Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Private Funds
Private funds reported by Raymond James & Associates, Inc..
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.
Ownership
Reported direct and indirect ownership ranges
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Raymond James & Associates, Inc...
No indirect ownership information reported in the source’s Schedule B.
Reported ownership and control details
Form ADV · Filing date 2026-09-25 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | RAYMOND JAMES FINANCIAL, INC.HOLDING COMPANYDomestic entity | RAYMOND JAMES & ASSOCIATES, INC. | 75% or moreCode E | Yes | HOLDING COMPANY02/1972 | Schedule APDF page 61 |
| 2 | TASHTEGO SPRING ELWYNPRESIDENT - CHIEF EXECUTIVE OFFICER DIRECTORIndividual | RAYMOND JAMES & ASSOCIATES, INC. | Less than 5%Code NA | Yes | PRESIDENT - CHIEF EXECUTIVE OFFICER DIRECTOR02/2014 | Schedule APDF page 61 |
| 3 | JONATHAN SANTELLIGENERAL COUNSEL / SECRETARYIndividual | RAYMOND JAMES & ASSOCIATES, INC. | Less than 5%Code NA | No | GENERAL COUNSEL / SECRETARY05/2016 | Schedule APDF page 61 |
| 4 | SHAWN JOSEPH BARKOCHIEF COMPLIANCE OFFICERIndividual | RAYMOND JAMES & ASSOCIATES, INC. | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER12/2017 | Schedule APDF page 61 |
| 5 | JAMES BUNNDIRECTORIndividual | RAYMOND JAMES & ASSOCIATES, INC. | Less than 5%Code NA | Yes | DIRECTOR03/2019 | Schedule APDF page 61 |
| 6 | SCOTT CURTISDIRECTORIndividual | RAYMOND JAMES & ASSOCIATES, INC. | Less than 5%Code NA | Yes | DIRECTOR03/2019 | Schedule APDF page 61 |
| 7 | JAMES PHILIP SICKLINGDIRECTORIndividual | RAYMOND JAMES & ASSOCIATES, INC. | Less than 5%Code NA | Yes | DIRECTOR03/2019 | Schedule APDF page 61 |
| 8 | PHILIP ROGER MARTINRIA CHIEF COMPLIANCE OFFICERIndividual | RAYMOND JAMES & ASSOCIATES, INC. | Less than 5%Code NA | No | RIA CHIEF COMPLIANCE OFFICER12/2019 | Schedule APDF page 61 |
| 9 | KEITH G RUSTDIRECTOR, PRINCIPAL OPERATIONS OFFICERIndividual | RAYMOND JAMES & ASSOCIATES, INC. | Less than 5%Code NA | Yes | DIRECTOR, PRINCIPAL OPERATIONS OFFICER10/2021 | Schedule APDF page 62 |
| 10 | ALLYSSA NICOLE DELEONPRINCIPAL FINANCIAL OFFICER / FINOPIndividual | RAYMOND JAMES & ASSOCIATES, INC. | Less than 5%Code NA | Yes | PRINCIPAL FINANCIAL OFFICER / FINOP02/2025 | Schedule APDF page 62 |
| 11 | RICHARD EUGENE KONEFALDIRECTORIndividual | RAYMOND JAMES & ASSOCIATES, INC. | Less than 5%Code NA | Yes | DIRECTOR01/2026 | Schedule APDF page 62 |
Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.
Compliance & Disclosures
Filing dated 9/25/2026 8:41:17 AM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
AFelonies2 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?No
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions4 Yes1 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?Yes
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions4 Yes1 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?Yes
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?Yes
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?Yes
ESelf-regulatory organization actions3 Yes1 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?Yes
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?Yes
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 Yes
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?Yes
HCivil judicial actions and proceedings4 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 85 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 1GRIMSTAD, KERRIE, MILLIGANPDF pages 63–64
- Advisory affiliate name — filed text
- GRIMSTAD, KERRIE, MILLIGAN
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: 4276095 This advisory affiliate is a Firm an Individual Registered: Yes No Name: GRIMSTAD, KERRIE, MILLIGAN (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 2COX, DONALD, MARSHALLPDF pages 64–66
- Advisory affiliate name — filed text
- COX, DONALD, MARSHALL
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: 716663 This advisory affiliate is a Firm an Individual Registered: Yes No Name: COX, DONALD, MARSHALL (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 3BUECHTING, EDWARD, RYANPDF pages 66–68
- Advisory affiliate name — filed text
- BUECHTING, EDWARD, RYAN
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: 3235635 This advisory affiliate is a Firm an Individual Registered: Yes No Name: BUECHTING, EDWARD, RYAN (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 4AYLESWORTH, JOSHUA, PAULPDF pages 68–69
- Advisory affiliate name — filed text
- AYLESWORTH, JOSHUA, PAUL
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: 3121494 This advisory affiliate is a Firm an Individual Registered: Yes No Name: AYLESWORTH, JOSHUA, PAUL (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 5RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INCPDF pages 69–71
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 149018 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: 11. Resolution Date (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 6RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 71–73
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- UNITED STATES SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 3,000,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, RJA, RJFS, AND RJFSA CONSENTED TO THE ENTRY BY THE SEC OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTION 8A OF THE SECURITIES ACT, SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, AND SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ("ORDER") (RELEASE NO. 86985, SEPT. 17, 2019). PURSUANT TO THE ORDER RJA AND RJFS MUST CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT; RJA AND RJFSA MUST CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. ALSO PURSUANT TO THE ORDER, RJA, RJFS, AND RJFSA WERE CENSURED AND MUST PAY DISGORGEMENT, PREJUDMENT INTEREST AND A CIVIL MONEY PENALTY TOTALING $15,171,113.81. IN DETERMINING TO ACCEPT RAYMOND JAMES' OFFER OF A SETTLEMENT, THE SEC TOOK INTO CONSIDERATION CERTAIN REMEDIAL EFFORTS PROMPTLY TAKEN BY, AND THE COOPERATION OF, RAYMOND JAMES.
Other filed details
Description of allegations — filed text
THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT RAYMOND JAMES & ASSOCIATES, INC. ("RJA") AND RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC. ("RJFSA") VIOLATED SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT"), AND RULE 206(4)-7 THEREUNDER, BY FAILING TO CONDUCT PROMISED SUITABILITY REVIEWS FOR CERTAIN ADVISORY ACCOUNTS, FAILING TO ADOPT POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS CONCERNING THE SUITABILITY OF FEE-BASED ADVISORY ACCOUNTS, AND OVERVALUING CERTAIN ASSETS THAT RESULTED IN CHARGING EXCESS ADVISORY FEES. THE SEC ALSO ALLEGED THAT RJA AND RAYMOND JAMES FINANCIAL SERVICES, INC. ("RJFS") VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT") BY FAILING TO HAVE A REASONABLE BASIS FOR RECOMMENDING CERTAIN UNIT INVESTMENT TRUST TRANSACTIONS TO BROKERAGE CUSTOMERS, AND FAILING TO DISCLOSE THE CONFLICT OF INTEREST ASSOCIATED WITH EARNING GREATER COMPENSATION WHEN RECOMMENDING CERTAIN SECURITIES WITHOUT PROVIDING APPLICABLE SALES-LOAD DISCOUNTS TO BROKERAGE CUSTOMERS.
Sanction detail — filed text
"IN THE ORDER, RJA, RJFS, AND RJFSA WERE CENSURED, REQUIRED TO PAY A CIVIL MONETARY PENALTY OF $3,000,000, WHICH WAS PAID ON 09/25/2019, AND REQUIRED TO PAY DISGORGEMENT OF $11,098,349.01. DISGORGEMENT PAID TO OPEN ACCOUNTS ON 9/9 AND CLOSED ACCOUNTS ON 9/16
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
6694
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
RAYMOND JAMES FINANCIAL
SERVICES, INC.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions:
CENSURED, DISGORGEMENT, AND CIVIL MONEY PENALTY.
3.
Date Initiated (MM/DD/YYYY):
09/17/2019
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-19464
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
RAYMOND JAMES & ASSOCIATES, INC
6.
Principal Product Type:
Unit Investment Trust(s)
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT RAYMOND JAMES & ASSOCIATES, INC. ("RJA") AND RAYMOND JAMES FINANCIAL
SERVICES ADVISORS, INC. ("RJFSA") VIOLATED SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT"), AND
RULE 206(4)-7 THEREUNDER, BY FAILING TO CONDUCT PROMISED SUITABILITY REVIEWS FOR CERTAIN ADVISORY ACCOUNTS, FAILING TO ADOPT
POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS CONCERNING THE SUITABILITY OF FEE-BASED ADVISORY ACCOUNTS,
AND OVERVALUING CERTAIN ASSETS THAT RESULTED IN CHARGING EXCESS ADVISORY FEES. THE SEC ALSO ALLEGED THAT RJA AND RAYMOND JAMES
FINANCIAL SERVICES, INC. ("RJFS") VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT") BY FAILING TO
HAVE A REASONABLE BASIS FOR RECOMMENDING CERTAIN UNIT INVESTMENT TRUST TRANSACTIONS TO BROKERAGE CUSTOMERS, AND FAILING TO
DISCLOSE THE CONFLICT OF INTEREST ASSOCIATED WITH EARNING GREATER COMPENSATION WHEN RECOMMENDING CERTAIN SECURITIES WITHOUT
PROVIDING APPLICABLE SALES-LOAD DISCOUNTS TO BROKERAGE CUSTOMERS.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
09/17/2019
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 3,000,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
"IN THE ORDER, RJA, RJFS, AND RJFSA WERE CENSURED, REQUIRED TO PAY A CIVIL MONETARY PENALTY OF $3,000,000, WHICH WAS PAID ON
09/25/2019, AND REQUIRED TO PAY DISGORGEMENT OF $11,098,349.01. DISGORGEMENT PAID TO OPEN ACCOUNTS ON 9/9 AND CLOSED
ACCOUNTS ON 9/16
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
WITHOUT ADMITTING OR DENYING THE FINDINGS, RJA, RJFS, AND RJFSA CONSENTED TO THE ENTRY BY THE SEC OF AN ORDER INSTITUTING
ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTION 8A OF THE SECURITIES ACT, SECTION 15(B) OF THE SECURITIES
EXCHANGE ACT OF 1934, AND SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A
CEASE-AND-DESIST ORDER ("ORDER") (RELEASE NO. 86985, SEPT. 17, 2019). PURSUANT TO THE ORDER RJA AND RJFS MUST CEASE AND DESIST FROM
COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT; RJA AND
RJFSA MUST CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE
ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. ALSO PURSUANT TO THE ORDER, RJA, RJFS, AND RJFSA WERE CENSURED AND MUST
PAY DISGORGEMENT, PREJUDMENT INTEREST AND A CIVIL MONEY PENALTY TOTALING $15,171,113.81. IN DETERMINING TO ACCEPT RAYMOND JAMES'
OFFER OF A SETTLEMENT, THE SEC TOOK INTO CONSIDERATION CERTAIN REMEDIAL EFFORTS PROMPTLY TAKEN BY, AND THE COOPERATION OF,
RAYMOND JAMES.Show 79 more source blocks
regulatory · block 7RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INCPDF pages 73–75
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 149018 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES ADVISORS, INC (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: 11. Resolution Date (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 8RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 75–76
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the y p circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: 11. Resolution Date (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 9RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 77–78
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2018058633501 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: 11. Resolution Date (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 10MEYERHANS, ROMANPDF pages 78–80
- Advisory affiliate name — filed text
- MEYERHANS, ROMAN
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: 4587943 This advisory affiliate is a Firm an Individual Registered: Yes No Name: MEYERHANS, ROMAN (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 11PDF pages 80–82
- Regulator name — filed text
- INTERNATIONAL SECURITIES EXCHANGE
- Monetary/Fine Amount — filed text
- $ 5,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
DURING THE REVIEW PERIOD (2/20/14 - 3/26/14)RAYMOND JAMES EXECUTED 4 QUALIFIED CONTINGENT CROSS TRANSACTIONS WITH SOLICITED SIZE OF LESS THAN 1000 CONTRACTS. THERE WAS A MONETARY FINE OF $5,000 (PAID ON 6/2/15) - NO AMOUNT WAS WAIVED.
