Firm profile

1st Discount Brokerage, Inc..

LAKE WORTH, FLCRD 39164Registration Status: ApprovedEffective since June 12, 2025SEC # 801-132978Latest ADV March 31, 2026

1ST Discount Brokerage, Inc. is an SEC registered investment adviser organized as a corporation with a primary office location in Lake Worth, FL. Its latest Form ADV filing, dated March 31, 2026, reports $131M in regulatory assets under management, 8 employees, 3 offices, and 352 accounts.

Assets Under Management
$131M
Employees
8
Offices
3 offices
Total Clients
219

Associated firm names

2 names listed
  • 1DB ASSET MANAGEMENT
  • 1ST DISCOUNT BROKERAGE, INC.

Leadership

1 roles identified
CCOGeorge Patrick Rohloff

Advisory services offered

6 types reported
Financial Planning Services
Other advisory services
Pension consulting services

Fee models offered

3 types reported
Asset based fees
Fixed fees
Hourly charges

Offices & Contact

Primary office

LAKE WORTH, Florida, United States

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Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

Florida

LAKE WORTHPrimary office

Rhode Island

PROVIDENCE

2 office records listed · 3 total offices reported. 1 additional office addresses are undisclosed and are not mapped. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$131Mas of March 31, 2026
Discretionary58.2%
$76M
58% of total RAUM58.2%
Non-discretionary41.8%
$55M
42% of total RAUM41.8%
Regulatory assets under management are split between discretionary and non-discretionary assets.

Client Coverage Demographics

Top client segmentIndividuals represent 60.7% of total clients.
Top client categories% of clientsClients
1
Individuals
60.7%
133
2
HNWI
37.9%
83
3
Pension Plans
0.5%
1
4
Charitable
0.5%
1
5
Corporations
0.5%
1
Categories with <5 clients
Charitable Organizations<5 clients
Corporations or other businesses not listed above<5 clients
Pension and profit sharing plans<5 clients

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$131M
Total Accounts352
10Y AUM Change+$23M (+21.5%)

Private Funds

Private funds reported by 1st Discount Brokerage, Inc..

Loading private fund disclosures…

Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees8
Clients per Employee27:1
10Y Employee Change-1 (-11.1%)

Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.

This firm has a multi year gap in available SEC ADV filing history between 2012 and 2025. Charts show the most recent available filing segment under this CRD.


Ownership

Reported direct and indirect ownership ranges

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
1DB FINANCIALDirect owner · Schedule AInterest in 1ST DISCOUNT BROKERAGE, INC.
75%+
WILLIAM HAROLD JR CORLEYIndirect owner · Schedule BInterest in 1DB FINANCIAL
75%+

Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to 1st Discount Brokerage, Inc...

Reported ownership and control details

Form ADV · Filing date 2026-03-31 · Schedules A and B

7 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1WILLIAM HAROLD JR CORLEYPRESIDENTIndividual1ST DISCOUNT BROKERAGE, INC.Less than 5%Code NAYesPRESIDENT07/1995Schedule APDF page 22
21DB FINANCIALPARENT COMPANYDomestic entity1ST DISCOUNT BROKERAGE, INC.75% or moreCode ENoPARENT COMPANY02/1999Schedule APDF page 22
3AILEEN M GALLAGHERFINOPIndividual1ST DISCOUNT BROKERAGE, INC.Less than 5%Code NANoFINOP02/2008Schedule APDF page 22
4GEORGE PATRICK ROHLOFFROSFPIndividual1ST DISCOUNT BROKERAGE, INC.Less than 5%Code NANoROSFP08/2012Schedule APDF page 22
5WILLIAM HAROLD JR CORLEYMUNICIPAL PRINCIPALIndividual1ST DISCOUNT BROKERAGE, INC.Less than 5%Code NAYesMUNICIPAL PRINCIPAL07/1995Schedule APDF page 22
6GEORGE PATRICK ROHLOFFCHIEF COMPLIANCE OFFICERIndividual1ST DISCOUNT BROKERAGE, INC.Less than 5%Code NANoCHIEF COMPLIANCE OFFICER06/2022Schedule APDF page 22
7WILLIAM HAROLD JR CORLEYSHAREHOLDERIndividual1DB FINANCIAL75% or moreCode EYesSHAREHOLDER02/1999Schedule BPDF page 23

Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.

Compliance & Disclosures

Filing dated 3/31/2026 2:25:54 PM

Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.

