Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Private Funds
Private funds reported by Janney Montgomery Scott LLC
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.
Ownership
Reported direct and indirect ownership ranges
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Janney Montgomery Scott LLC.
Reported ownership and control details
Form ADV · Filing date 2026-06-30 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | ANTHONY MATTHEW MILLERDIRECTOR, PRESIDENT AND CEOIndividual | JANNEY MONTGOMERY SCOTT LLC | Less than 5%Code NA | Yes | DIRECTOR, PRESIDENT AND CEO01/2024 | Schedule APDF page 43 |
| 2 | GREGORY BURNS MCSHEAGENERAL COUNSELIndividual | JANNEY MONTGOMERY SCOTT LLC | Less than 5%Code NA | No | GENERAL COUNSEL12/2012 | Schedule APDF page 43 |
| 3 | DANEEN ELIZABETH DOWNEYDEPUTY GENERAL COUNSELIndividual | JANNEY MONTGOMERY SCOTT LLC | Less than 5%Code NA | No | DEPUTY GENERAL COUNSEL06/2015 | Schedule APDF page 43 |
| 4 | JESSICA ELLEN LEMPAIA CCOIndividual | JANNEY MONTGOMERY SCOTT LLC | Less than 5%Code NA | No | IA CCO05/2018 | Schedule APDF page 43 |
| 5 | DAVID MICHAEL MULLANPRINCIPAL OPERATIONS OFFICERIndividual | JANNEY MONTGOMERY SCOTT LLC | Less than 5%Code NA | No | PRINCIPAL OPERATIONS OFFICER10/2018 | Schedule APDF page 43 |
| 6 | CAROLINE KATHRYNE HALLCHIEF COMPLIANCE OFFICERIndividual | JANNEY MONTGOMERY SCOTT LLC | Less than 5%Code NA | No | CHIEF COMPLIANCE OFFICER03/2021 | Schedule APDF page 43 |
| 7 | CHRISTOPHER FUSCOROSFPIndividual | JANNEY MONTGOMERY SCOTT LLC | Less than 5%Code NA | No | ROSFP03/2021 | Schedule APDF page 43 |
| 8 | KEVIN JUDE REEDEXECUTIVE OFFICERIndividual | JANNEY MONTGOMERY SCOTT LLC | Less than 5%Code NA | Yes | EXECUTIVE OFFICER01/2023 | Schedule APDF page 43 |
| 9 | MICHAEL J HRICKOCHIEF FINANCIAL OFFICERIndividual | JANNEY MONTGOMERY SCOTT LLC | Less than 5%Code NA | No | CHIEF FINANCIAL OFFICER02/2023 | Schedule APDF page 44 |
| 10 | JUNE PURCHASER LLCOWNERDomestic entity | JANNEY MONTGOMERY SCOTT LLC | 75% or moreCode E | Yes | OWNER11/2024 | Schedule APDF page 44 |
| 11 | BRETT STEPHAN RIGGICHIEF OPERATING OFFICERIndividual | JANNEY MONTGOMERY SCOTT LLC | Less than 5%Code NA | No | CHIEF OPERATING OFFICER02/2025 | Schedule APDF page 44 |
| 12 | JUNE HOLDCO, LLCACTIVEDomestic entity | JUNE PURCHASER LLC | 75% or moreCode E | Yes | ACTIVE11/2024 | Schedule BPDF page 44 |
| 13 | JUNE INTERMEDIATE, LLCACTIVEDomestic entity | JUNE HOLDCO, LLC | 75% or moreCode E | Yes | ACTIVE11/2024 | Schedule BPDF page 44 |
| 14 | JUNE TOPCO, LLCACTIVEDomestic entity | JUNE INTERMEDIATE, LLC | 75% or moreCode E | Yes | ACTIVE11/2024 | Schedule BPDF page 44 |
| 15 | KKR JUNE AGGREGATOR L.P.SHAREHOLDERDomestic entity | JUNE TOPCO, LLC | 75% or moreCode E | Yes | SHAREHOLDER11/2024 | Schedule BPDF page 44 |
| 16 | K-PEC JUNE AGGREGATOR GP LLCGENERAL PARTNERDomestic entity | KKR JUNE AGGREGATOR L.P. | Percentage not specifiedCode F | Yes | GENERAL PARTNER08/2024 | Schedule BPDF page 44 |
| 17 | K-PEC HOLDINGS LLCSHAREHOLDERDomestic entity | K-PEC JUNE AGGREGATOR GP LLC | 75% or moreCode E | Yes | SHAREHOLDER07/2024 | Schedule BPDF page 44 |
| 18 | KKR PRIVATE EQUITY CONGLOMERATE LLCSHAREHOLDERDomestic entity | K-PEC HOLDINGS LLC | 75% or moreCode E | No | SHAREHOLDER01/2023 | Schedule BPDF page 44 |
| 19 | KKR JUNE AGGREGATOR GP LLCGENERAL PARTNERDomestic entity | KKR JUNE AGGREGATOR L.P. | Percentage not specifiedCode F | Yes | GENERAL PARTNER11/2024 | Schedule BPDF page 44 |
| 20 | KKR NORTH AMERICA FUND XIII (JUNE) L.P.LIMITED PARTNERDomestic entity | KKR JUNE AGGREGATOR L.P. | 75% or moreCode E | No | LIMITED PARTNER11/2024 | Schedule BPDF page 44 |
| 21 | JUNE TOPCO GP LLCGENERAL PARTNERDomestic entity | KKR NORTH AMERICA FUND XIII (JUNE) L.P. | Percentage not specifiedCode F | Yes | GENERAL PARTNER11/2024 | Schedule BPDF page 44 |
| 22 | KKR NORTH AMERICA XIII (JUNE) BLOCKER LLCLIMITED PARTNERDomestic entity | KKR NORTH AMERICA FUND XIII (JUNE) L.P. | 50% to less than 75%Code D | No | LIMITED PARTNER11/2024 | Schedule BPDF page 44 |
| 23 | KKR NORTH AMERICA XIII (JUNE) BLOCKER PARENT L.P.MEMBERDomestic entity | KKR NORTH AMERICA XIII (JUNE) BLOCKER LLC | 75% or moreCode E | Yes | MEMBER11/2024 | Schedule BPDF page 44 |
| 24 | JUNE TOPCO GP LLCGENERAL PARTNERDomestic entity | KKR NORTH AMERICA XIII (JUNE) BLOCKER PARENT L.P. | Percentage not specifiedCode F | Yes | GENERAL PARTNER11/2024 | Schedule BPDF page 44 |
| 25 | KKR GROUP ASSETS HOLDINGS III L.P.SHAREHOLDERDomestic entity | KKR PRIVATE EQUITY CONGLOMERATE LLC | 75% or moreCode E | Yes | SHAREHOLDER12/2022 | Schedule BPDF page 44 |
| 26 | KKR GROUP ASSETS III GP LLCSHAREHOLDERDomestic entity | KKR GROUP ASSETS HOLDINGS III L.P. | 75% or moreCode E | Yes | SHAREHOLDER08/2020 | Schedule BPDF page 44 |
| 27 | KKR GROUP PARTNERSHIP L.P.SHAREHOLDERDomestic entity | KKR GROUP ASSETS III GP LLC | 75% or moreCode E | Yes | SHAREHOLDER08/2020 | Schedule BPDF page 45 |
| 28 | KKR GROUP HOLDINGS CORP.GENERAL PARTNERDomestic entity | KKR GROUP PARTNERSHIP L.P. | 50% to less than 75%Code D | Yes | GENERAL PARTNER01/2020 | Schedule BPDF page 45 |
| 29 | KKR GROUP HOLDINGS CORP.GENERAL PARTNERDomestic entity | KKR GROUP HOLDINGS L.P. | Percentage not specifiedCode F | Yes | GENERAL PARTNER05/2022 | Schedule BPDF page 45 |
| 30 | KKR GROUP HOLDINGS L.P.LIMITED PARTNERForeign entity | KKR GROUP PARTNERSHIP L.P. | 25% to less than 50%Code C | No | LIMITED PARTNER01/2020 | Schedule BPDF page 45 |
| 31 | KKR GROUP CO. INC.LIMITED PARTNERDomestic entity | KKR GROUP HOLDINGS L.P. | 75% or moreCode E | No | LIMITED PARTNER05/2022 | Schedule BPDF page 45 |
| 32 | KKR GROUP CO. INC.SOLE SHAREHOLDERDomestic entity | KKR GROUP HOLDINGS CORP. | 75% or moreCode E | Yes | SOLE SHAREHOLDER07/2018 | Schedule BPDF page 45 |
| 33 | KKR & CO. INC.SOLE SHAREHOLDERDomestic entity | KKR GROUP CO. INC. | 75% or moreCode E | Yes | SOLE SHAREHOLDER05/2022 | Schedule BPDF page 45 |
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 6/30/2026 5:32:52 PM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
AFelonies2 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?No
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC 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 actions3 Yes2 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?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?Yes
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?Yes
ESelf-regulatory organization actions1 Yes3 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 41 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 1PARKER/HUNTER INCORPORATEDPDF pages 45–47
- Advisory affiliate name — filed text
- PARKER/HUNTER INCORPORATED
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 7324 This advisory affiliate is a Firm an Individual Registered: Yes No Name: PARKER/HUNTER INCORPORATED (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: 11. Resolution Date (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 2PDF pages 47–49
- Regulator name — filed text
- THE STATE OF ILLINOIS
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE FORMAL HEARING SCHEDULED ON THIS MATTER IS HEREBY DISMISSED WITHOUT FURTHER PROCEEDINGS.
Other filed details
Description of allegations — filed text
RESPONDENT'S REGISTRATION AS A DEALER IN THE STATE OF ILLINOIS IS SUBJECT TO PROHIBITION PURSUANT TO SECTION 8.E(1)(K) OF THE ILLINOIS SECURITIES LAW BECAUSE RESPONDENT CONSENTED TO A SECURITIES AND EXCHANGE COMMISSION ORDER.
Sanction detail — filed text
RESPONDENT IS CENSURED AND WILL PAY $7,500 FOR THE COST OF THE INVESTIGATION.
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) THE STATE OF ILLINOIS 2. Principal Sanction: Revocation Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 12/01/2004 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 0400652 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: NO PRODUCT 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): RESPONDENT'S REGISTRATION AS A DEALER IN THE STATE OF ILLINOIS IS SUBJECT TO PROHIBITION PURSUANT TO SECTION 8.E(1)(K) OF THE ILLINOIS SECURITIES LAW BECAUSE RESPONDENT CONSENTED TO A SECURITIES AND EXCHANGE COMMISSION ORDER. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 06/02/2005 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: $ 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: RESPONDENT IS CENSURED AND WILL PAY $7,500 FOR THE COST OF THE INVESTIGATION. 13. Provide a brief summary of 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 FORMAL HEARING SCHEDULED ON THIS MATTER IS HEREBY DISMISSED WITHOUT FURTHER PROCEEDINGS.
regulatory · block 3PDF pages 49–50
- Regulator name — filed text
- STATE OF DELAWARE
- Monetary/Fine Amount — filed text
- $ 105,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
THE STATE OF DELAWARE, OFFICE OF INVESTOR PROTECTION, AND JANNEY MONTGOMERY SCOTT LLC ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER, WHICH WAS ADOPTED BY THE OFFICE THROUGH A FINAL ORDER DATED JUNE 10, 2015 AND RECEIVED BY THE FIRM ON JUNE 29, 2015. THE FIRM CONSENTED TO FINDINGS THAT ONE OF ITS FINANCIAL ADVISORS, WHO LEFT THE FIRM ON NOVEMBER 7, 2008, RECOMMENDED CERTAIN UNSUITABLE TRANSACTIONS AND THAT FINANCIAL ADVISOR WAS NOT REASONABLY SUPERVISED. THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE OF $75,000, $30,000 TOWARD THE COST OF THE STATE'S INVESTIGATION AND REFRAIN FROM ANY FUTURE VIOLATIONS.
Other filed details
Description of allegations — filed text
IT WAS ALLEGED THAT FORMER FINANCIAL ADVISOR, WHO LEFT THE FIRM ON NOVEMBER 7, 2008, RECOMMENDED CERTAIN UNSUITABLE TRANSACTIONS AND THAT BLOCK WAS NOT REASONABLY SUPERVISED.
Sanction detail — filed text
THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE OF $75,000, $30,000 TOWARD THE COST OF THE STATE'S INVESTIGATION AND REFRAIN FROM ANY FUTURE VIOLATIONS.
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 DELAWARE 2. Principal Sanction: Cease and Desist Other Sanctions: ADMINISTRATIVE CONSENT ORDER AND MONETARY FINE 3. Date Initiated (MM/DD/YYYY): 06/29/2015 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 11-2-4 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): IT WAS ALLEGED THAT FORMER FINANCIAL ADVISOR, WHO LEFT THE FIRM ON NOVEMBER 7, 2008, RECOMMENDED CERTAIN UNSUITABLE TRANSACTIONS AND THAT BLOCK WAS NOT REASONABLY SUPERVISED. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 06/29/2015 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: $ 105,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE OF $75,000, $30,000 TOWARD THE COST OF THE STATE'S INVESTIGATION AND REFRAIN FROM ANY FUTURE VIOLATIONS. 13. Provide a brief summary of 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 STATE OF DELAWARE, OFFICE OF INVESTOR PROTECTION, AND JANNEY MONTGOMERY SCOTT LLC ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER, WHICH WAS ADOPTED BY THE OFFICE THROUGH A FINAL ORDER DATED JUNE 10, 2015 AND RECEIVED BY THE FIRM ON JUNE 29, 2015. THE FIRM CONSENTED TO FINDINGS THAT ONE OF ITS FINANCIAL ADVISORS, WHO LEFT THE FIRM ON NOVEMBER 7, 2008, RECOMMENDED CERTAIN UNSUITABLE TRANSACTIONS AND THAT FINANCIAL ADVISOR WAS NOT REASONABLY SUPERVISED. THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE OF $75,000, $30,000 TOWARD THE COST OF THE STATE'S INVESTIGATION AND REFRAIN FROM ANY FUTURE VIOLATIONS.
regulatory · block 4PDF pages 50–52
- Regulator name — filed text
- UNITED STATES SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 875,000.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
DURING 1999 AND 2000, JANNEY MONTGOMERY RECEIVED THREE PAYMENTS IN CONSIDERATION FOR PUBLISHING RESEARCH ON THREE PUBLIC COMPANIES. JANNEY MONTGOMERY DID NOT DISCLOSE THOSE PAYMENTS IN ITS RESEARCH REPORTS. THE FIRM'S FAILURE TO DISCLOSE THESE PAYMENTS WERE IN VIOLATION OF SECTION 17(B) OF THE SECURITIES ACT. IN ADDITION, FROM JULY 1999 THROUGH JUNE 2001, JANNEY MONTGOMERY FAILED TO PRESERVE BUSINESS-RELATED INTERNAL ELECTRONIC MAIL COMMUNICATIONS THAT IT WAS REQUIRED TO MAINTAIN PURSUANT TO SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER.
Other filed details
Description of allegations — filed text
IN THREE INSTANCES IN 1999 AND 2000, THE FIRM FAILED TO DISCLOSE THAT IT HAD RECEIVED A PAYMENT FOR PUBLISHING RESEARCH. IT WAS ALSO ALLEGED THE FIRM FAILED TO MAINTAIN INTERNAL ELECTRONIC MAIL COMMUNICATIONS FROM JULY 1999 THROUGH JUNE 2001.
Sanction detail — filed text
A FINE OF $875,000 WAS PAID IN FULL 09/16/2004.
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) UNITED STATES SECURITIES AND EXCHANGE COMMISSION 2. Principal Sanction: Censure Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 07/02/2003 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: SEC RELEASE NO. 33-8475 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): IN THREE INSTANCES IN 1999 AND 2000, THE FIRM FAILED TO DISCLOSE THAT IT HAD RECEIVED A PAYMENT FOR PUBLISHING RESEARCH. IT WAS ALSO ALLEGED THE FIRM FAILED TO MAINTAIN INTERNAL ELECTRONIC MAIL COMMUNICATIONS FROM JULY 1999 THROUGH JUNE 2001. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 09/16/2004 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: $ 875,000.00 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: A FINE OF $875,000 WAS PAID IN FULL 09/16/2004. 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). DURING 1999 AND 2000, JANNEY MONTGOMERY RECEIVED THREE PAYMENTS IN CONSIDERATION FOR PUBLISHING RESEARCH ON THREE PUBLIC COMPANIES. JANNEY MONTGOMERY DID NOT DISCLOSE THOSE PAYMENTS IN ITS RESEARCH REPORTS. THE FIRM'S FAILURE TO DISCLOSE THESE PAYMENTS WERE IN VIOLATION OF SECTION 17(B) OF THE SECURITIES ACT. IN ADDITION, FROM JULY 1999 THROUGH JUNE 2001, JANNEY MONTGOMERY FAILED TO PRESERVE BUSINESS-RELATED INTERNAL ELECTRONIC MAIL COMMUNICATIONS THAT IT WAS REQUIRED TO MAINTAIN PURSUANT TO SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER.
regulatory · block 5PDF pages 52–54
- Regulator name — filed text
- STATE OF COLORADO-SECURITIES COMMISSION
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
JMS ALLOWED ALBERT COPPERSTONE, AN UNLICENSED SALES REPRESENTATIVE IN COLORADO, TO CONDUCT SECURITIES TRANSACTIONS WITH A COLORADO RESIDENT.