Other filed details
Description of allegations — filed text
DURING THE REVIEW PERIOD (2/20/14 - 3/26/14)RAYMOND JAMES EXECUTED 4 QUALIFIED CONTINGENT CROSS TRANSACTIONS WITH SOLICITED SIZE OF LESS THAN 1000 CONTRACTS.
Sanction detail — filed text
THE FIRM WAS FINED $5000 (PAID ON 6/2/15) - NO AMOUNT WAS WAIVED.
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) INTERNATIONAL SECURITIES EXCHANGE 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 05/08/2015 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2014-131 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): DURING THE REVIEW PERIOD (2/20/14 - 3/26/14)RAYMOND JAMES EXECUTED 4 QUALIFIED CONTINGENT CROSS TRANSACTIONS WITH SOLICITED SIZE OF LESS THAN 1000 CONTRACTS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 05/20/2015 Exact Explanation If not exact, provide explanation: AWC EXECUTED BY FINRA ON 5/20/15. PAYMENT REMITTED BY FIRM ON 6/2/15. 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 5,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS FINED $5000 (PAID ON 6/2/15) - NO AMOUNT 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). DURING THE REVIEW PERIOD (2/20/14 - 3/26/14)RAYMOND JAMES EXECUTED 4 QUALIFIED CONTINGENT CROSS TRANSACTIONS WITH SOLICITED SIZE OF LESS THAN 1000 CONTRACTS. THERE WAS A MONETARY FINE OF $5,000 (PAID ON 6/2/15) - NO AMOUNT WAS WAIVED.
regulatory · block 12PDF pages 82–83
- Regulator name — filed text
- FINRA
- 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 DISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALES CHARGE. THE FINDINGS STATED THAT THE CUSTOMERS WERE INSTEAD SOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE OR CLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHER ONGOING FEES AND EXPENSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT CUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TO ADOPT ANY CONTROLS TO DETECT INSTANCES IN WHICH THE FIRM DID NOT PROVIDE SALES CHARGE WAIVERS TO CUSTOMERS IN CONNECTION WITH THEIR MUTUAL FUND PURCHASES.
Sanction detail — filed text
THE FIRM IS CENSURED, ORDERED TO PAY RESTITUTION IN THE TOTAL AMOUNT OF $4,489,553.70 TO CUSTOMERS, AND WITH RESPECT TO ANY CUSTOMER THAT PURCHASED CLASS B OR C SHARES AND STILL HOLDS SUCH SHARES IN AN ACCOUNT AT THE FIRM, THE FIRM UNDERTAKES TO OFFER SUCH CUSTOMER THE OPTION OF CONVERTING SUCH CLASS B OR C SHARES TO CLASS A SHARES AT NO EXPENSE TO THE CUSTOMER.
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 Other Sanctions: N/A 3. Date Initiated (MM/DD/YYYY): 07/06/2015 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2015044309001 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): N/A 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 SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALES CHARGE. THE FINDINGS STATED THAT THE CUSTOMERS WERE INSTEAD SOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE OR CLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHER ONGOING FEES AND EXPENSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT CUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TO ADOPT ANY CONTROLS TO DETECT INSTANCES IN WHICH THE FIRM DID NOT PROVIDE SALES CHARGE WAIVERS TO CUSTOMERS IN CONNECTION WITH THEIR MUTUAL FUND PURCHASES. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 07/06/2015 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: UNDERTAKING Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM IS CENSURED, ORDERED TO PAY RESTITUTION IN THE TOTAL AMOUNT OF $4,489,553.70 TO CUSTOMERS, AND WITH RESPECT TO ANY CUSTOMER THAT PURCHASED CLASS B OR C SHARES AND STILL HOLDS SUCH SHARES IN AN ACCOUNT AT THE FIRM, THE FIRM UNDERTAKES TO OFFER SUCH CUSTOMER THE OPTION OF CONVERTING SUCH CLASS B OR C SHARES TO CLASS A SHARES AT NO EXPENSE TO THE CUSTOMER. 13. Provide a brief summary of 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 13RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 84–86
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- STATE OF HAWAII
- Monetary/Fine Amount — filed text
- $ 3,972.17
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RAYMOND JAMES FINALIZED A SETTLEMENT AGREEMENT WITH THE STATE OF HAWAII ON 9/16/2014, IN WHICH IT CONSENTED: (I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS. (II) TO USE ITS BEST EFFORTS TO PROVIDE INSTITUTIONAL MONEY MANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS. (III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE CUSTOMERS WHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHO TRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIOR TO JANUARY 1, 2006. (IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLE INTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO TOOK OUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECURED BY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THE TIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITH THE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTAL INTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THE DURATION OF THE LOAN. (V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY CUSTOMER WHO PURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2) SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR BETWEEN FEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANY SUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE AT WHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUS REASONABLE INTEREST.
Other filed details
Description of allegations — filed text
STATE OF HAWAII ALLEGED THAT RAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OF SECURITIES IN VIOLATION OF HRS 485-15(7). FURTHER, THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATION OF HRS 485-15(10). RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERS AUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELY CHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THE TRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS. ALTHOUGH RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSED THE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMES WAS NOT OBLIGED TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE, SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELY DESCRIBED ARS AS ALTERNATIVES TO MONEY MARKET FUNDS AND OTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSING THE AUCTION PROCESS OR THE RISK OF ILLIQUIDITY IF THESE AUCTIONS FAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARS AUCTIONS FAILED, RESULTING IN AN OVERALL MARKET COLLAPSE THAT LEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMOND JAMES' CUSTOMERS, HOLDING ARS THAT THEY HAVE, IN SOME INSTANCES, NOT BEEN ABLE TO LIQUIDATE.
Sanction detail — filed text
ON 9/16/2014, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF $3,972.17 TO THE TREASURER OF STATE OF HAWAII.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
6694
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
RAYMOND JAMES FINANCIAL
SERVICES, INC.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
STATE OF HAWAII
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
CEASE & DESIST
3.
Date Initiated (MM/DD/YYYY):
09/16/2014
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
SEU-2011-13
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):
STATE OF HAWAII ALLEGED THAT RAYMOND JAMES ENGAGED IN DISHONEST OR UNETHICAL PRACTICES IN THE SALE OF SECURITIES IN VIOLATION OF
HRS 485-15(7). FURTHER, THE SECURITIES DIVISION ALLEGED THAT RAYMOND JAMES FAILED TO REASONABLY SUPERVISE THEIR AGENTS IN VIOLATION
OF HRS 485-15(10). RAYMOND JAMES OFFERED AND SOLD TO SOME OF ITS CUSTOMERS AUCTION RATE SECURITIES ("ARS") WHILE NOT ACCURATELY
CHARACTERIZING OR WHILE FAILING TO ADEQUATELY DISCLOSE THE TRUE NATURE AND RISKS ASSOCIATED WITH THESE INVESTMENTS. ALTHOUGH
RAYMOND JAMES' ARS TRADE CONFIRMATIONS DISCLOSED THE RISK THAT ARS AUCTIONS COULD FAIL AND THAT RAYMOND JAMES WAS NOT OBLIGED
TO ENSURE THEIR SUCCESS, AT THE POINT-OF-SALE, SOME OF RAYMOND JAMES' FINANCIAL ADVISERS INACCURATELY DESCRIBED ARS AS
ALTERNATIVES TO MONEY MARKET FUNDS AND OTHER CASH-LIKE INVESTMENTS, WITHOUT ADEQUATELY DISCLOSING THE AUCTION PROCESS OR THE
RISK OF ILLIQUIDITY IF THESE AUCTIONS FAILED. ON FEBRUARY 13, 2008, A SIGNIFICANT NUMBER OF ARS AUCTIONS FAILED, RESULTING IN AN
OVERALL MARKET COLLAPSE THAT LEFT THOUSANDS OF INVESTORS, INCLUDING SOME OF RAYMOND JAMES' CUSTOMERS, HOLDING ARS THAT THEY
HAVE, IN SOME INSTANCES, NOT BEEN ABLE TO LIQUIDATE.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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):
09/16/2014
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: $ 3,972.17
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:
ON 9/16/2014, RAYMOND JAMES PAID A FINE IN THE AMOUNT OF $3,972.17 TO THE TREASURER OF STATE OF HAWAII.
