE RESULT OF A PROGRAMMING GLITCH IN DBSI'S NTRADE ALGORITHMIC ORDER ROUTING AND TRADING PLATFORM AND A
PROGRAMMING MISTAKE IN CONNECTION WITH AN EXCEPTION REPORT RELATING TO ITS ARINA TRADING PLATFORM. DBSI PROMPTLY CORRECTED
THESE ISSUES WHEN IT BECAME AWARE OF THEM. THE $50,000 FINE WAS PAID ON SEPTEMBER 29, 2009.

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

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

2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE, FINE, RESTITUTION, AND OTHER (WITHIN 150 DAYS OF ISSUANCE OF THE AWC, DBSI MUST CERTIFY THAT IT HAS POLICIES AND
PROCEDURES IN PLACE RELATING TO OUTSOURCING IN CONNECTION WITH PUBLIC OFFERINGS OF COMMON STOCK THAT ARE REASONABLY DESIGNED
TO ACHIEVE COMPLIANCE WITH FINRA RULES, AND PROVIDE A WRITTEN DESCRIPTION OF SUCH POLICIES AND PROCEDURES.)
3.
Date Initiated (MM/DD/YYYY): 
09/22/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20060054508-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") FAILED TO ESTABLISH ADEQUATE SUPERVISORY PROCEDURES AND SYSTEMS FOR THE
OUTSOURCING OF COMMUNICATIONS WITH ITS CUSTOMERS ABOUT THE SALE OF VONAGE LLC SECURITIES IN CONNECTION WITH VONAGE'S
DIRECTED SHARE PROGRAM, WHICH WAS PART OF VONAGE'S INITIAL PUBLIC OFFERING IN MAY 2006.
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):
09/22/2009
 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: $ 100,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
WITHIN 150 DAYS OF ISSUANCE OF THE AWC, DBSI MUST CERTIFY THAT IT HAS POLICIES AND PROCEDURES IN PLACE RELATING TO
OUTSOURCING IN CONNECTION WITH PUBLIC OFFERINGS OF COMMON STOCK THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE
WITH FINRA RULES, AND PROVIDE A WRITTEN DESCRIPTION OF SUCH POLICIES AND PROCEDURES.
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: 
FINE OF $100,000 PAID ON OCTOBER 6, 2009; RESTITUTION OF NO MORE THAN APPROXIMATELY $52,000 TO NO MORE THAN APPROXIMATELY 59
CUSTOMERS TO BE PAID IN ACCORDANCE WITH PROCEDURES SET FORTH IN THE 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).
DBSI EXECUTED AN AWC WITHOUT ADMITTING OR DENYING FINRA'S FINDINGS. FINRA FOUND THAT DBSI, ONE OF THREE LEAD UNDERWRITERS FOR
THE MAY 24, 2006 INITIAL PUBLIC OFFERING OF THE COMMON STOCK OF VONAGE LLC, FAILED TO ESTABLISH SUPERVISORY PROCEDURES AND
SYSTEMS REASONABLY DESIGNED TO SUPERVISE THE ACTIVITIES OF A THIRD PARTY COMPANY TO WHOM DBSI OUTSOURCED COMMUNICATIONS WITH
DBSI'S CUSTOMERS THROUGH A WEBSITE DEVELOPED BY THE THIRD PARTY COMPANY TO ADMINISTER VONAGE'S DIRECTED SHARE PROGRAM. DBSI
PAID A $100,000 FINE ON OCTOBER 6, 2009 AS REQUIRED. THE AWC SETS FORTH A TIMETABLE PURSUANT TO WHICH (1) FINRA WILL IDENTIFY
CUSTOMERS ELIGIBLE FOR RESTITUTION, (2) DBSI WILL PREPARE NOTIFICATIONS AND CERTIFICATIONS, AND ONCE APPROVED BY FINRA, WILL SEND

SUCH MATERIALS TO ELIGIBLE CUSTOMERS, (3) ELIGIBLE CUSTOMERS MAY RETURN EXECUTED CERTIFICATIONS, AND (4) DBSI WILL PROVIDE
RESTITUTION TO CUSTOMERS WHO TIMELY RETURN EXECUTED CERTIFICATIONS. FURTHER, DBSI IS IN THE PROCESS OF REVIEWING CERTAIN ASPECTS
OF ITS SUPERVISORY POLICIES AND PROCEDURES, IN ACCORDANCE WITH THE TERMS OF THE AWC.

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) 
ALABAMA SECURITIES COMMISSION ("THE COMMISSION")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 

11/05/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NO. CO-2009-0037
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMISSION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
11/05/2009
 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: $ 38,853.36
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO AN ADMINISTRATIVE CONSENT ORDER ENTERED BY THE COMMISSION ON NOVEMBER 5, 2009, DBSI AGREED TO A PAYMENT OF
$18,853.36 TO THE ALABAMA SECURITIES COMMISSION AND $20,000 TO THE STATE OF ALABAMA AND TO TAKE CERTAIN MEASURES WITH
RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 ADMINISTRATIVE CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S
PARENT AND NASAA AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000
TO NASAA MEMBER JURISDICTIONS, AND THE $30,000 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY
AMOUNT. THE ADMINISTRATIVE CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS;
REIMBURSE ELIGIBLE INVESTORS THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL
DAMAGES CLAIMS BY ELIGIBLE INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS
BUY BACK; AND PROVIDE OTHER RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE ADMINISTRATIVE CONSENT ORDER, DBSI CONSENTED TO THE COMMISSION MAKING THE
FOLLOWING CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY
DISCLOSE TO CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS
TO ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST
AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. CODE OF ALABAMA 8-6-3(J)(7) ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO
TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION
WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND

ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. CODE OF ALABAMA 8-6-3(J)(10) ALLOWS THE
COMMISSION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR
EMPLOYEES.

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) 
DIVISION OF SECURITIES OF THE OFFICE OF THE STATE AUDITOR, STATE OF WEST VIRGINIA ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 

11/23/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ORDER NO. 90-2525
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
11/23/2009
 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: $ 30,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO A CONSENT ORDER ENTERED BY THE DIVISION ON NOVEMBER 23, 2009, DBSI AGREED TO PAY A PENALTY OF $30,000 TO THE
WEST VIRGINIA SECURITIES DIVISION AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED
ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $30,000 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE CONSENT
ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT
SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS;
WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS
DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. WEST VIRGINIA CODE SECTION 32-2-204 ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR,
TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION
WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND

ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. WEST VIRGINIA CODE SECTION 32-4-407 ALLOWS THE
DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR
EMPLOYEES.

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

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

11/06/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
11/06/2009
 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: $ 30,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO A CONSENT ORDER ENTERED BY THE DEPARTMENT ON NOVEMBER 6, 2009, DBSI AGREED TO PAY A PENALTY OF $30,000 TO THE
NORTH DAKOTA SECURITIES DEPARTMENT AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT
PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $30,000 PENALTY IMPOSED BY THE DEPARTMENT IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DEPARTMENT MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. N.D.C.C. § 10­4­11(1)(C) ALLOWS THE DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO TAKE
ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH
THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND

ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. N.D.C.C. . § 10­4­11(1)(M) ALLOWS THE DEPARTMENT,
THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
DIVISION OF SECURITIES OF THE DEPARTMENT OF JUSTICE, STATE OF DELAWARE ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/05/2009
 Exact
 Explanation

If not exact, provide explanation:
4.
Docket/Case Number:
CASE NO. 09-7-1
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
11/05/2009
 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: $ 33,075.19
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO A CONSENT ORDER ENTERED BY THE DIVISION ON NOVEMBER 5, 2009, DBSI AGREED TO PAY A PENALTY OF $33,075.19 TO THE
STATE OF DELAWARE AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE
FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $33,075.19 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. 6 DEL. C. §§ 7316(A)(7) ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION
AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH THE
FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. 6 DEL. C. §§ 7316(A)(10) ALLOWS THE DIVISION,

THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
MARKET ASSURANCE DIVISION OF THE DEPARTMENT OF COMMERCE, STATE OF MINNESOTA ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/01/2009
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
12/01/2009
 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: $ 534,460.63
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO A CONSENT ORDER ENTERED BY THE DIVISION ON DECEMBER 1, 2009, DBSI AGREED TO PAY A PENALTY OF $534,460.63 TO THE
MINNESOTA DEPARTMENT OF COMMERCE AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED
ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $534,460.63 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. MINN. STAT. §§ 80A.07, SUBD. 1(7) AND 80A.67(D)(13) ALLOWS THE DIVISION, THROUGH ITS
ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2)
IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE
WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS,
AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY
SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. MINN. STAT. §§ 80A.07, SUBD. 1(10)
AND 80A.67(D)(9) ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY

SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
THE OFFICE OF THE COMMISSIONER OF FINANCIAL INSTITUTIONS OF THE COMMONWEALTH OF PUERTO RICO ("THE OFFICE").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/04/2009
 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
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE OFFICE ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
12/04/2009
 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: $ 30,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO A CONSENT ORDER ENTERED BY THE OFFICE ON DECEMBER 4, 2009, DBSI AGREED TO PAY A PENALTY OF $30,000 TO THE
SECRETARY OF THE TREASURY OF THE COMMONWEALTH OF PUERTO RICO AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND
FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $30,000 PENALTY IMPOSED BY THE OFFICE IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE CONSENT
ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT
SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS;
WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS
DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. SECTION 204(A)(2)(G) OF ACT NO. 60 ALLOWS THE OFFICE, THROUGH ITS ADMINISTRATOR, TO
TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION
WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. SECTION 204(A)(2)(J) OF ACT NO. 60 ALLOWS THE
OFFICE, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR
EMPLOYEES.

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) 
DIVISION OF SECURITIES OF THE DEPARTMENT OF FINANCIAL INSTITUTIONS, STATE OF WASHINGTON ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/01/2009
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
ORDER NO. S-09-195-09-CO01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
12/01/2009
 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: $ 154,308.35
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO A CONSENT ORDER ENTERED BY THE DIVISION ON DECEMBER 1, 2009, DBSI AGREED TO PAY A PENALTY OF $154,308.35 TO THE
WASHINGTON DIVISION OF SECURITIES AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED
ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $30,000 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE CONSENT
ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT
SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS;
WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS
DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. RCW 21.20.110(1)(G) ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION
AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH THE
FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. RCW 21.20.110(1)(J) ALLOWS THE DIVISION,
THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
OFFICE OF FINANCIAL AND INSURANCE REGULATION OF THE DEPARTMENT OF ENERGY, LABOR, AND ECONOMIC GROWTH OF THE STATE OF MICHIGAN
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/02/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:

N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE OFFICE ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
12/02/2009
 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: $ 30,722.72
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO A CONSENT ORDER ENTERED BY THE OFFICE ON DECEMBER 2, 2009, DBSI AGREED TO PAY A PENALTY OF $27,650.45 TO THE
STATE OF MICHIGAN AND $3,072.27 TO THE MICHIGAN INVESTOR PROTECTION TRUST AND TO TAKE CERTAIN MEASURES WITH RESPECT TO
CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $30,722.72 PENALTY IMPOSED BY THE OFFICE IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE CONSENT
ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT
SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS;
WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS
DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE OFFICE MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. MCL 451.604(A)(1)(G) ALLOWS THE OFFICE, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION
AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH THE
FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. MCL 451.604(A)(2) ALLOWS THE OFFICE, THROUGH
ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
COMMISSION OF SECURITIES OF THE COMMONWEALTH OF PENNSYLVANIA ("THE COMMISSION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/15/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
DOCKET NO. 2009-07-10