Other filed details
Description of allegations — filed text
JANNEY MONTGOMERY SCOTT (JMS) ALLOWED ALBERT COPPERSTONE, AN UNLICENSED SALES REPRESENTATIVE IN COLORADO, TO CONDUCT SECURITIES TRANSACTIONS WITH A COLORADO RESIDENT.
Sanction detail — filed text
JMS REQUIRED TO CONDUCT 4 INTERNAL AUDITS OF BOCA RATON BRANCH; JULY - DECEMBER, 2005, JAN-JUNE 2006, AND JAN- JULY 2007. BRANCH MANAGER TERRY METZGER, REQUIRED TO COMPLETE CONTINUING ED PROGRAM WITH TWO YEARS OF ORDERS. RESTITUTION OF $259,227.82
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 COLORADO-SECURITIES COMMISSION 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 05/04/2005 Exact Explanation If not exact, provide explanation: THIS REPRESENTS A FINAL DECISION OF A PREVIOUSLY REPORTED MATTER. 4. Docket/Case Number: XY 2004 004 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): JANNEY MONTGOMERY SCOTT LLC 6. Principal Product Type: Other Other Product Types: INVESTMENT ADVICE 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): JANNEY MONTGOMERY SCOTT (JMS) ALLOWED ALBERT COPPERSTONE, AN UNLICENSED SALES REPRESENTATIVE IN COLORADO, TO CONDUCT SECURITIES TRANSACTIONS WITH A COLORADO RESIDENT. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 05/04/2005 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: $ 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: JMS REQUIRED TO CONDUCT 4 INTERNAL AUDITS OF BOCA RATON BRANCH; JULY - DECEMBER, 2005, JAN-JUNE 2006, AND JAN- JULY 2007. BRANCH MANAGER TERRY METZGER, REQUIRED TO COMPLETE CONTINUING ED PROGRAM WITH TWO YEARS OF ORDERS. RESTITUTION OF $259,227.82 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). JMS ALLOWED ALBERT COPPERSTONE, AN UNLICENSED SALES REPRESENTATIVE IN COLORADO, TO CONDUCT SECURITIES TRANSACTIONS WITH A COLORADO RESIDENT.
regulatory · block 6PDF pages 54–56
- Regulator name — filed text
- NASD
- Monetary/Fine Amount — filed text
- $ 1,200,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
THE NASD ALLEGED THAT JANNEY ENGAGED IN CONDUCT WHICH PERMITTED TWO HEDGE FUND CLIENTS TO ENGAGE IN MARKET-TIMING. THE NASD ALSO ALLEGED THAT JANNEY FAILED TO APPROPRIATELY RESPOND TO MARKET TIMING THAT WAS OCCURRING AND FAILED TO ESTABLISH AND MAINTAIN SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO PREVENT AND DETECT MARKET TIMING AND LATE TRADING. FURTHER, THE NASD ALLEGED THAT JANNEY, FROM MAY 2, 2003 THROUGH SEPTEMBER 18, 2003, FAILED TO CREATE RECORDS REFLECTING THE TIME OF RECEIPT OF MUTUAL FUND ORDERS. FINALLY, THE NASD ALLEGED THAT JANNEY FAILED TO ESTABLISH AND MAINTAIN SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT IT CONDUCTED ADEQUATE DUE DILIGENCE FOR ITS RESPONSES TO REGULATORY INQUIRIES.
Sanction detail — filed text
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS DESCRIBED IN PARAGRAPH 7 ABOVE JANNEY CONSENTED TO THE ISSUANCE OF AN NASD AWC IMPOSING A CENSURE, A FINE OF $1,200,000, AND RESTITUTION IN THE AMOUNT OF $998,285.81.
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): 07/21/2005 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: EAF0300920002 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): THE NASD ALLEGED THAT JANNEY ENGAGED IN CONDUCT WHICH PERMITTED TWO HEDGE FUND CLIENTS TO ENGAGE IN MARKET-TIMING. THE NASD ALSO ALLEGED THAT JANNEY FAILED TO APPROPRIATELY RESPOND TO MARKET TIMING THAT WAS OCCURRING AND FAILED TO ESTABLISH AND MAINTAIN SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO PREVENT AND DETECT MARKET TIMING AND LATE TRADING. FURTHER, THE NASD ALLEGED THAT JANNEY, FROM MAY 2, 2003 THROUGH SEPTEMBER 18, 2003, FAILED TO CREATE RECORDS REFLECTING THE TIME OF RECEIPT OF MUTUAL FUND ORDERS. FINALLY, THE NASD ALLEGED THAT JANNEY FAILED TO ESTABLISH AND MAINTAIN SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT IT CONDUCTED ADEQUATE DUE DILIGENCE FOR ITS RESPONSES TO REGULATORY INQUIRIES. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 07/21/2005 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: $ 1,200,000.00 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: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS DESCRIBED IN PARAGRAPH 7 ABOVE JANNEY CONSENTED TO THE ISSUANCE OF AN NASD AWC IMPOSING A CENSURE, A FINE OF $1,200,000, AND RESTITUTION IN THE AMOUNT OF $998,285.81. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
Show 35 more source blocks
regulatory · block 7PDF pages 56–58
- Regulator name — filed text
- PHILADELPHIA STOCK EXCHANGE
- Monetary/Fine Amount — filed text
- $ 20,000.00
- How was matter resolved — filed text
- Decision & Order of Offer of Settlement
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR VIOLATIONS, RESPONDENT CONSENTED TO FINDINGS THAT FROM DECEMBER 3, 2001, THROUGH MAY 8, 2002, IT VIOLATED PHLX RULES 707, 708, AND 748. SPECIFICALLY, (I) AN EMPLOYEE OF RESPONDENT REPRESENTED AND EXECUTED FOR RESPONDENT 46 ORDERS ON THE PHLX FLOOR AT A TIME WHEN SUCH EMPLOYEE WAS NOT A MEMBER OF THE PHLX ELIGIBLE TO CONDUCT BUSINESS ON THE PHLX FLOOR; (II) ANTHER EMPLOYEE OF RESPONDENT REPRESENTED AND EXECUTED FOR RESPONDENT 41 ORDERS ON THE PHLX FLOOR AT A TIME WHEN SUCH EMPLOYEE HAD NOT BECOME AN EFFECTIVE MEMBER OF THE PHLX BY TEMPORARILY ASSUMING LEGAL TITLE TO ONE OF RESPONDENT'S PHLX MEMBERSHIPS; (III) RESPONDENT AVOIDED COSTS ASSOCIATED WITH ACQUIRING EQUITABLE TITLE TO A THIRD PHLX MEMBERSHIP AND AVOIDED HAVING PAY TO THE PHLX CERTAIN DUES, FEES AND CHARGES; AND (IV) RESPONDENT FAILED TO MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES, AND A SYSTEM TO ENFORCE SUCH PROCEDURES, REGARDING ITS OPERATIONS ON THE PHLX FLOOR.
Sanction detail — filed text
RESPONDENT CONSENTED TO: (I) A CENSURE; (II) A FINE IN THE AMOUNT OF $20,000; AND (III) COMPLETION OF THE FOLLOWING UNDERTAKINGS: (1) ISSUANCE OF WRITTEN POLICIES AND PROCEDURES (INCLUDING SUPERVISORY PROCEDURES) PERTAINING TO THE CONDUCT OF BUSINESS BY RESPONDENT ON THE PHLX FLOOR. SUCH POLICIES AND PROCEDURES SHOULD INFORM RESPONDENT'S EXCHANGE FLOOR PERSONNEL AND SUPERVISORS OF, AMONG OTHER THINGS, RESPONDENT'S POLICIES AND PROCEDURES CONCERNING INACTIVE NOMINEE STATUS ON THE PHLX FLOOR; AND (2) ISSUANCE OF A COMPLIANCE BULLETIN, NOT UNACCEPTABLE TO PHLX STAFF, TO ALL MEMBERS OF RESPONDENT'S EXCHANGE FLOOR OPERATIONS, EXPLAINING RESPONDENT'S POLICIES AND PROCEDURES CONCERNING INACTIVE NOMINEE STATUS ON THE PHLX FLOOR.
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) PHILADELPHIA STOCK EXCHANGE 2. Principal Sanction: Censure Other Sanctions: MONETARY/FINE OF $20,000.00 3. Date Initiated (MM/DD/YYYY): 07/17/2002 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: ENFORCEMENT NUMBER 2002-09 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): WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR VIOLATIONS, RESPONDENT CONSENTED TO FINDINGS THAT FROM DECEMBER 3, 2001, THROUGH MAY 8, 2002, IT VIOLATED PHLX RULES 707, 708, AND 748. SPECIFICALLY, (I) AN EMPLOYEE OF RESPONDENT REPRESENTED AND EXECUTED FOR RESPONDENT 46 ORDERS ON THE PHLX FLOOR AT A TIME WHEN SUCH EMPLOYEE WAS NOT A MEMBER OF THE PHLX ELIGIBLE TO CONDUCT BUSINESS ON THE PHLX FLOOR; (II) ANTHER EMPLOYEE OF RESPONDENT REPRESENTED AND EXECUTED FOR RESPONDENT 41 ORDERS ON THE PHLX FLOOR AT A TIME WHEN SUCH EMPLOYEE HAD NOT BECOME AN EFFECTIVE MEMBER OF THE PHLX BY TEMPORARILY ASSUMING LEGAL TITLE TO ONE OF RESPONDENT'S PHLX MEMBERSHIPS; (III) RESPONDENT AVOIDED COSTS ASSOCIATED WITH ACQUIRING EQUITABLE TITLE TO A THIRD PHLX MEMBERSHIP AND AVOIDED HAVING PAY TO THE PHLX CERTAIN DUES, FEES AND CHARGES; AND (IV) RESPONDENT FAILED TO MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES, AND A SYSTEM TO ENFORCE SUCH PROCEDURES, REGARDING ITS OPERATIONS ON THE PHLX FLOOR. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 11/24/2003 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: $ 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: RESPONDENT CONSENTED TO: (I) A CENSURE; (II) A FINE IN THE AMOUNT OF $20,000; AND (III) COMPLETION OF THE FOLLOWING UNDERTAKINGS: (1) ISSUANCE OF WRITTEN POLICIES AND PROCEDURES (INCLUDING SUPERVISORY PROCEDURES) PERTAINING TO THE CONDUCT OF BUSINESS BY RESPONDENT ON THE PHLX FLOOR. SUCH POLICIES AND PROCEDURES SHOULD INFORM RESPONDENT'S EXCHANGE FLOOR PERSONNEL AND SUPERVISORS OF, AMONG OTHER THINGS, RESPONDENT'S POLICIES AND PROCEDURES CONCERNING INACTIVE NOMINEE STATUS ON THE PHLX FLOOR; AND (2) ISSUANCE OF A COMPLIANCE BULLETIN, NOT UNACCEPTABLE TO PHLX STAFF, TO ALL MEMBERS OF RESPONDENT'S EXCHANGE FLOOR OPERATIONS, EXPLAINING RESPONDENT'S POLICIES AND PROCEDURES CONCERNING INACTIVE NOMINEE STATUS ON THE PHLX FLOOR. 13. Provide a brief summary of 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 8PDF pages 58–59
- Regulator name — filed text
- THE STATE OF ILLINOIS
- Monetary/Fine Amount — filed text
- $ 5,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
CONSENT ORDER OF CENSURE ISSUED. RESPONDENT, WHILE NEITHER ADMITTING NOR DENYING THE TRUTH OF THE ALLEGATIONS REGARDING THE REGISTRATION OF TWO OF ITS FINANCIAL CONSULTANTS IN THE STATE OF ILLINOIS, CONSENTED TO A CENSURE AND WILL PAY FOR THE COST OF INVESTIGATION.
Other filed details
Description of allegations — filed text
RESPONDENT'S REGISTRATION AS A DEALER IN THE STATE OF ILLINOIS IS SUBJECT TO REVOCATION BECAUSE OF AN INADVERTENT REGISTRATION ERROR RELATING TO THE REGISTRATION OF TWO FINANCIAL CONSULTANTS OF THE FIRM.
Sanction detail — filed text
CONSENT ORDER OF CENSURE ISSUED. RESPONDENT IS CENSURED AND WILL PAY FOR THE COST OF INVESTIGATION.
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) THE STATE OF ILLINOIS 2. Principal Sanction: Revocation Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 05/07/2004 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 0300927 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): RESPONDENT'S REGISTRATION AS A DEALER IN THE STATE OF ILLINOIS IS SUBJECT TO REVOCATION BECAUSE OF AN INADVERTENT REGISTRATION ERROR RELATING TO THE REGISTRATION OF TWO FINANCIAL CONSULTANTS OF THE FIRM. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 08/16/2004 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: $ 5,000.00 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: CONSENT ORDER OF CENSURE ISSUED. RESPONDENT IS CENSURED AND WILL PAY FOR THE COST OF INVESTIGATION. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). CONSENT ORDER OF CENSURE ISSUED. RESPONDENT, WHILE NEITHER ADMITTING NOR DENYING THE TRUTH OF THE ALLEGATIONS REGARDING THE REGISTRATION OF TWO OF ITS FINANCIAL CONSULTANTS IN THE STATE OF ILLINOIS, CONSENTED TO A CENSURE AND WILL PAY FOR THE COST OF INVESTIGATION.
regulatory · block 9PDF pages 59–61
- Regulator name — filed text
- THE STATE OF GEORGIA
- Monetary/Fine Amount — filed text
- $ 3,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
JANNEY MONTGOMERY SCOTT LLC NEITHER ADMITS NOR DENIES THE FINDING OF FACT AND CONCLUSIONS OF LAW CONTAINED HEREIN, BUT CONSENTS TO THE ENTRY OF THE FOREGOING CONSENT ORDER.
Other filed details
Description of allegations — filed text
IT WAS ALLEGED JANNEY MONTGOMERY FAILED TO KEEP THE REQUIRED REGISTRATION RECORDS OF LICENSES AND REGISTRATIONS PERTAINING TO TWO REGISTERED REPRESENTATIVES.
Sanction detail — filed text
THE CIVIL PENALTY OF $3,000 PLUS $2,000 FOR COST OF THE INVESTIGATION WAS PAID 08/13/2004. RESTITUTION IN THE AMOUNT OF $1,096.50 WAS PAID TO TWO CUSTOMERS ON 09/08/2004.
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) THE STATE OF GEORGIA 2. Principal Sanction: Censure Other Sanctions: CIVIL PENALTY 3. Date Initiated (MM/DD/YYYY): 05/13/2004 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: CASE NUMBER EN-19766 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): IT WAS ALLEGED JANNEY MONTGOMERY FAILED TO KEEP THE REQUIRED REGISTRATION RECORDS OF LICENSES AND REGISTRATIONS PERTAINING TO TWO REGISTERED REPRESENTATIVES. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 08/18/2004 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: $ 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 CIVIL PENALTY OF $3,000 PLUS $2,000 FOR COST OF THE INVESTIGATION WAS PAID 08/13/2004. RESTITUTION IN THE AMOUNT OF $1,096.50 WAS PAID TO TWO CUSTOMERS ON 09/08/2004. 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). JANNEY MONTGOMERY SCOTT LLC NEITHER ADMITS NOR DENIES THE FINDING OF FACT AND CONCLUSIONS OF LAW CONTAINED HEREIN, BUT CONSENTS TO THE ENTRY OF THE FOREGOING CONSENT ORDER.
regulatory · block 10PDF pages 61–63
- Regulator name — filed text
- THE STATE OF RHODE ISLAND
- Monetary/Fine Amount — filed text
- $ 10,250.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
DUE TO AN ADMINISTRATIVE ERROR A VIOLATION OF SECTION 203 OF RIUSA OCCURRED WHEN JANNEY MONTGOMERY SCOTT LLC PERMITTED ONE INVESTMENT ADVISOR REPRESENTATIVE TO SERVICE ONE RHODE ISLAND ACCOUNT IN JANUARY 2006 WITHOUT EFFECTIVE LICENSING.
Other filed details
Description of allegations — filed text
IT WAS ALLEGED THERE WAS A VIOLATION OF SECTION 203 OF RIUSA IN JANNEY MONTGOMERY SCOTT LLC EMPLOYMENT OF ONE INDIVIDUAL AS AN INVESTMENT ADVISOR REPRESENTATIVE WHO SERVICED ONE RHODE ISLAND ACCOUNT JANUARY 2006 WITHOUT EFFECTIVE LICENSING.