13. Provide a brief summary of 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, RAYMOND JAMES FINALIZED A SETTLEMENT AGREEMENT WITH THE STATE OF HAWAII ON
9/16/2014, IN WHICH IT CONSENTED: (I) TO PURCHASE ELIGIBLE ARS HELD BY ELIGIBLE CUSTOMERS. (II) TO USE ITS BEST EFFORTS TO PROVIDE
INSTITUTIONAL MONEY MANAGERS OPPORTUNITIES TO LIQUIDATE THEIR ELIGIBLE ARS. (III) TO USE ITS BEST EFFORTS TO IDENTIFY AND LOCATE
CUSTOMERS WHO PURCHASED ELIGIBLE ARS AT RAYMOND JAMES BUT WHO TRANSFERRED SUCH ELIGIBLE ARS AWAY FROM RAYMOND JAMES PRIOR TO
JANUARY 1, 2006. (IV) TO IDENTIFY, AND REPAY EXCESS EXPENSES AND REASONABLE INTEREST THEREON, INCURRED BY ELIGIBLE CUSTOMERS WHO
TOOK OUT LOANS FROM RAYMOND JAMES AFTER FEBRUARY 13, 2008 SECURED BY ELIGIBLE ARS THAT WERE NOT SUCCESSFULLY AUCTIONING AT THE
TIME THE LOAN WAS TAKEN AND WHO PAID INTEREST ASSOCIATED WITH THE ARS-BASED PORTION OF THOSE LOANS IN EXCESS OF THE TOTAL
INTEREST AND DIVIDENDS RECEIVED ON THE ELIGIBLE ARS DURING THE DURATION OF THE LOAN. (V) TO USE ITS BEST EFFORTS TO IDENTIFY ANY
CUSTOMER WHO PURCHASED ELIGIBLE ARS ON OR BEFORE FEBRUARY 13, 2008; AND (2) SUBSEQUENTLY SOLD THOSE ELIGIBLE ARS BELOW PAR
BETWEEN FEBRUARY 13, 2008 AND THE DATE OF THE ORDER, AND TO REPAY ANY SUCH CUSTOMER THE DIFFERENCE BETWEEN PAR AND THE PRICE AT
WHICH SUCH CUSTOMER SOLD OR REDEEMED THE ELIGIBLE ARS, PLUS REASONABLE INTEREST.regulatory · block 14RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 86–88
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 8,000,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, AND ITS AMLCO, FAILED TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES TO REASONABLY DETECT AND CAUSE THE REPORTING OF SUSPICIOUS TRANSACTIONS. THE FINDINGS STATED THAT AS THE FIRM'S AMLCO, THE REPRESENTATIVE WAS RESPONSIBLE FOR ENSURING THAT THE FIRM'S AML PROGRAM WAS ADEQUATELY TAILORED TO THE FIRM'S BUSINESS AND FOR APPROPRIATELY MONITORING, DETECTING AND REPORTING SUSPICIOUS ACTIVITY. DESPITE THE SEPARATE AML DEPARTMENTS AND PROGRAMS, THE FIRM AS A CLEARING FIRM, ITS AMLCO, AND THE FIRM FOR WHICH THE FIRM SERVED AS CLEARING FIRM CREATED A SYSTEM UNDER WHICH THIS FIRM HEAVILY RELIED UPON ITS CLEARING FIRM TO PROVIDE CERTAIN SYSTEMS AND TOOLS AS PART OF THE FIRM'S AML PROGRAM. THE FIRM FAILED TO COMMIT ADEQUATE RESOURCES TO THE FIRM'S AML PROGRAMS. THE FIRM'S STAFFING OF ITS AML DEPARTMENTS WAS INADEQUATE IN LIGHT OF THE EXTENSIVE RESPONSIBILITIES ASSIGNED TO THE FEW INDIVIDUALS, INCLUDING THE LABOR-INTENSIVE MANUAL REVIEWS, PARTICULARLY IN LIGHT OF THE FIRM'S GROWTH. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND IMPLEMENT AML PROCEDURES AND SYSTEMS REASONABLY EXPECTED TO DETECT SUSPICIOUS ACTIVITY. THE FIRM FAILED TO ESTABLISH REASONABLE WRITTEN PROCEDURES FOR CERTAIN ASPECTS OF THE FIRM'S AML PROGRAMS. THE FIRM FAILED TO ESTABLISH REASONABLE AML SYSTEMS TAILORED TO ITS BUSINESS. THE AML PROCEDURES THAT WERE IN PLACE REQUIRED THE FIRM TO REVIEW ACCOUNTS FOR POTENTIAL SUSPICIOUS ACTIVITY. THE FIRM, HOWEVER, FAILED TO DEVELOP AND IMPLEMENT SURVEILLANCE REPORTS TAILORED TO DETECT CERTAIN TYPES OF POTENTIALLY SUSPICIOUS TRANSACTIONS. FOR EXAMPLE, THE FIRM HAD NO WRITTEN PROCEDURES REQUIRING REVIEW OF, OR SURVEILLANCE REPORTS MONITORING FOR, THE FOLLOWING HIGH-RISK ACTIVITIES: TRANSFERS OF FUNDS TO UNRELATED ACCOUNTS WITHOUT ANY APPARENT BUSINESS PURPOSE; JOURNALING SECURITIES AND CASH BETWEEN UNRELATED ACCOUNTS FOR NO APPARENT BUSINESS PURPOSE, PARTICULARLY INTERNAL TRANSFERS OF CASH FROM CUSTOMER ACCOUNTS TO EMPLOYEE OR EMPLOYEE-RELATED ACCOUNTS; AND MOVEMENT OF FUNDS, BY WIRE TRANSFER OR OTHERWISE, FROM MULTIPLE ACCOUNTS TO THE SAME THIRD PARTY ACCOUNT. THE FIRM'S SURVEILLANCE REPORTS FAILED TO REASONABLY MONITOR FOR SUSPICIOUS ACTIVITY. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO REASONABLY INVESTIGATE RED FLAGS. AS A RESULT OF THE FIRM'S AML PROCEDURES, THE FIRM HAD GAPS IN ITS SURVEILLANCE OF ACTIVITY FOR AML RED FLAGS. EVEN WHEN THE EXCEPTION REPORTS OR OTHER SURVEILLANCE IDENTIFIED RED FLAGS, THE FIRM FAILED TO REASONABLY INVESTIGATE MANY INSTANCES IN ORDER TO DETERMINE WHETHER A SAR SHOULD BE FILED. ALSO, ALTHOUGH THE FIRM AML ANALYSTS IDENTIFIED SOME RED FLAGS AND OPENED INVESTIGATIONS, THE INVESTIGATIONS WERE DEFICIENT. FINRA FOUND THAT THE FIRM FAILED TO REASONABLY ENFORCE ITS DUE DILIGENCE PROCEDURES FOR CERTAIN CORRESPONDENT ACCOUNTS OF CERTAIN FOREIGN FINANCIAL INSTITUTIONS (FFIS). MOREOVER, THE FIRM ALSO HAD NO RELIABLE PERIODIC REVIEW PROCESS IN PLACE TO ENSURE THAT THE ACTIVITY IN THE FFIS' ACCOUNTS WAS CONSISTENT WITH REPRESENTATIONS MADE BY FFIS AT THE TIME OF ACCOUNT OPENING. THIS FAILURE RESULTED IN THE FIRM PERFORMING NO PERIODIC RISK REVIEWS OF A PORTUGUESE FFI ACCOUNT, EVEN THOUGH THE FFI WAS ASSIGNED A HIGH-RISK RATING BY THE FIRM. FINRA ALSO FOUND THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECTION 5 OF THE SECURITIES ACT THROUGH INCOMPLETE RISK REVIEWS, DUE DILIGENCE FAILURES, AND FAILURES TO IMPLEMENT EXISTING PROCEDURES RELEVANT TO LOW PRICED SECURITIES.
Sanction detail — filed text
THE FIRM WAS CENSURED, FINED $8,000,000 AND REQUIRED TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF ITS AML AND SUPERVISORY POLICIES, SYSTEMS, PROCEDURES, AND TRAINING. AT THE CONCLUSION OF THE REVIEW, WHICH SHALL BE NO MORE THAN 180 DAYS AFTER THE DATE OF THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALL CERTIFY THAT ITS PROCEDURES ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 3310. THE CERTIFICATION SHALL BE PROVIDED IN A WRITTEN LETTER TO FINRA. THE LETTER SHALL BE ACCOMPANIED BY A WRITTEN REPORT, AT A MINIMUM, STATING (I) THE ADEQUACY OF THE FIRM'S POLICIES, SYSTEMS, PROCEDURES AND TRAINING RELATING TO AML AND SUPERVISION; (II) A DESCRIPTION OF THE REVIEW PERFORMED AND THE CONCLUSIONS REACHED; AND (III) RECOMMENDATIONS FOR MODIFICATIONS AND ADDITIONS TO THE FIRM'S POLICIES, SYSTEMS, PROCEDURES AND TRAINING. THE $8,000,000 FINE WAS PAID ON 5/26/16.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FINRA 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 05/18/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2014043592001 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Annuity(ies) - Variable Other Product Types: LOW PRICED SECURITIES 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, AND ITS AMLCO, FAILED TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES TO REASONABLY DETECT AND CAUSE THE REPORTING OF SUSPICIOUS TRANSACTIONS. THE FINDINGS STATED THAT AS THE FIRM'S AMLCO, THE REPRESENTATIVE WAS RESPONSIBLE FOR ENSURING THAT THE FIRM'S AML PROGRAM WAS ADEQUATELY TAILORED TO THE FIRM'S BUSINESS AND FOR APPROPRIATELY MONITORING, DETECTING AND REPORTING SUSPICIOUS ACTIVITY. DESPITE THE SEPARATE AML DEPARTMENTS AND PROGRAMS, THE FIRM AS A CLEARING FIRM, ITS AMLCO, AND THE FIRM FOR WHICH THE FIRM SERVED AS CLEARING FIRM CREATED A SYSTEM UNDER WHICH THIS FIRM HEAVILY RELIED UPON ITS CLEARING FIRM TO PROVIDE CERTAIN SYSTEMS AND TOOLS AS PART OF THE FIRM'S AML PROGRAM. THE FIRM FAILED TO COMMIT ADEQUATE RESOURCES TO THE FIRM'S AML PROGRAMS. THE FIRM'S STAFFING OF ITS AML DEPARTMENTS WAS INADEQUATE IN LIGHT OF THE EXTENSIVE RESPONSIBILITIES ASSIGNED TO THE FEW INDIVIDUALS, INCLUDING THE LABOR-INTENSIVE MANUAL REVIEWS, PARTICULARLY IN LIGHT OF THE FIRM'S GROWTH. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND IMPLEMENT AML PROCEDURES AND SYSTEMS REASONABLY EXPECTED TO DETECT SUSPICIOUS ACTIVITY. THE FIRM FAILED TO ESTABLISH REASONABLE WRITTEN PROCEDURES FOR CERTAIN ASPECTS OF THE FIRM'S AML PROGRAMS. THE FIRM FAILED TO ESTABLISH REASONABLE AML SYSTEMS TAILORED TO ITS BUSINESS. THE AML PROCEDURES THAT WERE IN PLACE REQUIRED THE FIRM TO REVIEW ACCOUNTS FOR POTENTIAL SUSPICIOUS ACTIVITY. THE FIRM, HOWEVER, FAILED TO DEVELOP AND IMPLEMENT SURVEILLANCE REPORTS TAILORED TO DETECT CERTAIN TYPES OF POTENTIALLY SUSPICIOUS TRANSACTIONS. FOR EXAMPLE, THE FIRM HAD NO WRITTEN PROCEDURES REQUIRING REVIEW OF, OR SURVEILLANCE REPORTS MONITORING FOR, THE FOLLOWING HIGH-RISK ACTIVITIES: TRANSFERS OF FUNDS TO UNRELATED ACCOUNTS WITHOUT ANY APPARENT BUSINESS PURPOSE; JOURNALING SECURITIES AND CASH BETWEEN UNRELATED ACCOUNTS FOR NO APPARENT BUSINESS PURPOSE, PARTICULARLY INTERNAL TRANSFERS OF CASH FROM CUSTOMER ACCOUNTS TO EMPLOYEE OR EMPLOYEE-RELATED ACCOUNTS; AND MOVEMENT OF FUNDS, BY WIRE TRANSFER OR OTHERWISE, FROM MULTIPLE ACCOUNTS TO THE SAME THIRD PARTY ACCOUNT. THE FIRM'S SURVEILLANCE REPORTS FAILED TO REASONABLY MONITOR FOR SUSPICIOUS ACTIVITY. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO REASONABLY INVESTIGATE RED FLAGS. AS A RESULT OF THE FIRM'S AML PROCEDURES, THE FIRM HAD GAPS IN ITS SURVEILLANCE OF ACTIVITY FOR AML RED FLAGS. EVEN WHEN THE EXCEPTION REPORTS OR OTHER SURVEILLANCE IDENTIFIED RED FLAGS, THE FIRM FAILED TO REASONABLY INVESTIGATE MANY INSTANCES IN ORDER TO DETERMINE WHETHER A SAR SHOULD BE FILED. ALSO, ALTHOUGH THE FIRM AML ANALYSTS IDENTIFIED SOME RED FLAGS AND OPENED INVESTIGATIONS, THE INVESTIGATIONS WERE DEFICIENT. FINRA FOUND THAT THE FIRM FAILED TO REASONABLY ENFORCE ITS DUE DILIGENCE PROCEDURES FOR CERTAIN CORRESPONDENT ACCOUNTS OF CERTAIN FOREIGN FINANCIAL INSTITUTIONS (FFIS). MOREOVER, THE FIRM ALSO HAD NO RELIABLE PERIODIC REVIEW PROCESS IN PLACE TO ENSURE THAT THE ACTIVITY IN THE FFIS' ACCOUNTS WAS CONSISTENT WITH REPRESENTATIONS MADE BY FFIS AT THE TIME OF ACCOUNT OPENING. THIS FAILURE RESULTED IN THE FIRM PERFORMING NO PERIODIC RISK REVIEWS OF A PORTUGUESE FFI ACCOUNT, EVEN THOUGH THE FFI WAS ASSIGNED A HIGH-RISK RATING BY THE FIRM. FINRA ALSO FOUND THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECTION 5 OF THE SECURITIES ACT THROUGH INCOMPLETE RISK REVIEWS, DUE DILIGENCE FAILURES, AND FAILURES TO IMPLEMENT EXISTING PROCEDURES RELEVANT TO LOW PRICED SECURITIES. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 05/18/2016 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 8,000,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKING Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS CENSURED, FINED $8,000,000 AND REQUIRED TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF ITS AML AND SUPERVISORY POLICIES, SYSTEMS, PROCEDURES, AND TRAINING. AT THE CONCLUSION OF THE REVIEW, WHICH SHALL BE NO MORE THAN 180 DAYS AFTER THE DATE OF THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALL CERTIFY THAT ITS PROCEDURES ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 3310. THE CERTIFICATION SHALL BE PROVIDED IN A WRITTEN LETTER TO FINRA. THE LETTER SHALL BE ACCOMPANIED BY A WRITTEN REPORT, AT A MINIMUM, STATING (I) THE ADEQUACY OF THE FIRM'S POLICIES, SYSTEMS, PROCEDURES AND TRAINING RELATING TO AML AND SUPERVISION; (II) A DESCRIPTION OF THE REVIEW PERFORMED AND THE CONCLUSIONS REACHED; AND (III) RECOMMENDATIONS FOR MODIFICATIONS AND ADDITIONS TO THE FIRM'S POLICIES, SYSTEMS, PROCEDURES AND TRAINING. THE $8,000,000 FINE WAS PAID ON 5/26/16. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 15RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 88–90
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 500,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT CAUSED CERTAIN NEWLY-RECRUITED REGISTERED REPRESENTATIVES FROM OTHER BROKERAGE FIRMS TO DISCLOSE CUSTOMER NONPUBLIC PERSONAL INFORMATION TO IT IN VIOLATION OF REGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934. THE FINDINGS STATED THAT THE FIRM USED THE NONPUBLIC PERSONAL INFORMATION PROVIDED TO PRE-POPULATE NEW ACCOUNT FORMS WITH CERTAIN CUSTOMER INFORMATION. THE FIRM, HOWEVER, FAILED TO MAKE ANY DETERMINATION AS TO WHETHER THE RECRUITS, OR THE CURRENT BROKER-DEALERS WITH WHICH THE RECRUITS WERE ASSOCIATED, HAD OBTAINED THE CUSTOMERS' CONSENT TO PROVIDE THE FIRM WITH THE CUSTOMERS' NONPUBLIC PERSONAL INFORMATION OR PROVIDED CUSTOMERS WITH NOTICE OF, AND AN OPPORTUNITY TO OPT-OUT OF, THE DISCLOSURE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN REASONABLE SUPERVISORY SYSTEMS, INCLUDING WSPS AND TRAINING, TO ENSURE COMPLIANCE WITH REGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934. THE FIRM FAILED TO PREVENT THE IMPROPER SOLICITATION OF NONPUBLIC PERSONAL INFORMATION FROM RECRUITS, FAILED TO ADEQUATELY TRAIN AND EDUCATE ITS STAFF ON WHAT CONSTITUTED NONPUBLIC PERSONAL INFORMATION AND THE APPROPRIATE CIRCUMSTANCES IN WHICH SUCH INFORMATION COULD BE SHARED, AND WITH RESPECT TO REGISTERED REPRESENTATIVES WHO WERE TRANSITIONING FROM THE FIRM TO ANOTHER BROKER-DEALER. IT WAS UNABLE TO DEMONSTRATE THAT ITS WSPS WERE SYSTEMATICALLY FOLLOWED AND ENFORCED.