5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMISSION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
12/15/2009
 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: $ 344,384.49
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER ENTERED BY THE COMMISSION ON DECEMBER 15, 2009, DBSI
AGREED TO PAY A PENALTY OF $344,384.49 TO THE COMMONWEALTH OF PENNSYLVANIA AND TO TAKE CERTAIN MEASURES WITH RESPECT TO
CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST
2008 BETWEEN DBSI'S PARENT AND NASAA AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL
PENALTY OF $15,000,000 TO NASAA MEMBER JURISDICTIONS, AND THE $344,384.49 PENALTY IMPOSED BY THE COMMISSION IS ITS PRO-RATA
SHARE OF THE TOTAL PENALTY AMOUNT. THE ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE
INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR
CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT
PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS DESCRIBED IN THE ORDER.
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 ALLEGATIONS IN THE ORDER, DBSI CONSENTED TO THE COMMISSION MAKING THE FOLLOWING CONCLUSIONS
OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO CLIENTS THE
EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO ARTIFICIALLY PREVENT
FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND UNETHICAL CONDUCT
IN THE SECURITIES BUSINESS. 70 P.S. SECTION 305(A)(IX) ALLOWS THE COMMISSION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI
IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH THE FAILURE TO (I)
PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES
CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE ADEQUATE
DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND ESTABLISH
AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. 70 P.S. SECTION 305(A)(VII) ALLOWS THE COMMISSION,
THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
OFFICE OF SECURITIES OF THE DEPARTMENT OF PROFESSIONAL AND FINANCIAL REGULATION OF THE STATE OF MAINE (THE "OFFICE").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/12/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NO. 09-076
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

y
p
y
g
y
g
y
(
pp
)
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE OFFICE ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/12/2010
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 37,407.91
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE OFFICE ON JANUARY 12, 2010, DBSI AGREED TO PAY A PENALTY OF $37,407.91 TO THE
TREASURER OF THE STATE OF MAINE AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS
BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $37,407.91 PENALTY IMPOSED BY THE OFFICE IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE CONSENT
ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT
SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS;
WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS
DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE OFFICE MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. 32 M.R.S.A. § 16412(4)(M) ALLOWS THE OFFICE, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION
AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH THE
FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. 32 M.R.S.A. § 16412(4)(I) ALLOWS THE OFFICE,
THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
DIVISION OF SECURITIES OF THE OFFICE OF THE SECRETARY OF STATE, STATE OF INDIANA ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/08/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CAUSE NO. 09-0140 CO
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/08/2010
 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: $ 36,504.51
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO FINDINGS OF FACT, CONCLUSIONS OF LAW, AND CONSENT ORDER ENTERED BY THE DIVISION ON JANUARY 8, 2010, DBSI AGREED
TO PAY A PENALTY OF $36,504.51 TO THE INDIANA SECRETARY OF STATE SECURITIES DIVISION AND TO TAKE CERTAIN MEASURES WITH RESPECT
TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 FINDINGS OF FACT, CONCLUSIONS OF LAW, AND CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN
AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A
TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER JURISDICTIONS, AND THE $36,504.51 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA
SHARE OF THE TOTAL PENALTY AMOUNT. THE CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE
INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR
CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT
PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE FINDINGS OF FACT, CONCLUSIONS OF LAW, AND CONSENT ORDER, DBSI CONSENTED TO
THE DIVISION MAKING THE FOLLOWING CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE
FAILURE TO ADEQUATELY DISCLOSE TO CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE
USE OF SUPPORTING BIDS TO ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI
ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. IND. CODE § 23­19­4­12(D)(13) ALLOWS THE DIVISION, THROUGH
ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND
(2) IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE
WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS,
AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY
SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. IND. CODE § 23­19­4­12(D)(9)
ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS
REPRESENTATIVES OR EMPLOYEES.

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) 
DIVISION OF SECURITIES OF THE DEPARTMENT OF THE SECRETARY OF STATE, STATE OF NORTH CAROLINA ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/13/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NC FILE NO. 09SEC48
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/13/2010
 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: $ 92,568.01
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE ADMINISTRATIVE ORDER ENTERED BY THE DIVISION ON JANUARY 13, 2010, DBSI AGREED TO PAY A PENALTY OF $92,568.01
TO THE NORTH CAROLINA SECRETARY OF STATE AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT
PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 ADMINISTRATIVE ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND
NASAA AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA
MEMBER JURISDICTIONS, AND THE $92,568.01 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT.
THE ADMINISTRATIVE ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE
INVESTORS THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY
ELIGIBLE INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND
PROVIDE OTHER RELIEF AS DESCRIBED IN THE ADMINISTRATIVE ORDER.
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 ALLEGATIONS IN THE ADMINISTRATIVE ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. N.C.G.S. 78A-39(A)(2)(G) ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE
ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH
THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. N.C.G.S. 78A-39(A1)(2)(A) ALLOWS THE DIVISION,
THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
DEPARTMENT OF SECURITIES OF THE STATE OF ARKANSAS ("THE DEPARTMENT").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/13/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ORDER NO. S-09-024-09-CO07
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:

Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/13/2010
 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: $ 35,781.78
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DEPARTMENT ON JANUARY 13, 2010, DBSI AGREED TO PAY A PENALTY OF $35,781.78
($3,578.17 TO THE ARKANSAS STATE FUND AT THE INVESTOR PROTECTION TRUST AND $32,203.61 TO THE DEPARTMENT) AND TO TAKE CERTAIN
MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $35,781.78 PENALTY IMPOSED BY THE DEPARTMENT IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DEPARTMENT MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. ARK. CODE ANN. § 23­42­308(A)(2)(G) ALLOWS THE DEPARTMENT, THROUGH ITS
ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2)
IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE
WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS,
AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY
SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. ARK. CODE ANN. § 23­42­308(A)(2)(J)
ALLOWS THE DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS
REPRESENTATIVES OR EMPLOYEES.

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) 
DEPARTMENT OF FINANCIAL INSTITUTIONS OF THE PUBLIC PROTECTION CABINET OF THE COMMONWEALTH OF KENTUCKY ("THE DEPARTMENT").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/11/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AGENCY CASE NO. 2010-AH-002
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:

Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/11/2010
 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: $ 355,586.70
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DEPARTMENT ON JANUARY 11, 2010, DBSI AGREED TO PAY A PENALTY OF $355,386.70 TO
THE KENTUCKY STATE TREASURER AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS
BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $355,386.70 PENALTY IMPOSED BY THE DEPARTMENT IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DEPARTMENT MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. KRS 292.330(13)(A)7 ALLOWS THE DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO TAKE
ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH
THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. KRS 292.330(13)(A)9A ALLOWS THE DEPARTMENT,
THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
OFFICE OF THE SECURITIES COMMISSIONER OF THE STATE OF KANSAS (THE OFFICE").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/08/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
KSC NO. 2010-5641
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other

Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE OFFICE ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/08/2010
 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: $ 30,903.40
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE OFFICE ON JANUARY 8, 2010, DBSI AGREED TO PAY A PENALTY OF $30,903.40 TO THE
OFFICE OF THE KANSAS SECURITIES COMMISSIONER AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT
PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $30,903.40 PENALTY IMPOSED BY THE OFFICE IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE CONSENT
ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT
SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS;
WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS
DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE OFFICE MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. K.S.A. 17-12A412(D)(13) ALLOWS THE OFFICE, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION
AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH THE
FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. K.S.A. 17-12A412(D)(9) ALLOWS THE OFFICE,
THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
DIVISION OF SECURITIES OF THE OFFICE OF THE SECRETARY OF STATE OF THE STATE OF MISSOURI (THE "DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/14/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE NO. AP-10-04
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 

AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/14/2010
 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: $ 42,466.97
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DIVISION ON JANUARY 14, 2010, DBSI AGREED TO PAY A PENALTY OF $42,466.97 TO THE
MISSOURI SECURITIES DIVISION AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS
BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $42,466.97 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. SECTION 409.4-412(D)(13), RSMO. ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO
TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION
WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. SECTION 409.4-412(D)(13), RSMO. ALLOWS THE
DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR
EMPLOYEES.

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) 
DIVISION OF SECURITIES OF THE DEPARTMENT OF STATE OF THE COMMONWEALTH OF MASSACHUSETTS ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/26/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
E-2009-0066
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 

AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/26/2010
 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: $ 3,210,161.72
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE ADMINISTRATIVE CONSENT ORDER ENTERED BY THE DIVISION ON JANUARY 26, 2010, DBSI AGREED TO PAY A PENALTY OF
$3,210,161.72 TO THE DIVISION OF SECURITIES AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT
PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 ADMINISTRATIVE CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S
PARENT AND NASAA AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000
TO NASAA MEMBER JURISDICTIONS, AND THE $3,210,161.72 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY
AMOUNT. THE ADMINISTRATIVE CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS;
REIMBURSE ELIGIBLE INVESTORS THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL
DAMAGES CLAIMS BY ELIGIBLE INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS
BUY BACK; AND PROVIDE OTHER RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE FINDINGS OF FACT, CONCLUSIONS OF LAW, AND CONSENT ORDER, DBSI CONSENTED TO
THE DIVISION MAKING THE FOLLOWING CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE
FAILURE TO ADEQUATELY DISCLOSE TO CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE
USE OF SUPPORTING BIDS TO ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI
ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. MASS. GEN. L. CH. 110A. § 204(A)(2)(G) ALLOWS THE DIVISION,
THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES
BUSINESS; AND (2) IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND
MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO
CLIENTS BY ITS AGENTS, AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI
FAILED TO REASONABLY SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. MASS. GEN.
L. CH. 110A. § 204(A)(2)(J) ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY
SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
DEPARTMENT OF SECURITIES OF THE STATE OF OKLAHOMA ("THE DEPARTMENT").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
02/01/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ODS FILE NO. 09-142
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 

AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
02/01/2010
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 37,407.91
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DEPARTMENT ON FEBRUARY 1, 2010, DBSI AGREED TO PAY A PENALTY OF $37,407.91 TO
THE OKLAHOMA SECURITIES DEPARTMENT AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT
PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $37,407.91 PENALTY IMPOSED BY THE DEPARTMENT IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. OKLAHOMA SECURITIES COMMISSION RULE 660:11-5-42 ALLOWS THE DEPARTMENT, THROUGH
ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND
(2) IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE
WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS,
AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY
SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. OKLAHOMA SECURITIES COMMISSION
RULE 660:11-5-42 ALLOWS THE DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY
SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
DIVISION OF FINANCE AND CORPORATE SECURITIES, STATE OF OREGON ("THE DIVISON")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/27/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE NO. S-09-0039
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 

AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/27/2010
 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: $ 40,298.80
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE ORDER ASSESSING CIVIL PENALTY AND CONSENT TO ENTRY OF ORDER ENTERED BY THE DIVISION ON JANUARY 27, 2010, DBSI
AGREED TO PAY A PENALTY OF $40,298.80 TO THE STATE OF OREGON AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND
FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 ASSESSING CIVIL PENALTY AND CONSENT TO ENTRY OF ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN
AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A
TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER JURISDICTIONS, AND THE $40,298.80 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA
SHARE OF THE TOTAL PENALTY AMOUNT. THE ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE
INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR
CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT
PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE ORDER ASSESSING CIVIL PENALTY AND CONSENT TO ENTRY OF ORDER, DBSI CONSENTED
TO THE DIVISION MAKING THE FOLLOWING CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II)
THE FAILURE TO ADEQUATELY DISCLOSE TO CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III)
THE USE OF SUPPORTING BIDS TO ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS,
DBSI ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. ORS 59.205(2) ALLOWS THE DIVISION, THROUGH ITS
ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2)
IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE
WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS,
AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY
SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. ORS 59.205(13) ALLOWS THE
DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR
EMPLOYEES.

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) 
DIVISION OF SECURITIES OF THE DEPARTMENT OF REGULATORY AGENCIES OF THE DEPARTMENT OF STATE OF THE STATE OF COLORADO
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/20/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ORDER NO 10-6-14
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 

AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/20/2010
 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: $ 184,843.39
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DIVISION ON JANUARY 20, 2010, DBSI AGREED TO PAY A PENALTY OF $184,843.39 TO THE
DIVISION OF SECURITIES AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE
FEBRUARY 13, 2008
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $184,843.39 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE FINDINGS OF FACT, CONCLUSIONS OF LAW, AND CONSENT ORDER, DBSI CONSENTED TO
THE DIVISION MAKING THE FOLLOWING CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE
FAILURE TO ADEQUATELY DISCLOSE TO CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE
USE OF SUPPORTING BIDS TO ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI
ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. C.R.S. § 11­51­410(1)(G) ALLOWS THE DIVISION, THROUGH ITS
ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2)
IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE
WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS,
AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY
SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. C.R.S. § 11­51­410(1)(G)(I) ALLOWS
THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR
EMPLOYEES.

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

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

11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
ACCEPTANCE, WAIVER AND CONSENT ("AWC")
3.
Date Initiated (MM/DD/YYYY): 
02/16/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2008014450501
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)

Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT DBSI VIOLATED RULES 200(G), 203(A)(1), 203(B)(1), AND 203(B)(3) OF REGULATION SHO, RULES 15C-3(M), 15C3-(N) AND 17A-3
OF THE SECURITIES ACT OF 1934, FINRA RULE 2010, AND NASD RULES 2110, 3010, 3110(A) AND 8211 IN THAT THE FIRM ALLEGEDLY: ACCEPTED
SHORT SALE ORDERS FROM ITS CLIENTS AND SUBSEQUENTLY RELEASED THEM FOR EXECUTION THROUGH ITS DIRECT MARKET ACCESS PLATFORM
WITHOUT HAVING BORROWED THE SECURITIES OR ENTERED INTO BONA-FIDE ARRANGEMENTS TO BORROW THE SECURITIES, OR HAVING REASONABLE
GROUNDS TO BELIEVE THAT THE SECURITIES COULD BE BORROWED FOR DELIVERY WHEN DUE, AND WITHOUT THE PROPER DOCUMENTED
COMPLIANCE OF SUCH; FAILED TO HAVE REASONABLE GROUNDS TO MARK CLIENT SELL ORDERS AS LONG AND UTILIZED BORROWED SHARES FOR
DELIVERY AND/OR FAILED TO DELIVER SECURITIES RELATED TO SUCH CLIENT LONG SALES; FAILED TO MONITOR ITS FAILS IN THRESHOLD SECURITIES
LISTED ON THE ARCHIPELAGO EXCHANGE, AND CONSEQUENTLY DID NOT CLOSE OUT SUCH FAILS AS REQUIRED AND/OR EXECUTED SHORT SALES IN
THESE SECURITIES WHILE AN AGED FAIL WAS PENDING WITHOUT FIRST HAVING BORROWED OR ARRANGED TO BORROW THE SECURITY AS REQUIRED;
PROVIDED INACCURATE INFORMATION ON THE FIRM'S BLUE SHEET REPORTS BY ERRONEOUSLY REFLECTING POSITION MOVEMENTS BETWEEN RELATED
CLIENT ACCOUNTS AS BUY AND SELL TRANSACTIONS AND, IN CERTAIN INSTANCES ERRONEOUSLY REPORTED SHORT SALES AS LONG SALES; DID NOT
MONITOR, EFFECT BUY-INS OR FILE EXTENSIONS FOR CLIENT LONG SALE ORDERS WHERE THE FIRM HAD NOT OBTAINED POSSESSION OF THE
SECURITIES FROM THE CUSTOMER WITHIN 10 DAYS AFTER SETTLEMENT DATE; THE FIRM INCORRECTLY BOOKED CUSTOMER LONG SALE ORDERS TO
SHORT ACCOUNTS WHEN CUSTOMERS DID NOT MAINTAIN A LONG POSITION AT THE FIRM AND FAILED TO MAINTAIN TRADE DATA RELATING TO A
CUSTOMER THAT SUBMITTED TRADES THROUGH ITS DIRECT MARKET ACCESS PLATFORM; IN CONNECTION WITH THE POINTS ABOVE, FAILING TO
IMPLEMENT PROCEDURES AND SYSTEMS REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE RELEVANT SECTIONS OF REG. SHO, THE RULES
OF THE NASD AND FINRA, AND OTHER SECURITIES LAWS AND REGULATIONS.
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):
02/16/2010
 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: $ 575,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND FINE OF $575,000. THE FINE WAS PAID ON MARCH 2, 2010.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), CONSENTING TO A
CENSURE AND FINE OF $575,000.00.