Sanction detail — filed text
THE FINE WAS PAID ON DECEMBER 4, 2006
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) THE STATE OF RHODE ISLAND 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 10/12/2006 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: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): IT WAS ALLEGED THERE WAS A VIOLATION OF SECTION 203 OF RIUSA IN JANNEY MONTGOMERY SCOTT LLC EMPLOYMENT OF ONE INDIVIDUAL AS AN INVESTMENT ADVISOR REPRESENTATIVE WHO SERVICED ONE RHODE ISLAND ACCOUNT JANUARY 2006 WITHOUT EFFECTIVE LICENSING. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 12/21/2006 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: $ 10,250.00 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 DECEMBER 4, 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). DUE TO AN ADMINISTRATIVE ERROR A VIOLATION OF SECTION 203 OF RIUSA OCCURRED WHEN JANNEY MONTGOMERY SCOTT LLC PERMITTED ONE INVESTMENT ADVISOR REPRESENTATIVE TO SERVICE ONE RHODE ISLAND ACCOUNT IN JANUARY 2006 WITHOUT EFFECTIVE LICENSING.
regulatory · block 11PDF pages 63–65
- Regulator name — filed text
- NASD
- 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
SEC RULE 604 OF REGULATION NMS (FORMERLY SEC RULE 11AC1-4) RESPONDENT MEMBER FAILED FROM APRIL 1, 2004 TO SEPTEMBER 30, 2004 TO DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION WHEN EACH SUCH ORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SECURITY AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SECURITY.
Sanction detail — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, JANNEY MONTGOMERY SCOTT LLC, CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS 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) NASD 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 07/27/2007 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 20050001285-01 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): SEC RULE 604 OF REGULATION NMS (FORMERLY SEC RULE 11AC1-4) RESPONDENT MEMBER FAILED FROM APRIL 1, 2004 TO SEPTEMBER 30, 2004 TO DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION WHEN EACH SUCH ORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SECURITY AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SECURITY. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 07/27/2007 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: $ 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, JANNEY MONTGOMERY SCOTT LLC, CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS 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).
regulatory · block 12PDF pages 65–66
- Regulator name — filed text
- NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT
- Monetary/Fine Amount — filed text
- $ 2,500,000.00
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
IN RESOLVING THIS MATTER, THE NYSE CONSIDERED (1) THAT THE FIRM IMMEDIATELY AND VOLUNTARILY UNDERTOOK NUMEROUS REMEDIAL EFFORTS, (2) IMPLEMENTED REVISED AND ENHANCED WRITTEN SUPERVISORY PROCEDURES, (3) VOLUNTARILY COMMENCED RECORDING ALL TELEPHONE CONVERSATIONS IN THE STOCK LOAN DEPARTMENT, (4) THE FIRM'S COOPERATION WITH NYSE REGULATION AND (5) THAT NO CUSTOMER ACCOUNTS WERE AFFECTED BY THE ALLEGED IMPROPER ACTIVITIES IN THE STOCK LOAN DEPARTMENT.
Other filed details
Description of allegations — filed text
THE NYSE ALLEGED THAT JANNEY (1) ENGAGED IN AWAY-FROM-MARKET STOCK LOAN TRANSACTIONS; (2) COMPENSATED ALLEGED FINDERS IN CONNECTION WITH STOCK LOAN TRANSACTIONS WHEN THOSE FINDERS HAD PURPORTEDLY NOT PERFORMED ANY SERVICES IN CONNECTION WITH THOSE TRANSACTIONS; (3) FAILED TO REASONABLY SUPERVISE OR CONTROL CERTAIN OF ITS BUSINESS ACTIVITIES; (4) FAILED TO PROVIDE FOR APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL AND ESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO DETERMINE THAT DELEGATED AUTHORITY AND RESPONSIBILITY WAS BEING PROPERLY EXERCISED; AND (5) FAILED TO MAKE AND KEEP ACCURATE RECORDS REFLECTING ITS STOCK LOAN ACTIVITIES.
Sanction detail — filed text
WITHOUT ADMITTING OR DENYING GUILT, THE FIRM CONSENTED TO (1) A CENSURE; (2) A FINE IN THE AMOUNT OF $2,500,000; AND (3) AN UNDERTAKING TO REQUIRING THE FIRM TO CONTINUE TO RECORD THE TELEPHONE CONVERSATIONS OF ITS STOCK LOAN DEPARTMENT AND RETAIN THE RECORDINGS FOR A PERIOD OF NO LESS THAN ONE YEAR.
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) NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT 2. Principal Sanction: Censure Other Sanctions: FINE & UNDERTAKING 3. Date Initiated (MM/DD/YYYY): 07/27/2006 Exact Explanation If not exact, provide explanation: ON OR AROUND JULY 27, 2006, THE NYSE DIVISION OF ENFORCEMENT INFORMED THE FIRM THAT IT WAS BEING REFERRED FOR DISCIPLINARY PROCEEDINGS. 4. Docket/Case Number: HPD#07-107 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: SECURITIES LENDING AND BORROWING 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE NYSE ALLEGED THAT JANNEY (1) ENGAGED IN AWAY-FROM-MARKET STOCK LOAN TRANSACTIONS; (2) COMPENSATED ALLEGED FINDERS IN CONNECTION WITH STOCK LOAN TRANSACTIONS WHEN THOSE FINDERS HAD PURPORTEDLY NOT PERFORMED ANY SERVICES IN CONNECTION WITH THOSE TRANSACTIONS; (3) FAILED TO REASONABLY SUPERVISE OR CONTROL CERTAIN OF ITS BUSINESS ACTIVITIES; (4) FAILED TO PROVIDE FOR APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL AND ESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO DETERMINE THAT DELEGATED AUTHORITY AND RESPONSIBILITY WAS BEING PROPERLY EXERCISED; AND (5) FAILED TO MAKE AND KEEP ACCURATE RECORDS REFLECTING ITS STOCK LOAN ACTIVITIES. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 08/10/2007 Exact Explanation If not exact, provide explanation: THE NYSE'S HEARING BOARD DECISION CONFIRMING THE STIPULATION OF FACTS AND CONSENT TO PENALTY BECAME FINAL ON THE CLOSE OF BUSINESS ON AUGUST 10, 2007. 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 2,500,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKING Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: WITHOUT ADMITTING OR DENYING GUILT, THE FIRM CONSENTED TO (1) A CENSURE; (2) A FINE IN THE AMOUNT OF $2,500,000; AND (3) AN UNDERTAKING TO REQUIRING THE FIRM TO CONTINUE TO RECORD THE TELEPHONE CONVERSATIONS OF ITS STOCK LOAN DEPARTMENT AND RETAIN THE RECORDINGS FOR A PERIOD OF NO LESS THAN ONE YEAR. 13. Provide a brief summary of 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 RESOLVING THIS MATTER, THE NYSE CONSIDERED (1) THAT THE FIRM IMMEDIATELY AND VOLUNTARILY UNDERTOOK NUMEROUS REMEDIAL EFFORTS, (2) IMPLEMENTED REVISED AND ENHANCED WRITTEN SUPERVISORY PROCEDURES, (3) VOLUNTARILY COMMENCED RECORDING ALL TELEPHONE CONVERSATIONS IN THE STOCK LOAN DEPARTMENT, (4) THE FIRM'S COOPERATION WITH NYSE REGULATION AND (5) THAT NO CUSTOMER ACCOUNTS WERE AFFECTED BY THE ALLEGED IMPROPER ACTIVITIES IN THE STOCK LOAN DEPARTMENT.
regulatory · block 13PDF pages 67–68
- Regulator name — filed text
- FLORIDA OFFICE OF FINANCIAL REGULATION
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS RAISED BY THE STATE OF FLORIDA, OFFICE OF FINANCIAL REGULATION, JANNEY MONTGOMERY SCOTT LLC ENTERED INTO A STIPULATION AND CONSENT AGREEMENT WITH THE OFFICE, WHICH WAS ADOPTED BY THE OFFICE THROUGH A FINAL ORDER DATED APRIL 19, 2011. JANNEY CONSENTED TO THE FINDING THAT IT DID NOT COMPLY WITH CERTAIN TERMS OF THE REGISTRATION AGREEMENTS BELONGING TO SEVERAL OF ITS REGISTERED REPRESENTATIVES, AGREED TO CEASE AND DESIST FROM ANY OTHER VIOLATIONS OF FLORIDA'S ADMINISTRATIVE RULES AND PAID AN ADMINISTRATIVE FINE OF $10,000. THE OFFICE OF FINANCIAL REGULATION AGREED TO RELEASE THREE REGISTERED REPRESENTATIVES FROM THEIR REGISTRATION AGREEMENTS.
Other filed details
Description of allegations — filed text
IT WAS ALLEGED THAT JANNEY DID NOT COMPLY WITH CERTAIN ITEMS IN THE REGISTRATION AGREEMENTS OF SEVERAL REGISTERED REPRESENTATIVES.
Sanction detail — filed text
ADMINISTRATIVE FINE OF $10,000.00 PAID IN FULL BY JANNEY MONTGOMERY SCOTT LLC ON 04/19/2011.
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) FLORIDA OFFICE OF FINANCIAL REGULATION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CEASE AND DESIST 3. Date Initiated (MM/DD/YYYY): 04/19/2011 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 0356-S-07/10 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): IT WAS ALLEGED THAT JANNEY DID NOT COMPLY WITH CERTAIN ITEMS IN THE REGISTRATION AGREEMENTS OF SEVERAL REGISTERED REPRESENTATIVES. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 04/19/2011 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: $ 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: ADMINISTRATIVE FINE OF $10,000.00 PAID IN FULL BY JANNEY MONTGOMERY SCOTT LLC ON 04/19/2011. 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 RAISED BY THE STATE OF FLORIDA, OFFICE OF FINANCIAL REGULATION, JANNEY MONTGOMERY SCOTT LLC ENTERED INTO A STIPULATION AND CONSENT AGREEMENT WITH THE OFFICE, WHICH WAS ADOPTED BY THE OFFICE THROUGH A FINAL ORDER DATED APRIL 19, 2011. JANNEY CONSENTED TO THE FINDING THAT IT DID NOT COMPLY WITH CERTAIN TERMS OF THE REGISTRATION AGREEMENTS BELONGING TO SEVERAL OF ITS REGISTERED REPRESENTATIVES, AGREED TO CEASE AND DESIST FROM ANY OTHER VIOLATIONS OF FLORIDA'S ADMINISTRATIVE RULES AND PAID AN ADMINISTRATIVE FINE OF $10,000. THE OFFICE OF FINANCIAL REGULATION AGREED TO RELEASE THREE REGISTERED REPRESENTATIVES FROM THEIR REGISTRATION AGREEMENTS.
regulatory · block 14PDF pages 68–70
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM WAS CENSURED AND FINED $75,000 RELATED TO VIOLATIONS OF MSRB RULES G-32, G-8, G-27 AND G-17, STEMMING FROM ITS UNTIMELY DELIVERY OF OFFICIAL STATEMENTS TO CUSTOMERS WHO PURCHASED MUNICIPAL SECURITIES DURING THE PRIMARY OFFERING DISCLOSURE PERIOD, IN TRANSACTIONS IN WHICH JANNEY WAS NEITHER AN UNDERWRITER NOR PART OF THE UNDERWRITING SYNDICATE. IN RESPONSE, JANNEY ENHANCED ITS POLICIES AND PROCEDURES RELATING TO TIMELY DELIVERY OF OFFICIAL STATEMENTS AND PROVIDED STAFF TRAINING ON RULE REQUIREMENTS AND THE ENHANCED PROCEDURES. JANNEY ALSO NOTIFIED CLIENTS WHO MAY NOT HAVE RECEIVED AN OFFICIAL STATEMENT BY SETTLEMENT DATE AND PROVIDED INSTRUCTIONS AS TO HOW ONE MIGHT BE OBTAINED. JANNEY IS CONFIDENT THAT THESE MEASURES DEMONSTRATE ITS ONGOING COMMITMENT TO COMPLIANCE IN ALL AREAS OF ITS BUSINESS, INCLUDING ITS OBLIGATIONS AS TO MUNICIPAL SECURITIES DISCLOSURE OBLIGATIONS.
Other filed details
Description of allegations — filed text
IT IS ALLEGED THAT JANNEY DID NOT COMPLY WITH MSRB RULES G-8, G-17, G-27, G-32, RELATED TO THE DELIVERY OF OFFICIAL STATEMENTS.
Sanction detail — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $75,000.
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): 05/10/2011 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2009018503501 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): IT IS ALLEGED THAT JANNEY DID NOT COMPLY WITH MSRB RULES G-8, G-17, G-27, G-32, RELATED TO THE DELIVERY OF OFFICIAL STATEMENTS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 05/10/2011 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: $ 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: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $75,000. 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). WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM WAS CENSURED AND FINED $75,000 RELATED TO VIOLATIONS OF MSRB RULES G-32, G-8, G-27 AND G-17, STEMMING FROM ITS UNTIMELY DELIVERY OF OFFICIAL STATEMENTS TO CUSTOMERS WHO PURCHASED MUNICIPAL SECURITIES DURING THE PRIMARY OFFERING DISCLOSURE PERIOD, IN TRANSACTIONS IN WHICH JANNEY WAS NEITHER AN UNDERWRITER NOR PART OF THE UNDERWRITING SYNDICATE. IN RESPONSE, JANNEY ENHANCED ITS POLICIES AND PROCEDURES RELATING TO TIMELY DELIVERY OF OFFICIAL STATEMENTS AND PROVIDED STAFF TRAINING ON RULE REQUIREMENTS AND THE ENHANCED PROCEDURES. JANNEY ALSO NOTIFIED CLIENTS WHO MAY NOT HAVE RECEIVED AN OFFICIAL STATEMENT BY SETTLEMENT DATE AND PROVIDED INSTRUCTIONS AS TO HOW ONE MIGHT BE OBTAINED. JANNEY IS CONFIDENT THAT THESE MEASURES DEMONSTRATE ITS ONGOING COMMITMENT TO COMPLIANCE IN ALL AREAS OF ITS BUSINESS, INCLUDING ITS OBLIGATIONS AS TO MUNICIPAL SECURITIES DISCLOSURE OBLIGATIONS.
regulatory · block 15PDF pages 70–72
- Regulator name — filed text
- UNITED STATES SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 850,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
JANNEY SUBMITTED AN OFFER OF SETTLEMENT, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AND CONSENTED TO THE FINDING THAT FROM 2005 THROUGH 2009, THE FIRM FAILED TO ADEQUATELY ESTABLISH, MAINTAIN AND ENFORCE POLICITES AND PROCEDURES REASONABLE DESIGNED, TAKING INTO CONSIDERATION THE NATURE OF ITS BUSINESS, TO PREVENT THE MISUSE OF MATERIAL, NONPUBLIC INFORMATION PURSUANT TO SECTION 15(G) OF THE EXCHANGE ACT AND IN CERTAIN INSTANCES, SUCH POLICIES AND PROCEDURES WERE NOT PROPERLY IMPLEMENTED OR ENFORCED. THROUGHOUT THE COURSE OF THIS MATTER, JANNEY COMMITTED SIGNIFIGANT RESOURCES TO IMPROVING ITS SECTION 15(G) POLICIES AND PROCEDURES AND WILL CONTINUE TO EVALUATE THESE PROCEDURES WHILE WORKING WITH AN INDEPENDENT CONSULTANT.
Other filed details
Description of allegations — filed text
IT IS ALLEGED THAT JANNEY FAILED TO ADEQUATELY ESTABLISH, MAINTAIN AND ENFORCE POLICIES AND PROCEDURES REASONABLY DESIGNED, TAKING INTO CONSIDERATION OF ITS BUSINESS, TO PREVENT THE MISUSE OF MATERIAL, NONPUBLIC INFORMATION PURSUANT TO SECTION 15(G) OF THE EXCHANGE ACT AND IN CERTAIN INSTANCES, FAILED TO PROPERLY IMPLEMENT OR ENFORCE SUCH POLICIES AND PROCEDURES.
Sanction detail — filed text
CIVIL MONETARY PENALTY OF $850,000 PAID IN FULL BY JANNEY MONTGOMERY SCOTT LLC ON JULY 12, 2011.
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: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CEASE AND DESIST, CENSURE AND AN UNDERTAKING TO RETAIN A QUALIFIED, INDEPENDENT CONSULTANT TO REVIEW THE FIRM'S RELEVANT POLICIES AND PROCEDURES RELATED TO SECTION 15(G) OF THE EXCHANGE ACT. 3. Date Initiated (MM/DD/YYYY): 07/11/2011 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 3-14459 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): IT IS ALLEGED THAT JANNEY FAILED TO ADEQUATELY ESTABLISH, MAINTAIN AND ENFORCE POLICIES AND PROCEDURES REASONABLY DESIGNED, TAKING INTO CONSIDERATION OF ITS BUSINESS, TO PREVENT THE MISUSE OF MATERIAL, NONPUBLIC INFORMATION PURSUANT TO SECTION 15(G) OF THE EXCHANGE ACT AND IN CERTAIN INSTANCES, FAILED TO PROPERLY IMPLEMENT OR ENFORCE SUCH POLICIES AND 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: Order 11. Resolution Date (MM/DD/YYYY): 07/11/2011 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: $ 850,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: JANNEY HAS UNDERTAKEN TO RETAIN A QUALIFIED, INDEPENDENT CONSULTANT TO REVIEW THE FIRM'S RELEVANT POLICIES AND PROCEDURES RELATED TO SECTION 15(G) OF THE EXCHANGE ACT. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: CIVIL MONETARY PENALTY OF $850,000 PAID IN FULL BY JANNEY MONTGOMERY SCOTT LLC ON JULY 12, 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). JANNEY SUBMITTED AN OFFER OF SETTLEMENT, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AND CONSENTED TO THE FINDING THAT FROM 2005 THROUGH 2009, THE FIRM FAILED TO ADEQUATELY ESTABLISH, MAINTAIN AND ENFORCE POLICITES AND PROCEDURES REASONABLE DESIGNED, TAKING INTO CONSIDERATION THE NATURE OF ITS BUSINESS, TO PREVENT THE MISUSE OF MATERIAL, NONPUBLIC INFORMATION PURSUANT TO SECTION 15(G) OF THE EXCHANGE ACT AND IN CERTAIN INSTANCES, SUCH POLICIES AND PROCEDURES WERE NOT PROPERLY IMPLEMENTED OR ENFORCED. THROUGHOUT THE COURSE OF THIS MATTER, JANNEY COMMITTED SIGNIFIGANT RESOURCES TO IMPROVING ITS SECTION 15(G) POLICIES AND PROCEDURES AND WILL CONTINUE TO EVALUATE THESE PROCEDURES WHILE WORKING WITH AN INDEPENDENT CONSULTANT.
regulatory · block 16PDF pages 72–74
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 12,500.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
THE FIRM HAS UPDATED ITS WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO TRADE REPORTING TRANSACTIONS BY WAY OF A GIVE UP AGREEMENT.