RIA or supervised-person involvementThe RIA reported that one or more events below involve the firm or its supervised persons.RIA responseYes
AFelonies2 No

In the past ten years, have you or any advisory affiliate:

  • A1Been convicted of or pleaded guilty or no contest to a felony?No
  • A2Been charged with a felony?No
BMisdemeanors2 No

In the past ten years, have you or any advisory affiliate:

  • B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
  • B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions3 Yes2 No

Has the SEC or CFTC ever:

  • C1Found you or an advisory affiliate made a false statement or omission?No
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
  • C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions1 Yes4 No

Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:

  • D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
  • D2Found you or an advisory affiliate violated investment-related regulations or statutes?Yes
  • D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions2 Yes2 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?Yes
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
  • GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No

(1) Court actions

Has a domestic or foreign court:

  • H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
  • H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
  • H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No

(2) Pending civil proceedings

  • H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 9 source blocks

Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.

regulatory · block 1PDF pages 23–25
Regulator name — filed text
STATE OF FLORIDA, OFFICE OF FINANCIAL REGULATION
Monetary/Fine Amount — filed text
$ 2,500.00
How was matter resolved — filed text
Stipulation and Consent

Action status / disposition — filed text

FINED PAID, FIRM PRINCIPAL REGISTERED IN THE STATE OF FL
Other filed details

Description of allegations — filed text

CONDUCTING INVESTMENT ADVISORY BUSINESS IN FL WITHOUT HAVING AT LEAST ONE PRINCIPAL REGISTERED INT HE STATE OF FLORIDA, IN VIOLATION OF CHAPTER 517.12(4).

Sanction detail — filed text

$2500.00 PAID ON 06/25/2004
Full extracted filing text

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

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

One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
STATE OF FLORIDA, OFFICE OF FINANCIAL REGULATION
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE
3.
Date Initiated (MM/DD/YYYY): 
03/17/2004
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
0107-S-3/04
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
INVESTMENT ADVISORY BUSINESS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CONDUCTING INVESTMENT ADVISORY BUSINESS IN FL WITHOUT HAVING AT LEAST ONE PRINCIPAL REGISTERED INT HE STATE OF FLORIDA, IN
VIOLATION OF CHAPTER 517.12(4).
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):
07/13/2004
 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: $ 2,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
REGISTER INVESTMENT ADVISORY PRINCIPAL IN THE STATE OF FLORIDA
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: 
$2500.00 PAID ON 06/25/2004
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).
FINED PAID, FIRM PRINCIPAL REGISTERED IN THE STATE OF FL
regulatory · block 2PDF pages 25–27
Regulator name — filed text
NASD
Monetary/Fine Amount — filed text
$ 10,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)
Other filed details

Description of allegations — filed text

FAILURE TO DISCLOSE DETAILS OF PAYMENT FOR ORDER FLOW ON CONFIRMATIONS, AT TIME OF ACCOUNT OPENING AND ANNUALY THEREAFTER. FAILURE TO QUATERLY DISCLOSE ASPECTS OF PAYMENT FOR ORDER FLOW AND PROFIT SHARING WITH LAMPOST CAPITAL.

Sanction detail — filed text

4/16/2003
Full extracted filing text

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

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

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NASD
2.
Principal Sanction:
Censure
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/19/2003
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
C07030017
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: 
EQUITIES OPTIONS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FAILURE TO DISCLOSE DETAILS OF PAYMENT FOR ORDER FLOW ON CONFIRMATIONS, AT TIME OF ACCOUNT OPENING AND ANNUALY THEREAFTER.
FAILURE TO QUATERLY DISCLOSE ASPECTS OF PAYMENT FOR ORDER FLOW AND PROFIT SHARING WITH LAMPOST CAPITAL.
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):
03/19/2003
 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: $ 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: 
4/16/2003
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).
regulatory · block 3PDF pages 27–28
Regulator name — filed text
NASD
Monetary/Fine Amount — filed text
$ 10,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

THIS DRP IS DUPLICATE
Other filed details

Description of allegations — filed text

FAILURE TO DISCLOSE DETAILS OF PAYMENT FOR ORDER FLOW ON CONFIRMATIONS, AT TIME OF ACCOUNT OPENING AND ANNUALLY THEREAFTER. FAILURE TO QUARTERLY DISCLOSE ASPECTS OF PAYMENT FOR ORDER FLOW AND PROFIT SHARING WITH LAMPOST CAPITAL.

Sanction detail — filed text

4/16/2003
Full extracted filing text

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

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

3.
Date Initiated (MM/DD/YYYY): 
03/19/2003
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
C07030017
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: 
EQUITIES OPTIONS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FAILURE TO DISCLOSE DETAILS OF PAYMENT FOR ORDER FLOW ON CONFIRMATIONS, AT TIME OF ACCOUNT OPENING AND ANNUALLY THEREAFTER.
FAILURE TO QUARTERLY DISCLOSE ASPECTS OF PAYMENT FOR ORDER FLOW AND PROFIT SHARING WITH LAMPOST CAPITAL.
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):
03/19/2003
 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: $ 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: 
4/16/2003
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).
THIS DRP IS DUPLICATE
regulatory · block 4PDF pages 28–30
Regulator name — filed text
NASD
Monetary/Fine Amount — filed text
$ 12,500.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