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) 
DEPARTMENT OF BANKING AND FINANCE OF THE STATE OF NEBRASKA ("THE DEPARTMENT").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/05/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE

SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
03/05/2010
 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: $ 74,086.10
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE FINDINGS OF FACT, CONCLUSIONS OF LAW, AND CONSENT ORDER ENTERED BY THE DEPARTMENT ON MARCH 5, 2010, DBSI
AGREED TO PAY A PENALTY OF $74,086.10 TO THE NEBRASKA DEPARTMENT OF BANKING AND FINANCE AND TO TAKE CERTAIN MEASURES WITH
RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 FINDINGS OF FACT, CONCLUSIONS OF LAW, AND CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN
AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A
TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER JURISDICTIONS, AND THE $74,086.10 PENALTY IMPOSED BY THE DEPARTMENT IS ITS PRO-
RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM
ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR
CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT
PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE FINDINGS OF FACT, CONCLUSIONS OF LAW, AND CONSENT ORDER, DBSI CONSENTED TO
THE DEPARTMENT MAKING THE FOLLOWING CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II)
THE FAILURE TO ADEQUATELY DISCLOSE TO CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III)
THE USE OF SUPPORTING BIDS TO ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS,
DBSI ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. NEB. REV. STAT. § 8­1103(9)(A)(VII) ALLOWS THE
DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE
SECURITIES BUSINESS; AND (2) IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE
AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS
TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS,
DBSI FAILED TO REASONABLY SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. NEB.
REV. STAT. § 8­1103(9)(A)(XI) ALLOWS THE DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO
REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
DIVISION OF SECURITIES OF THE DEPARTMENT OF REGULATION AND LICENSING OF THE STATE OF NEW MEXICO ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/10/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ORDER NO. 09-09-053-059
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES

BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
03/10/2010
 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: $ 51,862.37
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DIVISION ON MARCH 10, 2010, DBSI AGREED TO PAY A PENALTY OF $51,862.37 TO THE
DIVISION OF SECURITIES AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE
FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $51,862.37 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. NMSA § 58­13B­16A(2)(H) ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE
ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH
THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. NMSA § 58­13B­16A(2)(K) ALLOWS THE DIVISION,
THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
DIVISION OF SECURITIES OF THE OFFICE OF THE ATTORNEY GENERAL OF THE STATE OF SOUTH CAROLINA ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/11/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 09090
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS

AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
03/11/2010
 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: $ 33,252.25
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE ADMINISTRATIVE CONSENT ORDER ENTERED BY THE DIVISION ON MARCH 11, 2010, DBSI AGREED TO PAY A PENALTY OF
$33,252.25 TO THE DIVISION OF SECURITIES AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT
PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 ADMINISTRATIVE CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S
PARENT AND NASAA AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000
TO NASAA MEMBER JURISDICTIONS, AND THE $33,252.25 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY
AMOUNT. THE ADMINISTRATIVE CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS;
REIMBURSE ELIGIBLE INVESTORS THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL
DAMAGES CLAIMS BY ELIGIBLE INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS
BUY BACK; AND PROVIDE OTHER RELIEF AS DESCRIBED IN THE ADMINISTRATIVE CONSENT ORDER.
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 ALLEGATIONS IN THE ADMINISTRATIVE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE
FOLLOWING CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY
DISCLOSE TO CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS
TO ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST
AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. THE SOUTH CAROLINA UNIFORM SECURITIES ACT OF 2005 ALLOWS THE DIVISION,
THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES
BUSINESS; AND (2) IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND
MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO
CLIENTS BY ITS AGENTS, AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI
FAILED TO REASONABLY SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. THE SOUTH
CAROLINA UNIFORM SECURITIES ACT OF 2005 ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS
FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
BUREAU OF SECURITIES OF THE DEPARTMENT OF FINANCE OF THE STATE OF IDAHO ("THE DEPARTMENT").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/08/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
DOCKET NO. 2009-07
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY

SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
04/08/2010
 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: $ 30,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DEPARTMENT ON APRIL 8, 2010, DBSI AGREED TO PAY A PENALTY OF $30,000 TO THE
IDAHO DEPARTMENT OF FINANCE AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS
BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $30,000 PENALTY IMPOSED BY THE DEPARTMENT IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DEPARTMENT MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. IDAHO CODE SECTION 30-14-412(D)(13) ALLOWS THE DEPARTMENT, THROUGH ITS
ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2)
IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE
WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS,
AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY
SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. IDAHO CODE SECTION 30-14-412(D)
(9) ALLOWS THE DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS
REPRESENTATIVES OR EMPLOYEES.

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

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

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
STATE SECURITIES BOARD OF THE STATE OF TEXAS ("THE BOARD").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/08/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ORDER NO. IC10-CAF-11
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE BOARD ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS

AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
04/08/2010
 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: $ 827,886.15
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE BOARD ON APRIL 8, 2010, DBSI AGREED TO PAY A PENALTY OF $827,886.15 TO THE TEXAS
STATE SECURITIES BOARD AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE
FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $827,886.15 PENALTY IMPOSED BY THE BOARD IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE BOARD MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. SECTION 115.10(B)(1) OF THE BOARD RULES ALLOWS THE BOARD, THROUGH ITS
ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2)
IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE
WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS,
AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY
SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. SECTION 115.10(B)(1) OF THE BOARD
RULES ALLOWS THE BOARD, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS
REPRESENTATIVES OR EMPLOYEES.

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) 
DIVISION OF SECURITIES OF THE OFFICE OF THE SECRETARY OF STATE, STATE OF WYOMING ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/09/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ORDER NO. 09-09
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS

AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
04/09/2010
 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: $ 79,325.84
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DIVISION ON APRIL 9, 2010, DBSI AGREED TO PAY A PENALTY OF $79,325.84 TO THE
WYOMING SECRETARY OF STATE AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS
BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $79,325.84 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. W.S. § 17­4­106(A)(II)(G) ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE
ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH
THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. W.S. § 17­4­106(B)(II) ALLOWS THE DIVISION,
THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS OF THE STATE OF HAWAII ("THE DEPARTMENT").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/13/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
SEU-2008-73
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.

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):
04/13/2010
 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: $ 33,071.57
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DEPARTMENT ON APRIL 13, 2010, DBSI AGREED TO PAY A PENALTY OF $33,071.57 TO THE
HAWAII DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS - COMPLIANCE RESOLUTION FUND, AND TO TAKE CERTAIN MEASURES WITH
RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $33,071.57 PENALTY IMPOSED BY THE DEPARTMENT IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DEPARTMENT MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. HRS § 485­15(7) ALLOWS THE DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION
AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH THE
FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. HRS § 485­15(10) ALLOWS THE DEPARTMENT,
THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File

with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
STATE CORPORATION COMMISSION OF THE COMMONWEALTH OF VIRGINIA (THE "COMMISSION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/16/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE NO. SEC-2009-00074
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMISSION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.

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):
04/16/2010
 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: $ 214,475.04
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE COMMISSION ON APRIL 16, 2010, DBSI AGREED TO PAY A PENALTY OF $214,475.04 TO THE
TREASURER OF THE COMMONWEALTH OF VIRGINIA AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT
PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $214,475.04 PENALTY IMPOSED BY THE COMMISSION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE COMMISSION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. COMMISSION RULES 21 VAC 5-20-280 A 3 AND E 12 ALLOW THE COMMISSION, THROUGH ITS
ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2)
IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE
WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS,
AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY
SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. COMMISSION RULES 21 VAC 5-20-
260 A AND B ALLOW THE COMMISSION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE
ITS REPRESENTATIVES OR EMPLOYEES.

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) 
DIVISION OF SECURITIES OF THE DEPARTMENT OF FINANCIAL INSTITUTIONS OF THE STATE OF WISCONSIN (THE "DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/08/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. S-09148(EX)
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.

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):
04/08/2010
 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: $ 44,454.46
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DIVISION ON APRIL 8, 2010, DBSI AGREED TO PAY A PENALTY OF $44,454.46 TO THE
WISCONSIN DEPARTMENT OF FINANCIAL INSTITUTIONS AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS
THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $44,454.46 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE FINDINGS OF FACT, CONCLUSIONS OF LAW, AND CONSENT ORDER, DBSI CONSENTED TO
THE DIVISION MAKING THE FOLLOWING CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE
FAILURE TO ADEQUATELY DISCLOSE TO CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE
USE OF SUPPORTING BIDS TO ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI
ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. WIS. STATS. § 551.34(1)(G) ALLOWS THE DIVISION, THROUGH ITS
ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2)
IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE
WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS,
AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY
SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. WIS. STATS. § 551.34(1)(J) ALLOWS
THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR
EMPLOYEES.

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) 
ICE FUTURES U.S., INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/15/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2010-015
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED EXCHANGE FLOOR TRADING RULE 4.31 (C) BY FAILING TO REPORT (4) BLOCK TRADES WITHIN
THE FIVE (5) MINUTES REQUIRED TIME PERIOD.
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):
04/15/2010
 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: $ 500.00
 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: 
DBSI WAS ISSUED A SUMMARY FINE OF $500.00. IT WAS PAID ON MAY 5, 2010.
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).
DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED EXCHANGE FLOOR TRADING RULE 4.31 (C) BY FAILING TO REPORT (4) BLOCK TRADES WITHIN
THE FIVE (5) MINUTES REQUIRED TIME PERIOD. DBSI WAS ISSUED A SUMMARY FINE OF $500.00. IT WAS PAID ON MAY 5, 2010.

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) 
DIVISION OF SECURITIES OF THE DEPARTMENT OF COMMERCE AND INSURANCE OF THE STATE OF TENNESSEE (THE "DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/10/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CAUSE NO. 09-018 (SI-2008-010)
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
05/10/2010
 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: $ 468,512.16

 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DIVISION ON MAY 10, 2010, DBSI AGREED TO PAY A PENALTY OF $468,512.16 TO THE
TENNESSEE DEPARTMENT OF COMMERCE AND INSURANCE AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS
THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $468,512.16 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. TENN. CODE ANN. § 48­2­112(A)(2)(G) ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR,
TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION
WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. TENN. CODE ANN. § 48­2­112(A)(2)(J) ALLOWS THE
DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR
EMPLOYEES.

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) 
DIVISION OF SECURITIES AND CHARITIES OF THE OFFICE OF THE MISSISSIPPI SECRETARY OF STATE (THE "DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/10/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. S-09-0225
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
05/10/2010
 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: $ 30,000.00

 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DIVISION ON MAY 10, 2010, DBSI AGREED TO PAY A PENALTY OF $30,000 TO THE
MISSISSIPPI OFFICE OF THE SECRETARY OF STATE AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT
PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $30,000 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE CONSENT
ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT
SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS;
WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS
DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. MISS. CODE ANN. SECTION 75-71-321(A)(F) ALLOWS THE DIVISION, THROUGH ITS
ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2)
IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE
WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS,
AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY
SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. MISS. CODE ANN. SECTION 75-71-
321(B)(A) ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS
REPRESENTATIVES OR EMPLOYEES.