Other filed details
Description of allegations — filed text
BETWEEN JUNE 1, 2007 AND MAY 31, 2009, IT IS ALLEGED THAT JANNEY REPORTED 12,733 TRANSACTIONS ON OTC SECURITIES WHICH IT WAS NOT REQUIRED TO REPORT AND THAT THE FIRM'S SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS CONCERNING TRADE REPORTING.
Sanction detail — filed text
$12,500.00 PAID BY CREDIT CARD ON 12/28/2011.
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: A CENSURE, FINE AND UNDERTAKING 3. Date Initiated (MM/DD/YYYY): 12/16/2011 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 20080141700-01 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): BETWEEN JUNE 1, 2007 AND MAY 31, 2009, IT IS ALLEGED THAT JANNEY REPORTED 12,733 TRANSACTIONS ON OTC SECURITIES WHICH IT WAS NOT REQUIRED TO REPORT AND THAT THE FIRM'S SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS CONCERNING 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): 12/16/2011 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: $ 12,500.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKING TO REVIEW FIRM'S RELEVANT SUPERVISORY PROCEDURES AND ADVISE FINRA IN WRITING WITHIN 30 DAYS OF AWC ACCEPTANCE OF ANY REVISIONS TO SUCH 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: $12,500.00 PAID BY CREDIT CARD ON 12/28/2011. 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). THE FIRM HAS UPDATED ITS WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO TRADE REPORTING TRANSACTIONS BY WAY OF A GIVE UP AGREEMENT.
regulatory · block 17PDF pages 74–76
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 175,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
JANNEY ENTERED INTO AN AWC ARISING FROM ISSUES IDENTIFIED IN FINRA'S ROUTINE CYCLE EXAMINATIONS OF THE FIRM IN THE YEARS 2003 THROUGH 2005. THE VIOLATIONS SET FORTH IN THE AWC, WHICH JANNEY NEITHER ADMITTED NOR DENIED, INCLUDE 1) A FAILURE TO ADEQUATELY MONITOR AND SUPERVISE CERTAIN ELEMENTS OF COMPLIANCE WITH ITS AML PROGRAM AND 2) FAILURE TO ESTABLISH AND MAINTAIN CERTAIN ELEMENTS OF ITS BRANCH SUPERVISION PROGRAM RELATED TO REGISTERED REPRESENTATIVES AND OTHER ASSOCIATED PERSONS, INCLUDING FAILURE TO SUPERVISE CERTAIN ACTIVITIES OF BRANCH MANAGERS, FAILURE TO REVIEW BLOOMBERG EMAILS AND INSTANT MESSAGES OF SOME EMPLOYEES, FAILURE TO ESTABLISH PROCEDURES FOR APPROVAL AND SUPERVISION OF USE OF PERSONAL COMPUTERS, FAILURE TO DETERMINE THE NUMBER OF OUTSIDE ACCOUNTS MAINTAINED BY EMPLOYEES , IN 2003 A FAILURE TO DOCUMENT SUPERVISORY REVIEW OF TRADING IN OPTIONS ACCOUNTS, AND SEVERAL INSTANCES EACH YEAR OF FAILURE TO PRE-REVIEW AND APPROVE COMMUNICATIONS WITH THE PUBLIC.
Sanction detail — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM WAS CENSURED AND FINED $175,000, WITH $25,000 RELATED TO VIOLATIONS OF MSRB RULE G-41. JANNEY ALSO SUBMITTED A CORRECTIVE ACTION STATEMENT WHICH SETS FORTH THE ENHANCEMENTS MADE TO THE FIRM'S COMPLIANCE AND SUPERVISORY POLICIES AND PROCEDURES. THE ENHANCEMENTS INCLUDE IMPLEMENTING NEW PROCEDURES, CONTRACTING NEW VENDORS, AND ADOPTING NEW TECHNOLOGIES, AS WELL BOLSTERING SUPERVISORY EFFORTS IN CERTAIN AREAS. IN ADDITION, JANNEY PLACED A FIRM-WIDE EMPHASIS ON ITS AML PROGRAM, INCLUDING FIRM-WIDE AML TRAINING AND ENHANCED SURVEILLANCE TOOLS. JANNEY IS CONFIDENT THAT THESE MEASURES DEMONSTRATE ITS ONGOING COMMITMENT TO COMPLIANCE IN ALL AREAS OF ITS BUSINESS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
CENSURE
3.
Date Initiated (MM/DD/YYYY):
11/03/2010
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), NO. 2007009458001
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):
JANNEY ENTERED INTO AN AWC ARISING FROM ISSUES IDENTIFIED IN FINRA'S ROUTINE CYCLE EXAMINATIONS OF THE FIRM IN THE YEARS 2003
THROUGH 2005. THE VIOLATIONS SET FORTH IN THE AWC, WHICH JANNEY NEITHER ADMITTED NOR DENIED, INCLUDE 1) A FAILURE TO ADEQUATELY
MONITOR AND SUPERVISE CERTAIN ELEMENTS OF COMPLIANCE WITH ITS AML PROGRAM AND 2) FAILURE TO ESTABLISH AND MAINTAIN CERTAIN
ELEMENTS OF ITS BRANCH SUPERVISION PROGRAM RELATED TO REGISTERED REPRESENTATIVES AND OTHER ASSOCIATED PERSONS, INCLUDING
FAILURE TO SUPERVISE CERTAIN ACTIVITIES OF BRANCH MANAGERS, FAILURE TO REVIEW BLOOMBERG EMAILS AND INSTANT MESSAGES OF SOME
EMPLOYEES, FAILURE TO ESTABLISH PROCEDURES FOR APPROVAL AND SUPERVISION OF USE OF PERSONAL COMPUTERS, FAILURE TO DETERMINE THE
NUMBER OF OUTSIDE ACCOUNTS MAINTAINED BY EMPLOYEES , IN 2003 A FAILURE TO DOCUMENT SUPERVISORY REVIEW OF TRADING IN OPTIONS
ACCOUNTS, AND SEVERAL INSTANCES EACH YEAR OF FAILURE TO PRE-REVIEW AND APPROVE COMMUNICATIONS WITH THE PUBLIC.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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):
11/03/2010
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: $ 175,000.00
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 WAS CENSURED AND FINED $175,000, WITH $25,000 RELATED TO VIOLATIONS OF
MSRB RULE G-41. JANNEY ALSO SUBMITTED A CORRECTIVE ACTION STATEMENT WHICH SETS FORTH THE ENHANCEMENTS MADE TO THE FIRM'S
COMPLIANCE AND SUPERVISORY POLICIES AND PROCEDURES. THE ENHANCEMENTS INCLUDE IMPLEMENTING NEW PROCEDURES, CONTRACTING
NEW VENDORS, AND ADOPTING NEW TECHNOLOGIES, AS WELL BOLSTERING SUPERVISORY EFFORTS IN CERTAIN AREAS. IN ADDITION, JANNEY
PLACED A FIRM-WIDE EMPHASIS ON ITS AML PROGRAM, INCLUDING FIRM-WIDE AML TRAINING AND ENHANCED SURVEILLANCE TOOLS. JANNEY IS
CONFIDENT THAT THESE MEASURES DEMONSTRATE ITS ONGOING COMMITMENT TO COMPLIANCE IN ALL AREAS OF ITS BUSINESS.
13. Provide a brief summary of 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 18PDF pages 76–77
- Regulator name — filed text
- FINRAFINANCIAL INDUSTRY REGULATORY AUTHORITY (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
RESPONDENT JANNEY FAILED IN 2007 TO REPORT TO TRACE LARGE BLOCK TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION IN VIOLATION OF NASD RULES 2110 AND 6230(A)
Sanction detail — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, JANNEY CONSENTED TO A FINE OF $5,000,DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS.
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) FINRAFINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 01/20/2010 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2007009222201 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): RESPONDENT JANNEY FAILED IN 2007 TO REPORT TO TRACE LARGE BLOCK TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION IN VIOLATION OF NASD RULES 2110 AND 6230(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): 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: $ 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, JANNEY CONSENTED TO A FINE OF $5,000,DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS. 13. Provide a brief summary of 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 19PDF pages 77–79
- Regulator name — filed text
- FINANCIAL INDUSTRY REGULATORY AUTHORITY
- Monetary/Fine Amount — filed text
- $ 200,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
JANNEY ENTERED INTO THE AWC WITHOUT ADMITTING OR DENYING THE ALLEGATIONS. IN THE AWC FINRA TOOK INTO ACCOUNT THE SIGNIFICANT STEPS JANNEY HAD TAKEN TO ADDRESS POTENTIAL HARM SUSTAINED BY CUSTOMERS AS A RESULT OF THE ILLIQUIDITY IN THE ARS MARKET THAT BEGAN IN FEBRUARY 2008. ADDITIONALLY JANNEY BEGAN THE FOLLOWING ACTIONS PRIOR TO FINRA INVESTIGATION: EXTENDING COST NEUTRAL MARGIN OR NONPURPOSE LOANS TO CUSTOMERS WHO HAD LIQUIDITY NEEDS. IN AUGUST 2008 JANNEY CHOSE TO REPURCHASE ALL CUSTOMERS' ARS HOLDINGS THAT WERE PART OF NONFUNCTIONING MARKETS ARS HOLDINGS THAT WERE NOT PURCHASED AT JANNEY AS LONG AS THEY WERE IN A JANNEY ACCOUNT BY AUGUST 15, 2008.
Other filed details
Description of allegations — filed text
THE VIOLATIONS SET FORTH IN THE AWC WHICH JANNEY ENTERED INTO WITHOUT ADMITTING OR DENYING WERE: 1) FAILURE TO ADEQUATELY DISCLOSE THE RISK OF INVESTING IN ARS, THAT ARS COULD BECOME ILLIQUID AND THAT CUSTOMERS MIGHT BE UNABLE TO OBTAIN ACCESS TO FUNDS INVESTED IN ARS FOR SUBSTANTIAL PERIODS OF TIME; 2) FAILURE TO ESTABLISH AND MAINTAIN PROCEDURES REASONABLY DESIGNED TO ENSURE THAT ARS WERE MARKETED AND SOLD IN COMPLIANCE WITH APPLICABLE RULES AND LAWS; 3) FAILURE TO MAINTAIN POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE ACCURATE DESCRIPTIONS OF ARS TO CUSTOMERS DURING SALES PRESENTATIONS; AND 4) FAILURE TO PROVIDE ADEQUATE TRAINING TO REGISTERED REPRESENTATIVES REGARDING ARS CHARACTERISTICS.
Sanction detail — filed text
PRIOR TO THE ACCEPTANCE BY FINRA OF THE AWC, JANNEY COMPLETED ITS VOLUNTARY REPURCHASE OF ELIGIBLE ARS, REPAID THE DIFFERENCE TO THE SINGLE INVESTOR IT REASONABLY IDENTIFIED WHO SOLD FOR LESS THAN PAR DURING THE RELEVANT CLASS PERIOD. JANNEY ALSO COMPLETED AN OFFER AND REPURCHASE TO 14 FORMER CUSTOMERS WHO HAD PURCHASED WITHIN THE RELEVANT CLASS PERIOD BUT TRANSFERRED THEIR POSITION. JANNEY PAID THE FINE ON MAY 11, 2009.
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) FINANCIAL INDUSTRY REGULATORY AUTHORITY 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CENSURE; COMPLETE VOLUNTARY PURCHASE OF ELIGIBLE ARS FROM INVESTORS IN RELEVANT CLASS; MAKE BEST EFFORTS TO PROVIDE LIQUIDITY TO ARS PURCHASERS NOT IN RELEVANT CLASS; PAY DIFFERENCE BETWEEN PAR & PRICE AT WHICH ANY INVESTOR IN RELEVANT CLASS WHO SOLD ELIGIBLE ARS AT BELOW PAR; AGREE TO ARBITRATE CLAIMS FOR CONSEQUENTIAL DAMAGES FILED BY THOSE IN RELEVANT CLASS THROUGH A SPECIAL ARBITRATION PROGRAM; PROVIDE FINRA WITH REPORTS OF THE REPURCHASE & LIQUIDITY PROVISIONS OF AWC. 3. Date Initiated (MM/DD/YYYY): 05/06/2009 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2008013056401 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 VIOLATIONS SET FORTH IN THE AWC WHICH JANNEY ENTERED INTO WITHOUT ADMITTING OR DENYING WERE: 1) FAILURE TO ADEQUATELY DISCLOSE THE RISK OF INVESTING IN ARS, THAT ARS COULD BECOME ILLIQUID AND THAT CUSTOMERS MIGHT BE UNABLE TO OBTAIN ACCESS TO FUNDS INVESTED IN ARS FOR SUBSTANTIAL PERIODS OF TIME; 2) FAILURE TO ESTABLISH AND MAINTAIN PROCEDURES REASONABLY DESIGNED TO ENSURE THAT ARS WERE MARKETED AND SOLD IN COMPLIANCE WITH APPLICABLE RULES AND LAWS; 3) FAILURE TO MAINTAIN POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE ACCURATE DESCRIPTIONS OF ARS TO CUSTOMERS DURING SALES PRESENTATIONS; AND 4) FAILURE TO PROVIDE ADEQUATE TRAINING TO REGISTERED REPRESENTATIVES REGARDING ARS CHARACTERISTICS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 05/06/2009 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: $ 200,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: COMPLETE ITS VOLUNTARY PURCHASE AT PAR OF ELIGIBLE AUCTION RATE SECURITIES (ARS) (AS DEFINED IN THE AWC) FROM INVESTORS IN RELEVANT CLASS; MAKE BEST EFFORTS TO PROVIDE LIQUIDITY TO OTHER INVESTORS NOT IN RELEVANT CLASS (AS DEFINED IN THE AWC) WHO PURCHASED ARS FROM MEMBER FIRM; PAY THE DIFFERENCE BETWEEN PAR AND THE PRICE AT WHICH ANY INVESTOR IN RELEVANT CLASS WHO SOLD ELIGIBLE ARS AT BELOW PAR; AGREE TO ARBITRATE CLAIMS FOR CONSEQUENTIAL DAMAGES FILED BY INVESTORS IN THE RELEVANT CLASS RELATING TO ELIGIBLE ARS THROUGH A SPECIAL ARBITRATION PROGRAM (SAP); PROVIDE FINRA WITH REPORTS OF THE REPURCHASE AND LIQUIDITY PROVISIONS OF THE AWC. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: PRIOR TO THE ACCEPTANCE BY FINRA OF THE AWC, JANNEY COMPLETED ITS VOLUNTARY REPURCHASE OF ELIGIBLE ARS, REPAID THE DIFFERENCE TO THE SINGLE INVESTOR IT REASONABLY IDENTIFIED WHO SOLD FOR LESS THAN PAR DURING THE RELEVANT CLASS PERIOD. JANNEY ALSO COMPLETED AN OFFER AND REPURCHASE TO 14 FORMER CUSTOMERS WHO HAD PURCHASED WITHIN THE RELEVANT CLASS PERIOD BUT TRANSFERRED THEIR POSITION. JANNEY PAID THE FINE ON MAY 11, 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). JANNEY ENTERED INTO THE AWC WITHOUT ADMITTING OR DENYING THE ALLEGATIONS. IN THE AWC FINRA TOOK INTO ACCOUNT THE SIGNIFICANT STEPS JANNEY HAD TAKEN TO ADDRESS POTENTIAL HARM SUSTAINED BY CUSTOMERS AS A RESULT OF THE ILLIQUIDITY IN THE ARS MARKET THAT BEGAN IN FEBRUARY 2008. ADDITIONALLY JANNEY BEGAN THE FOLLOWING ACTIONS PRIOR TO FINRA INVESTIGATION: EXTENDING COST NEUTRAL MARGIN OR NONPURPOSE LOANS TO CUSTOMERS WHO HAD LIQUIDITY NEEDS. IN AUGUST 2008 JANNEY CHOSE TO REPURCHASE ALL CUSTOMERS' ARS HOLDINGS THAT WERE PART OF NONFUNCTIONING MARKETS ARS HOLDINGS THAT WERE NOT PURCHASED AT JANNEY AS LONG AS THEY WERE IN A JANNEY ACCOUNT BY AUGUST 15, 2008.
regulatory · block 20PDF pages 79–81
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 55,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, JANNEY ENTERED INTO AN AWC CONSENTING TO A CENSURE AND FINE OF $55,000 RELATED TO NASD AND FINRA RULE VIOLATIONS STEMMING FROM A MARKET ORDER TIMELINESS("MOT") SWEEP FOR THE 3RD QUARTER OF 2009 AS WELL AS FINDINGS RELATED TO THE TRADING AND MARKET MAKING SURVEILLANCE ("TMMS") EXAMINATION OF THE FIRM IN JANUARY 2010. THE FIRM HAS UPDATED ITS WRITTEN SUPERVISORY PROCEDURES TO ADDRESS THESE FINDINGS.