AWC ACCEPTED BY THE NASD, FINE PAID
Other filed details

Description of allegations — filed text

THE FIRM DID NOT REASONABLY MONITOR THE OUTSIDE BUSINESS ACTIVITIES OF REGISTERED REPRESENTATIVE CHARLES PARSONS (CRD# 2642216) FOR COMPLIANCE WITH NASD RULE 3030. PARSONS INFORMED THE FIRM THAT HE INTENDED TO PERFORM CLERICAL SERVICES FOR A COMPANY INVOLVED IN THE SECURITIES FIELD, AND THE FIRM TREATED PARSONS' ACTIVITIES AS NOT INVESTMENT-RELATED. MORE THOROUGH MONITORING BY THE FIRM MAY HAVE UNCOVERED PARSONS' TRUE OUTSIDE BUSINESS ACTIVITIES. BEGINNING NO LATER THAN FEB. 2003 AND CONTINUING UNTIL OCTOBER 2003, PARSONS CIRCULATED, OR CAUSED TO BE CIRCULATED, MISLEADING, EXGERRATED, AND UNWARRANTED INVESTMENT OPINIONS AND RESEARCH REPORTS TOUTING HIGHLY SPECULATIVE OVER-THE-COUNTER BULLETIN BOARD AND PINK SHEET SECURITIES AND CONTAINING UNSUBSTANTIATED PRICE PROJECTIONS. PARSONS' INVESTMENT OPINIONS WERE NOT BASED ON PRINCIPALS OF FAIR DEALINGS AND GOOD FAITH AND THEY FAILED TO PROVIDE SOUND BASIS FOR EVALUATING THE FACTS RELATING TO THE SECURITIES HE COVERED. AS A RESULT, IN PART, OF 1ST DISCOUNT'S SUPERVISORY DEFICIENCIES, PARSONS' MISCONDUCT WAS NOT DETECTED BY THE FIRM. PARSONS VIOLATED NASD CONDUCT RULES 2110, 2120, 2210, 2711, AND 3030. AND SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 10(B)-5. PARSONS WAS BARRED BY THE NAASD IN AUGUST 2004 AS A CONSEQUENCE OF HIS MISCONDUCT. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLILANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND NASD RULES CONCERNING COMPLIANCE WITH CONDUCT RULE 3030.

Sanction detail — filed text

AWC AND A FINE OF $12,500.
Full extracted filing text

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

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

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NASD
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE OF $12,500
3.
Date Initiated (MM/DD/YYYY): 
01/27/2004
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CMS040185 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):
THE FIRM DID NOT REASONABLY MONITOR THE OUTSIDE BUSINESS ACTIVITIES OF REGISTERED REPRESENTATIVE CHARLES PARSONS (CRD# 2642216)
FOR COMPLIANCE WITH NASD RULE 3030. PARSONS INFORMED THE FIRM THAT HE INTENDED TO PERFORM CLERICAL SERVICES FOR A COMPANY

INVOLVED IN THE SECURITIES FIELD, AND THE FIRM TREATED PARSONS' ACTIVITIES AS NOT INVESTMENT-RELATED. MORE THOROUGH MONITORING BY
THE FIRM MAY HAVE UNCOVERED PARSONS' TRUE OUTSIDE BUSINESS ACTIVITIES. BEGINNING NO LATER THAN FEB. 2003 AND CONTINUING UNTIL
OCTOBER 2003, PARSONS CIRCULATED, OR CAUSED TO BE CIRCULATED, MISLEADING, EXGERRATED, AND UNWARRANTED INVESTMENT OPINIONS AND
RESEARCH REPORTS TOUTING HIGHLY SPECULATIVE OVER-THE-COUNTER BULLETIN BOARD AND PINK SHEET SECURITIES AND CONTAINING
UNSUBSTANTIATED PRICE PROJECTIONS. PARSONS' INVESTMENT OPINIONS WERE NOT BASED ON PRINCIPALS OF FAIR DEALINGS AND GOOD FAITH
AND THEY FAILED TO PROVIDE SOUND BASIS FOR EVALUATING THE FACTS RELATING TO THE SECURITIES HE COVERED. AS A RESULT, IN PART, OF 1ST
DISCOUNT'S SUPERVISORY DEFICIENCIES, PARSONS' MISCONDUCT WAS NOT DETECTED BY THE FIRM. PARSONS VIOLATED NASD CONDUCT RULES
2110, 2120, 2210, 2711, AND 3030. AND SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 10(B)-5. PARSONS WAS BARRED BY
THE NAASD IN AUGUST 2004 AS A CONSEQUENCE OF HIS MISCONDUCT. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION
REASONABLY DESIGNED TO ACHIEVE COMPLILANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND NASD RULES CONCERNING
COMPLIANCE WITH CONDUCT RULE 3030.
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):
11/19/2004
 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: $ 12,500.00
 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: 
AWC AND A FINE OF $12,500.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
AWC ACCEPTED BY THE NASD, FINE PAID
regulatory · block 5PDF pages 30–32
Regulator name — filed text
FINRA
Monetary/Fine Amount — filed text
$ 60,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)
Other filed details