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) 
LOUISIANA OFFICE OF FINANCIAL INSTITUTIONS, COMMISSIONER OF SECURITIES (THE "COMMISSIONER").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/07/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE NO. OFI-2010-006
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMISSIONER ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
06/07/2010
 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: $ 30,000.00

 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE COMMISSIONER ON JUNE 7, 2010, DBSI AGREED TO PAY A PENALTY OF $30,000 TO THE
LOUISIANA COMMISSIONER OF SECURITIES AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT
PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $30,000 PENALTY IMPOSED BY THE COMMISSIONER IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE COMMISSIONER MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. LSA-R.S. 51:712A(2) ALLOWS THE COMMISSIONER TO TAKE ACTION AGAINST DBSI IF IT HAS
ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH THE FAILURE TO (I) PROVIDE
ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS,
(III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS
OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES
NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. LSA-R.S. 51:712A ALLOWS THE COMMISSIONER TO TAKE ACTION AGAINST DBSI IF IT HAS
FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
DIVISION OF SECURITIES OF THE OFFICE OF THE SECRETARY OF STATE, STATE OF IOWA ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/14/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
DOCKET NO. 67154
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
06/14/2010
 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: $ 31,445.45
 Revocation/Expulsion/Denial
 Disgorgement/Restitution

 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DIVISION ON JUNE 14, 2010, DBSI AGREED TO PAY A PENALTY OF $31,445.45 TO THE
IOWA INSURANCE DIVISION AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE
FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $31,445.45 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. IOWA CODE § 502.412(4)(M) (2009) ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO
TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION
WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. IOWA CODE § 502.412(4)(I) (2009) ALLOWS THE
DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR
EMPLOYEES.

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

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.

This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
ACCEPTANCE, WAIVER AND CONSENT ("AWC")
3.
Date Initiated (MM/DD/YYYY): 
07/20/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2008012808701
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESIDENTIAL MORTGAGE BACKED SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED VIOLATIONS BY THE FIRM OF NASD RULE 2110 RELATING TO (1) NEGLIGENT ERRORS IN DESCRIBING, IN THE PROSPECTUS
SUPPLEMENTS FOR 6 RMBS OFFERINGS, THE METHODOLOGY BY WHICH MORTGAGE DELINQUENCY RATES WERE CALCULATED AND (2) NEGLIGENT
ERRORS IN REPORTING HISTORICAL MORTGAGE DELINQUENCY RATES IN STATIC POOL INFORMATION POSTED ON THE FIRM'S REG AB WEBSITE IN
CONNECTION WITH 16 RMBS OFFERINGS. IN ADDITION, FINRA ALLEGED THAT THE FIRM FAILED TO HAVE A SUFFICIENT SYSTEM IN PLACE TO IDENTIFY
AND CORRECT INACCURACIES IN STATIC POOL INFORMATION POSTED ON THE FIRMS' REG AB WEBSITE, IN VIOLATION OF NASD RULES 3010 AND
2110.
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):
07/20/2010
 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: $ 7,500,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND FINE OF $7,500,00.00. THE FINE WAS PAID ON 8/2/2010.
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 ALLEGATIONS, DBSI AGREED TO AS LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") CONSENTING TO
A CENSURE AND FINE OF $7,500,000.00.

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) 
DEPARTMENT OF BANKING OF THE STATE OF CONNECTICUT ("THE DEPARTMENT").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/09/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
DOCKET NO. CO-10-7799-S
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
08/09/2010
 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: $ 343,481.09
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DEPARTMENT ON AUGUST 9, 2010, DBSI AGREED TO PAY A PENALTY OF $343,481.09 TO
THE TREASURER OF THE STATE OF CONNECTICUT AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT
PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER

JURISDICTIONS, AND THE $343,481.09 PENALTY IMPOSED BY THE DEPARTMENT IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DEPARTMENT MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. SECTION 36B-15(A)(2)(H) OF THE CONNECTICUT UNIFORM SECURITIES ACT ALLOWS THE
DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE
SECURITIES BUSINESS; AND (2) IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE
AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS
TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS,
DBSI FAILED TO REASONABLY SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT.
SECTION 36B-31-6(F)(B) OF THE REGULATIONS OF CONNECTICUT STATE AGENCIES ENACTED PURSUANT TO THE CONNECTICUT UNIFORM SECURITES
ACT ALLOWS THE DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS
REPRESENTATIVES OR EMPLOYEES.

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) 
DIVISION OF BANKING AND INSURANCE IN THE OFFICE OF THE LIEUTENANT GOVERNOR OF THE UNITED STATES VIRGIN ISLANDS ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/12/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CAUSE NO. 08-10
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THERE WERE NO AFFECTED INVESTORS FROM THE VIRGIN ISLANDS. THE DIVISION STATED THAT IT HAD JURISDICTION OVER THIS MATTER PURSUANT
TO CHAPTER 23, 9VIC, SECTIONS 602(1) AND 661(A). THE DIVISION FOUND THAT THE RELIEF WAS APPROPRIATE AND IN THE PUBLIC INTEREST.
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):
08/12/2010
 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: $ 30,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE ADMINISTRATIVE CONSENT ORDER ENTERED BY THE DIVISION ON AUGUST 12, 2010, DBSI AGREED TO PAY A PENALTY OF
$30,000 TO THE VIRGIN ISLANDS DIVISION OF BANKING AND INSURANCE.
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 ADMINISTRATIVE CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S
PARENT AND NASAA AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000
TO NASAA MEMBER JURISDICTIONS, AND THE $30,000 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY

AMOUNT.
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).
DBSI DID NOT ADMIT OR DENY THE ALLEGATIONS IN THE ADMINISTRATIVE CONSENT ORDER. THERE WERE NO AFFECTED INVESTORS FROM THE VIRGIN
ISLANDS. THE DIVISION STATED THAT IT HAD JURISDICTION OVER THIS MATTER PURSUANT TO CHAPTER 23, 9VIC, SECTIONS 602(1) AND 661(A). THE
DIVISION FOUND THAT THE RELIEF WAS APPROPRIATE AND IN THE PUBLIC INTEREST.

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) 
DIVISION OF SECURITIES OF THE OFFICE OF THE ATTORNEY GENERAL OF THE STATE OF MARYLAND ("THE DIVISION").
2.
Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/22/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
SECURITIES DIVISON NO. 2009-0311
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
09/22/2010
 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: $ 718,212.94
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DIVISION ON SEPTEMBER 22, 2010, DBSI AGREED TO PAY A PENALTY OF $718,212.94 TO
THE MARYLAND DIVISION OF SECURITIES AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED
ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $718,212.94 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE FINDINGS OF FACT, CONCLUSIONS OF LAW, AND CONSENT ORDER, DBSI CONSENTED TO
THE DIVISION MAKING THE FOLLOWING CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE
FAILURE TO ADEQUATELY DISCLOSE TO CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE
USE OF SUPPORTING BIDS TO ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI

ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. SECTION 11-412(A)(7) OF THE MARYLAND SECURITIES ACT
ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES
IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II)
CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS
CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS
BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH
CONDUCT. SECTION 11-412(A)(7) OF THE MARYLAND SECURITIES ACT ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION
AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
CHICAGO BOARD OF TRADE (CME GROUP)
2.
Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/29/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
03-CH-0310
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):
CHICAGO BOARD OF TRADE (CME GROUP) ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED CBOT RULE 980.A IN THAT IT FAILED TO
TIMELY PROVIDE THE NECESSARY DOCUMENTS TO THE CHICAGO BOARD OF TRADE TO COMPLETE ITS AUDIT.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
09/29/2010
 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: $ 25,000.00
 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: 
DBSI WAS FINED $25,000.00. IT WAS PAID ON OCTOBER 12, 2010.
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 ALLEGATIONS DBSI AGREED TO PAY THE FINE OF $25,000.00. THE FINE WAS FINE WAS PAID ON OCTOBER 12,
2010.

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) 
ICE FUTURES U.S., INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/04/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2010-055
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):

DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED EXCHANGE FLOOR TRADING RULE 4.31(C) BY FAILING TO REPORT (1) BLOCK TRADE WITHIN FIVE
(5) MINUTES REQUIRED TIME.
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):
10/04/2010
 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: $ 1,000.00
 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: 
DBSI WAS ISSUED A SUMMARY FINE OF $1,000.00. IT WAS PAID ON OCTOBER 12, 2010.
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).
DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED EXCHANGE FLOOR TRADING 4.31(C)BY FAILING TO REPORT (1) BLOCK TRADE WITHIN THE FIVE
(5) MINUTES REQUIRED TIME PERIOD. DBSI WAS ISSUED A SUMMARY FINE OF $1,000.00. IT WAS PAID ON OCTOBER 12, 2010.

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) 
CHICAGO BOARD OF TRADE ("CBOT")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/11/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE # 10-05138
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHICAGO BOARD OF TRADE ("CBOT") DURING A ROUTINE COMPUTERIZED TRADING RECONSTRUCTION SYSTEM ("CTR") EXAMINATION (FOR THE
PERIOD OF 7/12/10 THROUGH 7/20/10) ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED CBOT RULE 536.F IN THAT TRADE DATA
FOR CERTAIN TRADE DATES REFLECTED A CTR ERROR RATE HIGHER THAT CBOT'S ACCEPTABLE THRESHOLD.
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):
11/11/2010
 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: 
DEUTSCHE BANK SECURITIES INC. ("DBSI") CONSENTED TO A FINE OF $5,000.00 IN ACCORDANCE WITH THE AUTOMATIC FINE SCHEDULE. THE
FINE WAS PAID ON 11/5/2010.
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).
DBSI PAID THE FINE ON 11/5/10.

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) 
CHICAGO MERCANTILE EXCHANGE INC. ("CME")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/11/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE # 10-07425
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHICAGO MERCANTILE EXCHANGE INC. ("CME") DURING A ROUTINE COMPUTERIZED TRADING RECONSTRUCTION SYSTEM ("CTR") EXAMINATION
(FOR THE PERIOD 7/6/10 THROUGH 7/22/10) ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED CBOT RULE 536.F IN THAT TRADE
DATA FOR CERTAIN TRADE DATES REFLECTED A CTR ERROR RATE HIGHER THAT CBOT'S ACCEPTABLE THRESHOLD.
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):
11/11/2010
 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: $ 2,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
DEUTSCHE BANK SECURITIES INC. ("DBSI") CONSENTED TO A FINE OF $2,500.00 IN ACCORDANCE WITH THE AUTOMATIC FINE SCHEDULE. THE
FINE WAS PAID ON 11/5/2010.

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).
DBSI PAID THE FINE ON 11/5/2010.

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) 
DEPARTMENT OF COMMERCE, COMMUNITY, AND ECONOMIC DEVELOPMENT, DIVISION OF BANKING AND SECURITIES OF THE STATE OF ALASKA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 

3.
Date Initiated (MM/DD/YYYY): 
12/23/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ORDER NO. 10-15-S
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
12/23/2010
 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: $ 30,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE ADMINISTRATIVE CONSENT ORDER ENTERED BY THE DIVISION ON DECEMBER 23, 2010, DBSI AGREED TO PAY A PENALTY OF
$30,000 TO THE STATE OF ALASKA AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS
BEFORE FEBRUARY 13, 2008.
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 ADMINISTRATIVE CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S
PARENT AND NASAA AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000
TO NASAA MEMBER JURISDICTIONS, AND THE $30,000 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY
AMOUNT. THE ADMINISTRATIVE CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS;
REIMBURSE ELIGIBLE INVESTORS THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL
DAMAGES CLAIMS BY ELIGIBLE INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS
BUY BACK; AND PROVIDE OTHER RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE FINDINGS OF FACT, CONCLUSIONS OF LAW, AND CONSENT ORDER, DBSI CONSENTED TO
THE DIVISION MAKING THE FOLLOWING CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE
FAILURE TO ADEQUATELY DISCLOSE TO CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE
USE OF SUPPORTING BIDS TO ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI
ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. A.S. 45.55.060(A)(7) ALLOWS THE DIVISION, THROUGH ITS
ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2)
IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE
WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS,

AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY
SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. A.S. 45.55.060(B)(1) ALLOWS THE
DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR
EMPLOYEES.