Other filed details
Description of allegations — filed text
FINRA RULE 2010, 6380A, 6182, 7450; NASD RULE 2111(A), 2320, 3010; SEC RULE 17A-3, 17A-4, 200(G), AND RULE 611(A)(1). IN THE THIRD QUARTER OF 2009 IN CERTAIN INSTANCES THE FIRM FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY AND FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTERDEALER MARKET AVAILABLE. ADDITIONALLY IN DECEMBER 2009 IN CERTAIN INSTANCES THE FIRM INCORRECTLY MARKED ITS LEDGER AS LONG WHEN THE FIRMS POSITION WAS SHORT, FAILED TO MAINTAIN CUSTOMER CONFIRMATIONS, FAILED TO ACCURATELY DOCUMENT PROPRIETARY POSITIONS, FAILED TO SHOW CORRECT ORDER ENTRY AND FAILED TO PROVIDE ORDER MEMORANDA. THE FIRM ALSO INCORRECTLY REPORTED THE SECOND LEG OF CERTAIN RISKLESS PRINCIPAL TRANSACTIONS AND TRANSMITTED INACCURATE FORMATTED ORDERS TO OATS. THE FIRM EXECUTED SHORT SALE TRANSACTIONS AND FAILED TO APPEND A SHORT SALE MODIFIER TO TRF AND EXECUTED SHORT SALE ORDERS AND FAILED TO MARK THE ORDER AS SHORT. ADDITIONALLY THE FIRM'S WRITTEN SUPERVISORY PROCEDURES FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS WITH RESPECT TO THE RULES OF FINRA AND THE SEC IN THE FOLLOWING SUBJECT AREAS: ORDER HANDLING; BEST EXECUTION; ANTI-INTIMIDATION; TRADE REPORTING; SALE TRANSACTIONS; TRADE HALTS; ERRORS; SOFT DOLLAR ACCOUNTS; OATS; SUB-PENNY RULES; ELECTRONIC COMMUNICATION; TRADE THROUGHS OF PROTECTED QUOTATIONS IN NMS STOCKS; BACKING AWAY; AND INFORMATION BARRIERS.
Sanction detail — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS THE FIRM CONSENTED TO A CENSURE, A FINE IN THE AMOUNT OF $55,000 AND AN UNDERTAKING TO REVISE ITS WSPS WITH RESPECT TO ORDER HANDLING; BEST EXECUTION; ANTI-INTIMIDATION; TRADE REPORTING; SALE TRANSACTIONS; TRADE HALTS; ERRORS; SOFT DOLLAR ACCOUNTS; OATS; SUB-PENNY RULES; ELECTRONIC COMMUNICATION; TRADE THROUGHS OF PROTECTED QUOTATIONS IN NMS STOCKS; BACKING AWAY; AND INFORMATION BARRIERS.
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):
04/24/2012
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2009020826501
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
NATIONAL MARKET SYSTEM (NMS) STOCKS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA RULE 2010, 6380A, 6182, 7450; NASD RULE 2111(A), 2320, 3010; SEC RULE 17A-3, 17A-4, 200(G), AND RULE 611(A)(1). IN THE THIRD QUARTER
OF 2009 IN CERTAIN INSTANCES THE FIRM FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY AND FAILED TO USE REASONABLE DILIGENCE TO
ASCERTAIN THE BEST INTERDEALER MARKET AVAILABLE. ADDITIONALLY IN DECEMBER 2009 IN CERTAIN INSTANCES THE FIRM INCORRECTLY MARKED
ITS LEDGER AS LONG WHEN THE FIRMS POSITION WAS SHORT, FAILED TO MAINTAIN CUSTOMER CONFIRMATIONS, FAILED TO ACCURATELY DOCUMENT
PROPRIETARY POSITIONS, FAILED TO SHOW CORRECT ORDER ENTRY AND FAILED TO PROVIDE ORDER MEMORANDA. THE FIRM ALSO INCORRECTLY
REPORTED THE SECOND LEG OF CERTAIN RISKLESS PRINCIPAL TRANSACTIONS AND TRANSMITTED INACCURATE FORMATTED ORDERS TO OATS. THE
FIRM EXECUTED SHORT SALE TRANSACTIONS AND FAILED TO APPEND A SHORT SALE MODIFIER TO TRF AND EXECUTED SHORT SALE ORDERS AND
FAILED TO MARK THE ORDER AS SHORT. ADDITIONALLY THE FIRM'S WRITTEN SUPERVISORY PROCEDURES FAILED TO PROVIDE FOR THE MINIMUM
REQUIREMENTS WITH RESPECT TO THE RULES OF FINRA AND THE SEC IN THE FOLLOWING SUBJECT AREAS: ORDER HANDLING; BEST EXECUTION;
ANTI-INTIMIDATION; TRADE REPORTING; SALE TRANSACTIONS; TRADE HALTS; ERRORS; SOFT DOLLAR ACCOUNTS; OATS; SUB-PENNY RULES;
ELECTRONIC COMMUNICATION; TRADE THROUGHS OF PROTECTED QUOTATIONS IN NMS STOCKS; BACKING AWAY; AND INFORMATION BARRIERS.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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):
04/24/2012
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: $ 55,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
A CENSURE, A FINE OF $55,000 AND AN UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO THE
ABOVE REFERENCED ALLEGATIONS.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement 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 A CENSURE, A FINE IN THE AMOUNT OF $55,000 AND AN
UNDERTAKING TO REVISE ITS WSPS WITH RESPECT TO ORDER HANDLING; BEST EXECUTION; ANTI-INTIMIDATION; TRADE REPORTING; SALE
TRANSACTIONS; TRADE HALTS; ERRORS; SOFT DOLLAR ACCOUNTS; OATS; SUB-PENNY RULES; ELECTRONIC COMMUNICATION; TRADE THROUGHS
OF PROTECTED QUOTATIONS IN NMS STOCKS; BACKING AWAY; AND INFORMATION BARRIERS.
13. Provide a brief summary of 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, JANNEY ENTERED INTO AN AWC CONSENTING TO A CENSURE AND FINE OF $55,000 RELATED TO
NASD AND FINRA RULE VIOLATIONS STEMMING FROM A MARKET ORDER TIMELINESS("MOT") SWEEP FOR THE 3RD QUARTER OF 2009 AS WELL AS
FINDINGS RELATED TO THE TRADING AND MARKET MAKING SURVEILLANCE ("TMMS") EXAMINATION OF THE FIRM IN JANUARY 2010. THE FIRM HAS
UPDATED ITS WRITTEN SUPERVISORY PROCEDURES TO ADDRESS THESE FINDINGS.regulatory · block 21PDF pages 81–83
- Regulator name — filed text
- NASDAQ STOCK MARKET
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, JANNEY ENTERED INTO AN AWC WITH NASDAQ CONSENTING TO A CENSURE AND FINE OF $10,000 FOR VIOLATIONS OF NASDAQ RULES 4755, 2110, AND 3010. THESE VIOLATIONS RELATING TO FINDINGS FROM THE FIRM'S JANUARY 2010 TRADING AND MARKET MAKING SURVEILLANCE ("TMMS") EXAMINATION. THE FIRM HAS UPDATED IT WRITTEN SUPERVISORY PROCEDURES TO ADDRESS THESE FINDINGS.
Other filed details
Description of allegations — filed text
NASDAQ RULES 4755, 2110, AND 3010: DURING DECEMBER 2009 THE FIRM ENTERED 29 ORDERS TO THE NASDAQ MARKET THAT FAILED TO CORRECTLY INDICATE WHETHER THE ORDERS WERE A BUY, LONG SALE OR SHORT SALE. IN ADDITION THE FIRM'S WRITTEN SUPERVISORY PROCEDURES FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS WITH RESPECT TO THE RULES OF NASDAQ IN THE FOLLOWING SUBJECT AREAS: ACCURACY OF NASDAQ ORDER ENTRY INFORMATION; REFRAINING FROM LOCKING OR CROSSING AN EXISTING QUOTE ON NASDAQ; AND CLEARLY ERRONEOUS TRANSACTIONS.
Sanction detail — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS THE FIRM CONSENTED TO A CENSURE, A FINE IN THE AMOUNT OF $10,000 AND AN UNDERTAKING TO REVISE ITS WSPS WITH RESPECT TO NASDAQ ORDER ENTRY INFORMATION, QUOTE SURVEILLANCE AND CLEARLY ERRONEOUS TRANSACTIONS.
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)
NASDAQ STOCK MARKET
2.
Principal Sanction:
Censure
Other Sanctions:
CENSURE AND FINE
3.
Date Initiated (MM/DD/YYYY):
04/24/2012
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20090208265-02
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
NASDAQ SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NASDAQ RULES 4755, 2110, AND 3010: DURING DECEMBER 2009 THE FIRM ENTERED 29 ORDERS TO THE NASDAQ MARKET THAT FAILED TO CORRECTLY
INDICATE WHETHER THE ORDERS WERE A BUY, LONG SALE OR SHORT SALE. IN ADDITION THE FIRM'S WRITTEN SUPERVISORY PROCEDURES FAILED TO
PROVIDE FOR THE MINIMUM REQUIREMENTS WITH RESPECT TO THE RULES OF NASDAQ IN THE FOLLOWING SUBJECT AREAS: ACCURACY OF NASDAQ
ORDER ENTRY INFORMATION; REFRAINING FROM LOCKING OR CROSSING AN EXISTING QUOTE ON NASDAQ; AND CLEARLY ERRONEOUS 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):
04/24/2012
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: $ 10,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
A $10,000 FINE AND AN UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO THE ABOVE
ALLEGATIONS.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement 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 A CENSURE, A FINE IN THE AMOUNT OF $10,000 AND AN
UNDERTAKING TO REVISE ITS WSPS WITH RESPECT TO NASDAQ ORDER ENTRY INFORMATION, QUOTE SURVEILLANCE AND CLEARLY ERRONEOUS
TRANSACTIONS.
13. Provide a brief summary of 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, JANNEY ENTERED INTO AN AWC WITH NASDAQ CONSENTING TO A CENSURE AND FINE OF $10,000
FOR VIOLATIONS OF NASDAQ RULES 4755, 2110, AND 3010. THESE VIOLATIONS RELATING TO FINDINGS FROM THE FIRM'S JANUARY 2010 TRADING
AND MARKET MAKING SURVEILLANCE ("TMMS") EXAMINATION. THE FIRM HAS UPDATED IT WRITTEN SUPERVISORY PROCEDURES TO ADDRESS THESE
FINDINGS.regulatory · block 22PDF pages 83–85
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 52,500.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
IN CONNECTION WITH A SETTLEMENT OF MATTERS ARISING OUT OF AN EXAMINATION FOR THE 2009-2010 PERIOD, FINRA ALLEGED THE FIRM VIOLATED REG SHO RULES 204(A) AND 204(B) BY FAILING TO CLOSE OUT FAILS TO DELIVER RESULTING FROM SALE TRANSACTIONS IN CERTAIN PROPRIETARY ACCOUNTS AND AS A RESULT NOT DETERMINING SECURITIES SHOULD HAVE BEEN RESTRICTED FROM FURTHER SHORT SALES, FAILING TO COMPLY WITH THE CLOSE-OUT REQUIREMENTS IN CERTAIN CUSTOMER ACCOUNTS AND FAILING TO MAINTAIN AND APPLY CERTAIN CORRESPONDING WRITTEN SUPERVISORY PROCEDURES AS REQUIRED BY FINRA RULE 3010, 3010(A) AND (B). FINRA ALSO ALLEGED THE FIRM VIOLATED MSRB RULES IN CONNECTION WITH CERTAIN OFFERINGS DURING THE PERIOD BY FILING FORM G-32 WITH THE MUNICIPAL SECURITIES RULEMAKING BOARD (MSRB) CONTAINING AN INCORRECT DATE FOR THREE OFFERINGS AND LATE TO EMMA FOR TEN OFFERINGS, FAILING TO TIMELY SEND THE FINAL SETTLEMENT LETTERS TO ACCOMPLISH FINAL SETTLEMENT REQUIRED BY G-11 FOR TWO OFFERINGS, AND AMENDING BY ONE DAY LATE THE OFFICIAL STATEMENT WITH MSRB REQUIRED BY G-36 IN THREE OFFERINGS. FINALLY FINRA ALLEGED THE FIRM VIOLATED RULE 3010 AND MSRB G-27 BY FAILING TO ENFORCE ITS WRITTEN POLICIES AND PROCEDURES PERTAINING TO DEPOSITS OF LOW-PRICED SECURITIES THAT TRADED ON THE OTCBB BY ACCEPTING A CERTIFICATE FOR 5 MILLION SHARES IN ONE BRANCH OFFICE WITHOUT OBTAINING AN EXCEPTION AS REQUIRED AND EXECUTING FOUR RETAIL VARIABLE RATE DEMAND OBLIGATION (VRDO) SECURITIES TRADES WITHOUT UPDATING ITS WRITTEN SUPERVISORY PROCEDURES (WSPS) TO ADDRESS THE DISCLOSURE OF ALL MATERIAL INFORMATION TO CUSTOMERS IN CONNECTION WITH SUCH TRANSACTIONS.
Sanction detail — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. THE FIRM WAS CENSURED AND FINED $52,500 ($5,000 OF WHICH PERTAINS TO THE MSRB RULE VIOLATIONS).
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: CIVIL AND ADMINISTRATIVE PENALTY/FINE 3. Date Initiated (MM/DD/YYYY): 08/08/2012 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2011028261501 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: MUNICIPAL SECURITIES 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): IN CONNECTION WITH A SETTLEMENT OF MATTERS ARISING OUT OF AN EXAMINATION FOR THE 2009-2010 PERIOD, FINRA ALLEGED THE FIRM VIOLATED REG SHO RULES 204(A) AND 204(B) BY FAILING TO CLOSE OUT FAILS TO DELIVER RESULTING FROM SALE TRANSACTIONS IN CERTAIN PROPRIETARY ACCOUNTS AND AS A RESULT NOT DETERMINING SECURITIES SHOULD HAVE BEEN RESTRICTED FROM FURTHER SHORT SALES, FAILING TO COMPLY WITH THE CLOSE-OUT REQUIREMENTS IN CERTAIN CUSTOMER ACCOUNTS AND FAILING TO MAINTAIN AND APPLY CERTAIN CORRESPONDING WRITTEN SUPERVISORY PROCEDURES AS REQUIRED BY FINRA RULE 3010, 3010(A) AND (B). FINRA ALSO ALLEGED THE FIRM VIOLATED MSRB RULES IN CONNECTION WITH CERTAIN OFFERINGS DURING THE PERIOD BY FILING FORM G-32 WITH THE MUNICIPAL SECURITIES RULEMAKING BOARD (MSRB) CONTAINING AN INCORRECT DATE FOR THREE OFFERINGS AND LATE TO EMMA FOR TEN OFFERINGS, FAILING TO TIMELY SEND THE FINAL SETTLEMENT LETTERS TO ACCOMPLISH FINAL SETTLEMENT REQUIRED BY G-11 FOR TWO OFFERINGS, AND AMENDING BY ONE DAY LATE THE OFFICIAL STATEMENT WITH MSRB REQUIRED BY G-36 IN THREE OFFERINGS. FINALLY FINRA ALLEGED THE FIRM VIOLATED RULE 3010 AND MSRB G-27 BY FAILING TO ENFORCE ITS WRITTEN POLICIES AND PROCEDURES PERTAINING TO DEPOSITS OF LOW-PRICED SECURITIES THAT TRADED ON THE OTCBB BY ACCEPTING A CERTIFICATE FOR 5 MILLION SHARES IN ONE BRANCH OFFICE WITHOUT OBTAINING AN EXCEPTION AS REQUIRED AND EXECUTING FOUR RETAIL VARIABLE RATE DEMAND OBLIGATION (VRDO) SECURITIES TRADES WITHOUT UPDATING ITS WRITTEN SUPERVISORY PROCEDURES (WSPS) TO ADDRESS THE DISCLOSURE OF ALL MATERIAL INFORMATION TO CUSTOMERS IN CONNECTION WITH SUCH 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): 08/08/2012 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: $ 52,500.00 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: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. THE FIRM WAS CENSURED AND FINED $52,500 ($5,000 OF WHICH PERTAINS TO THE MSRB RULE VIOLATIONS). 13. Provide a brief summary of 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 23PDF pages 85–87
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 45,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
FINRA ALLEGED THE FIRM DID NOT CLOSE OUT FAIL-TO-DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY WITHIN THE TIME FRAME PRESCRIBED BY REG SHO AND RULE 204 AND 204T. FURTHER, THE FIRM DID NOT PROPERLY TRANSMIT REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) WITHIN THE APPROPRIATE TIME PERIOD DUE TO CONTEXT OR SYNTAX ERRORS. THE FIRM ALSO DID NOT PROPERLY REPAIR OR RESUBMIT CERTAIN INACCURATE ROES WITHIN THE APPROPRIATE TIME PERIOD AS PRESCRIBED BY FINRA RULE 7450 . FINALLY, AS REQUIRED BY MSRB RULE G-17 AND G-30(A), THE FIRM DID NOT REASONABLY PRICE CERTAIN MUNICIPAL SECURITIES THAT WERE PURCHASED IN THE AGGREGATE FROM CUSTOMER ACCOUNTS.