Description of allegations — filed text

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EXECUTED SALES WITHOUT CONDUCTING A REASONABLE SEARCHING INQUIRY TO DETERMINE WHETHER THE SECURITIES WERE REGISTERED OR THE TRANSACTIONS WERE SUBJECT TO AN EXEMPTION FROM REGISTRATION UNDER SECTION OF THE SECURITIES ACT OF 1933 (SECURITIES ACT). THE FINDINGS STATED THAT THE FIRM'S CUSTOMERS ENGAGED IN A PATTERN OF DEPOSITING LARGE BLOCKS OF LOW-PRICED SECURITIES IN THEIR ACCOUNTS, OF LIQUIDATING THE LOW-PRICED SECURITIES AND WIRING THE SALES PROCEEDS TO AN ACCOUNT OUTSIDE THE FIRM WITHOUT RE- INVESTMENT. THEI FIRM FACILITATED CUSTOMER LIQUIDATIONS OF APPROXIMATELY 7,764,600 SHARES OF NINE DIFFERENT ISSUERS TRADED ON EITHER THE OTC PINK SHEETS OR THE OTC BULLETIN BOARD, OF WHICH EIGHT WERE SHARES OF LOW-PRICED SECURITIES. THE FINDINGS ALSO INCLUDED THAT THE FIRM HAD INADEQUATE WRITTEN SUPERVISORY PROCEDURES (WSPS) TO ENSURE COMPLIANCE WITH SECTION 5 OF THE SECURITIES ACT. THE FIRM'S WSPS DID NOT REQUIRE A REASONABLE SEARCHIGN INQUIRY TO CONFIRM WHETHER A LOW-PRICED SECURITY WAS REGISTERED OR THE PROPOSED TRANSACTION WAS SUBJECT TO AN EXEMPTION FROM REGISTRATION. THE FIRM ESSENTIALLY RELIED UPON ITS CLEARING FIRM, AND VARIOUS STOCK TRANSFER AGENTS, TO DETERMINE WHETHER SHARES OF STOCK WERE FREELY TRADABLE. THE FIRM FAILED TO ADEQUATELY UPDATE ITS WSPS TO INCLUDE SPECIFIC PROCEDURES RELATING TO THE DEPOSIT AND LIQUIDATION OF LOW-PRICED SECURITIES. FINRA FOUND THAT THE FIRM'S ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM WAS ALSO DEFICIENT IN MONITORING FOR POTENTIALLY SUSPICIOUS ACTIVITY RELATED TO THE DEPOSIT AND LIQUIDATION OF LOW-PRICED SECURITIES. THE FIRM FAILED TO ESTABLISH AND IMPLEMENT ANTI MONEY LAUNDERING POLICIES AND PROCEDURES THAT COULD REASONABLY BE EXPECTED TO DETECT AND CAUSE THE REPORTING OF POTENTIALLY SUSPICIOUS TRANSACTIONS RELATED TO THE RISKS POSED BY THE DEPOSIT AND LIQUIDATION OF LOW-PRICED SECURITIES. THE FIRM FAILED TO PROVIDE ADEQUATE TRAINING RELATED TO THE RISKS POSED BY THE DEPOSIT AND LIQUIDATION OF LOW-PRICED SECURITIES, TO RELEVANT PERSONNEL IN OPERATIONS, SALES AND COMPLIANCE TO ALLOW FOR THE DETECTION, INVESTIGATION AND REPORTING, WHERE APPROPRIATE, OF SUSPICIOUS ACTIVITY.

Sanction detail — filed text

1ST DISCOUNT CONSENTS TO THE IMPOSITION OF THE FOLLOWING SANCTIONS: - A CENSURE; AND - A FINE IN THE AMOUNT OF $60,000.00
Full extracted filing text

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

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

A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
DISGORGEMENT
3.
Date Initiated (MM/DD/YYYY): 
04/23/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2009020821501
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Penny Stock(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EXECUTED
SALES WITHOUT CONDUCTING A REASONABLE SEARCHING INQUIRY TO DETERMINE WHETHER THE SECURITIES WERE REGISTERED OR THE
TRANSACTIONS WERE SUBJECT TO AN EXEMPTION FROM REGISTRATION UNDER SECTION OF THE SECURITIES ACT OF 1933 (SECURITIES ACT). THE
FINDINGS STATED THAT THE FIRM'S CUSTOMERS ENGAGED IN A PATTERN OF DEPOSITING LARGE BLOCKS OF LOW-PRICED SECURITIES IN THEIR
ACCOUNTS, OF LIQUIDATING THE LOW-PRICED SECURITIES AND WIRING THE SALES PROCEEDS TO AN ACCOUNT OUTSIDE THE FIRM WITHOUT RE-
INVESTMENT. THEI FIRM FACILITATED CUSTOMER LIQUIDATIONS OF APPROXIMATELY 7,764,600 SHARES OF NINE DIFFERENT ISSUERS TRADED ON
EITHER THE OTC PINK SHEETS OR THE OTC BULLETIN BOARD, OF WHICH EIGHT WERE SHARES OF LOW-PRICED SECURITIES. THE FINDINGS ALSO
INCLUDED THAT THE FIRM HAD INADEQUATE WRITTEN SUPERVISORY PROCEDURES (WSPS) TO ENSURE COMPLIANCE WITH SECTION 5 OF THE
SECURITIES ACT. THE FIRM'S WSPS DID NOT REQUIRE A REASONABLE SEARCHIGN INQUIRY TO CONFIRM WHETHER A LOW-PRICED SECURITY WAS
REGISTERED OR THE PROPOSED TRANSACTION WAS SUBJECT TO AN EXEMPTION FROM REGISTRATION. THE FIRM ESSENTIALLY RELIED UPON ITS
CLEARING FIRM, AND VARIOUS STOCK TRANSFER AGENTS, TO DETERMINE WHETHER SHARES OF STOCK WERE FREELY TRADABLE. THE FIRM FAILED TO