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) 
OFFICE OF FINANCIAL REGULATION OF THE STATE OF FLORIDA (THE "OFFICE")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 

3.
Date Initiated (MM/DD/YYYY): 
02/01/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ADMINISTRATIVE PROCEEDING NO. 0441-S-07/09
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE OFFICE ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
02/01/2011
 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: $ 509,165.32
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT AGREEMENT AND FINAL ORDER ENTERED BY THE OFFICE ON FEBRUARY 1, 2011, DBSI AGREED TO PAY A PENALTY OF
$509,165.32 TO THE DEPARTMENT OF FINANCIAL SERVICES OF THE STATE OF FLORIDA AND TO TAKE CERTAIN MEASURES WITH RESPECT TO
CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT AGREEMENT AND FINAL ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN
DBSI'S PARENT AND NASAA AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF
$15,000,000 TO NASAA MEMBER JURISDICTIONS, AND THE $509,165.32 PENALTY IMPOSED BY THE OFFICE IS ITS PRO-RATA SHARE OF THE TOTAL
PENALTY AMOUNT. THE CONSENT AGREEMENT AND FINAL ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE
INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR
CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT
PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT AGREEMENT AND FINAL ORDER, DBSI CONSENTED TO THE OFFICE MAKING THE
FOLLOWING CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY
DISCLOSE TO CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS
TO ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST
AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. SECTION 517.161(1)(H) OF THE FLORIDA STATUTES AND RULE 69W-600.013(1)(H)(1) OF
THE FLORIDA ADMINISTRATIVE CODE ALLOWS THE OFFICE, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN
UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE
TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE

ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST
CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO
DETECT AND PREVENT SUCH CONDUCT. SECTION 517.161(1)(H) OF THE FLORIDA STATUTES AND RULE 69W-600.013(1)(H)(1) OF THE FLORIDA
ADMINISTRATIVE CODE ALLOWS THE OFFICE, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY
SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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

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

3.
Date Initiated (MM/DD/YYYY): 
01/25/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20060065005-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
NASDAQ SECURITIES, NYSE SECURITIES, REPORTABLE SECURITIES, CONVENTIONAL OPTIONS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT DBSI VIOLATED: (1) NASD RULE 3360 WITH RESPECT TO CERTAIN SHORT INTEREST REPORTS BETWEEN FEBRUARY 15, 2006 AND
FEBRUARY 15, 2007 AND NASD RULE 2110 AND NYSE RULE 421.10 REGARDING A SHORT INTEREST POSITION REPORT FOR SEPTEMBER 15, 2006; (2)
NASD RULE 6955(A) WITH RESPECT TO CERTAIN OATS REPORTS FROM JULY 1, 2006 THROUGH SEPTEMBER 30, 2006; (3) NASD RULE 2860(B)(5) WITH
RESPECT TO CERTAIN LOPRS FROM JUNE 11, 2007 THROUGH JUNE 15, 2007; (4) NASD RULE 6130(B) BY FAILING TO ACCEPT OR DECLINE CERTAIN
TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES FROM MAY 1, 2007 THROUGH AUGUST 31, 2007; AND (5) NASD RULE 6130(B) BY
FAILING TO ACCEPT OR DECLINE CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES FROM MAY 1, 2008 THROUGH AUGUST 31,
2008.
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):
01/25/2011
 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: $ 65,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND FINE OF $65,000.00. THE FINE WAS PAID ON 2/11/11.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSNET ("AWC") CONSENTING TO A
CENSURE AND FINE OF $65,000.00

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) 
DIVISION OF SECURITIES OF THE DEPARTMENT OF COMMERCE OF THE STATE OF OHIO ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/21/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ORDER NO. 11-013
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:

Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
03/21/2011
 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: $ 110,583.61
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DIVISION ON MARCH 21, 2011, DBSI AGREED TO PAY A PENALTY OF $110,583.61 TO THE
OHIO DIVISION OF SECURITIES' INVESTOR EDUCATION AND ENFORCEMENT EXPENSE FUND AND TO TAKE CERTAIN MEASURES WITH RESPECT TO
CURRENT AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $110,583.61 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. ORC SECTIONS 1707.19(A)(4),(9) ALLOW THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE
ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION WITH
THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. ORC SECTIONS 1707.19(A)(4),(9) AND OHIO
ADMINISTRATIVE CODE RULE 1301:6-3-19(B)(9) ALLOW THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS
FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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) 
AMERICAN STOCK EXCHANGE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
02/17/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
HBD# 11-AMEX-1
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:

Options
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NYSE AMEX ALLEGED THAT DURING THE PERIOD OF NOVEMBER 2003 THROUGH MARCH 2008 DBSI: 1. VIOLATED AMERICAN STOCK EXCHANGE RULE
906(A) BY REPORTING THE OPTIONS POSITIONS OF APPROXIMATELY 340 PRIME BROKERAGE CLIENTS TO THE LARGE OPTIONS POSITION REPORT IN
THE AGGREGATE VIA AN OMNIBUS ACCOUNT RATHER THAT AT THE CLIENT ACCOUNT LEVEL 2. VIOLATED AMERICAN STOCK EXCHANGE RULE 320 BY
FAILING TO REASONABLY SUPERVISE AND IMPLEMENT ADEQUATE CONTROLS, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW,
REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH AMERICAN STOCK EXCHANGE RULE 906(A).
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
04/27/2011
 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: $ 150,000.00
 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: 
DBSI CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE OF $150.000.00. THE FINE WILL BE PAID.
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 ALLEGATIONS, DBSI CONSENTED TO THE IMPOSITION OF A CENSURE AND A FINE OF $150.000.00

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) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
06/28/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE NO. 2008013864402
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON MAY 17, 2011 DEUTSCHE BANK SECURITIES INC. (DBSI) SUBMITTED AN OFFER OF ACCEPTANCE, WAIVER & CONSENT (AWC) TO FINDINGS BY FINRA
THAT DBSI DID NOT ADEQUATELY SUPERVISE THE TRADING ACTIVITY OF CERTAIN FORMER DBSI REGISTERED REPRESENTATIVES WHO, BETWEEN
JANUARY 2005 AND MAY 2008, "SHADOWED" THE CONFIDENTIAL TRADING STRATEGIES OF THIRD-PARTY INVESTMENT ADVISERS. THE AWC FOUND THAT
DBSI FAILED TO IMPLEMENT APPROPRIATE PROCEDURES TO DETECT AND PREVENT THE SHADOWING ACTIVITY, WHICH VIOLATED DBSI POLICY AND
AGREEMENTS BETWEEN DBSI AND THE INVESTMENT ADVISERS. AS A RESULT, THE AWC FOUND THAT DBSI VIOLATED NASD RULES 2110 AND 3010.
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):
06/28/2011
 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: $ 350,000.00
 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: 
DBSI CONSENTED TO MAKE PAYMENT OF A $350,000 FINE, WHICH IT PAID ON JUNE 28, 2011. DBSI ALSO CONSENTED TO A CENSURE.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON MAY 17, 2011, DBSI SUBMITTED AN AWC TO FINRA, AND WAS NOTIFIED OF ITS ACCEPTANCE BY FINRA ON JUNE 28, 2011. IN THE AWC, SOLELY FOR
THE PURPOSE OF THE PROCEEDING ANY OTHER ACTION IN WHICH FINRA IS A PARTY AND WITHOUT ADMITTING OR DENYING THE FINDINGS SET FORTH
IN THE AWC, DBSI CONSENTED TO FINDINGS THAT DBSI VIOLATED CERTAIN NASD RULES AS SET FORTH IN 7, ABOVE. IN ADDITION TO THE PAYMENT OF
THE FINE, DBSI AGREED TO A CENSURE.

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) 
DEPARTMENT OF INSURANCE, SECURITIES AND BANKING OF THE DISTRICT OF COLUMBIA ("THE DEPARTMENT").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/11/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ORDER NO. SB-CO-10-11
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY
SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
05/11/2011
 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: $ 125,399.43

 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE ADMINISTRATIVE CONSENT ORDER ENTERED BY THE DEPARTMENT ON MAY 11, 2011, DBSI AGREED TO PAY A PENALTY OF
$125,399.43 TO THE DC DEPARTMENT OF INSURANCE, SECURITIES AND BANKING AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT
AND FORMER CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 ADMINISTRATIVE CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S
PARENT AND NASAA AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000
TO NASAA MEMBER JURISDICTIONS, AND THE $125,399.43 PENALTY IMPOSED BY THE DEPARTMENT IS ITS PRO-RATA SHARE OF THE TOTAL
PENALTY AMOUNT. THE ADMINISTRATIVE CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE
INVESTORS; REIMBURSE ELIGIBLE INVESTORS THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR
CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT
PART OF THE ARS BUY BACK; AND PROVIDE OTHER RELIEF AS DESCRIBED IN THE ADMINISTRATIVE CONSENT ORDER.
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 ALLEGATIONS IN THE ADMINISTRATIVE CONSENT ORDER, DBSI CONSENTED TO THE DEPARTMENT MAKING THE
FOLLOWING CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY
DISCLOSE TO CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS
TO ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST
AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. D.C. CODE § 31­5602.07(A)(9) ALLOWS THE DEPARTMENT, THROUGH ITS ADMINISTRATOR,
TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2) IN CONNECTION
WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE WRITTEN SUPERVISORY
PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS, AND (IV) ENSURE
ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE, AND
ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. D.C. CODE § 31­5602.07(A)(12) ALLOWS THE
DEPARTMENT, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR
EMPLOYEES.

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) 
DIVISION OF SECURITIES OF THE OFFICE OF THE SECRETARY OF STATE OF THE STATE OF GEORGIA ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/21/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ENSC-10059
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
09/21/2011
 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: $ 146,719.76

 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE ADMINISTRATIVE CONSENT ORDER ENTERED BY THE DIVISION ON SEPTEMBER 21, 2011, DBSI AGREED TO PAY A PENALTY OF
$146,719.76 TO THE GEORGIA OFFICE OF THE SECRETARY OF STATE AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER
CLIENTS THAT PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 ADMINISTRATIVE CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S
PARENT AND NASAA AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000
TO NASAA MEMBER JURISDICTIONS, AND THE $146,719.76 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY
AMOUNT. THE CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE
ELIGIBLE INVESTORS THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES
CLAIMS BY ELIGIBLE INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK;
AND PROVIDE OTHER RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE ADMINISTRATIVE CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE
FOLLOWING CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY
DISCLOSE TO CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS
TO ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST
AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. SECTION 10-5-4(A)(8) OF THE GEORGIA SECURITIES ACT OF 1973 ALLOWS THE DIVISION,
THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES
BUSINESS; AND (2) IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND
MAINTAIN ADEQUATE WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO
CLIENTS BY ITS AGENTS, AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI
FAILED TO REASONABLY SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. SECTION 10-
5-4(A)(11) OF THE GEORGIA SECURITIES ACT OF 1973 ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT
HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVES OR EMPLOYEES.

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:
This advisory affiliate is 
a Firm
an Individual

Registered:
Yes
No
Name:
DEUTSCHE BANK AG ("DBAG")
(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) 
ICE U.S. OTC COMMODITY MARKETS, LLC
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/12/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
MATTER NO. 11-00116
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ICE U.S. OTC COMMODITY MARKETS, LLC ALLEGED DBAG VIOLATED ICE OTC RULE 1.13 (ENFORCEMENT OF POSITION LIMITS AND POSITION
ACCOUNTABILITY LEVELS)BY HOLDING BOTH INTRA-DAY AND INTER-DAY POSITIONS IN EXCESS OF THE FIRM'S EXEMPTED POSITION LIMIT FOR JULY
2011 ICE HENRY HUB LD1 CONTRACT BETWEEN JUNE 23, 2011 AND JUNE 24, 2011.
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):
10/12/2011
 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: $ 20,000.00
 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 FINE OF $20,000 WAS PAID ON OCTOBER 18, 2011.
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 ALLEGATIONS, DBAG AGREED TO THE SETTLEMENT AND FINE OF $20,000.

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) 
DIVISION OF SECURITIES OF THE DEPARTMENT OF COMMERCE OF THE STATE OF UTAH ("THE DIVISION").
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/27/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
DOCKET NO. SD-11-0088
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"): (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE SECURITIES
BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS"), AND (2) FAILED TO REASONABLY SUPERVISE ITS
AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
10/27/2011
 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: $ 188,095.65
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE STIPULATION AND CONSENT ORDER ENTERED BY THE DIVISION ON OCTOBER 27, 2011, DBSI AGREED TO PAY A PENALTY OF
$188,095.65 TO THE UTAH DIVISION OF SECURITIES AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT
PURCHASED ARS BEFORE FEBRUARY 13, 2008.
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 STIPULATION AND CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S
PARENT AND NASAA AND THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000

TO NASAA MEMBER JURISDICTIONS, AND THE $188,095.65 PENALTY IMPOSED BY THE DIVISION IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY
AMOUNT. THE CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE
ELIGIBLE INVESTORS THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURE FOR CONSEQUENTIAL DAMAGES
CLAIMS BY ELIGIBLE INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK;
AND PROVIDE OTHER RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE STIPULATION AND CONSENT ORDER, DBSI CONSENTED TO THE DIVISION MAKING THE
FOLLOWING CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY
DISCLOSE TO CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS
TO ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST
AND UNETHICAL CONDUCT IN THE SECURITIES BUSINESS. UTAH CODE ANN. § 61­1­6(2)(A)(II)(G) ALLOWS THE DIVISION, THROUGH ITS
ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS ENGAGED IN UNETHICAL OR DISHONEST PRACTICES IN THE SECURITIES BUSINESS; AND (2)
IN CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS, (II) CREATE AND MAINTAIN ADEQUATE
WRITTEN SUPERVISORY PROCEDURES CONCERNING ARS, (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS,
AND (IV) ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY
SUPERVISE, AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT. UTAH CODE ANN. § 61­1­6(2)(A)(II)(J)
ALLOWS THE DIVISION, THROUGH ITS ADMINISTRATOR, TO TAKE ACTION AGAINST DBSI IF IT HAS FAILED TO REASONABLY SUPERVISE ITS
REPRESENTATIVES OR EMPLOYEES.