Sanction detail — filed text
THE FIRM WAS CENSURED, FINED $500,000.00, AND REQUIRED TO REVIEW AND REVISE, AS NECESSARY, ITS POLICIES, PROCEDURES, AND INTERNAL CONTROLS. WITHIN 45 BUSINESS DAYS OF THE ISSUANCE OF THE NOTICE OF ACCEPTANCE OF THIS AWC, THE CHIEF EXECUTIVE OFFICER AND CHIEF COMPLIANCE OFFICER AT THE FIRM SHALL CERTIFY IN WRITING TO FINRA THAT, WITH RESPECT TO THE AREAS DESCRIBED IN THE AWC, (1) THE FIRM HAS ENGAGED IN THE REVIEW DESCRIBED ABOVE; AND (II) AS OF THE DATE OF THIS CERTIFICATION, THE FIRM HAS ESTABLISHED AND IMPLEMENTED POLICIES, PROCEDURES AND INTERNAL CONTROLS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FINRA 2. Principal Sanction: Other Other Sanctions: N/A 3. Date Initiated (MM/DD/YYYY): 03/08/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2013035599201 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT CAUSED CERTAIN NEWLY-RECRUITED REGISTERED REPRESENTATIVES FROM OTHER BROKERAGE FIRMS TO DISCLOSE CUSTOMER NONPUBLIC PERSONAL INFORMATION TO IT IN VIOLATION OF REGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934. THE FINDINGS STATED THAT THE FIRM USED THE NONPUBLIC PERSONAL INFORMATION PROVIDED TO PRE-POPULATE NEW ACCOUNT FORMS WITH CERTAIN CUSTOMER INFORMATION. THE FIRM, HOWEVER, FAILED TO MAKE ANY DETERMINATION AS TO WHETHER THE RECRUITS, OR THE CURRENT BROKER-DEALERS WITH WHICH THE RECRUITS WERE ASSOCIATED, HAD OBTAINED THE CUSTOMERS' CONSENT TO PROVIDE THE FIRM WITH THE CUSTOMERS' NONPUBLIC PERSONAL INFORMATION OR PROVIDED CUSTOMERS WITH NOTICE OF, AND AN OPPORTUNITY TO OPT-OUT OF, THE DISCLOSURE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN REASONABLE SUPERVISORY SYSTEMS, INCLUDING WSPS AND TRAINING, TO ENSURE COMPLIANCE WITH REGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934. THE FIRM FAILED TO PREVENT THE IMPROPER SOLICITATION OF NONPUBLIC PERSONAL INFORMATION FROM RECRUITS, FAILED TO ADEQUATELY TRAIN AND EDUCATE ITS STAFF ON WHAT CONSTITUTED NONPUBLIC PERSONAL INFORMATION AND THE APPROPRIATE CIRCUMSTANCES IN WHICH SUCH INFORMATION COULD BE SHARED, AND WITH RESPECT TO REGISTERED REPRESENTATIVES WHO WERE TRANSITIONING FROM THE FIRM TO ANOTHER BROKER-DEALER. IT WAS UNABLE TO DEMONSTRATE THAT ITS WSPS WERE SYSTEMATICALLY FOLLOWED AND ENFORCED. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 03/08/2016 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 500,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKING Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS CENSURED, FINED $500,000.00, AND REQUIRED TO REVIEW AND REVISE, AS NECESSARY, ITS POLICIES, PROCEDURES, AND INTERNAL CONTROLS. WITHIN 45 BUSINESS DAYS OF THE ISSUANCE OF THE NOTICE OF ACCEPTANCE OF THIS AWC, THE CHIEF EXECUTIVE OFFICER AND CHIEF COMPLIANCE OFFICER AT THE FIRM SHALL CERTIFY IN WRITING TO FINRA THAT, WITH RESPECT TO THE AREAS DESCRIBED IN THE AWC, (1) THE FIRM HAS ENGAGED IN THE REVIEW DESCRIBED ABOVE; AND (II) AS OF THE DATE OF THIS CERTIFICATION, THE FIRM HAS ESTABLISHED AND IMPLEMENTED POLICIES, PROCEDURES AND INTERNAL CONTROLS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REGULATION S-P UNDER THE SECURITIES EXCHANGE ACT OF 1934. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 16PDF pages 90–92
- Regulator name — filed text
- FINRA
- 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 OVER REPORTED TRANSACTIONS IN OVER-THE-COUNTER (OTC) EQUITY SECURITIES TO THE OVER THE COUNTER REPORTING FACILITY (OTCRF) THAT WERE EXECUTED IN CANADA AND ALSO REPORTED TO THE REGULATOR OF SECURITIES MARKETS FOR THAT COUNTRY. THE FINDINGS STATED THAT THE UNDERLYING SECURITIES WERE DUALLY LISTED IN THE UNITED STATES AND IN CANADA. THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF FINRA, CONCERNING TRADE REPORTING OF TRANSACTIONS INVOLVING SECURITIES THAT ARE DUALLY LISTED IN THE UNITED STATES AND ANOTHER COUNTRY.
Sanction detail — filed text
THE FIRM WAS CENSURED, FINED $12,500, AND UNDERTAKES TO REVISE ITS WSPS. THE FINE WAS PAID ON 7/28/16, AND WSPS WERE REVISED ON 4/6/2015.
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): 07/15/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2013037852901 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 OVER REPORTED TRANSACTIONS IN OVER-THE-COUNTER (OTC) EQUITY SECURITIES TO THE OVER THE COUNTER REPORTING FACILITY (OTCRF) THAT WERE EXECUTED IN CANADA AND ALSO REPORTED TO THE REGULATOR OF SECURITIES MARKETS FOR THAT COUNTRY. THE FINDINGS STATED THAT THE UNDERLYING SECURITIES WERE DUALLY LISTED IN THE UNITED STATES AND IN CANADA. THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF FINRA, CONCERNING TRADE REPORTING OF TRANSACTIONS INVOLVING SECURITIES THAT ARE DUALLY LISTED IN THE UNITED STATES AND ANOTHER COUNTRY. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 07/15/2016 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: $ 12,500.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKING: REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS). Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement 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 $12,500, AND UNDERTAKES TO REVISE ITS WSPS. THE FINE WAS PAID ON 7/28/16, AND WSPS WERE REVISED ON 4/6/2015. 13. Provide a brief summary of 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 17PDF pages 92–93
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 5,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT ACCEPTED AND HELD CUSTOMER ORDERS TRADED FOR ITS OWN ACCOUNT AT PRICES THAT WOULD HAVE SATISFIED THE CUSTOMER ORDERS, AND FAILED TO EXECUTE OR IMMEDIATELY EXECUTE THE CUSTOMER ORDERS IN OVER-THE COUNTER (OTC) SECURITIES UP TO THE SIZE AND AT THE SAME PRICE AT WHICH IT TRADED FOR ITS OWN ACCOUNT OR AT A BETTER PRICE. THE FINDINGS STATED THAT IN SEVERAL INSTANCES THE FIRM FAILED TO MAKE EVERY EFFORT TO CROSS A MARKETABLE CUSTOMER ORDER WITH ANOTHER ORDER RECEIVED BY THE FIRM ON THE OPPOSITE SIDE OF THE MARKET. FURTHER, ON MULTIPLE OCCASIONS INVOLVING EITHER A TRADING AHEAD AND/OR CROSSING FAILURE, THE FIRM FAILED TO EXECUTE A MARKETABLE CUSTOMER ORDER FULLY AND PROMPTLY.
Sanction detail — filed text
THE FIRM WAS FINED $5000.00, AND ORDERED TO PAY $601.83, PLUS INTEREST IN RESTITUTION TO CUSTOMERS. THE FINE WAS PAID ON 10/4/16.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE 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): 09/20/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2014042145301 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: OTC SECURITIES 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT ACCEPTED AND HELD CUSTOMER ORDERS TRADED FOR ITS OWN ACCOUNT AT PRICES THAT WOULD HAVE SATISFIED THE CUSTOMER ORDERS, AND FAILED TO EXECUTE OR IMMEDIATELY EXECUTE THE CUSTOMER ORDERS IN OVER-THE COUNTER (OTC) SECURITIES UP TO THE SIZE AND AT THE SAME PRICE AT WHICH IT TRADED FOR ITS OWN ACCOUNT OR AT A BETTER PRICE. THE FINDINGS STATED THAT IN SEVERAL INSTANCES THE FIRM FAILED TO MAKE EVERY EFFORT TO CROSS A MARKETABLE CUSTOMER ORDER WITH ANOTHER ORDER RECEIVED BY THE FIRM ON THE OPPOSITE SIDE OF THE MARKET. FURTHER, ON MULTIPLE OCCASIONS INVOLVING EITHER A TRADING AHEAD AND/OR CROSSING FAILURE, THE FIRM FAILED TO EXECUTE A MARKETABLE CUSTOMER ORDER FULLY AND PROMPTLY. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 09/20/2016 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: $ 5,000.00 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 FINED $5000.00, AND ORDERED TO PAY $601.83, PLUS INTEREST IN RESTITUTION TO CUSTOMERS. THE FINE WAS PAID ON 10/4/16. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 18PDF pages 94–95
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 30,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO PUBLISH IMMEDIATELY A BID OR OFFER THAT REFLECTED THE FULL SIZE OF CUSTOMER LIMIT ORDERS FOR OVER-THE-COUNTER (OTC) EQUITY SECURITIES HELD BY THE FIRM THAT WERE AT A PRICE THAT WOULD HAVE IMPROVED THE BID OR OFFER OF THE FIRM IN SUCH SECURITIES. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO CERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS, AND/OR THE RULES OF FINRA. THE FIRM'S WRITTEN SUPERVISORY PROCEDURE (WSPS) FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS FOR ADEQUATE PROCEDURES REGARDING FINRA RULE 6460.