ADEQUATELY UPDATE ITS WSPS TO INCLUDE SPECIFIC PROCEDURES RELATING TO THE DEPOSIT AND LIQUIDATION OF LOW-PRICED SECURITIES.
FINRA FOUND THAT THE FIRM'S ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM WAS ALSO DEFICIENT IN MONITORING FOR POTENTIALLY
SUSPICIOUS ACTIVITY RELATED TO THE DEPOSIT AND LIQUIDATION OF LOW-PRICED SECURITIES. THE FIRM FAILED TO ESTABLISH AND IMPLEMENT
ANTI MONEY LAUNDERING POLICIES AND PROCEDURES THAT COULD REASONABLY BE EXPECTED TO DETECT AND CAUSE THE REPORTING OF
POTENTIALLY SUSPICIOUS TRANSACTIONS RELATED TO THE RISKS POSED BY THE DEPOSIT AND LIQUIDATION OF LOW-PRICED SECURITIES. THE FIRM
FAILED TO PROVIDE ADEQUATE TRAINING RELATED TO THE RISKS POSED BY THE DEPOSIT AND LIQUIDATION OF LOW-PRICED SECURITIES, TO
RELEVANT PERSONNEL IN OPERATIONS, SALES AND COMPLIANCE TO ALLOW FOR THE DETECTION, INVESTIGATION AND REPORTING, WHERE
APPROPRIATE, OF SUSPICIOUS ACTIVITY.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
04/23/2015
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 60,000.00
 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: 
1ST DISCOUNT CONSENTS TO THE IMPOSITION OF THE FOLLOWING SANCTIONS: - A CENSURE; AND - A FINE IN THE AMOUNT OF $60,000.00
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).
regulatory · block 6PDF pages 32–34
Regulator name — filed text
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Monetary/Fine Amount — filed text
$ 40,000.00
How was matter resolved — filed text
Order

Action status / disposition — filed text

IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS, RESPONDENT SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER RESPONDENT AND THE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED, RESPONDENT CONSENTED TO THE ENTRY OF THE ORDER INSTITUTING ADMINISTRATIVE PROCEEDINGS PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTIONS 203(E) AND 203(F) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, IMPOSING REMEDIAL SANCTIONS AND A CENSURE ORDER AS TO 1ST DISCOUNT BROKERAGE, INC. THE COMMISSION DEEMED IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE RESPONDENT'S OFFER. ACCORDINGLY, PURSUANT TO SECTION 15(B) OF THE EXCHANGE ACT AND SECTIONS 203(E) AND 203(F) OF THE ADVISERS ACT, IT IS HEREBY ORDERED THAT RESPONDENT 1DB SHALL PAY CIVIL PENALTIES OF $40,000 TO THE UNITED STATES TREASURY. RESPONDENT 1DB IS CENSURED.
Other filed details