Sanction detail — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. THE FIRM WAS ALSO CENSURED, FINED $45,000, ORDERED TO PAY $5,758.36 IN RESTITUTION TO CUSTOMERS RELATING TO THE MUNICIPAL SECURITIES PRICING, AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING OATS.
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: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 12/12/2012 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2009020223601 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: EQUITY SECURITIES 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FINRA ALLEGED THE FIRM DID NOT CLOSE OUT FAIL-TO-DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY WITHIN THE TIME FRAME PRESCRIBED BY REG SHO AND RULE 204 AND 204T. FURTHER, THE FIRM DID NOT PROPERLY TRANSMIT REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) WITHIN THE APPROPRIATE TIME PERIOD DUE TO CONTEXT OR SYNTAX ERRORS. THE FIRM ALSO DID NOT PROPERLY REPAIR OR RESUBMIT CERTAIN INACCURATE ROES WITHIN THE APPROPRIATE TIME PERIOD AS PRESCRIBED BY FINRA RULE 7450 . FINALLY, AS REQUIRED BY MSRB RULE G-17 AND G-30(A), THE FIRM DID NOT REASONABLY PRICE CERTAIN MUNICIPAL SECURITIES THAT WERE PURCHASED IN THE AGGREGATE FROM CUSTOMER 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: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 12/12/2012 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: $ 45,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKING Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. THE FIRM WAS ALSO CENSURED, FINED $45,000, ORDERED TO PAY $5,758.36 IN RESTITUTION TO CUSTOMERS RELATING TO THE MUNICIPAL SECURITIES PRICING, AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING OATS. 13. Provide a brief summary of 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 24PDF pages 87–89
- Regulator name — filed text
- COMMONWEALTH OF MASSACHUSETTS, DIVISION OF INSURANCE
- How was matter resolved — filed text
- Decision & Order of Offer of Settlement
Action status / disposition — filed text
THE MASSACHUSETTS DIVISION OF INSURANCE ALLEGES JANNEY MONTGOMERY SCOTT FAILED TO ACCURATELY ANSWER A BACKGROUND QUESTION ON ITS 2010 LICENSE APPLICATION IN VIOLATION OF M.G.L. C.175 162R(A)(1). IN LIGHT OF ALL THE FACTS AND CIRCUMSTANCES, THE DIVISION PROPOSED TO RESOLVE THIS MATTER THROUGH A SETTLEMENT IF JANNEY, WITHOUT ADMITTING TO ANY VIOLATION OF MASSACHUSETTS INSURANCE LAWS, AGREES TO CEASE AND DESIST FROM THE ABOVE ALLEGED CONDUCT. THIS MATTER WAS RESOLVED ON MAY 28, 2013.
Other filed details
Description of allegations — filed text
THE MASSACHUSETTS DIVISION OF INSURANCE ALLEGES JANNEY MONTGOMERY SCOTT FAILED TO ACCURATELY ANSWER A BACKGROUND QUESTION ON ITS 2010 LICENSE APPLICATION IN VIOLATION OF M.G.L. C.175 162R(A)(1).
Sanction detail — filed text
CEASE AND DESIST FROM THE ALLEGED CONDUCT.
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) COMMONWEALTH OF MASSACHUSETTS, DIVISION OF INSURANCE 2. Principal Sanction: Cease and Desist Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 05/28/2013 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: SIU NO 7511 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 MASSACHUSETTS DIVISION OF INSURANCE ALLEGES JANNEY MONTGOMERY SCOTT FAILED TO ACCURATELY ANSWER A BACKGROUND QUESTION ON ITS 2010 LICENSE APPLICATION IN VIOLATION OF M.G.L. C.175 162R(A)(1). 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 05/28/2013 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: $ 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: CEASE AND DESIST FROM THE ALLEGED CONDUCT. 13. Provide a brief summary of 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 MASSACHUSETTS DIVISION OF INSURANCE ALLEGES JANNEY MONTGOMERY SCOTT FAILED TO ACCURATELY ANSWER A BACKGROUND QUESTION ON ITS 2010 LICENSE APPLICATION IN VIOLATION OF M.G.L. C.175 162R(A)(1). IN LIGHT OF ALL THE FACTS AND CIRCUMSTANCES, THE DIVISION PROPOSED TO RESOLVE THIS MATTER THROUGH A SETTLEMENT IF JANNEY, WITHOUT ADMITTING TO ANY VIOLATION OF MASSACHUSETTS INSURANCE LAWS, AGREES TO CEASE AND DESIST FROM THE ABOVE ALLEGED CONDUCT. THIS MATTER WAS RESOLVED ON MAY 28, 2013.
regulatory · block 25PDF pages 89–90
- Regulator name — filed text
- FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA")
- Monetary/Fine Amount — filed text
- $ 17,500.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO SHOW THE CORRECT TIME OF ENTRY AND THE TERMS AND CONDITIONS ON THE MEMORANDUM OF 50 BROKERAGE ORDERS AND TRANSMITTED 50 REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA TO THE ORDER AUDIT TRAIL SYSTEM (OATS). THE FIRM HAS PAID THE REQUIRED PENALTY ($17,500) AND THE PROCESSES IN QUESTION HAVE SINCE BEEN AUTOMATED AND THE FIRMS POLICIES AND PROCEDURES UPDATED ACCORDINGLY.
Other filed details
Description of allegations — filed text
FINRA ALLEGED THE FIRM FAILED TO SHOW THE CORRECT TIME OF ENTRY AND THE TERMS AND CONDITIONS ON THE MEMORANDUM OF 50 BROKERAGE ORDERS DURING THE REVIEW PERIOD IN VIOLATION OF SEC RULE 17A-3 AND FINRA RULE 4511. ADDITIONALLY, DURING THE REVIEW PERIOD, THE FIRM TRANSMITTED TO OATS 50 REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA. SPECIFICALLY, THE REPORTS CONTAINED 50 INACCURATE ORDER RECEIPT TIMESTAMPS, 33 INACCURATE ACCOUNT TYPE CODES, 33 INACCURATE CAPACITY CODES, AND 50 INCOMPLETE SPECIAL HANDLING CODES IN VIOLATION OF FINRA RULE 7450(A).
Sanction detail — filed text
THE FIRM PAID THE REQUIRED PENALTY OF $17,500.
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)
FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
03/02/2015
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20120341461-01
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):
FINRA ALLEGED THE FIRM FAILED TO SHOW THE CORRECT TIME OF ENTRY AND THE TERMS AND CONDITIONS ON THE MEMORANDUM OF 50 BROKERAGE
ORDERS DURING THE REVIEW PERIOD IN VIOLATION OF SEC RULE 17A-3 AND FINRA RULE 4511. ADDITIONALLY, DURING THE REVIEW PERIOD, THE
FIRM TRANSMITTED TO OATS 50 REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA. SPECIFICALLY, THE
REPORTS CONTAINED 50 INACCURATE ORDER RECEIPT TIMESTAMPS, 33 INACCURATE ACCOUNT TYPE CODES, 33 INACCURATE CAPACITY CODES, AND
50 INCOMPLETE SPECIAL HANDLING CODES IN VIOLATION OF FINRA RULE 7450(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):
03/02/2015
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: $ 17,500.00
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 FIRM PAID THE REQUIRED PENALTY OF $17,500.
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).
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
SHOW THE CORRECT TIME OF ENTRY AND THE TERMS AND CONDITIONS ON THE MEMORANDUM OF 50 BROKERAGE ORDERS AND TRANSMITTED 50
REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA TO THE ORDER AUDIT TRAIL SYSTEM (OATS). THE FIRM HAS
PAID THE REQUIRED PENALTY ($17,500) AND THE PROCESSES IN QUESTION HAVE SINCE BEEN AUTOMATED AND THE FIRMS POLICIES AND
PROCEDURES UPDATED ACCORDINGLY.regulatory · block 26PDF pages 90–92
- Regulator name — filed text
- NASDAQ STOCK MARKET
- Monetary/Fine Amount — filed text
- $ 12,500.00
- 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 FAILED TO DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES (INCLUDING THE ORDERS' FULL SIZE AND PRICE) IN ITS PUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCH SECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCH SECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SUCH SECURITY, IN VIOLATION OF SEC RULE 604 OF REGULATION NMS.
Sanction detail — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, JANNEY ENTERED IN AN AWC WITH NASDAQ IN WHICH IT CONSENTED TO A CENSURE AND FINE IN THE AMOUNT OF $12,500 RELATED TO SEC RULE 604 OF REGULATION NMS. THE FIRM HAS UPDATED ITS SUPERVISORY POLICIES AND PROCEDURES TO ADDRESS THESE FINDINGS.
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) NASDAQ STOCK MARKET 2. Principal Sanction: Censure Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 07/11/2014 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2012034405001 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): WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES (INCLUDING THE ORDERS' FULL SIZE AND PRICE) IN ITS PUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCH SECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCH SECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SUCH SECURITY, IN VIOLATION OF SEC RULE 604 OF REGULATION NMS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 07/11/2014 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: WITHOUT ADMITTING OR DENYING THE FINDINGS, JANNEY ENTERED IN AN AWC WITH NASDAQ IN WHICH IT CONSENTED TO A CENSURE AND FINE IN THE AMOUNT OF $12,500 RELATED TO SEC RULE 604 OF REGULATION NMS. THE FIRM HAS UPDATED ITS SUPERVISORY POLICIES AND PROCEDURES TO ADDRESS THESE FINDINGS. 13. Provide a brief summary of 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 27PDF pages 92–94
- Regulator name — filed text
- FINRA
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
IN MAY 2015, THE FIRM SELF-REPORTED THAT SOME ELIGIBLE CUSTOMERS HAD NOT RECEIVED AVAILABLE SALES CHARGE WAIVERS. AS A RESULT, THE FIRM ESTIMATES THAT ELIGIBLE CUSTOMERS WERE OVERCHARGED BY APPROXIMATELY $1,030,235 FOR MUTUAL FUND PURCHASES MADE BETWEEN JULY 1, 2009 AND JUNE 24, 2015. AS PART OF THIS SETTLEMENT, THE FIRM AGREES TO PAY RESTITUTION PLUS INTEREST. THE FIRM WILL ALSO ENSURE THAT RETIREMENT AND CHARITABLE ACCOUNT MUTUAL FUND FEE WAIVERS ARE APPROPRIATELY APPLIED TO ALL FUTURE TRANSACTIONS. IN RESOLVING THIS MATTER, FINRA HAS RECOGNIZED THE EXTRAORDINARY COOPERATION OF THE FIRM FOR HAVING: (1) INITIATED, PRIOR TO DETECTION OR INTERVENTION BY A REGULATOR, AN INVESTIGATION TO IDENTIFY WHETHER ELIGIBLE CUSTOMERS RECEIVED SALES CHARGE WAIVERS DURING THE RELEVANT PERIOD; (2) PROMPTLY ESTABLISHED A PLAN OF REMEDIATION FOR ELIGIBLE CUSTOMERS WHO DID NOT RECEIVE APPROPRIATE SALES CHARGE WAIVERS; (3) PROMPTLY SELF-REPORTED TO FINRA; (4) PROMPTLY TAKEN ACTION AND REMEDIAL STEPS TO CORRECT THE VIOLATIVE CONDUCT; AND (5) EMPLOYED SUBSEQUENT CORRECTIVE MEASURES, PRIOR TO DETECTION OR INTERVENTION BY A REGULATOR, TO REVISE ITS PROCEDURES TO AVOID RECURRENCE OF THE MISCONDUCT.
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE ENTRY OF FINDINGS THAT CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION CUSTOMERS ELIGIBLE TO PURCHASE CERTAIN MUTUAL FUNDS AT A DISCOUNT WERE NOT ISSUED APPLICABLE DISCOUNTS. THE FINDINGS FURTHER STATED THAT THE FIRM FAILED TO MAINTAIN POLICIES AND PROCEDURES DESIGNED TO ENSURE SUCH DISCOUNTS WERE OFFERED AS APPROPRIATE.
Sanction detail — filed text
THE FIRM WAS CENSURED AND AGREED TO PAY APPROXIMATELY $1,030,235, IN RESTITUTION PLUS INTEREST TO ELIGIBLE CUSTOMERS.
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: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 10/27/2015 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2015045368001 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): WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE ENTRY OF FINDINGS THAT CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION CUSTOMERS ELIGIBLE TO PURCHASE CERTAIN MUTUAL FUNDS AT A DISCOUNT WERE NOT ISSUED APPLICABLE DISCOUNTS. THE FINDINGS FURTHER STATED THAT THE FIRM FAILED TO MAINTAIN POLICIES AND PROCEDURES DESIGNED TO ENSURE SUCH DISCOUNTS WERE OFFERED AS APPROPRIATE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 10/27/2015 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: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: INTEREST Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS CENSURED AND AGREED TO PAY APPROXIMATELY $1,030,235, IN RESTITUTION PLUS INTEREST TO ELIGIBLE CUSTOMERS. 13. Provide a brief summary of 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 MAY 2015, THE FIRM SELF-REPORTED THAT SOME ELIGIBLE CUSTOMERS HAD NOT RECEIVED AVAILABLE SALES CHARGE WAIVERS. AS A RESULT, THE FIRM ESTIMATES THAT ELIGIBLE CUSTOMERS WERE OVERCHARGED BY APPROXIMATELY $1,030,235 FOR MUTUAL FUND PURCHASES MADE BETWEEN JULY 1, 2009 AND JUNE 24, 2015. AS PART OF THIS SETTLEMENT, THE FIRM AGREES TO PAY RESTITUTION PLUS INTEREST. THE FIRM WILL ALSO ENSURE THAT RETIREMENT AND CHARITABLE ACCOUNT MUTUAL FUND FEE WAIVERS ARE APPROPRIATELY APPLIED TO ALL FUTURE TRANSACTIONS. IN RESOLVING THIS MATTER, FINRA HAS RECOGNIZED THE EXTRAORDINARY COOPERATION OF THE FIRM FOR HAVING: (1) INITIATED, PRIOR TO DETECTION OR INTERVENTION BY A REGULATOR, AN INVESTIGATION TO IDENTIFY WHETHER ELIGIBLE CUSTOMERS RECEIVED SALES CHARGE WAIVERS DURING THE RELEVANT PERIOD; (2) PROMPTLY ESTABLISHED A PLAN OF REMEDIATION FOR ELIGIBLE CUSTOMERS WHO DID NOT RECEIVE APPROPRIATE SALES CHARGE WAIVERS; (3) PROMPTLY SELF-REPORTED TO FINRA; (4) PROMPTLY TAKEN ACTION AND REMEDIAL STEPS TO CORRECT THE VIOLATIVE CONDUCT; AND (5) EMPLOYED SUBSEQUENT CORRECTIVE MEASURES, PRIOR TO DETECTION OR INTERVENTION BY A REGULATOR, TO REVISE ITS PROCEDURES TO AVOID RECURRENCE OF THE MISCONDUCT.
regulatory · block 28PDF pages 94–96
- Regulator name — filed text
- UNITED STATES SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 500,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM CONSENTED TO THE ENTRY OF AN SEC ORDER INSTITUTING ADMINISTRATIVE CEASE AND DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 (THE "ORDER"). THE ORDER STEMS FROM THE FIRM'S SELF-REPORTING OF CERTAIN ACTIVITIES RELATED TO CONTINUING DISCLOSURE OBLIGATIONS SPECIFIED IN RULES 15C2-12 UNDER THE SECURITIES EXCHANGE ACT WHEREBY THE FIRM MUST 1) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT, 2) PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000, AND 3) COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDING RETENTION OF AN INDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF THE FIRM'S POLICIES AND PROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE.
Other filed details
Description of allegations — filed text
RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVES VIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITING OF CERTAIN MUNICIPAL SECURITIES OFFERINGS. RESPONDENT, A REGISTERED BROKER-DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAIN OFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIAL REPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENT OFFERING AND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLY MISLEADING DISCLOSURE DOCUMENTS. THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THE COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION (MCDC) INITIATIVE.
Sanction detail — filed text
THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) (2)OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 AND COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.