Sanction detail — filed text
THE FIRM WAS CENSURED, FINED $30,000 AND UNDERTAKES TO REVISE ITS WSPS WITH RESPECT TO THE AREAS DESCRIBED IN THE AWC, AND WITHIN 30 BUSINESS DAYS OF THE AWC, A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT TO FINRA A SIGNED, DATED LETTER, OR AN E- MAIL PROVIDING THE FOLLOWING INFORMATION: A REFERENCE TO THIS MATTER; A REPRESENTATION THAT THE FIRM HAS REVISED ITS WSPS, TO ADDRESS THE DEFICIENCIES DESCRIBED IN THE AWC; AND, THE DATE THE REVISED PROCEDURES WERE IMPLEMENTED. PAYMENT WAS SENT ON 9/28/16.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE 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): 09/12/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2014043168701 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 PUBLISH IMMEDIATELY A BID OR OFFER THAT REFLECTED THE FULL SIZE OF CUSTOMER LIMIT ORDERS FOR OVER-THE-COUNTER (OTC) EQUITY SECURITIES HELD BY THE FIRM THAT WERE AT A PRICE THAT WOULD HAVE IMPROVED THE BID OR OFFER OF THE FIRM IN SUCH SECURITIES. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO CERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS, AND/OR THE RULES OF FINRA. THE FIRM'S WRITTEN SUPERVISORY PROCEDURE (WSPS) FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS FOR ADEQUATE PROCEDURES REGARDING FINRA RULE 6460. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 09/12/2016 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: $ 30,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKINGS Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS CENSURED, FINED $30,000 AND UNDERTAKES TO REVISE ITS WSPS WITH RESPECT TO THE AREAS DESCRIBED IN THE AWC, AND WITHIN 30 BUSINESS DAYS OF THE AWC, A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT TO FINRA A SIGNED, DATED LETTER, OR AN E- MAIL PROVIDING THE FOLLOWING INFORMATION: A REFERENCE TO THIS MATTER; A REPRESENTATION THAT THE FIRM HAS REVISED ITS WSPS, TO ADDRESS THE DEFICIENCIES DESCRIBED IN THE AWC; AND, THE DATE THE REVISED PROCEDURES WERE IMPLEMENTED. PAYMENT WAS SENT ON 9/28/16. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 19PDF pages 95–97
- Regulator name — filed text
- STATE OF VERMONT, DEPARTMENT OF FINANCIAL REGULATION
- Monetary/Fine Amount — filed text
- $ 5,950,000.00
- How was matter resolved — filed text
- Order
Other filed details
Description of allegations — filed text
VIOLATION OF 9 VERMONT SECURITIES ACT (VSA) 5412(D)(9)
Sanction detail — filed text
RJA SHALL CEASE AND DESIST FROM VIOLATING SECTION 5412(D)(9) OF THE VERMONT UNIFORM SECURITIES ACT (VUSA) AND WILL COMPLY WITH ALL APPLICABLE PROVISIONS OF THE VUSA. WITHIN TEN (10) BUSINESS DAYS OF THE DATE OF THIS ORDER, RJA SHALL PAY TO THE DEPARTMENT OF FINANCIAL REGULATION (DFR) THE SUM OF $1,450,0000, OF WHICH $1,250,000 REPRESENTS AN ADMINISTRATIVE PENALTY AND $200,000 SHALL REIMBURSE THE OFR FOR ITS COSTS. THE COMMISSIONER DIRECTS THAT WITHIN TEN (10) BUSINESS DAYS OF THE DATE OF THIS ORDER RJA PAY $4,500,000 TO THE RECEIVER APPOINTED IN THE MATTER ENTITLED SEC V. QUIROS, NO.1:16-CV-21301-DPG (S.D. FLA.) FOR THE SOLE PURPOSE OF REIMBURSING CLAIMS BY THE EB-5 INVESTORS. THE SUM OF $2,750,000 REPRESENTS THE TOTAL REVENUES EARNED BY RJA AND THE REGISTERED REPRESENTATIVE IN CONNECTION WITH THE QUIROS-CONTROLLED ACCOUNTS, AND THE BALANCE REPRESENTS RESTITUTION. THE FINES WERE PAID ON JULY 7, 2016.
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 VERMONT, DEPARTMENT OF FINANCIAL REGULATION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CEASE AND DESIST ORDER 3. Date Initiated (MM/DD/YYYY): 06/29/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 16-026-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): VIOLATION OF 9 VERMONT SECURITIES ACT (VSA) 5412(D)(9) 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 06/29/2016 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: $ 5,950,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RJA SHALL CEASE AND DESIST FROM VIOLATING SECTION 5412(D)(9) OF THE VERMONT UNIFORM SECURITIES ACT (VUSA) AND WILL COMPLY WITH ALL APPLICABLE PROVISIONS OF THE VUSA. WITHIN TEN (10) BUSINESS DAYS OF THE DATE OF THIS ORDER, RJA SHALL PAY TO THE DEPARTMENT OF FINANCIAL REGULATION (DFR) THE SUM OF $1,450,0000, OF WHICH $1,250,000 REPRESENTS AN ADMINISTRATIVE PENALTY AND $200,000 SHALL REIMBURSE THE OFR FOR ITS COSTS. THE COMMISSIONER DIRECTS THAT WITHIN TEN (10) BUSINESS DAYS OF THE DATE OF THIS ORDER RJA PAY $4,500,000 TO THE RECEIVER APPOINTED IN THE MATTER ENTITLED SEC V. QUIROS, NO.1:16-CV-21301-DPG (S.D. FLA.) FOR THE SOLE PURPOSE OF REIMBURSING CLAIMS BY THE EB-5 INVESTORS. THE SUM OF $2,750,000 REPRESENTS THE TOTAL REVENUES EARNED BY RJA AND THE REGISTERED REPRESENTATIVE IN CONNECTION WITH THE QUIROS-CONTROLLED ACCOUNTS, AND THE BALANCE REPRESENTS RESTITUTION. THE FINES WERE PAID ON JULY 7, 2016. 13. Provide a brief summary of 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 20PDF pages 97–99
- Regulator name — filed text
- UNITED STATES SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 600,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THE FIRM HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THE FIRM CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING A CEASE-AND-DESIST ORDER. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, THE FIRM VIOLATED SECTION 206(4) OF THE ADVISERS ACT, AND RULE 206(4)-7 THEREUNDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE TO IMPOSE THE SANCTIONS AGREED TO IN THE FIRM'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THAT PURSUANT TO SECTION 203(K) OF THE ADVISERS ACT, THE FIRM SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, SHALL WITHIN TEN DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $600,000, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER.
Other filed details
Description of allegations — filed text
THIS MATTER ARISES FROM RAYMOND JAMES & ASSOCIATES, INC.'S ("RJA") FAILURE TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES RELATING TO TRADING COMMISSIONS CHARGED TO CLIENTS PARTICIPATING IN THE RAYMOND JAMES CONSULTING SERVICES ("RJCS") SEPARATELY MANAGED ACCOUNT PROGRAM. UNDER THE RJCS PROGRAM, CLIENTS SELECT AN AVAILABLE INVESTMENT MANAGER TO DEVELOP A MODEL PORTFOLIO IN THE CLIENT'S SEPARATELY MANAGED ACCOUNT. RJA CHARGES THE RJCS PROGRAM CLIENTS A NEGOTIABLE "WRAP FEE." IN ADDITION TO THE WRAP FEE, RJA CLIENTS ALSO WERE ASSESSED COMMISSIONS ON CERTAIN EQUITY TRANSACTIONS EXECUTED BY BROKER-DEALERS UNAFFILIATED WITH RJA. ALTHOUGH RJA'S FORM ADV PART 2A BROCHURES DISCLOSE THAT AN INVESTMENT MANAGER MAY DIRECT ITS TRADING TO FIRMS UNAFFILIATED WITH RJA AND THAT ANY COMMISSIONS ASSESSED BY THESE OTHER FIRMS WILL BE IN ADDITION TO THE WRAP FEE CHARGED BY RJA, RJA DID NOT OBTAIN INFORMATION REGARDING THE AMOUNT OF COMMISSIONS CHARGED FOR THESE TRANSACTIONS OR WHETHER THAT AMOUNT WAS MATERIAL. INSTEAD, RJA RECEIVED INFORMATION REGARDING THESE SECURITIES TRANSACTIONS ON A NET BASIS WITH ANY EQUITY COMMISSION COST INCLUDED IN THE PRICE OF THE SECURITY. RJCS PROGRAM CLIENTS ALSO WERE UNAWARE OF THE ACTUAL COMMISSIONS INCURRED FOR TRADING AWAY BECAUSE THEIR ACCOUNT STATEMENTS DISCLOSED ONLY NET PRICES CHARGED PER EQUITY TRADE AND THEY DID NOT RECEIVE INFORMATION ABOUT COMMISSIONS FROM ANY OTHER SOURCE. AS A RESULT, RJA FAILED TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO ALLOW IT TO DETERMINE WHETHER THE RJCS PROGRAM OR PARTICULAR INVESTMENT MANAGERS WERE SUITABLE FOR ITS PROSPECTIVE AND EXISTING RJCS CLIENTS, SUCH AS COLLECTING, TRACKING AND DISCLOSING INFORMATION REGARDING COMMISSIONS ASSOCIATED WITH TRADING AWAY. IN ADDITION, THE FIRM HAD NO POLICIES AND PROCEDURES TO COMMUNICATE TO RJCS PROGRAM CLIENTS THE INVESTMENT MANAGERS' TRADING AWAY PRACTICES AND ASSOCIATED COSTS, AND THEREFORE THOSE CLIENTS DID NOT NECESSARILY HAVE ADEQUATE INFORMATION: (I) TO NEGOTIATE MEANINGFULLY THE WRAP FEE WITH RJA; (II) TO ASSESS THE TOTAL COSTS OF THE RJCS PROGRAM; AND (III) TO DETERMINE WHICH RJCS PROGRAM INVESTMENT MANAGERS TO SELECT. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, THE FIRM VIOLATED SECTION 206(4) OF THE ADVISERS ACT, AND RULE 206(4)-7 THEREUNDER.
Sanction detail — filed text
THE FIRM WAS CENSURED, FINED $600,000 AND ORDERED TO COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER. THE FINE WAS PAID ON 10/12/16.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
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:
N/A
3.