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) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA")
2.
Principal Sanction:
Censure
Other Sanctions: 
CIVIL AND ADMINISTRATIVE PENALT(IES)/FINE(S). UNDERTAKINGS TO INCLUDE ADDITIONAL TERMS IN THE FIRM'S ELECTRONIC MESSAGE REVIEW
PROTOCOL, AND TO REVIEW ITS SUPERVISORY SYSTEM AND PROCEDURES, WITH RESPECT TO PERSONAL FINANCIAL DIFFICULTIES OF CLIENT
ADVISORS AND RESPONDING TO "RED FLAGS" OF POTENTIAL MISCONDUCT RELATING TO SUCH PERSONAL FINANCIAL DIFFICULTIES.
3.
Date Initiated (MM/DD/YYYY): 
08/10/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NO. 2010023096302
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):
THIS MATTER STEMS FROM THE PERSONAL FINANCIAL DIFFICULTIES OF A FORMER DBSI CLIENT ADVISOR IN THE FIRM'S BOSTON BRANCH.  BETWEEN
APPROXIMATELY JANUARY 2009 AND APRIL 2010, THE CLIENT ADVISOR MISUSED A CORPORATE CREDIT CARD FOR PERSONAL CHARGES, BOUNCED
CHECKS, AND BORROWED MONEY FROM ONE OF HIS CUSTOMERS. DBSI TERMINATED HIS EMPLOYMENT IN APRIL 2010.  IN THE AWC SETTLING THIS
MATTER, DBSI ACCEPTED AND CONSENTED, WITHOUT ADMITTING OR DENYING, THAT THE FIRM'S LEXICON-BASED SEARCH SYSTEM FOR THE REVIEW OF
ELECTRONIC CORRESPONDENCE IN THE PCS DIVISION WAS INADEQUATE TO SEARCH FOR TERMS INDICATING THAT A CLIENT ADVISOR MIGHT BE
EXPERIENCING PERSONAL FINANCIAL DIFFICULTIES AND/OR VIOLATING CERTAIN APPLICABLE LAWS, RULES OR REGULATIONS IN CONNECTION WITH
THOSE DIFFICULTIES, AND THAT THE FIRM'S SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE TO EFFECTIVELY
RESPOND TO SUCH "RED FLAGS."  ACCORDINGLY, AS SET FORTH MORE FULLY IN THE AWC,  THE FIRM HAS UNDERTAKEN TO ADD TERMS TO ITS EMAIL
REVIEW LEXICON FOR CLIENT ADVISORS, TO REVIEW ELECTRONIC COMMUNICATIONS OF CLIENT ADVISORS FROM JANUARY 1, 2012 TO DATE USING
THOSE ADDITIONAL TERMS,  AND TO REVIEW ITS SUPERVISORY PROCEDURES FOR RESPONDING TO "RED FLAGS" OF POTENTIAL MISCONDUCT BY A
CLIENT ADVISOR RELATING TO SUCH PERSONAL FINANCIAL DIFFICULTIES.
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):
08/10/2012
 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: $ 100,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND FINE OF $100,000.00. THE FINE WAS PAID ON 8/22/12.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") CONSENTING TO A
CENTURE AND FINE OF $100,000.00.

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) 
CHICAGO BOARD OF TRADE (CME GROUP)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/07/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CBOT 11-8175-BC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CHICAGO BOARD OF TRADE (CME GROUP) ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED CBOT RULE 17107.B. IN THAT DURING
THE MARCH 2011 DELIVERY CYCLE, BASED UPON INTENTS AND INVOICES THE FIRM SUBMITTED TO THE EXCHANGE, DBSI WAS SHORT-POSITION
HOLDER SCHEDULED TO DELIVER ROUGH RICE RECEIPTS TO MULTIPLE LONG-POSITION HOLDERS STOPPED FOR DELIVERY. HOWEVER, DBSI FAILED TO
COMPLETELY DELIVER ALL RECEIPTS OVER THE ELECTRONIC WAREHOUSE RECEIPT SYSTEM PRIOR TO THE 1:00 PM DEAD LINE ON MARCH 2, 2011.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
08/07/2012
 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: $ 15,000.00
 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: 
DBSI WAS FINED $15,000.00. IT WAS PAID ON 8/10/2012.
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 ALLEGATIONS, DBSI AGREED TO PAY THE FINE OF $15,000.00. THE FINE WAS PAID ON 8/10/2012.

DRP Pages

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) 
CHICAGO MERCANTILE EXCHANGE ("CME")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/18/2012
 Exact
 Explanation

p
If not exact, provide explanation:
4.
Docket/Case Number:
12-CH-1204
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):
CME ALLEGED THAT DEUTSCHE BANK SECURITIES INC ("DBSI") VIOLATED CHICAGO BOARD OF TRADE ("CBOT") RULE 970.A.4 RELATING TO COMPUTING
AND RECORDING BALANCES IN THE NET CAPITAL COMPUTATION, CBOT RULE 971.A.2 RELATING TO RECORDING AND REPORTING BALANCES IN
SEGREGATION SECURED SEQUESTERED ACCOUNTS, AND CBOT RULE 971.A.3 RELATING TO IDENTIFYING SEGREGATED, SECURED AND SEQUESTERED
ACCOUNTS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
08/29/2012
 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:
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: 
DBSI WAS ORDERED TO PAY A FINE OF $50,000.00
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).
ON AUGUST 6, 2012, DBSI SUBMITTED AN OFFER OF SETTLEMENT FOR $50,000.00 WITHOUT ADMITTING OR DENYING THE CHARGES. CME ACCEPTED
DBSI'S OFFER OF SETTLEMENT EFFECTIVE AUGUST 29, 2012. THE FIRM PAID THE $50,000.00.

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) 
CME
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/27/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CME 11-08055-BC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CME ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") BETWEEN JULY 2010 AND MARCH 2012, EXECUTED MULTIPLE BLOCK TRADES FOR
CUSTOMERS IN VARIOUS CME CONTRACTS THAT WERE NOT REPORTED TO THE EXCHANGE WITHIN THE APPLICABLE TIME LIMIT FOLLOWING
EXECUTION IN VIOLATION OF CME RULE 526.F. DURING THE SAME TIME FRAME, DBSI MISREPORTED TO THE EXCHANGE THE ACCURATE TIME OF
EXECUTION OF MULTIPLE BLOCK TRADES IN VIOLATION OF CME RULE 432.I. IN ADDITION, DBSI FAILED TO MAINTAIN ACCURATE RECORDS OF THE

BLOCK TRADE TRANSACTIONS. CME ALSO FOUND THAT THE FIRM VIOLATED CME RULE 432.W BY FAILING TO DILIGENTLY SUPERVISE ITS EMPLOYEES
OR AGENTS IN THE CONDUCT OF THEIR BUSINESS RELATING TO THE EXCHANGE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
11/27/2012
 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: $ 250,000.00
 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: 
DBSI CONSENTED TO THE DECISION & ORDER OF SETTLEMENT AND FINED $250,000.00. THE FINE WAS PAID ON DECEMBER 7, 2012.
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 ALLEGATIONS, DBSI ACCEPTED THE DECISION & OFFER OF SETTLEMENT CONSENTING TO A FINE OF
$250,000.00.

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) 
CHICAGO BOARD OF TRADE ("CBOT")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/27/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CBOT 09-04307-BC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CBOT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") BETWEEN OCTOBER 1, 2009 AND MARCH 16, 2012, EXECUTED MULTIPLE BLOCK
TRADES FOR CUSTOMERS IN VARIOUS CBOT CONTRACTS THAT WERE NOT REPORTED TO THE EXCHANGE WITHIN THE APPLICABLE TIME LIMIT
FOLLOWING EXECUTION. DBSI EMPLOYEES ALSO REPORTED SEVERAL INTER-COMMODITY SPREAD TRADES TO THE EXCHANGE AS BLOCK TRADES WHEN
THESE TRANSACTIONS DID NOT MEET THE MINIMUM QUANTITY THRESHOLD FOR INTER-COMMODITY SPREAD BLOCK TRADES, THESES ACTIONS
VIOLATED CBOT RULES 526.A AND F . DURING THE SAME TIME FRAME, DBSI, MISREPORTED TO THE EXCHANGE THE TRUE AND ACCURATE TIME OF
EXECUTION OF MULTIPLE BLOCK TRADES, ON TWO OCCASIONS, DBSI EMPLOYEES APPEARED TO INTENTIONALLY MISREPORT BLOCK TRADES'
EXECUTION TIMES IN ORDER TO GIVE THE APPEARANCE THAT THE TRANSACTIONS WERE REPORTED TO THE EXCHANGE WITHIN THE APPLICABLE TIME
LIMIT FOLLOWING EXECUTION, THESE ACTIONS VIOLATED CBOT RULE 432.I. IN ADDITION, DBSI FAILED TO MAINTAIN ACCURATE WRITTEN OR
ELECTRONIC RECORDS OF THE BLOCK TRADE TRANSACTIONS, THESE ACTIONS VIOLATED CBOT RULE 536. CME ALSO FOUND THAT THE FIRM VIOLATED
CME RULE 432.W BY FAILING TO DILIGENTLY SUPERVISE ITS EMPLOYEES OR AGENTS IN THE CONDUCT OF THEIR BUSINESS RELATING TO THE
EXCHANGE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
11/27/2012
 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: $ 550,000.00
 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: 
DBSI CONSENTED TO THE DECISION & ORDER OF OFFER SETTLEMENT AND FINED $550,000.00. THE FINE WAS PAID ON DECEMBER 6, 2012.
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 ALLEGATIONS, DBSI ACCEPTED THE DECISION & ORDER OF SETTLEMENT CONSENTING TO A FINE OF
$550,000.00

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) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
RESTITUTION
3.
Date Initiated (MM/DD/YYYY): 
11/26/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20090174106-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
OTC, CORPORATE AND MUNICIPAL DEBT
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI"), (A) IN SEVEN TRANSACTION PAIRS BETWEEN OCTOBER 1, 2008 AND DECEMBER 31,
2008, THE FIRM SOLD CORPORATE BONDS TO CUSTOMERS AND FAILED TO SELL SUCH BONDS AT A PRICE THAT WAS FAIR, TAKING INTO
CONSIDERATION ALL RELEVANT CIRCUMSTANCES, IN VIOLATION OF NASD RULES 2110, 2440 AND IM-2440.; (B) FROM MARCH 14, 2008 TO APRIL 15,
20 I 0, ON 29 SETTLEMENT DATES, THE FIRM SUBMITTED TO FINRA INACCURATE SHORT INTEREST POSITION REPORTS IN VIOLATION OF NASD RULE
3360, NYSE RULE 421, AND FINRA RULE 4560 (FOR SETTLEMENT DATES ON OR AFTER DECEMBER 15, 2008).; (C) DURING THE PERIODS JANUARY 14,
2008 THROUGH MARCH 31, 2008 AND JULY 8, 2008 THROUGH SEPTEMBER 30, 2008, THE FIRM TRANSMITTED TO THE FNTRF 70 LAST SALE REPORTS OF
TRANSACTIONS IN DESIGNATED SECURITIES AND FAILED TO DESIGNATE SUCH REPORTS AS REFLECTING A PRICE DIFFERENT FROM THE CURRENT
MARKET WHEN THE EXECUTION WAS BASED ON A PRIOR REFERENCE POINT IN TIME IN VIOLATION OF NASD RULE 4632(A)(5)(G). THE FIRM ALSO
FAILED TO DESIGNATE AS ".W" TO THE FNTRF 13 LAST SALES REPORTS OF TRANSACTIONS IN NMS SECURITIES THAT OCCURRED AT PRICES BASED ON
AN AVERAGE WEIGHTING OR ANOTHER SPECIAL PRICING FORMULA IN VIOLATION OF NASD RULE 4632(A)(5)(E) AND FAILED TO REPORT THE CORRECT
TIME OF EXECUTION TO THE FNTRF IN 78 LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES IN VIOLATION OF NASD RULE 4632(C)
(5).; (D) DURING THE PERIOD MAY 1, 2010 THROUGH MAY 31, 2010, THE FIRM FAILED TO SHOW THE CORRECT TERMS AND CONDITIONS ON THE
MEMORANDUM OF 41 BROKERAGE ORDERS IN VIOLATION OF SEC RULE 17A-3 AND NASD RULE 3110.; (E) DURING THE PERIOD JULY 1, 2010 THROUGH
SEPTEMBER 30, 2010, THE FIRM FAILED TO REPORT THE CORRECT TIME OF TRADE TO THE RTRS IN 24 REPORTS OF TRANSACTIONS IN MUNICIPAL
SECURITIES IN VIOLATION OF MSRB RULE G-14(B)(II). THE FIRM ALSO FAILED TO REPORT INFORMATION REGARDING 24 PURCHASE AND SALE
TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE RTRS IN THE MANNER PRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS
USERS MANUAL IN VIOLATION OF MSRB RULE G-14, AND IN 23 INSTANCES, THE FIRM IMPROPERLY REPORTED INFORMATION TO THE RTRS THAT IT WAS
NOT REQUIRED TO REPORT IN VIOLATION OF MSRB RULE G-14. THE FIRM ALSO FAILED TO SHOW THE CORRECT TIME OF EXECUTION ON THE
MEMORANDUM OF 24 BROKERAGE ORDERS IN MUNICIPAL SECURITIES IN VIOLATION OF MSRB RULE G-8. (F) DURING THE PERIOD APRIL 1, 2010
THROUGH JUNE 30, 2010, THE FIRM FAILED TO REPAIR 3,041 REJECTED ROES TRANSMITTED TO OATS IN VIOLATION OF FINRA RULE 7450. (G) DURING
THE PERIOD MAY 1, 2010 THROUGH AUGUST 31, 2010, THE FIRM FAILED TO ACCEPT OR DECLINE IN THE FNTRF 126 TRANSACTIONS IN REPORTABLE
SECURITIES WITHIN 20 MINUTES AFTER EXECUTION IN VIOLATION OF FINRA RULE 7230A; (H) DURING THE PERIOD JULY 1, 2010 THROUGH SEPTEMBER
30, 2010, IN 49 INSTANCES THE FIRM IMPROPERLY REPORTED INFORMATION TO THE RTRS THAT IT SHOULD NOT HAVE IN VIOLATION OF MSRB RULE G-
14; AND (I) DURING THE PERIOD JULY 1, 2011 THROUGH SEPTEMBER 30, 2011 THE FIRM FAILED TO REPORT TO TRACE 629 S1 TRANSACTIONS WITHIN
15 MINUTES OF THE TIME OF EXECUTION IN VIOLATION OF FINRA RULE 6730( A) 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):
11/26/2012
 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: $ 175,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
$10,314.44 PLUS INTEREST RESITUTION
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: 
DBSI CONSENTED TO A CENSURE AND FINE OF $175,000.00. THE FINE WAS PAID ON DECEMBER 13, 2012.
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 ALLEGATIONS DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") CONSENTING TO A
CENSURE AND FINE. THE FINE OF $175,000 WAS COMPRISED OF $20,000 FOR THE FAIR PRICING VIOLATIONS; $50,000 FOR THE SHORT INTEREST
REPORTING VIOLATIONS; $22,500 FOR THE TRADE REPORTING VIOLATIONS; $5,000 FOR THE BOOKS AND RECORDS VIOLATIONS; $12,500 FOR THE
VIOLATIONS OF MSRB RULE G-14 AND $2,500 FOR THE VIOLATIONS OF MSRB RULE G-8; 12,500 FOR THE OATS VIOLATIONS; $22,500 FOR THE TRADE
REPORTING VIOLATIONS; $22,500 FOR THE VIOLATIONS OF MSRB RULE G-14; AND $5,000 FOR THE TRACE REPORTING VIOLATIONS. RESTITUTION IN A
TOTAL AMOUNT OF $10,314.44 PLUS STATUTORY INTEREST TO CUSTOMERS IN CONNECTION WITH THE FAIR PRICING 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:
Censure
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/21/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2008016167401
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Options
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") FROM JULY 2006 THROUGH DECEMBER 15, 2008, FAILED TO REPORT APPROXIMATELY
8,760 OPTIONS POSITIONS IN CONVENTIONAL OPTIONS TO THE LOPR IN VIOLATION OF NASD RULE 2860(B)(5). ALSO BETWEEN MARCH 23, 2011 AND
MARCH 30, 2011, ONE OF THE FIRM'S CUSTOMERS EXCEEDED THE POSITION LIMIT IN HK939 IN VIOLATION OF FINRA RULE 2360(B)(3) AND THE FIRM
FAILED TO SUBMIT TO THE OCC ITS OCEND FOR APPROXIMATELY TWO MONTHS FROM MARCH 23, 2011 THROUGH MAY 31, 2011 IN VIOLATION OF
FINRA RULE 2360(B)(3)(A)(VII)(B)(4)(B). IN ADDITION, FROM DECEMBER 1, 2010 THROUGH OCTOBER 6, 2011 THE FIRM FAILED TO ACCURATELY
REPORT APPROXIMATELY 20,542 OPTIONS POSITIONS IN CONVENTIONAL OPTIONS TO THE LOPR IN VIOLATION OF FINRA RULE 2360(B)(5), AND FROM
JULY 2006 TO DECEMBER 2011, THE FIRM FAILED TO IMPLEMENT AND MAINTAIN AN ADEQUATE SYSTEM OF FOLLOW-UP AND REVIEW DESIGNED TO
REASONABLE ENSURE THE SUBMISSION OF COMPLETE AND ACCURATE LOPRS IN VIOLATION OF NASD RULE 3010, NASD 2110 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):