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: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 02/02/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 3-17090 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): RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVES VIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITING OF CERTAIN MUNICIPAL SECURITIES OFFERINGS. RESPONDENT, A REGISTERED BROKER-DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAIN OFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIAL REPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENT OFFERING AND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLY MISLEADING DISCLOSURE DOCUMENTS. THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THE COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION (MCDC) INITIATIVE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 02/02/2016 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 500,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKING Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) (2)OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 AND COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. 13. Provide a brief summary of 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 VIOLATIONS, THE FIRM CONSENTED TO THE ENTRY OF AN SEC ORDER INSTITUTING ADMINISTRATIVE CEASE AND DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 (THE "ORDER"). THE ORDER STEMS FROM THE FIRM'S SELF-REPORTING OF CERTAIN ACTIVITIES RELATED TO CONTINUING DISCLOSURE OBLIGATIONS SPECIFIED IN RULES 15C2-12 UNDER THE SECURITIES EXCHANGE ACT WHEREBY THE FIRM MUST 1) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT, 2) PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000, AND 3) COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDING RETENTION OF AN INDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF THE FIRM'S POLICIES AND PROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE.
regulatory · block 29PDF pages 96–98
- Regulator name — filed text
- COMMONWEALTH OF PENNSYLVANIA
- Monetary/Fine Amount — filed text
- $ 125,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
THE COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF BANKING AND SECURITIES, AND JANNEY MONTGOMERY SCOTT LLC ENTERED INTO AN ADMINISTRATIVE CONSENT AGREEMENT AND ORDER, WHICH WAS ADOPTED BY THE COMMONWEALTH THROUGH A FINAL ORDER FILED ON JULY 18, 2016. BASED ON THE RESULTS OF THE INVESTIGATION, WHICH INCLUDED THE FULL COOPERATION OF JANNEY, THE FIRM CONSENTED TO THE FINDINGS, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THAT THE FIRM OPERATED IN VIOLATION OF THE PENNSYLVANIA SECURITIES ACT OF 1972, HAVING FAILED TO REASONABLY SUPERVISE THE SECURITIES ACTIVITIES OF THE FORMER FINANCIAL ADVISOR.
Other filed details
Description of allegations — filed text
THE COMMONWEALTH OF PENNSYLVANIA CONDUCTED AN INVESTIGATION OF JANNEY MONTGOMERY SCOTT LLC ("JANNEY") REGARDING A FORMER FINANCIAL ADVISOR, WHO WAS TERMINATED BY THE FIRM ON JULY 27, 2010. IT IS ALLEGED THAT JANNEY FAILED TO REASONABLY SUPERVISE THE FINANCIAL ADVISOR DURING THE TERM OF HER EMPLOYMENT, RESULTING IN FAILURE TO DETECT AND PREVENT A FRAUDULENT SCHEME CONDUCTED BY THE FORMER FINANCIAL ADVISOR.
Sanction detail — filed text
THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE OF $125,000 AND $10,000 TOWARDS THE COST OF THE INVESTIGATION.
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)
COMMONWEALTH OF PENNSYLVANIA
2.
Principal Sanction:
Other
Other Sanctions:
ADMINISTRATIVE CONSENT ORDER AND MONETARY FINE
3.
Date Initiated (MM/DD/YYYY):
07/18/2016
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
160041
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 COMMONWEALTH OF PENNSYLVANIA CONDUCTED AN INVESTIGATION OF JANNEY MONTGOMERY SCOTT LLC ("JANNEY") REGARDING A FORMER
FINANCIAL ADVISOR, WHO WAS TERMINATED BY THE FIRM ON JULY 27, 2010. IT IS ALLEGED THAT JANNEY FAILED TO REASONABLY SUPERVISE THE
FINANCIAL ADVISOR DURING THE TERM OF HER EMPLOYMENT, RESULTING IN FAILURE TO DETECT AND PREVENT A FRAUDULENT SCHEME CONDUCTED
BY THE FORMER FINANCIAL ADVISOR.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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):
07/18/2016
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 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:
THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE OF $125,000 AND $10,000 TOWARDS THE COST OF THE INVESTIGATION.
13. Provide a brief summary of 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 COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF BANKING AND SECURITIES, AND JANNEY MONTGOMERY SCOTT LLC ENTERED INTO AN
ADMINISTRATIVE CONSENT AGREEMENT AND ORDER, WHICH WAS ADOPTED BY THE COMMONWEALTH THROUGH A FINAL ORDER FILED ON JULY 18,
2016. BASED ON THE RESULTS OF THE INVESTIGATION, WHICH INCLUDED THE FULL COOPERATION OF JANNEY, THE FIRM CONSENTED TO THE
FINDINGS, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THAT THE FIRM OPERATED IN VIOLATION OF THE PENNSYLVANIA SECURITIES ACT OF
1972, HAVING FAILED TO REASONABLY SUPERVISE THE SECURITIES ACTIVITIES OF THE FORMER FINANCIAL ADVISOR.regulatory · block 30PDF pages 98–99
- Regulator name — filed text
- UNITED STATES SECURITIES AND EXCHANGE COMMISSION
- How was matter resolved — filed text
- Other
Other filed details
Description of allegations — filed text
IN JUNE OF 2018, THE FIRM VOLUNTARILY SELF-REPORTED THAT SOME CUSTOMERS ELIGIBLE TO PURCHASE MUTUAL FUNDS WHICH DID NOT CHARGE 12B-1 FEES DID NOT RECEIVE THE AVAILABLE LESS EXPENSIVE SHARE CLASS. AS A RESULT, THE FIRM ESTIMATED THAT ELIGIBLE CUSTOMERS WERE OVERCHARGED $215,761 PLUS PRE JUDGEMENT INTEREST FOR MUTUAL FUND PURCHASES MADE SINCE JANUARY 1, 2014. THE FIRM AGREES TO PAY RESTITUTION PLUS INTEREST, AS WELL AS TO REVIEW ITS RELATED DISCLOSURES AND PROCEDURES. THE FIRM HAS HAD PROCEDURES IN PLACE INTENDED TO ADDRESS THIS ISSUE FOR MORE THAN A DECADE.
Sanction detail — filed text
THE FIRM HAS SUBMITTED AN OFFER OF SETTLEMENT, WHICH HAS BEEN ACCEPTED BY THE COMMISSION. THE FIRM SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $215,761.17 AND PREJUDGMENT INTEREST OF $25,465.87, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.
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: Cease and Desist Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 03/11/2019 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 3-19087 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): IN JUNE OF 2018, THE FIRM VOLUNTARILY SELF-REPORTED THAT SOME CUSTOMERS ELIGIBLE TO PURCHASE MUTUAL FUNDS WHICH DID NOT CHARGE 12B-1 FEES DID NOT RECEIVE THE AVAILABLE LESS EXPENSIVE SHARE CLASS. AS A RESULT, THE FIRM ESTIMATED THAT ELIGIBLE CUSTOMERS WERE OVERCHARGED $215,761 PLUS PRE JUDGEMENT INTEREST FOR MUTUAL FUND PURCHASES MADE SINCE JANUARY 1, 2014. THE FIRM AGREES TO PAY RESTITUTION PLUS INTEREST, AS WELL AS TO REVIEW ITS RELATED DISCLOSURES AND PROCEDURES. THE FIRM HAS HAD PROCEDURES IN PLACE INTENDED TO ADDRESS THIS ISSUE FOR MORE THAN A DECADE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 03/11/2019 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKINGS AND PREJUDGMENT INTEREST Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM HAS SUBMITTED AN OFFER OF SETTLEMENT, WHICH HAS BEEN ACCEPTED BY THE COMMISSION. THE FIRM SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $215,761.17 AND PREJUDGMENT INTEREST OF $25,465.87, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. 13. Provide a brief summary of 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 31PDF pages 100–101
- Regulator name — filed text
- MASSACHUSETTS
- Monetary/Fine Amount — filed text
- $ 286,622.02
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
ON APRIL 1, 2020, JANNEY ENTERED INTO A CONSENT ORDER WITH THE STATE OF MASSACHUSETTS. WITHOUT ADMITTING OR DENYING ANY FINDINGS, THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE OF $286,622.02 IN CONNECTION WITH AN ALLEGED FAILURE TO SUPERVISE THE MUTUAL FUND A SHARE SALES PRACTICES OF A FORMER FINANCIAL ADVISOR UNDER SECTION 204(A)(2)(J) OF THE MASS GENERAL LAWS CHAPTER 110A. THE FIRM FURTHER AGREED TO PROVIDE AN ACCOUNTING OF IMPACTED CUSTOMERS AND SUBSEQUENTLY PROVIDE WRITTEN OFFERS OF RESTITUTION; REVIEW ITS WRITTEN POLICIES AND PROCEDURES RELATED TO TRADING OF CLASS A SHARES OF MUTUAL FUNDS; ACCEPTED A CENSURE AND AGREED TO CEASE AND DESIST FROM SUCH ALLEGED VIOLATIONS.
Other filed details
Description of allegations — filed text
SALES PRACTICE VIOLATIONS INVOLVING SHORT TERM TRADING IN CLASS A SHARES OF MUTUAL FUNDS BY AN ADVISOR WHO LEFT JANNEY IN 2018.
Sanction detail — filed text
THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE OF $286,622.02. PAYMENT WAS MADE ON APRIL 3, 2020.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) MASSACHUSETTS 2. Principal Sanction: Cease and Desist Other Sanctions: ACCOUNTING RESTITUTION FINE 3. Date Initiated (MM/DD/YYYY): 05/07/2019 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2019-0050 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): JANNEY MONTGOMERY SCOTT LLC 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): SALES PRACTICE VIOLATIONS INVOLVING SHORT TERM TRADING IN CLASS A SHARES OF MUTUAL FUNDS BY AN ADVISOR WHO LEFT JANNEY IN 2018. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 04/01/2020 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 286,622.02 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: PROVIDE ACCOUNTING OF IMPACTED CUSTOMERS; PROVIDE WRITTEN OFFERS OF RESTITUTION; REVIEW WRITTEN POLICIES AND PROCEDURES RELATED TO TRADING OF CLASS A SHARES OF MUTUAL FUNDS Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE OF $286,622.02. PAYMENT WAS MADE ON APRIL 3, 2020. 13. Provide a brief summary of 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 APRIL 1, 2020, JANNEY ENTERED INTO A CONSENT ORDER WITH THE STATE OF MASSACHUSETTS. WITHOUT ADMITTING OR DENYING ANY FINDINGS, THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE OF $286,622.02 IN CONNECTION WITH AN ALLEGED FAILURE TO SUPERVISE THE MUTUAL FUND A SHARE SALES PRACTICES OF A FORMER FINANCIAL ADVISOR UNDER SECTION 204(A)(2)(J) OF THE MASS GENERAL LAWS CHAPTER 110A. THE FIRM FURTHER AGREED TO PROVIDE AN ACCOUNTING OF IMPACTED CUSTOMERS AND SUBSEQUENTLY PROVIDE WRITTEN OFFERS OF RESTITUTION; REVIEW ITS WRITTEN POLICIES AND PROCEDURES RELATED TO TRADING OF CLASS A SHARES OF MUTUAL FUNDS; ACCEPTED A CENSURE AND AGREED TO CEASE AND DESIST FROM SUCH ALLEGED VIOLATIONS.
regulatory · block 32PDF pages 101–103
- Regulator name — filed text
- NASDAQ STOCK MARKET
- Monetary/Fine Amount — filed text
- $ 27,500.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
CASE NO. 20160511406 (INCLUDES 20170545706 (INCLUDES 20170567114) AND 20180594816). SUBSEQUENT TO THE REVIEW PERIOD, THE FIRM UPDATED ITS SUPERVISORY SYSTEMS, INCLUDING T+1 SURVEILLANCE AND AN INTRADAY REVIEW, THEREFORE, ENFORCEMENT IS NOT RECOMMENDING AN UNDERTAKING.
Other filed details
Description of allegations — filed text
ON MARCH 21, 2019, THE FIRM ENTERED INTO AN AWC WITH NASDAQ. WITHOUT ADMITTING OR DENYING ANY FINDINGS BY NASDAQ, THE FIRM AGREED TO A FINE OF $27,500 WITH RESPECT TO ITS FAILURE BETWEEN 2015 AND 2017 TO MAINTAIN A CONTINUOUS TWO-SIDED TRADING INTEREST DURING REGULAR MARKET HOURS AT PRICES WITHIN CERTAIN PERCENTAGES AWAY FROM THE NATIONAL BEST BID OR OFFER (NBBO).
Sanction detail — filed text
THE FIRM WAS CENSURED AND FINED $27,500.
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) NASDAQ STOCK MARKET 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 03/22/2019 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2016051140601 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: UNSPECIFIED SECURITIES 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ON MARCH 21, 2019, THE FIRM ENTERED INTO AN AWC WITH NASDAQ. WITHOUT ADMITTING OR DENYING ANY FINDINGS BY NASDAQ, THE FIRM AGREED TO A FINE OF $27,500 WITH RESPECT TO ITS FAILURE BETWEEN 2015 AND 2017 TO MAINTAIN A CONTINUOUS TWO-SIDED TRADING INTEREST DURING REGULAR MARKET HOURS AT PRICES WITHIN CERTAIN PERCENTAGES AWAY FROM THE NATIONAL BEST BID OR OFFER (NBBO). 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 03/22/2019 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 27,500.00 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 FIRM WAS CENSURED AND FINED $27,500. 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). CASE NO. 20160511406 (INCLUDES 20170545706 (INCLUDES 20170567114) AND 20180594816). SUBSEQUENT TO THE REVIEW PERIOD, THE FIRM UPDATED ITS SUPERVISORY SYSTEMS, INCLUDING T+1 SURVEILLANCE AND AN INTRADAY REVIEW, THEREFORE, ENFORCEMENT IS NOT RECOMMENDING AN UNDERTAKING.
regulatory · block 33PDF pages 103–105
- Regulator name — filed text
- STATE OF DELAWARE
- Monetary/Fine Amount — filed text
- $ 105,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
THE STATE OF DELAWARE, OFFICE OF INVESTOR PROTECTION, AND JANNEY MONTGOMERY SCOTT LLC ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER, WHICH WAS ADOPTED BY THE OFFICE THROUGH A FINAL ORDER DATED JUNE 10, 2015 AND RECEIVED BY THE FIRM ON JUNE 29, 2015. THE FIRM CONSENTED TO FINDINGS THAT ONE OF ITS FINANCIAL ADVISORS, WHO LEFT THE FIRM ON NOVEMBER 7, 2008, RECOMMENDED CERTAIN UNSUITABLE TRANSACTIONS AND THAT FINANCIAL ADVISOR WAS NOT REASONABLY SUPERVISED. THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE OF $75,000, $30,000 TOWARD THE COST OF THE STATE'S INVESTIGATION AND REFRAIN FROM ANY FUTURE VIOLATIONS.
Other filed details
Description of allegations — filed text
IT WAS ALLEGED THAT FORMER FINANCIAL ADVISOR, WHO LEFT THE FIRM ON NOVEMBER 7, 2008, RECOMMENDED CERTAIN UNSUITABLE TRANSACTIONS AND THAT BLOCK WAS NOT REASONABLY SUPERVISED.
Sanction detail — filed text
THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE OF $75,000, $30,000 TOWARD THE COST OF THE STATE'S INVESTIGATION AND REFRAIN FROM ANY FUTURE VIOLATIONS.
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 DELAWARE 2. Principal Sanction: Cease and Desist Other Sanctions: ADMINISTRATIVE CONSENT ORDER AND MONETARY FINE 3. Date Initiated (MM/DD/YYYY): 06/29/2015 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 11-2-4 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): IT WAS ALLEGED THAT FORMER FINANCIAL ADVISOR, WHO LEFT THE FIRM ON NOVEMBER 7, 2008, RECOMMENDED CERTAIN UNSUITABLE TRANSACTIONS AND THAT BLOCK WAS NOT REASONABLY SUPERVISED. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 06/29/2015 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: $ 105,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE OF $75,000, $30,000 TOWARD THE COST OF THE STATE'S INVESTIGATION AND REFRAIN FROM ANY FUTURE VIOLATIONS. 13. Provide a brief summary of 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 STATE OF DELAWARE, OFFICE OF INVESTOR PROTECTION, AND JANNEY MONTGOMERY SCOTT LLC ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER, WHICH WAS ADOPTED BY THE OFFICE THROUGH A FINAL ORDER DATED JUNE 10, 2015 AND RECEIVED BY THE FIRM ON JUNE 29, 2015. THE FIRM CONSENTED TO FINDINGS THAT ONE OF ITS FINANCIAL ADVISORS, WHO LEFT THE FIRM ON NOVEMBER 7, 2008, RECOMMENDED CERTAIN UNSUITABLE TRANSACTIONS AND THAT FINANCIAL ADVISOR WAS NOT REASONABLY SUPERVISED. THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE OF $75,000, $30,000 TOWARD THE COST OF THE STATE'S INVESTIGATION AND REFRAIN FROM ANY FUTURE VIOLATIONS.
regulatory · block 34PDF pages 105–107
- Regulator name — filed text
- PENNSYLVANIA SECURITIES COMMISSION
- Monetary/Fine Amount — filed text
- $ 100,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
JANNEY MONTGOMERY SCOTT, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, CONSENTED TO THE ISSUANCE OF AND ACCEPTED THE FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER OF THE PENNSYLVANIA SECURITIES COMMISSION IN CONNECTION WITH THE SALE TO PENNSYLVANIA RESIDENTS OF CERTIN LIMITED PARTNERSHIPS.