Date Initiated (MM/DD/YYYY):
09/08/2016
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-17531
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
UNSPECIFIED SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THIS MATTER ARISES FROM RAYMOND JAMES & ASSOCIATES, INC.'S ("RJA") FAILURE TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES RELATING
TO TRADING COMMISSIONS CHARGED TO CLIENTS PARTICIPATING IN THE RAYMOND JAMES CONSULTING SERVICES ("RJCS") SEPARATELY MANAGED
ACCOUNT PROGRAM. UNDER THE RJCS PROGRAM, CLIENTS SELECT AN AVAILABLE INVESTMENT MANAGER TO DEVELOP A MODEL PORTFOLIO IN THE
CLIENT'S SEPARATELY MANAGED ACCOUNT. RJA CHARGES THE RJCS PROGRAM CLIENTS A NEGOTIABLE "WRAP FEE." IN ADDITION TO THE WRAP FEE,
RJA CLIENTS ALSO WERE ASSESSED COMMISSIONS ON CERTAIN EQUITY TRANSACTIONS EXECUTED BY BROKER-DEALERS UNAFFILIATED WITH RJA.
ALTHOUGH RJA'S FORM ADV PART 2A BROCHURES DISCLOSE THAT AN INVESTMENT MANAGER MAY DIRECT ITS TRADING TO FIRMS UNAFFILIATED WITH
RJA AND THAT ANY COMMISSIONS ASSESSED BY THESE OTHER FIRMS WILL BE IN ADDITION TO THE WRAP FEE CHARGED BY RJA, RJA DID NOT OBTAIN
INFORMATION REGARDING THE AMOUNT OF COMMISSIONS CHARGED FOR THESE TRANSACTIONS OR WHETHER THAT AMOUNT WAS MATERIAL.
INSTEAD, RJA RECEIVED INFORMATION REGARDING THESE SECURITIES TRANSACTIONS ON A NET BASIS WITH ANY EQUITY COMMISSION COST
INCLUDED IN THE PRICE OF THE SECURITY. RJCS PROGRAM CLIENTS ALSO WERE UNAWARE OF THE ACTUAL COMMISSIONS INCURRED FOR TRADING
AWAY BECAUSE THEIR ACCOUNT STATEMENTS DISCLOSED ONLY NET PRICES CHARGED PER EQUITY TRADE AND THEY DID NOT RECEIVE INFORMATION
ABOUT COMMISSIONS FROM ANY OTHER SOURCE. AS A RESULT, RJA FAILED TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY
DESIGNED TO ALLOW IT TO DETERMINE WHETHER THE RJCS PROGRAM OR PARTICULAR INVESTMENT MANAGERS WERE SUITABLE FOR ITS
PROSPECTIVE AND EXISTING RJCS CLIENTS, SUCH AS COLLECTING, TRACKING AND DISCLOSING INFORMATION REGARDING COMMISSIONS
ASSOCIATED WITH TRADING AWAY. IN ADDITION, THE FIRM HAD NO POLICIES AND PROCEDURES TO COMMUNICATE TO RJCS PROGRAM CLIENTS THE
INVESTMENT MANAGERS' TRADING AWAY PRACTICES AND ASSOCIATED COSTS, AND THEREFORE THOSE CLIENTS DID NOT NECESSARILY HAVE
ADEQUATE INFORMATION: (I) TO NEGOTIATE MEANINGFULLY THE WRAP FEE WITH RJA; (II) TO ASSESS THE TOTAL COSTS OF THE RJCS PROGRAM; AND
(III) TO DETERMINE WHICH RJCS PROGRAM INVESTMENT MANAGERS TO SELECT. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, THE FIRM
VIOLATED SECTION 206(4) OF THE ADVISERS ACT, AND RULE 206(4)-7 THEREUNDER.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
09/08/2016
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 600,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
THE FIRM WAS CENSURED, FINED $600,000 AND ORDERED TO COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER. THE FINE WAS
PAID ON 10/12/16.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THE FIRM HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS
DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE
COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THE
COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THE FIRM CONSENTS TO THE
ENTRY OF THIS ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940,
MAKING FINDINGS, AND IMPOSING A CEASE-AND-DESIST ORDER. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, THE FIRM VIOLATED SECTION
206(4) OF THE ADVISERS ACT, AND RULE 206(4)-7 THEREUNDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE TO IMPOSE
THE SANCTIONS AGREED TO IN THE FIRM'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THAT PURSUANT TO SECTION 203(K) OF THE ADVISERS ACT,
THE FIRM SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THE
ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, SHALL WITHIN TEN DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE
AMOUNT OF $600,000, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER.regulatory · block 21PDF pages 99–101
- 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
ON MARCH 9, 2017, THE OFFICE OF FINANCIAL REGULATION ENTERED A FINAL ORDER AGAINST RAYMOND JAMES & ASSOCIATES, INC., ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THE MATTER OF RAYMOND JAMES & ASSOCIATES, INC. RAYMOND JAMES & ASSOCIATES, INC., ACCEPTS AND CONSENTS, WITHOUT ADMITTING OR DENYING THE FINDINGS BY THE OFFICE. THE FINDINGS BY THE OFFICE OF FINANCIAL REGULATION INCLUDE A FAILURE TO EXAMINE A NON-REGISTERED RESIDENCE LOCATION ("NRL"), CREATE AND MAINTAIN WSPS FOR SUCH NRL, AND MAINTAIN WRITTEN REPORTS OF ITS INSPECTION AND REVIEW OF ITS NRLS.
Other filed details
Description of allegations — filed text
N/A
Sanction detail — filed text
03/09/2017 - $10,000 ADMINISTRATIVE FINE PAID IN FULL.
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:
3.
Date Initiated (MM/DD/YYYY):
03/09/2017
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
65556-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):
N/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:
Order
11. Resolution Date (MM/DD/YYYY):
03/09/2017
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 10,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
N/A
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
03/09/2017 - $10,000 ADMINISTRATIVE FINE PAID IN FULL.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON MARCH 9, 2017, THE OFFICE OF FINANCIAL REGULATION ENTERED A FINAL ORDER AGAINST RAYMOND JAMES & ASSOCIATES, INC., ADOPTING THE
STIPULATION AND CONSENT AGREEMENT IN THE MATTER OF RAYMOND JAMES & ASSOCIATES, INC. RAYMOND JAMES & ASSOCIATES, INC., ACCEPTS
AND CONSENTS, WITHOUT ADMITTING OR DENYING THE FINDINGS BY THE OFFICE. THE FINDINGS BY THE OFFICE OF FINANCIAL REGULATION INCLUDE
A FAILURE TO EXAMINE A NON-REGISTERED RESIDENCE LOCATION ("NRL"), CREATE AND MAINTAIN WSPS FOR SUCH NRL, AND MAINTAIN WRITTEN
REPORTS OF ITS INSPECTION AND REVIEW OF ITS NRLS.regulatory · block 22PDF pages 101–103
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 180,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT LACKED A REASONABLE SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES (WSPS), BY NOT, AMONG OTHER THINGS, INCLUDING ONGOING REVIEWS OF DAILY TRADE BLOTTERS OF ITS CONVERTIBLE BONDS DESK FOR SPECIFIC TRADING PATTERNS. THE FINDINGS STATED THAT THE FIRM'S CONVERTIBLE BONDS DESK, IN 99 INSTANCES, SOLD BONDS TO ANOTHER BROKER-DEALER IN A PRINCIPAL CAPACITY AND CONCURRENTLY (WITHIN A FEW MINUTES OR LESS) EITHER PURCHASED THE SAME AMOUNT OF BONDS FROM THE BROKER-DEALER IN AN AGENCY CAPACITY FOR A FIRM ADVISORY CLIENT OR CLIENTS, OR PURCHASED THE SAME AMOUNT OF BONDS FROM THE BROKER-DEALER IN A PRINCIPAL CAPACITY FOR AN ADVISORY CLIENT OR ADVISORY CLIENTS OF THE FIRM'S AFFILIATE. SINCE THE FIRM'S CONVERTIBLE BONDS WERE OFFERED ON A CONDITIONAL BASIS, ITS CONVERTIBLE BONDS DESK NEEDED TO MANUALLY ACCEPT ANY ATTEMPT BY A THIRD PARTY TO LIFT ITS OFFER OFF THE ALTERNATIVE TRADING SYSTEM USED. ACCORDINGLY, THE CONVERTIBLE BONDS DESK KNEW THAT THERE WAS AN ATTEMPT TO LIFT THE FIRM'S INVENTORY FOR THE EXACT SAME QUANTITY OF THE SAME CONVERTIBLE BOND THAT THE FIRM WAS CONCURRENTLY LOOKING TO BUY SUCH BONDS FOR AN ADVISORY CLIENT. WHILE THE FIRM'S WSPS PERTAINING TO MANAGED ACCOUNTS GENERALLY PROHIBITED PRINCIPAL TRADES WITH ADVISORY CLIENTS (ABSENT AN EXCEPTION) AND ESTABLISHED TRADING SYSTEM FUNCTIONALITY LIMITATIONS TO PRECLUDE PRINCIPAL FILLS DIRECTLY FOR ADVISORY CLIENTS, THE FIRM'S SUPERVISORY OVERSIGHT OVER ITS CONVERTIBLE BONDS TRADING DID NOT INCLUDE, AMONG OTHER THINGS, ONGOING REVIEWS OF DAILY TRADE BLOTTERS THAT MIGHT DETECT POTENTIALLY VIOLATIVE CONDUCT SUCH AS THE SPECIFIC TRADING PATTERN AT ISSUE.
Sanction detail — filed text
THE FIRM WAS CENSURED, FINED $180,000 AND UNDERTAKES TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES AND ADDRESS TRAINING OF ASSOCIATED PERSONS. THE FINE WAS PAID ON MARCH 24, 2017.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FINRA 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 03/02/2017 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2011030345701 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT LACKED A REASONABLE SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES (WSPS), BY NOT, AMONG OTHER THINGS, INCLUDING ONGOING REVIEWS OF DAILY TRADE BLOTTERS OF ITS CONVERTIBLE BONDS DESK FOR SPECIFIC TRADING PATTERNS. THE FINDINGS STATED THAT THE FIRM'S CONVERTIBLE BONDS DESK, IN 99 INSTANCES, SOLD BONDS TO ANOTHER BROKER-DEALER IN A PRINCIPAL CAPACITY AND CONCURRENTLY (WITHIN A FEW MINUTES OR LESS) EITHER PURCHASED THE SAME AMOUNT OF BONDS FROM THE BROKER-DEALER IN AN AGENCY CAPACITY FOR A FIRM ADVISORY CLIENT OR CLIENTS, OR PURCHASED THE SAME AMOUNT OF BONDS FROM THE BROKER-DEALER IN A PRINCIPAL CAPACITY FOR AN ADVISORY CLIENT OR ADVISORY CLIENTS OF THE FIRM'S AFFILIATE. SINCE THE FIRM'S CONVERTIBLE BONDS WERE OFFERED ON A CONDITIONAL BASIS, ITS CONVERTIBLE BONDS DESK NEEDED TO MANUALLY ACCEPT ANY ATTEMPT BY A THIRD PARTY TO LIFT ITS OFFER OFF THE ALTERNATIVE TRADING SYSTEM USED. ACCORDINGLY, THE CONVERTIBLE BONDS DESK KNEW THAT THERE WAS AN ATTEMPT TO LIFT THE FIRM'S INVENTORY FOR THE EXACT SAME QUANTITY OF THE SAME CONVERTIBLE BOND THAT THE FIRM WAS CONCURRENTLY LOOKING TO BUY SUCH BONDS FOR AN ADVISORY CLIENT. WHILE THE FIRM'S WSPS PERTAINING TO MANAGED ACCOUNTS GENERALLY PROHIBITED PRINCIPAL TRADES WITH ADVISORY CLIENTS (ABSENT AN EXCEPTION) AND ESTABLISHED TRADING SYSTEM FUNCTIONALITY LIMITATIONS TO PRECLUDE PRINCIPAL FILLS DIRECTLY FOR ADVISORY CLIENTS, THE FIRM'S SUPERVISORY OVERSIGHT OVER ITS CONVERTIBLE BONDS TRADING DID NOT INCLUDE, AMONG OTHER THINGS, ONGOING REVIEWS OF DAILY TRADE BLOTTERS THAT MIGHT DETECT POTENTIALLY VIOLATIVE CONDUCT SUCH AS THE SPECIFIC TRADING PATTERN AT ISSUE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 03/02/2017 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 180,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKING: REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES AND ADDRESS TRAINING OF ASSOCIATED PERSONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement 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 $180,000 AND UNDERTAKES TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES AND ADDRESS TRAINING OF ASSOCIATED PERSONS. THE FINE WAS PAID ON MARCH 24, 2017. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 23PDF pages 103–105
- Regulator name — filed text
- NASDAQ ISE, LLC
- Monetary/Fine Amount — filed text
- $ 20,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
ASSOCIATED MATTER INCLUDES ISE FILE NOS. 2015-265, 2016-036, AND 2016-247.