11/21/2012
 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: $ 35,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND A FINE OF $35,000. THE FINE WAS PAID ON DECEMBER 12, 2012.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") CONSENTING TO A
CENSURE AND FINE OF $35,000.00

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) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE, UNDERTAKING TO REVISE WRITTEN SUPERVISORY PROCEDURES
3.
Date Initiated (MM/DD/YYYY): 
12/14/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20080136798-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT DURING THE PERIOD FROM JANUARY 1, 2008 THROUGH JUNE 15, 2012, IN 98 INSTANCES, DEUTSCHE BANK SECURITIES INC.'S
("DBSI" OR "FIRM") TRADE VOLUME MANUALLY ADVERTISED BY TRADERS ON AUTEX, BLOOMBERG AND/OR REUTERS SUBSTANTIALLY EXCEEDED THE
FIRM'S EXECUTED TRADE VOLUME FOR THE SECURITY INVOLVED. FINRA ALLEGED THAT THIS CONDUCT VIOLATED NASD RULE S 2110, 2210, 3310 AND
IM-3310. IN ADDITION, FINRA ALLEGED THAT, DURING THE PERIOD OCTOBER 15, 2010 THROUGH JUNE 15, 2012, THE FIRM'S SYSTEMS FAILED TO
ACCURATELY ADVERTISE TRADE VOLUME. FINRA ALLEGED THAT MORE THAN FOUR BILLION SHARES, WHICH COMPRISED ABOUT FOUR PERCENT OF THE
FIRM'S VOLUME DURING THE PERIOD, THAT WERE NOT ELIGIBLE FOR ADVERTISEMENT WERE ADVERTISED. FINRA ALLEGED THAT THIS CONDUCT
VIOLATED FINRA RULES 2010 AND 5210 AND NASD RULE 2210. FINALLY, FINRA ALLEGED THAT THE FIRM FAILED TO ESTABLISH AND IMPLEMENT A
SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH REGULATORY REQUIREMENTS FOR ACCURACY IN THE FIRM'S
ADVERTISEMENTS OF EXECUTED TRADE VOLUME. FINRA ALLEGED THAT THIS CONDUCT VIOLATED NASD RULE 2010 (FOR THE PERIOD PRIOR TO
DECEMBER 15, 2008), FINRA RULE 2010 (FOR THE PERIOD ON AND AFTER DECEMBER 15, 2008) AND NASD RULE 3010.
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):
12/14/2012
 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: $ 1,250,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension

B.
Other Sanctions Ordered:
COMPLY WITH UNDERTAKING TO REVISE THE FIRM'S SUPERVISORY PROCEDURES
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 FINRA'S FINDINGS AND WITHOUT ADJUDICATION OF ANY ISSUE OF LAW OR FACT, DBSI CONSENTED, SOLELY
FOR THE PURPOSE OF THIS PROCEEDING, TO THE ENTRY OF FINRA'S FINDINGS WITH RESPECT TO ALLEGATIONS OF VIOLATIONS OF NASD AND
FINRA RULES (LISTED UNDER ALLEGATIONS) AS A RESULT OF OVERSTATING ITS ADVERTISED TRADE VOLUME AND FAILING TO ESTABLISH AND
IMPLEMENT APPROPRIATE SUPERVISORY PROCEDURES REGARDING ADVERTISED TRADE VOLUME. DBSI ALSO CONSENTED TO THE FOLLOWING
SANCTIONS: A CENSURE AND FINE IN THE AMOUNT OF $1.25 MILLION; AND AN UNDERTAKING TO REVISED THE FIRM'S SUPERVISORY
PROCEDURES RELATING TO ADVERTISED TRADE VOLUME. THE FINE WAS PAID ON 1/2/13.
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).
IN DETERMINING THE SANCTIONS IN THIS MATTER, FINRA TOOK INTO ACCOUNT THAT, UPON RECEIVING THE FINRA STAFF'S INITIAL INQUIRY LETTER
FOR THIS MATTER, THE FIRM (I) CONDUCTED AN INTERNAL INVESTIGATION, (II) PROVIDED A WRITTEN SUMMATION OF THE RESULTS OF THAT
INVESTIGATION, AND (III) IMPOSED DISCIPLINARY ACTIONS AGAINST SOME OF THE TRADERS RESPONSIBLE FOR CERTAIN OF THE INFLATED
ADVERTISEMENTS. IN ADDITION, THE FIRM SELF-REPORTED THE REMAINDER OF THE VIOLATIONS TO THE FINRA STAFF PRIOR TO FINRA BECOMING
AWARE OF THE ISSUES INVOLVED.

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) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
12/31/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2011029270401
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: 
EQUITY - EQUITY LISTED (COMMON & PREFERRED STOCK)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT DURING THE PERIOD JANUARY 1, 2009 THROUGH JUNE, 30, 2011, DEUTSCHE BANK SECURITIES INC. ("DBSI") FAILED TO DELIVER
CERTAIN MUTUAL FUND PROSPECTUSES TO DBSI CUSTOMERS WITHIN THREE BUSINESS DAYS OF THEIR PURCHASES, AND DBSI FAILED TO ESTABLISH
AND MAINTAIN ADEQUATE SUPERVISORY SYSTEMS AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO MONITOR AND ENSURE THE
TIMELY DELIVERY OF MUTUAL FUND PROSPECTUSES. IT WAS ALSO ALLEGED THAT DURING THE PERIOD JANUARY 1, 2011 THROUGH MAY 31, 2011, DBSI
FAILED TO DELIVER CERTAIN PRELIMINARY IPO PROSPECTUSES TO DBSI CUSTOMERS, AND DBSI FAILED TO ESTABLISH AND MAINTAIN ADEQUATE
SUPERVISORY SYSTEMS AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO MONITOR AND ENSURE THE TIMELY DELIVERY OF
PRELIMINARY IPO PROSPECTUSES. ACCORDINGLY, FINRA FOUND THAT DBSI VIOLATED NASD CONDUCT RULES 3010(A)(1) AND (B)(1) 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):
12/31/2012
 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: $ 125,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND FINE OF $125,000.00. THE FINE WAS PAID ON 1/9/2013.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") CONSENTING TO A
CENSURE AND FINE OF $125,000.00.

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) 
FINRA

2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
12/31/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20090161645-01
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: 
DEBT-MUNICIPAL
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT FROM MAY 11, 2009 THROUGH JANUARY 15, 2010, DBSI DID NOT SEPARATELY IDENTIFY ON ORDER MEMORANDA FOR NEGOTIATED
CORPORATE DEBT PRINCIPAL TRANSACTIONS WITH INSTITUTIONAL CUSTOMERS, THE TIME OF RECEIPT OF THE ORDER AND THE TIME OF EXECUTION
OF THE TRADE. INSTEAD, THE FIRM RECORDED ONLY ONE TIME FOR PURPOSES OF COMPLIANCE WITH SEC RULE 17A-3. THIS VIOLATED SEC RULE 17A-
3, NASD CONDUCT RULE 3110 AND FINRA RULE 2010. DURING THE SAME TIME PERIOD, THE FIRM DID NOT SEPARATELY IDENTIFY ON ORDER
MEMORANDA FOR NEGOTIATED MUNICIPAL DEBT PRINCIPAL TRANSACTIONS WITH INSTITUTIONAL CUSTOMERS, THE TIME OF RECEIPT OF THE ORDER
AND TIME OF EXECUTION OF THE TRADE. INSTEAD, THE FIRM RECORDED ONLY ONE TIME FOR PURPOSES OF COMPLIANCE WITH MSRB RULE G-8. THIS
VIOLATED MSRB RULE G-8. ADDITIONALLY, FINRA ALLEGED THAT, IN VIOLATION OF SEC RULE 10B-10 AND FINRA RULE 2010, IN 13 CONFIRMATIONS OF
TRACE ELIGIBLE CORPORATE DEBT TRANSACTIONS WITH INSTITUTIONAL CUSTOMERS THE FIRM DID NOT DISCLOSE THE REQUIRED YIELD AND 31
SUCH CONFIRMATIONS CONTAINED INACCURATE YIELD INFORMATION. FINALLY, FINRA ALLEGED THAT FROM JULY 21, 2009 THROUGH JANUARY 15,
2010, THE FIRM FAILED TO ENFORCE ITS WRITTEN PROCEDURES CONCERNING RECORDING TIMES OF ORDER RECEIPT, ENTRY AND EXECUTION WITH
RESPECT TO NEGOTIATED CORPORATE DEBT TRANSACTIONS WITH INSTITUTIONAL CUSTOMERS IN VIOLATION OF NASD RULE 3010 AND FINRA RULE
2010. BY FAILING TO ENFORCE THOSE PROCEDURES WITH RESPECT TO NEGOTIATED MUNICIPAL DEBT TRANSACTIONS WITH INSTITUTIONAL
CUSTOMERS, THE FIRM VIOLATED MSRB RULE 0-27. ADDITIONALLY, AT ALL RELEVANT TIMES, THE FIRM'S WRITTEN PROCEDURES REQUIRED THAT
CONFIRMATIONS TO CUSTOMERS INCLUDE RELEVANT YIELD INFORMATION. BY FAILING TO ENFORCE THOSE PROCEDURES TO ENSURE ACCURATE YIELD
INFORMATION WAS INCLUDED ON CERTAIN CONFIRMATIONS, AS SET FORTH ABOVE, THE FIRM VIOLATED NASD RULE 3010 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):
12/31/2012
 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:
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: 
DBSI CONSENTED TO A CENSURE AND FINE OF $75,000.00. THE FINE WAS PAID ON 1/15/2013.

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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") CONSENTING TO A
CENSURE AND FINE OF $75,000.00.