Other filed details
Description of allegations — filed text
FAILURE TO SUPERVISE; VIOLATION OF SECTION 305(A)(VII) OF THE PA SECURITIES ACT.
Sanction detail — filed text
THE FINE OF $100000.00 AND COSTS OF $28550.24 WAS PAID 10/30/1998.
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) PENNSYLVANIA SECURITIES COMMISSION 2. Principal Sanction: Censure Other Sanctions: BAR FOR 30 DAYS FROM SELLING LIMITED PARTNERSHIP INTERESTS EXCEPT PUBLICLY TRADED LIMITED PARTNERSHIPS. 3. Date Initiated (MM/DD/YYYY): 12/09/1993 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 9504-01LC 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Direct Investment(s) - DPP & LP Interest(s) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FAILURE TO SUPERVISE; VIOLATION OF SECTION 305(A)(VII) OF THE PA SECURITIES 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: Consent 11. Resolution Date (MM/DD/YYYY): 11/06/1996 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: $ 100,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: PAID COSTS OF $28,550.24. RESPONDENT WAS ORDERED TO ENGAGE AN INDEPENDENT CONSULTANT ACCEPTABLE TO COMMISSION STAFF, CONDUCT A REVIEW OF EXISTING PROCEDURES, PRACTICES AND POLICIES CONCERNING THE FIRM'S PENNSYLVANIA OFFICES AND THE FIRM'S SUPERVISION OF ITS PENNSYLVANIA OPERATIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement 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 $100000.00 AND COSTS OF $28550.24 WAS PAID 10/30/1998. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). JANNEY MONTGOMERY SCOTT, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, CONSENTED TO THE ISSUANCE OF AND ACCEPTED THE FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER OF THE PENNSYLVANIA SECURITIES COMMISSION IN CONNECTION WITH THE SALE TO PENNSYLVANIA RESIDENTS OF CERTIN LIMITED PARTNERSHIPS.
regulatory · block 35PDF pages 107–108
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 90,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
IT IS ALLEGED THE FIRM SUBMITTED INACCURATE OR INCOMPLETE REPORTABLE ORDER EVENTS (ROES) TO OATS, FAILED TO REASONABLY SUPERVISE FOR COMPLIANCE WITH ITS OATS REPORTING REQUIREMENTS, AND FAILED TO REASONABLY RESPOND TO IDENTIFIED OATS REPORTING DEFICIENCIES. THE FINDINGS STATE THE FIRM TRANSMITTED DESK REPORTS INCLUDING INACCURATE DESK TYPE CODE AND NEW ORDER TYPE EVENTS THAT FAILED TO REPORT AN INFORMATION BARRIER ID, SUBMITTING DESK REPORTS CODING ITS EQUITY RETAIL DESK AS DESK TYPE CODE OF "T", INDICATING ITS TRADING DESK RECEIVED THE RELEVANT ORDERS FOR EXECUTION. SINCE ALL ORDERS SENT THROUGH THE FIRM'S AGENCY DESK WERE ROUTED TO OTHER MARKET DESTINATIONS FOR EXECUTION, THE FIRM SHOULD HAVE USED THE DESK TYPE CODE OF "A" FOR AGENCY WHEN REPORTING THESE ORDERS TO OATS. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) DID NOT REQUIRE A REVIEW OF THE OATS DATA SUBMISSIONS TO ASSESS THE ACCURACY OF THE DESK TYPE CODE AND INFORMATION BARRIER IDS. THE FIRM'S REVISED WSPS FAILED TO PROVIDE REASONABLE GUIDANCE ON HOW THE OATS REVIEW SHOULD OCCUR AND WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS OATS REPORTING OBLIGATIONS.
Sanction detail — filed text
HE FIRM WAS CENSURED, FINED $90,000 AND REQUIRED TO REVISE ITS WSPS WITH RESPECT TO OATS COMPLIANCE.
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: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 09/08/2020 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2017054220101 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): IT IS ALLEGED THE FIRM SUBMITTED INACCURATE OR INCOMPLETE REPORTABLE ORDER EVENTS (ROES) TO OATS, FAILED TO REASONABLY SUPERVISE FOR COMPLIANCE WITH ITS OATS REPORTING REQUIREMENTS, AND FAILED TO REASONABLY RESPOND TO IDENTIFIED OATS REPORTING DEFICIENCIES. THE FINDINGS STATE THE FIRM TRANSMITTED DESK REPORTS INCLUDING INACCURATE DESK TYPE CODE AND NEW ORDER TYPE EVENTS THAT FAILED TO REPORT AN INFORMATION BARRIER ID, SUBMITTING DESK REPORTS CODING ITS EQUITY RETAIL DESK AS DESK TYPE CODE OF "T", INDICATING ITS TRADING DESK RECEIVED THE RELEVANT ORDERS FOR EXECUTION. SINCE ALL ORDERS SENT THROUGH THE FIRM'S AGENCY DESK WERE ROUTED TO OTHER MARKET DESTINATIONS FOR EXECUTION, THE FIRM SHOULD HAVE USED THE DESK TYPE CODE OF "A" FOR AGENCY WHEN REPORTING THESE ORDERS TO OATS. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) DID NOT REQUIRE A REVIEW OF THE OATS DATA SUBMISSIONS TO ASSESS THE ACCURACY OF THE DESK TYPE CODE AND INFORMATION BARRIER IDS. THE FIRM'S REVISED WSPS FAILED TO PROVIDE REASONABLE GUIDANCE ON HOW THE OATS REVIEW SHOULD OCCUR AND WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS OATS REPORTING OBLIGATIONS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 09/08/2020 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 90,000.00 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: HE FIRM WAS CENSURED, FINED $90,000 AND REQUIRED TO REVISE ITS WSPS WITH RESPECT TO OATS COMPLIANCE. 13. Provide a brief summary of 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 36PDF pages 108–110
- Regulator name — filed text
- STATE OF CONNECTICUT, DEPARTMENT OF BANKING
- Monetary/Fine Amount — filed text
- $ 100,000.00
- How was matter resolved — filed text
- Consent
Other filed details
Description of allegations — filed text
ON OCTOBER 21, 2020, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, JANNEY MONTGOMERY SCOTT LLC ("JANNEY") AGREED TO ENTRY OF AN ORDER ALLEGING THAT JANNEY PERMITTED A FORMER EMPLOYEE TO ACT AS EXECUTOR OF A CLIENT'S ESTATE IN CONTRAVENTION OF WRITTEN SUPERVISORY PROCEDURES. THE CONSENT ORDER ALSO ALLEGED THAT JANNEY FAILED TO TIMELY PRODUCE RECORDS REQUESTED BY THE AGENCY OR AMEND THE FORM U-5 PREVIOUSLY FILED RELATED TO THE FORMER EMPLOYEE.
Sanction detail — filed text
N/A
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
STATE OF CONNECTICUT, DEPARTMENT OF BANKING
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
10/21/2020
Exact
Explanation
If not exact, provide explanation:
REPRESENTS CONSENT ORDER ENTRY DATE.
4.
Docket/Case Number:
CO-20-8388-S
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):
ON OCTOBER 21, 2020, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, JANNEY MONTGOMERY SCOTT LLC ("JANNEY") AGREED TO ENTRY OF AN
ORDER ALLEGING THAT JANNEY PERMITTED A FORMER EMPLOYEE TO ACT AS EXECUTOR OF A CLIENT'S ESTATE IN CONTRAVENTION OF WRITTEN
SUPERVISORY PROCEDURES. THE CONSENT ORDER ALSO ALLEGED THAT JANNEY FAILED TO TIMELY PRODUCE RECORDS REQUESTED BY THE AGENCY
OR AMEND THE FORM U-5 PREVIOUSLY FILED RELATED TO THE FORMER EMPLOYEE.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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):
10/21/2020
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 100,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
THE ORDER DIRECTED THE FIRM TO CEASE AND DESIST FROM ANY RELATED VIOLATIONS. THE ORDER FURTHER ACKNOWLEDGED THAT THE FIRM
HAD REIMBURSED $108,459.68 TO THE ESTATE OF THE AFFECTED CLIENT AND ASSESSED A FINE OF $150,000, $100,000 IN INVESTIGATE COST
REIMBURSEMENT AND $100,000 TO THE STATE INVESTOR EDUCATION FUND. JANNEY ALSO AGREED TO RETAIN AN INDEPENDENT CONSULTANT
TO REVIEW PROCEDURES RELATED TO OUTSIDE BUSINESS ACTIVITIES AND HANDLING OF DECEASED CLIENT ACCOUNTS AND CODUCT TRAINING
RELATED TO REGULATORY PRODUCTIONS.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
N/A
13. Provide a brief summary of 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 37PDF pages 110–112
- Regulator name — filed text
- STATE OF MAINE, OFFICE OF SECURITIES
- Monetary/Fine Amount — filed text
- $ 2,500.00
- How was matter resolved — filed text
- Consent
Other filed details
Description of allegations — filed text
THE STATE PUBLISHED ADMINISTRATIVE ORDER 2020-45 THAT PROVIDES FIRMS LICENSED IN MAINE TEMPORARY RELIEF FROM ON-SITE BRANCH OFFICE INSPECTIONS DUE TO ONGOING COVID-19 PANDEMIC. THE ORDER REQUIRED FIRMS WITH BRANCH OFFICES IN MAINE TO PROVIDE THE STATE WITH A LIST OF THE DATE(S) ON WHICH THE FIRM LAST CONDUCTED AN ON-SITE INSPECTION AT EACH BRANCH OFFICE IN MAINE. JANNEY DID NOT COMPLY WITH THE ADMINISTRATIVE ORDER BY PROVIDING A RESPONSE TO THE STATE; THOUGH JANNEY DID CONDUCT AN ON-SITE INSPECTION OF ITS SINGLE BRANCH OFFICE IN MAINE IN 2019 AND 2020. THE STATE DEEMS JANNEY IS OUT OF COMPLIANCE DUE TO ITS LACK OF RESPONSE TO THE ORDER REQUIRED BY NOVEMBER 13, 2020.
Sanction detail — filed text
THE FIRM WAS FINED $2,500.
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) STATE OF MAINE, OFFICE OF SECURITIES 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 03/29/2021 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 21-17219 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 STATE PUBLISHED ADMINISTRATIVE ORDER 2020-45 THAT PROVIDES FIRMS LICENSED IN MAINE TEMPORARY RELIEF FROM ON-SITE BRANCH OFFICE INSPECTIONS DUE TO ONGOING COVID-19 PANDEMIC. THE ORDER REQUIRED FIRMS WITH BRANCH OFFICES IN MAINE TO PROVIDE THE STATE WITH A LIST OF THE DATE(S) ON WHICH THE FIRM LAST CONDUCTED AN ON-SITE INSPECTION AT EACH BRANCH OFFICE IN MAINE. JANNEY DID NOT COMPLY WITH THE ADMINISTRATIVE ORDER BY PROVIDING A RESPONSE TO THE STATE; THOUGH JANNEY DID CONDUCT AN ON-SITE INSPECTION OF ITS SINGLE BRANCH OFFICE IN MAINE IN 2019 AND 2020. THE STATE DEEMS JANNEY IS OUT OF COMPLIANCE DUE TO ITS LACK OF RESPONSE TO THE ORDER REQUIRED BY NOVEMBER 13, 2020. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: pp g y pp ( ) pp 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): 03/29/2021 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: 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 FIRM WAS FINED $2,500. 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).
regulatory · block 38PDF pages 112–114
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 100,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
FROM DECEMBER 2013 THROUGH DECEMBER 2016, JANNEY FAILED TO REASONABLY SUPERVISE TWO FORMER REGISTERED REPRESENTATIVES WHO RECOMMENDED THAT THEIR CUSTOMERS INVEST AN UNSUITABLY HIGH PERCENTAGE OF THEIR ASSETS IN ENERGY-SECTOR SECURITIES IN VIOLATION OF NASD RULE 3010 AND FINRA RULES 3110 AND 2010.
Sanction detail — filed text
THE FIRM WAS CENSURED, FINED $100,000, AND ORDERED TO PAY $145,019, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS.
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: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 10/19/2022 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2016051156903 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: ENERGY-SECTOR SECURITIES 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FROM DECEMBER 2013 THROUGH DECEMBER 2016, JANNEY FAILED TO REASONABLY SUPERVISE TWO FORMER REGISTERED REPRESENTATIVES WHO RECOMMENDED THAT THEIR CUSTOMERS INVEST AN UNSUITABLY HIGH PERCENTAGE OF THEIR ASSETS IN ENERGY-SECTOR SECURITIES IN VIOLATION OF NASD RULE 3010 AND FINRA RULES 3110 AND 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): 10/19/2022 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 p B. Other Sanctions Ordered: INTEREST ON RESTITUTION Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS CENSURED, FINED $100,000, AND ORDERED TO PAY $145,019, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. 13. Provide a brief summary of 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 39PDF pages 114–115
- Regulator name — filed text
- STATE OF DELAWARE
- Monetary/Fine Amount — filed text
- $ 72,255.00
- How was matter resolved — filed text
- Consent
Other filed details
Description of allegations — filed text
IN NOVEMBER 2022, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, JANNEY MONTGOMERY SCOTT LLC VOLUNTARILY ENTERED INTO A CONSENT ORDER WITH THE STATE OF DELAWARE RELATED TO FAILURE TO SUPERVISE THE SUITABILITY OF CERTAIN ACTIVITIES BY A FINANCIAL ADVISOR.
Sanction detail — filed text
SEE SANCTIONS ABOVE
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 DELAWARE 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 11/02/2022 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 20-0026 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): IN NOVEMBER 2022, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, JANNEY MONTGOMERY SCOTT LLC VOLUNTARILY ENTERED INTO A CONSENT ORDER WITH THE STATE OF DELAWARE RELATED TO FAILURE TO SUPERVISE THE SUITABILITY OF CERTAIN ACTIVITIES BY A FINANCIAL ADVISOR. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 11/02/2022 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: $ 72,255.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN THE ORDER THE FIRM AGREED TO A FINE OF $40,000, CLIENT REMEDIATION OF $32,255 AND TO PLACE THE FINANCIAL ADVISOR ON FIRM HEIGHTENED SUPERVISION FOR THE PERIOD OF ONE YEAR. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: SEE SANCTIONS ABOVE 13. Provide a brief summary of 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 40PDF pages 115–117
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 150,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
ON JULY 23, 2024, JANNEY ENTERED INTO AN AWC WITH FINRA, WITHOUT ADMITTING OR DENYING ANY FINDINGS, THE FIRM AGREED TO A $150,000 SETTLEMENT WITH RESPECT TO THE ALLEGATIONS AND UPDATED APPLICABLE WRITTEN SUPERVISORY PROCEDURES.
Other filed details
Description of allegations — filed text
FINRA ALLEGED THAT JANNEY DID NOT ACCURATELY REPORT CERTAIN TRANSACTIONS TO THE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") FROM JULY 2019 TO MAY 2021; AND TRADE REPORTING AND COMPLIANCE ENGINE ("TRACE") FROM MARCH 2022 TO MARCH 2023. FINRA ALSO ALLEGED THAT JANNEY DID NOT HAVE PROPER SUPERVISORY SYSTEMS AND WRITTEN SUPERVISORY PROCEDURES REGARDING SUCH TRADE REPORTING.
Sanction detail — filed text
THE FIRM AGREED TO A $150,000 SETTLEMENT.
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:
3.
Date Initiated (MM/DD/YYYY):
07/23/2024
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2022074617402
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):
FINRA ALLEGED THAT JANNEY DID NOT ACCURATELY REPORT CERTAIN TRANSACTIONS TO THE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB")
FROM JULY 2019 TO MAY 2021; AND TRADE REPORTING AND COMPLIANCE ENGINE ("TRACE") FROM MARCH 2022 TO MARCH 2023. FINRA ALSO
ALLEGED THAT JANNEY DID NOT HAVE PROPER SUPERVISORY SYSTEMS AND WRITTEN SUPERVISORY PROCEDURES REGARDING SUCH 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):
07/23/2024
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 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:
THE FIRM AGREED TO A $150,000 SETTLEMENT.
13. Provide a brief summary of 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 23, 2024, JANNEY ENTERED INTO AN AWC WITH FINRA, WITHOUT ADMITTING OR DENYING ANY FINDINGS, THE FIRM AGREED TO A $150,000
SETTLEMENT WITH RESPECT TO THE ALLEGATIONS AND UPDATED APPLICABLE WRITTEN SUPERVISORY PROCEDURES.regulatory · block 41GLOBAL ATLANTIC DISTRIBUTORS, LLCPDF pages 117–119
- Advisory affiliate name — filed text
- GLOBAL ATLANTIC DISTRIBUTORS, LLC
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 8326 This advisory affiliate is a Firm an Individual Registered: Yes No Name: GLOBAL ATLANTIC DISTRIBUTORS, LLC (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).
* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.