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 HAD IMPROPERLY USED THE INTERNATIONAL SECURITIES EXCHANGE'S (ISE) SOLICITED ORDER MECHANISM (SOM) AND FAILED TO ADEQUATELY SUPERVISE IN CONNECTION WITH ITS USE. THE FINDINGS STATED THAT SPECIFICALLY, THE FIRM IMPROPERLY USED THE SOM TO CROSS ORDERS THAT DID NOT INVOLVE SOLICITED CONTRA ORDERS ON 23 OCCASIONS DURING THE REVIEW PERIOD. THE FIRM FAILED TO HAVE ANY SUPERVISORY SYSTEMS AND CONTROLS IN PLACE, INCLUDING WRITTEN SUPERVISORY PROCEDURES AND SEPARATE SYSTEMS OF FOLLOW-UP AND REVIEW, WHICH WERE DESIGNED TO ENSURE COMPLIANCE WITH ISE RULES RELATED TO THE PROPER USE OF THE SOM.
Sanction detail — filed text
THE FIRM WAS CENSURED AND FINED $20,000.00.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) NASDAQ ISE, LLC 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 03/17/2017 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2016048918401 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): WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT HAD IMPROPERLY USED THE INTERNATIONAL SECURITIES EXCHANGE'S (ISE) SOLICITED ORDER MECHANISM (SOM) AND FAILED TO ADEQUATELY SUPERVISE IN CONNECTION WITH ITS USE. THE FINDINGS STATED THAT SPECIFICALLY, THE FIRM IMPROPERLY USED THE SOM TO CROSS ORDERS THAT DID NOT INVOLVE SOLICITED CONTRA ORDERS ON 23 OCCASIONS DURING THE REVIEW PERIOD. THE FIRM FAILED TO HAVE ANY SUPERVISORY SYSTEMS AND CONTROLS IN PLACE, INCLUDING WRITTEN SUPERVISORY PROCEDURES AND SEPARATE SYSTEMS OF FOLLOW-UP AND REVIEW, WHICH WERE DESIGNED TO ENSURE COMPLIANCE WITH ISE RULES RELATED TO THE PROPER USE OF THE SOM. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 07/17/2017 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 20,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS CENSURED AND FINED $20,000.00. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). ASSOCIATED MATTER INCLUDES ISE FILE NOS. 2015-265, 2016-036, AND 2016-247.
regulatory · block 24PDF pages 105–107
- Regulator name — filed text
- NYSE AMERICAN LLC
- Monetary/Fine Amount — filed text
- $ 200,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
IN DETERMINING TO RESOLVE THIS MATTER IN THE MANNER SET FORTH HEREIN, AND IN DETERMINING THE APPROPRIATE MONETARY SANCTION, THE EXCHANGE CONSIDERED THE FOLLOWING: (I) THE FIRM'S PROVISION OF EXTRAORDINARY COOPERATION WITH THIS INVESTIGATION BY RETAINING OUTSIDE COUNSEL AND AN OUTSIDE AUDITING FIRM TO CONDUCT AN EXTENSIVE REVIEW OF THE FIRM'S OPTIONS REPORTING SYSTEMS,PRACTICES, AND PROCEDURES, AND TO REPORT THESE FINDINGS TO FINRA; AND (II) THE EFFORTS AND ENHANCEMENTS MADE TO THE FIRM'S LOPR REPORTING SYSTEMS, AND SUPERVISORY PRACTICES AND PROCEDURES. CASE # 20140409820 (INCL. MERGED CASE NO. 20150455242)
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 REPORT POSITIONS TO THE LARGE OPTIONS POSITIONS REPORT (LOPR)SYSTEM IN APPROXIMATELY 627,430 INSTANCES, AND INACCURATELY REPORTED POSITIONS TO THE LOPR IN APPROXIMATELY 565,223 INSTANCES. THE FINDINGS STATED THAT THE FIRM'S LOPR REPORTING VIOLATIONS PRIMARILY RESULTED FROM: ITS ENTRY OF AN INCORRECT EFFECTIVE DATE WHEN SUBMITTING CERTAIN POSITIONS TO THE LOPR; AND ITS FAILURE TO PROPERLY AGGREGATE CERTAIN OF ITS REPORTABLE OPTIONS POSITIONS AS ACTING IN-CONCERT. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO HAVE A REASONABLE SUPERVISORY SYSTEM WITH RESPECT TO THE REPORTING OF OPTIONS POSITIONS, INCLUDING A REVIEW FOR ACCURACY OF LOPR SUBMISSIONS WITH RESPECT TO EFFECTIVE DATES AND ACCOUNTS ACTING IN-CONCERT. ADDITIONALLY, UNTIL NOVEMBER 2015, THE FIRM ALSO LACKED ANY WRITTEN SUPERVISORY PROCEDURES (WSPS) WITH RESPECT TO THE PROPER REPORTING OF OPTIONS POSITIONS, INCLUDING SYSTEMS OF FOLLOW-UP AND REVIEW, AND THEREAFTER, FAILED TO HAVE ADEQUATE WSPS UNTIL JANUARY 2017. REASONABLE WSPS SHOULD, AT A MINIMUM, SPECIFY: (I) THE IDENTIFICATION OF THE INDIVIDUAL(S) RESPONSIBLE FOR SUPERVISION; (II) THE SUPERVISORY STEPS AND REVIEWS TO BE TAKEN BY THE APPROPRIATE SUPERVISOR; (III) THE FREQUENCY OF SUCH REVIEWS; AND (IV) HOW SUCH REVIEWS SHALL BE DOCUMENTED.
Sanction detail — filed text
THE FIRM WAS CENSURED, FINED A TOTAL OF $400,000, OF WHICH $200,000 SHALL BE PAID TO THE EXCHANGE. THE FIRM WAS REQUIRED TO SUBMIT A WRITTEN REPORT WHICH CONFIRMS THAT IT HAS COMPLETED REMEDIATION OF ALL THE LOPR ISSUES IDENTIFIED IN THE AWC WITHIN 120 DAYS OF THE DATE OF NOTICE OF ACCEPTANCE OF THIS AWC. THE BALANCE OF THE FIRM'S FINE WILL BE PAID TO NYSE ARCA, INC., PURSUANT TO A SEPARATE SETTLEMENT AGREEMENT. THIS AWC BECAME FINAL ON JUNE 9, 2018.
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) NYSE AMERICAN LLC 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 04/27/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2014040982001 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 THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT POSITIONS TO THE LARGE OPTIONS POSITIONS REPORT (LOPR)SYSTEM IN APPROXIMATELY 627,430 INSTANCES, AND INACCURATELY REPORTED POSITIONS TO THE LOPR IN APPROXIMATELY 565,223 INSTANCES. THE FINDINGS STATED THAT THE FIRM'S LOPR REPORTING VIOLATIONS PRIMARILY RESULTED FROM: ITS ENTRY OF AN INCORRECT EFFECTIVE DATE WHEN SUBMITTING CERTAIN POSITIONS TO THE LOPR; AND ITS FAILURE TO PROPERLY AGGREGATE CERTAIN OF ITS REPORTABLE OPTIONS POSITIONS AS ACTING IN-CONCERT. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO HAVE A REASONABLE SUPERVISORY SYSTEM WITH RESPECT TO THE REPORTING OF OPTIONS POSITIONS, INCLUDING A REVIEW FOR ACCURACY OF LOPR SUBMISSIONS WITH RESPECT TO EFFECTIVE DATES AND ACCOUNTS ACTING IN-CONCERT. ADDITIONALLY, UNTIL NOVEMBER 2015, THE FIRM ALSO LACKED ANY WRITTEN SUPERVISORY PROCEDURES (WSPS) WITH RESPECT TO THE PROPER REPORTING OF OPTIONS POSITIONS, INCLUDING SYSTEMS OF FOLLOW-UP AND REVIEW, AND THEREAFTER, FAILED TO HAVE ADEQUATE WSPS UNTIL JANUARY 2017. REASONABLE WSPS SHOULD, AT A MINIMUM, SPECIFY: (I) THE IDENTIFICATION OF THE INDIVIDUAL(S) RESPONSIBLE FOR SUPERVISION; (II) THE SUPERVISORY STEPS AND REVIEWS TO BE TAKEN BY THE APPROPRIATE SUPERVISOR; (III) THE FREQUENCY OF SUCH REVIEWS; AND (IV) HOW SUCH REVIEWS SHALL BE DOCUMENTED. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 06/09/2018 Exact 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: UNDERTAKING Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS CENSURED, FINED A TOTAL OF $400,000, OF WHICH $200,000 SHALL BE PAID TO THE EXCHANGE. THE FIRM WAS REQUIRED TO SUBMIT A WRITTEN REPORT WHICH CONFIRMS THAT IT HAS COMPLETED REMEDIATION OF ALL THE LOPR ISSUES IDENTIFIED IN THE AWC WITHIN 120 DAYS OF THE DATE OF NOTICE OF ACCEPTANCE OF THIS AWC. THE BALANCE OF THE FIRM'S FINE WILL BE PAID TO NYSE ARCA, INC., PURSUANT TO A SEPARATE SETTLEMENT AGREEMENT. THIS AWC BECAME FINAL ON JUNE 9, 2018. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). IN DETERMINING TO RESOLVE THIS MATTER IN THE MANNER SET FORTH HEREIN, AND IN DETERMINING THE APPROPRIATE MONETARY SANCTION, THE EXCHANGE CONSIDERED THE FOLLOWING: (I) THE FIRM'S PROVISION OF EXTRAORDINARY COOPERATION WITH THIS INVESTIGATION BY RETAINING OUTSIDE COUNSEL AND AN OUTSIDE AUDITING FIRM TO CONDUCT AN EXTENSIVE REVIEW OF THE FIRM'S OPTIONS REPORTING SYSTEMS,PRACTICES, AND PROCEDURES, AND TO REPORT THESE FINDINGS TO FINRA; AND (II) THE EFFORTS AND ENHANCEMENTS MADE TO THE FIRM'S LOPR REPORTING SYSTEMS, AND SUPERVISORY PRACTICES AND PROCEDURES. CASE # 20140409820 (INCL. MERGED CASE NO. 20150455242)
regulatory · block 25PDF pages 107–109
- Regulator name — filed text
- NYSE ARCA, INC.
- Monetary/Fine Amount — filed text
- $ 200,000.00
- How was matter resolved — filed text
- Decision & Order of Offer of Settlement
Action status / disposition — filed text
IN DETERMINING TO RESOLVE THIS MATTER IN THE MANNER SET FORTH HEREIN, AND IN DETERMINING THE APPROPRIATE MONETARY SANCTION, NYSE ARCA CONSIDERED THE FOLLOWING: (I) THE FIRM'S PROVISION OF EXTRAORDINARY COOPERATION WITH THIS INVESTIGATION BY RETAINING OUTSIDE COUNSEL AND AN OUTSIDE AUDITING FIRM TO CONDUCT AN EXTENSIVE REVIEW OF THE FIRM'S OPTIONS REPORTING SYSTEMS, PRACTICES, AND PROCEDURES, AND TO REPORT THESE FINDINGS TO FINRA; AND (II) THE EFFORTS AND ENHANCEMENTS MADE TO THE FIRM'S LOPR REPORTING SYSTEMS, AND SUPERVISORY PRACTICES AND PROCEDURES.