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) 
CME
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 

3.
Date Initiated (MM/DD/YYYY): 
12/17/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
12-CH-1206
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
SWAPS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CME ALLEGED THAT DBSI VIOLATED CBOT RULES 971.B AND 971.E BY FAILING TO TIMELY FILE A DAILY STATEMENT OF SECURED AMOUNTS WITH CME
ON OCTOBER 9, 2012.
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):
12/17/2012
 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: $ 25,000.00
 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: 
DBSI WAS FINED $25,000. THE FINE WAS PAID ON 1/2/13.
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).
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREED TO SETTLE THE MATTER AND PAY A $25,000 FINE, WHICH WAS PAID ON
1/2/13.

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) 
ILLINOIS SECRETARY OF STATE, SECURITIES DEPARTMENT (THE "DEPARTMENT")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/16/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
1100301
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
AUCTION RATE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") (1) ENGAGED IN DISHONEST AND UNETHICAL CONDUCT IN THE
SECURITIES BUSINESS WITH RESPECT TO THE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS") AND (2) FAILED TO REASONABLY

SUPERVISE ITS AGENTS WITH RESPECT TO THE MARKETING AND SALE OF ARS.
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):
07/16/2012
 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: $ 536,364.03
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PURSUANT TO THE CONSENT ORDER ENTERED BY THE DEPARTMENT ON JULY 16, 2012, DBSI AGREED TO PAY A PENALTY OF $535,364.03 TO THE
ILLINOIS SECRETARY OF STATE AND TO TAKE CERTAIN MEASURES WITH RESPECT TO CURRENT AND FORMER CLIENTS THAT PURCHASED ARS
BEFORE FEBRUARY 13, 2008.
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 CONSENT ORDER FINALIZED THE TERMS OF A SETTLEMENT THAT HAD BEEN REACHED IN AUGUST 2008 BETWEEN DBSI'S PARENT AND NASAA
THAT RESULTED IN A TERM SHEET (THE "TERM SHEET"). THE TERM SHEET REQUIRED A TOTAL PENALTY OF $15,000,000 TO NASAA MEMBER
JURISDICTIONS, AND THE $535,364.03 PENALTY IMPOSED BY THE DEPARTMENT IS ITS PRO-RATA SHARE OF THE TOTAL PENALTY AMOUNT. THE
CONSENT ORDER REQUIRES THAT DBSI OFFER TO PURCHASE AT PAR CERTAIN ARS FROM ELIGIBLE INVESTORS; REIMBURSE ELIGIBLE INVESTORS
THAT SOLD ARS BELOW PAR; PARTICIPATE IN A SPECIAL ARBITRATION PROCEDURES FOR CONSEQUENTIAL DAMAGES CLAIMS BY ELIGIBLE
INVESTORS; WORK TO PROVIDE LIQUIDITY SOLUTIONS FOR INSTITUTIONAL INVESTORS NOT PART OF THE ARS BUY BACK; AND PROVIDE OTHER
RELIEF AS DESCRIBED IN THE CONSENT ORDER.
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 ALLEGATIONS IN THE CONSENT ORDER, DBSI CONSENTED TO THE DEPARTMENT MAKING THE FOLLOWING
CONCLUSIONS OF LAW: (1) IN CONNECTION WITH (I) THE MISREPRESENTATION OF ARS TO CLIENTS, (II) THE FAILURE TO ADEQUATELY DISCLOSE TO
CLIENTS THE EFFECT OF DBSI'S ROLE AS UNDERWRITER AND BROKER-DEALER FOR ARS ISSUES, AND (III) THE USE OF SUPPORTING BIDS TO
ARTIFICIALLY PREVENT FAILED ARS AUCTIONS AND FAILING TO ADEQUATELY DISCLOSE THE PRACTICE TO CLIENTS, DBSI ENGAGED IN DISHONEST AND
UNETHICAL CONDUCT IN THE SECURITIES BUSINESS, IN VIOLATION OF SECTION 8.E(1)(B) OF THE ILLINOIS SECURITIES ACT ("ACT); AND (2) IN
CONNECTION WITH THE FAILURE TO (I) PROVIDE ADEQUATE TRAINING TO AGENTS CONCERNING ARS; (II) CREATE AND MAINTAIN ADEQUATE
SUPERVISORY PROCEDURES CONCERNING ARS; (III) ENSURE ACCURATE DISCLOSURE OF ARS CHARACTERISTICS TO CLIENTS BY ITS AGENTS; AND (IV)
ENSURE ADEQUATE DISCLOSURE OF CONFLICTS OF INTEREST CONCERNING ARS TO CLIENTS BY ITS AGENTS, DBSI FAILED TO REASONABLY SUPERVISE,
AND ESTABLISH AND ENFORCE PROCEDURES NECESSARY TO DETECT AND PREVENT SUCH CONDUCT, IN VIOLATION OF ITS DUTIES UNDER SECTION
8.E(1)(E)(I) OF THE ACT. THE ACTIVITIES CITED IN THE CONSENT ORDER ARE GROUNDS, PURSUANT TO THE ACT, FOR THE INITIATION OF
ADMINISTRATIVE PROCEEDINGS, AND, PURSUANT TO THE ACT, TO IMPOSE SUCH OTHER REMEDIAL MEASURES AS MAY BE NECESSARY IN THE PUBLIC
INTEREST.

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

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

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
02/05/2013
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20080163813-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
DEBT-CORPORATE DEBT-MUNICIPAL
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT: (1) DURING THE PERIODS JULY 1, 2007 THROUGH SEPTEMBER 30, 2007, JULY 1, 2008 THROUGH SEPTEMBER 30, 2008, AND

APRIL 1, 2009 THROUGH JUNE 30, 2009, THE FIRM FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY IDENTIFIER FOR CERTAIN
TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES AND FAILED TO REPORT TO TRACE CERTAIN TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT
WAS REQUIRED TO REPORT. THESE ALLEGED FAILURES VIOLATED NASD RULES 6230(C)(6) AND 6230(B) OR FINRA RULES 6730(C)(6) AND 6730(B)(1);
(2) DURING THE PERIOD FROM APRIL 1, 2009 THROUGH JUNE 30, 2009, THE FIRM FAILED TO REPORT TO TRACE CERTAIN TRANSACTIONS IN TRACE-
ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION AND FAILED TO REPORT TO TRACE THE CORRECT TIME OF TRADE EXECUTION
FOR CERTAIN TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES IN VIOLATION OF FINRA RULES 6730(C)(8), 6730(A), AND 2010. IT ALSO FAILED TO
SHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDUM OF CERTAIN BROKERAGE ORDERS IN VIOLATION OF SEC RULE 17A-3 AND NASD RULE
3110; (3) FOR TRADE DATES APRIL 15 AND 16, 2009 AND JULY 28 AND 29, 2010, CERTAIN OF THE FIRM'S TRADE CONFIRMATIONS WITH INSTITUTIONAL
CUSTOMERS OMITTED CERTAIN INFORMATION OR CONTAINED INCORRECT INFORMATION IN VIOLATION OF SEC RULE 10B-10; (4) DURING THE
PERIODS JANUARY 1, 2009 THROUGH MARCH 31, 2009 AND JULY 1, 2009 THROUGH SEPTEMBER 30, 2009, RESPECTIVELY, THE FIRM FAILED TO REPORT
THE CORRECT TIME OF TRADE TO THE RTRS IN CERTAIN REPORTS OF TRANSACTIONS IN MUNICIPAL SECURITIES AND FAILED TO TIMELY REPORT
INFORMATION REGARDING CERTAIN PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE RTRS IN VIOLATION OF MSRB
RULE G-14. THE FIRM ALSO FAILED TO SHOW THE CORRECT TIME OF TRADE ON THE MEMORANDUM OF CERTAIN MUNICIPAL SECURITIES ORDERS IN
VIOLATION OF MSRB RULE G-8. (4) DURING THE PERIOD MAY 1, 2009 THROUGH AUGUST 31, 2009, THE FIRM FAILED TO ACCEPT OR DECLINE IN THE
FINRA/NASDAQ TRF OR THE OTC TRADE REPORTING FACILITY CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTER
EXECUTION IN VIOLATION OF FINRA RULES 7230A(B) OR 7330(B); (5) DURING THE PERIOD FROM JANUARY 1, 2010 THROUGH APRIL 30, 2010, THE FIRM
FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTC TRF CERTAIN LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY
SECURITIES IN VIOLATION OF FINRA RULES 6622(A) AND 2010. IT ALSO FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTC
TRF CERTAIN LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES, FAILED TO REPORT THE CORRECT TIME OF EXECUTION FOR SUCH
TRANSACTIONS, AND FAILED TO DESIGNATE TO THE OTC TRF SUCH LAST SALE REPORTS AS LATE, IN VIOLATION OF FINRA RULE 6622(A); (6) DURING
THE PERIOD FROM JANUARY 1, 2010 THROUGH APRIL 30, 2010, THE FIRM FAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE
FINRA/NASDAQ TRF CERTAIN LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES IN VIOLATION OF FINRA RULE 6380A AND FAILED TO
REPORT TO THE FINRA/NASDAQ TRF THE CORRECT TIME OF EXECUTION FOR CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES IN VIOLATION OF
FINRA RULE 7230A(D)(4); AND (7) DURING THE PERIOD JULY 1, 2008 THROUGH DECEMBER 31, 2008, THE FIRM EFFECTED 11 TRANSACTIONS IN SEVEN
SECURITIES WHILE A TRADING HALT WAS IN EFFECT WITH RESPECT TO EACH OF THE SECURITIES IN VIOLATION OF NASD RULES 3340 AND 2110 OR
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):
02/05/2013
 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: $ 215,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND FINE OF $215,000.00. THE FINE WAS PAID ON 2/14/2013.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") CONSENTING TO A
CENSURE AND FINE OF $215,000.00.

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) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
04/08/2013
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2008015717201
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6.
Principal Product Type:
Other
Other Product Types: 
EQUITY SWAPS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") , VIOLATED NASD RULES 2010, 2110 AND 3010 DURING THE PERIOD OF 2006-2011
BY FAILING TO ESTABLISH AND ENFORCE ADEQUATE WRITTEN SUPERVISORY PROCEDURES REGARDING DIVIDEND-RELATED YIELD ENHANCEMENT ON
TOTAL RETURN SWAP TRANSACTIONS THAT INVOLVED U.S. EQUITIES. SPECIFICALLY, FINRA ALLEGED THAT THE FIRM FAILED TO ESTABLISH ADEQUATE
WRITTEN PROCEDURES FOR THE TRANSACTIONS THEMSELVES, THE REVIEW OF THE TRANSACTIONS, OR FOR DOCUMENTING SUPERVISION THAT
OCCURRED. ALTHOUGH THE FIRM CONDUCTED REVIEWS, FINRA ALLEGED THAT IT RELIED ON INCOMPLETE DATA THAT DID NOT PROVIDE ENOUGH
INFORMATION TO ENSURE A COMPREHENSIVE REVIEW AND THAT IT FAILED TO DOCUMENT SUCH REVIEWS.
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):
04/08/2013
 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: $ 275,000.00
 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: 
DBSI CONSENTED TO A CENSURE AND FINE OF $275,000.00. THE FINE WAS PAID ON 4/15/2013.
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 ALLEGATIONS, DBSI AGREED TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") CONSENTING TO A
CENSURE AND FINE OF $275,000.00.

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) 
CME GROUP
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/05/2013
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CBOT 12-08830-BC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CME ALLEGED THAT DEUTSCHE BANK SECURITIES INC. ("DBSI") VIOLATED CBOT RULE 854 BETWEEN MARCH 1, 2012 AND MARCH 5, 2012, BY
OVERSTATING OPEN INTEREST ON CERTAIN FUTURES CONTRACTS BECAUSE IT IMPERMISSIBLY NETTED CERTAIN CONTRACTS AS A RESULT OF NOT
RECEIVING TIMELY CLOSE-OUT INSTRUCTIONS FROM ITS CUSTOMER.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
06/05/2013
 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: $ 65,000.00
 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: 
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, DBSI CONSENTED TO THE DECISION & ORDER OF SETTLEMENT AND WAS FINED
$65,000.00. THE FINE WAS PAID ON JUNE 11, 2013.
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).
OU
G O
G
G
O S,
S CO S
O
C S O
& O
O
S
S
O
$65,000 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
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DEUTSCHE BANK AG

(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) 
CHICAGO MERCANTILE EXCHANGE (CME GROUP)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/07/2013
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NYMEX-RSRH-13-1264/COMEX-RSRH-13-1265
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
DEUTSCHE BANK AG
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JULY 23, 2013, THE CME IMPOSED A SUMMARY FINE IN THE AMOUNT OF $3,500.00 ON DBAG, DBSI'S ULTIMATE PARENT, IN CONNECTION WITH ITS
ALLEGATION THAT DBAG DID NOT TIMELY REPORT SEVEN BLOCK TRADES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
08/07/2013
 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: $ 3,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
DBAG CONSENTED TO THE DECISION & ORDER OF SETTLEMENT AND FINED $3,500.00. THE FINE WAS PAID ON AUGUST 7, 2013.
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 ALLEGATIONS, DBAG ACCEPTED THE DECISION & OFFER OF SETTLEMENT CONSENTING TO A FINE OF $3,500.00.