Description of allegations — filed text

THE PROCEEDINGS AROSE OUT OF 1DB'S AND A FORMER EMPLOYEE'S FAILURE REASONABLY TO SUPERVISE A REGISTERED REPRESENTATIVE ("RR") WITH A VIEW TO PREVENTING AND DETECTING HIS VIOLATIONS OF SECTION 17(A) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"), AND SECTIONS 10(B) AND 15(A) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER. FROM 2002 TO 2008, WHILE THE RR WAS A REGISTERED REPRESENTATIVE ASSOCIATED WITH 1DB, HE OPERATED A PONZI SCHEME WHICH DEFRAUDED OVER 50 INVESTORS OF NEARLY $9 MILLION. 1DB DID NOT HAVE POLICIES AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT VIOLATIONS OF THE SECURITIES LAWS BY REGISTERED REPRESENTATIVES LIKE THE RR. HAD 1DB HAD SUCH REASONABLE POLICIES AND PROCEDURES, IT WOULD HAVE LIKELY UNCOVERED THE RR'S FRAUD. SPECIFICALLY, HAD 1DB HAD REASONABLE POLICIES AND PROCEDURES IN THE REVIEW OF THE "DOING BUSINESS AS" BUSINESS ACCOUNTS OF ITS REGISTERED REPRESENTATIVES, IT IS LIKELY THAT 1DB WOULD HAVE OBSERVED A SUBSTANTIAL INFLUX OF MONEY FROM 1DB'S EXISTING CUSTOMERS INTO THE RR'S BUSINESS ACCOUNT, THROUGH WHICH HE CONDUCTED HIS PONZI SCHEME. IN ADDITION, 1DB HAD NO POLICY REQUIRING COMPLIANCE AUDITORS WHO WERE CONDUCTING AUDITS TO REVIEW THE WORK PAPERS AND REPORTS OF PREVIOUS COMPLIANCE AUDITS. HAD 1DB HAD REASONABLE POLICIES AND PROCEDURES IN THIS REGARD, IT WOULD HAVE BEEN APPARENT THAT THE RR HAD A HISTORY OF INSUFFICIENT OR ABSENT SIGNAGE. AS A RESULT, AUDITORS WERE UNABLE TO IDENTIFY A REOCCURRING ISSUE THAT, WITH FOLLOW-UP, COULD HAVE UNCOVERED THAT THE RR TOOK STEPS TO CONCEAL FROM HIS CUSTOMERS HIS ASSOCIATION WITH 1DB FOR FEAR THAT THEY WOULD ALERT THE FIRM TO HIS SUSPICIOUS INVESTMENT SCHEME. 1DB ALSO FAILED TO CONDUCT UNANNOUNCED AUDITS IN THE NASHVILLE OFFICE AS SPECIFICALLY REQUIRED IN THE FIRM'S PROCEDURES. HAD 1DB IMPLEMENTED A SYSTEM TO FOLLOW ITS OWN PROCEDURE OF CONDUCTING UNANNOUNCED AUDITS IN THE NASHVILLE OFFICE, IT IS LIKELY THAT 1DB WOULD HAVE FOUND EVIDENCE OF THE RR'S PONZI SCHEME. FOR EXAMPLE, AN UNANNOUNCED AUDIT WOULD HAVE REVEALED THAT THE RR DID NOT CONSISTENTLY PROVIDE SIGNS TO INDICATE TO CUSTOMERS HIS ASSOCIATION WITH 1DB. THE COMMISSION FOUND THAT AS A RESULT OF THE CONDUCT, 1DB AND THE FORMER EMPLOYEE FAILED REASONABLY TO SUPERVISE THE RR WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT, AND WITHIN THE MEANING OF SECTION 203(E) AND 203(F) OF THE ADVISERS ACT, WHEN THEY FAILED TO SUPERVISE THE RR WITH A VIEW TO PREVENTING AND DETECTING HIS VIOLATIONS OF THE FEDERAL SECURITIES LAWS.

Sanction detail — filed text

IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS, RESPONDENT SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER RESPONDENT AND THE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED, RESPONDENT CONSENTED TO THE ENTRY OF THE ORDER INSTITUTING ADMINISTRATIVE PROCEEDINGS PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTIONS 203(E) AND 203(F) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, IMPOSING REMEDIAL SANCTIONS AND A CENSURE ORDER AS TO 1ST DISCOUNT BROKERAGE, INC. THE COMMISSION DEEMED IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE RESPONDENT'S OFFER. ACCORDINGLY, PURSUANT TO SECTION 15(B) OF THE EXCHANGE ACT AND SECTIONS 203(E) AND 203(F) OF THE ADVISERS ACT, IT IS HEREBY ORDERED THAT RESPONDENT 1DB SHALL PAY CIVIL PENALTIES OF $40,000 TO THE UNITED STATES TREASURY. RESPONDENT 1DB IS CENSURED.
Full extracted filing text

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

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

One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Censure
Other Sanctions: 
CIVIL AND ADMINISTRATIVE PENALTY (FINE)
3.
Date Initiated (MM/DD/YYYY): 
01/23/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-14710
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 PROCEEDINGS AROSE OUT OF 1DB'S AND A FORMER EMPLOYEE'S FAILURE REASONABLY TO SUPERVISE A REGISTERED REPRESENTATIVE ("RR")
WITH A VIEW TO PREVENTING AND DETECTING HIS VIOLATIONS OF SECTION 17(A) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"), AND
SECTIONS 10(B) AND 15(A) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER. FROM 2002 TO 2008, WHILE THE RR WAS A REGISTERED
REPRESENTATIVE ASSOCIATED WITH 1DB, HE OPERATED A PONZI SCHEME WHICH DEFRAUDED OVER 50 INVESTORS OF NEARLY $9 MILLION. 1DB DID
NOT HAVE POLICIES AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT VIOLATIONS OF THE SECURITIES LAWS BY REGISTERED
REPRESENTATIVES LIKE THE RR. HAD 1DB HAD SUCH REASONABLE POLICIES AND PROCEDURES, IT WOULD HAVE LIKELY UNCOVERED THE RR'S FRAUD.
SPECIFICALLY, HAD 1DB HAD REASONABLE POLICIES AND PROCEDURES IN THE REVIEW OF THE "DOING BUSINESS AS" BUSINESS ACCOUNTS OF ITS
REGISTERED REPRESENTATIVES, IT IS LIKELY THAT 1DB WOULD HAVE OBSERVED A SUBSTANTIAL INFLUX OF MONEY FROM 1DB'S EXISTING CUSTOMERS
INTO THE RR'S BUSINESS ACCOUNT, THROUGH WHICH HE CONDUCTED HIS PONZI SCHEME. IN ADDITION, 1DB HAD NO POLICY REQUIRING
COMPLIANCE AUDITORS WHO WERE CONDUCTING AUDITS TO REVIEW THE WORK PAPERS AND REPORTS OF PREVIOUS COMPLIANCE AUDITS. HAD 1DB
HAD REASONABLE POLICIES AND PROCEDURES IN THIS REGARD, IT WOULD HAVE BEEN APPARENT THAT THE RR HAD A HISTORY OF INSUFFICIENT OR
ABSENT SIGNAGE. AS A RESULT, AUDITORS WERE UNABLE TO IDENTIFY A REOCCURRING ISSUE THAT, WITH FOLLOW-UP, COULD HAVE UNCOVERED
THAT THE RR TOOK STEPS TO CONCEAL FROM HIS CUSTOMERS HIS ASSOCIATION WITH 1DB FOR FEAR THAT THEY WOULD ALERT THE FIRM TO HIS
SUSPICIOUS INVESTMENT SCHEME. 1DB ALSO FAILED TO CONDUCT UNANNOUNCED AUDITS IN THE NASHVILLE OFFICE AS SPECIFICALLY REQUIRED IN
THE FIRM'S PROCEDURES. HAD 1DB IMPLEMENTED A SYSTEM TO FOLLOW ITS OWN PROCEDURE OF CONDUCTING UNANNOUNCED AUDITS IN THE

NASHVILLE OFFICE, IT IS LIKELY THAT 1DB WOULD HAVE FOUND EVIDENCE OF THE RR'S PONZI SCHEME. FOR EXAMPLE, AN UNANNOUNCED AUDIT
WOULD HAVE REVEALED THAT THE RR DID NOT CONSISTENTLY PROVIDE SIGNS TO INDICATE TO CUSTOMERS HIS ASSOCIATION WITH 1DB. THE
COMMISSION FOUND THAT AS A RESULT OF THE CONDUCT, 1DB AND THE FORMER EMPLOYEE FAILED REASONABLY TO SUPERVISE THE RR WITHIN THE
MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT, AND WITHIN THE MEANING OF SECTION 203(E) AND 203(F) OF THE ADVISERS ACT, WHEN
THEY FAILED TO SUPERVISE THE RR WITH A VIEW TO PREVENTING AND DETECTING HIS VIOLATIONS OF THE FEDERAL SECURITIES LAWS.
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):
01/23/2012
 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: 
IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS, RESPONDENT SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE
COMMISSION DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON
BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS
TO THE COMMISSION'S JURISDICTION OVER RESPONDENT AND THE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED,
RESPONDENT CONSENTED TO THE ENTRY OF THE ORDER INSTITUTING ADMINISTRATIVE PROCEEDINGS PURSUANT TO SECTION 15(B) OF THE
SECURITIES EXCHANGE ACT OF 1934 AND SECTIONS 203(E) AND 203(F) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS,
IMPOSING REMEDIAL SANCTIONS AND A CENSURE ORDER AS TO 1ST DISCOUNT BROKERAGE, INC. THE COMMISSION DEEMED IT APPROPRIATE
AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE RESPONDENT'S OFFER. ACCORDINGLY, PURSUANT TO SECTION
15(B) OF THE EXCHANGE ACT AND SECTIONS 203(E) AND 203(F) OF THE ADVISERS ACT, IT IS HEREBY ORDERED THAT RESPONDENT 1DB SHALL
PAY CIVIL PENALTIES OF $40,000 TO THE UNITED STATES TREASURY. RESPONDENT 1DB IS CENSURED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS, RESPONDENT SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE
COMMISSION DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF
OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE
COMMISSION'S JURISDICTION OVER RESPONDENT AND THE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED, RESPONDENT
CONSENTED TO THE ENTRY OF THE ORDER INSTITUTING ADMINISTRATIVE PROCEEDINGS PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE
ACT OF 1934 AND SECTIONS 203(E) AND 203(F) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, IMPOSING REMEDIAL SANCTIONS
AND A CENSURE ORDER AS TO 1ST DISCOUNT BROKERAGE, INC. THE COMMISSION DEEMED IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE
THE SANCTIONS AGREED TO IN THE RESPONDENT'S OFFER. ACCORDINGLY, PURSUANT TO SECTION 15(B) OF THE EXCHANGE ACT AND SECTIONS
203(E) AND 203(F) OF THE ADVISERS ACT, IT IS HEREBY ORDERED THAT RESPONDENT 1DB SHALL PAY CIVIL PENALTIES OF $40,000 TO THE UNITED
STATES TREASURY. RESPONDENT 1DB IS CENSURED.
Show 3 more source blocks
regulatory · block 7PDF pages 34–36
Regulator name — filed text
FINRA
Monetary/Fine Amount — filed text
$ 50,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

AWC ACCEPTED BY FINRA
Other filed details

Description of allegations — filed text

A.) FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLY-DESIGNED SUPERVISORY SYSTEM AND WSPS REGARDING NON-TRADITIONAL ETFS B.) UNSUITABLE NON-TRADITIONAL ETF TRANSACTIONS

Sanction detail — filed text

- CENSURE - A FINE OF $50,000 - RESTITUTION IN THE AMOUNT OF $39,060.18 PLUS INTEREST
Full extracted filing text

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

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

11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE AND RESTITUTION
3.
Date Initiated (MM/DD/YYYY): 
11/09/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2013038328301
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
NON-TRADITIONAL ETF

7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
A.) FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLY-DESIGNED SUPERVISORY SYSTEM AND WSPS REGARDING NON-TRADITIONAL ETFS
B.) UNSUITABLE NON-TRADITIONAL ETF TRANSACTIONS
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):
11/09/2016
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 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 - A FINE OF $50,000 - RESTITUTION IN THE AMOUNT OF $39,060.18 PLUS INTEREST
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).
AWC ACCEPTED BY FINRA
regulatory · block 8PDF pages 36–38
Regulator name — filed text
FINRA
Monetary/Fine Amount — filed text
$ 7,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

THE FIRM FAILED TO RECORD THE CORRECT TIME OF TRADE EXECUTIONS FOR 29 TRANSACTIONS IN TRACE ELIGIBLE SECURITIES (OR APPROXIMATELY 10 PERCENT OF THE TOTAL NUMBER OF TRADES REPORTED TO TRACE BY THE FIRM DURING THE REVIEW PERIOD) DURING THE PERIOD FROM JAN 1, 2007 THROUGH MARCH 31, 2007. THE FIRM WAS CENSURED AND FINED FOR $7,000.
Other filed details

Description of allegations — filed text

THE FIRM FAILED TO RECORD THE CORRECT TIME OF TRADE EXECUTIONS FOR 29 TRANSACTIONS IN TRACE ELIGIBLE SECURITIES (OR APPROXIMATELY 10 PERCENT OF THE TOTAL NUMBER OF TRADES REPORTED TO TRACE BY THE FIRM DURING THE REVIEW PERIOD) DURING THE PERIOD FROM JAN 1, 2007 THROUGH MARCH 31, 2007.

Sanction detail — filed text

CENSURE AND FINE OF $7,000
Full extracted filing text

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

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

If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/22/2008
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20070087535-01
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: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE FIRM FAILED TO RECORD THE CORRECT TIME OF TRADE EXECUTIONS FOR 29 TRANSACTIONS IN TRACE ELIGIBLE SECURITIES (OR APPROXIMATELY
10 PERCENT OF THE TOTAL NUMBER OF TRADES REPORTED TO TRACE BY THE FIRM DURING THE REVIEW PERIOD) DURING THE PERIOD FROM JAN 1,
2007 THROUGH MARCH 31, 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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
10/13/2008
 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: $ 7,000.00
 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 $7,000
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE FIRM FAILED TO RECORD THE CORRECT TIME OF TRADE EXECUTIONS FOR 29 TRANSACTIONS IN TRACE ELIGIBLE SECURITIES (OR APPROXIMATELY
10 PERCENT OF THE TOTAL NUMBER OF TRADES REPORTED TO TRACE BY THE FIRM DURING THE REVIEW PERIOD) DURING THE PERIOD FROM JAN 1,
2007 THROUGH MARCH 31, 2007. THE FIRM WAS CENSURED AND FINED FOR $7,000.
regulatory · block 9PDF pages 38–40
Regulator name — filed text
FINRA
Monetary/Fine Amount — filed text
$ 5,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)
Other filed details

Description of allegations — filed text

MSRB RULE G-14 - 1ST DISCOUNT BROKERAGE, INC. FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL; THE FIRM FAILED TO REORT INFORMATION ABOUT SUCH TRANSACTIONS WITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRS PORTAL

Sanction detail — filed text

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREORE, THE FIRM WAS FINED $5,000
Full extracted filing text

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

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

B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE
3.
Date Initiated (MM/DD/YYYY): 
04/27/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2008012832401
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Municipal
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
MSRB RULE G-14 - 1ST DISCOUNT BROKERAGE, INC. FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS EFFECTED IN
MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBED BY RULE G-14 RTRS PROCEDURES
AND THE RTRS USERS MANUAL; THE FIRM FAILED TO REORT INFORMATION ABOUT SUCH TRANSACTIONS WITHIN 15 MINUTES OF TIME OF TRADE TO AN
RTRS PORTAL
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):
04/27/2009
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS;

THEREORE, THE FIRM WAS FINED $5,000
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

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