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT POSITIONS TO THE LARGE OPTIONS POSITION REPORT (LOPR) IN APPROXIMATELY 627,430 INSTANCES, AND INACCURATELY REPORTED POSITIONS TO THE LOPR IN APPROXIMATELY 565,223 INSTANCES. THE FINDINGS STATED THAT THE FIRM'S LOPR REPORTING VIOLATIONS PRIMARILY RESULTED FROM ITS ENTRY OF AN INCORRECT EFFECTIVE DATE WHEN SUBMITTING CERTAIN OPTIONS POSITIONS TO THE LOPR AND ITS FAILURE TO PROPERLY AGGREGATE CERTAIN OF ITS REPORTABLE OPTIONS POSITIONS AS ACTING IN-CONCERT. AS A RESULT OF ENTERING AN INCORRECT EFFECTIVE DATE, THE FIRM FAILED TO REPORT POSITIONS IN APPROXIMATELY 8,264 INSTANCES, UNDER-REPORTED POSITIONS IN APPROXIMATELY 37,700 INSTANCES, OVER-REPORTED POSITIONS IN APPROXIMATELY 16,343 INSTANCES, REPORTED POSITIONS IN APPROXIMATELY 3,478 INSTANCES WITH AN INACCURATE QUANTITY, AND REPORTED POSITIONS IN APPROXIMATELY 174,642 INSTANCES WITH AN INACCURATE COVERED QUANTITY. AS A RESULT OF FAILING TO PROPERLY AGGREGATE ACCOUNTS AS ACTING IN-CONCERT, THE FIRM FAILED TO REPORT POSITIONS IN APPROXIMATELY 619,076 INSTANCES, UNDER-REPORTED POSITIONS IN APPROXIMATELY 223,523 INSTANCES, OVER-REPORTED POSITIONS IN APPROXIMATELY 105,215 INSTANCES, AND REPORTED POSITIONS IN APPROXIMATELY 4,322 INSTANCES WITH AN INACCURATE QUANTITY. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO HAVE A REASONABLE SUPERVISORY SYSTEM WITH RESPECT TO THE REPORTING OF OPTIONS POSITIONS, INCLUDING A REVIEW FOR ACCURACY OF LOPR SUBMISSIONS WITH RESPECT TO EFFECTIVE DATES AND ACCOUNTS ACTING IN CONCERT. ADDITIONALLY, UNTIL NOVEMBER 2015, THE FIRM ALSO LACKED ANY WRITTEN SUPERVISORY PROCEDURES (WSPS) WITH RESPECT TO THE PROPER REPORTING OF OPTIONS POSITIONS, INCLUDING SYSTEMS OF FOLLOW-UP AND REVIEW, AND THEREAFTER, FAILED TO HAVE ADEQUATE WSPS UNTIL JANUARY 2017.
Sanction detail — filed text
THE FIRM WAS CENSURED, FINED A TOTAL OF $400,000, OF WHICH $200,000 SHALL BE PAID TO NYSE ARCA, INC. AND THE REMAINING AMOUNT PAID TO NYSE AMERICAN LLC, AND UNDERTAKES TO SUBMIT A WRITTEN REPORT CONFIRMING IT HAS COMPLETED REMEDIATION OF ALL THE LOPR ISSUES IDENTIFIED WITHIN 120 DAYS OF THE DATE OF THE DECISION.
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) NYSE ARCA, INC. 2. Principal Sanction: Censure Other Sanctions: MONETARY FINE & UNDERTAKING 3. Date Initiated (MM/DD/YYYY): 05/08/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 20160501987 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 THE ALLEGATIONS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REPORT POSITIONS TO THE LARGE OPTIONS POSITION REPORT (LOPR) IN APPROXIMATELY 627,430 INSTANCES, AND INACCURATELY REPORTED POSITIONS TO THE LOPR IN APPROXIMATELY 565,223 INSTANCES. THE FINDINGS STATED THAT THE FIRM'S LOPR REPORTING VIOLATIONS PRIMARILY RESULTED FROM ITS ENTRY OF AN INCORRECT EFFECTIVE DATE WHEN SUBMITTING CERTAIN OPTIONS POSITIONS TO THE LOPR AND ITS FAILURE TO PROPERLY AGGREGATE CERTAIN OF ITS REPORTABLE OPTIONS POSITIONS AS ACTING IN-CONCERT. AS A RESULT OF ENTERING AN INCORRECT EFFECTIVE DATE, THE FIRM FAILED TO REPORT POSITIONS IN APPROXIMATELY 8,264 INSTANCES, UNDER-REPORTED POSITIONS IN APPROXIMATELY 37,700 INSTANCES, OVER-REPORTED POSITIONS IN APPROXIMATELY 16,343 INSTANCES, REPORTED POSITIONS IN APPROXIMATELY 3,478 INSTANCES WITH AN INACCURATE QUANTITY, AND REPORTED POSITIONS IN APPROXIMATELY 174,642 INSTANCES WITH AN INACCURATE COVERED QUANTITY. AS A RESULT OF FAILING TO PROPERLY AGGREGATE ACCOUNTS AS ACTING IN-CONCERT, THE FIRM FAILED TO REPORT POSITIONS IN APPROXIMATELY 619,076 INSTANCES, UNDER-REPORTED POSITIONS IN APPROXIMATELY 223,523 INSTANCES, OVER-REPORTED POSITIONS IN APPROXIMATELY 105,215 INSTANCES, AND REPORTED POSITIONS IN APPROXIMATELY 4,322 INSTANCES WITH AN INACCURATE QUANTITY. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO HAVE A REASONABLE SUPERVISORY SYSTEM WITH RESPECT TO THE REPORTING OF OPTIONS POSITIONS, INCLUDING A REVIEW FOR ACCURACY OF LOPR SUBMISSIONS WITH RESPECT TO EFFECTIVE DATES AND ACCOUNTS ACTING IN CONCERT. ADDITIONALLY, UNTIL NOVEMBER 2015, THE FIRM ALSO LACKED ANY WRITTEN SUPERVISORY PROCEDURES (WSPS) WITH RESPECT TO THE PROPER REPORTING OF OPTIONS POSITIONS, INCLUDING SYSTEMS OF FOLLOW-UP AND REVIEW, AND THEREAFTER, FAILED TO HAVE ADEQUATE WSPS UNTIL JANUARY 2017. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 05/08/2018 Exact 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: UNDERTAKING Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS CENSURED, FINED A TOTAL OF $400,000, OF WHICH $200,000 SHALL BE PAID TO NYSE ARCA, INC. AND THE REMAINING AMOUNT PAID TO NYSE AMERICAN LLC, AND UNDERTAKES TO SUBMIT A WRITTEN REPORT CONFIRMING IT HAS COMPLETED REMEDIATION OF ALL THE LOPR ISSUES IDENTIFIED WITHIN 120 DAYS OF THE DATE OF THE DECISION. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). IN DETERMINING TO RESOLVE THIS MATTER IN THE MANNER SET FORTH HEREIN, AND IN DETERMINING THE APPROPRIATE MONETARY SANCTION, NYSE ARCA CONSIDERED THE FOLLOWING: (I) THE FIRM'S PROVISION OF EXTRAORDINARY COOPERATION WITH THIS INVESTIGATION BY RETAINING OUTSIDE COUNSEL AND AN OUTSIDE AUDITING FIRM TO CONDUCT AN EXTENSIVE REVIEW OF THE FIRM'S OPTIONS REPORTING SYSTEMS, PRACTICES, AND PROCEDURES, AND TO REPORT THESE FINDINGS TO FINRA; AND (II) THE EFFORTS AND ENHANCEMENTS MADE TO THE FIRM'S LOPR REPORTING SYSTEMS, AND SUPERVISORY PRACTICES AND PROCEDURES.
regulatory · block 26PDF pages 109–111
- Regulator name — filed text
- NEW YORK STOCK EXCHANGE
- Monetary/Fine Amount — filed text
- $ 400,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
THE ACTION WAS SETTLED PURSUANT TO AN ACCEPTANCE, WAIVER AND CONSENT WITH THE NYSE FINALIZED ON NOVEMBER 16, 2018. PURSUANT TO THE AWC, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND FINE IN THE AMOUNT OF $400,000.
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 IN VIOLATION OF SEC RULE 15C3-5 AND NYSE RULE 3110(B)(1), THE FIRM FAILED TO ESTABLISH, DOCUMENT, AND MAINTAIN A SYSTEM OF RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES REASONABLY DESIGNED TO MANAGE THE FINANCIAL AND REGULATORY RISKS OF ITS BUSINESS ACTIVITY. THE FINDINGS STATED THAT THIS MATTER CONCERNS THE ESTABLISHMENT AND IMPLEMENTATION OF CREDIT LIMITS FOR THE ORDERS OF INSTITUTIONAL COUNTERPARTIES THAT WERE EFFECTED ON AN AGENCY BASIS (THE "CUSTOMER ORDERS"). THE FIRM DID NOT PROVIDE THESE CUSTOMERS DIRECT MARKET ACCESS, AND FIRM TRADERS MANUALLY ENTERED THE CUSTOMER ORDERS INTO THE NYSE SUPERDOT. THE FIRM DID NOT ALLOW CUSTOMERS TO ENTER ORDERS INTO NYSE SUPERDOT. THE FIRM FAILED TO SATISFY THE MARKET ACCESS RULE CREDIT THRESHOLD REQUIREMENTS WITH RESPECT TO THE CUSTOMER ORDERS BY ADOPTING AN UNREASONABLE METHODOLOGY FOR DETERMINING CUSTOMER CREDIT THRESHOLDS AND FAILING TO REASONABLY IMPLEMENT ITS CUSTOMER CREDIT THRESHOLDS. THE FIRM'S IMPLEMENTATION OF ITS PRE-TRADE CREDIT THRESHOLDS WAS ALSO UNREASONABLE. THE FIRM FAILED TO UNDERTAKE THE ANALYSIS NECESSARY FOR IT TO DETERMINE AN APPROPRIATE RISK RATING AND CORRESPONDING CREDIT LIMIT FOR CERTAIN FIRM CUSTOMERS. THE FIRM FAILED TO IMPLEMENT AN AUTOMATED PRE-TRADE BLOCK FOR CUSTOMERS NOTWITHSTANDING THAT THE FIRM HAD ASSIGNED SUCH CUSTOMERS A RISK RATING AND CREDIT LIMIT. THE FIRM ALSO FAILED ON CERTAIN INSTANCES TO CORRECTLY ENTER AUTOMATED PRE-TRADE CREDIT THRESHOLDS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO SATISFY BROKER-DEALERS REQUIREMENTS BY FAILING TO IMPLEMENT CERTAIN HARD LIMIT ERRONEOUS ORDER CONTROLS BASED ON THE INDIVIDUAL TRADING CHARACTERISTICS OF THE RELEVANT SECURITY, SHARE QUANTITY, OR A REASONABLE NOTIONAL QUANTITY, AND FAILING TO REASONABLY SUPERVISE THE OVERRIDING OF SOFT LIMIT ERRONEOUS ORDER CONTROLS. THE FIRM USED CERTAIN SOFT LIMITS. HOWEVER, THE FIRM FAILED TO TRAIN OR SUPERVISE ITS TRADERS WITH RESPECT TO THE OVERRIDING OF SUCH LIMITS, AND FAILED TO MAINTAIN ANY RECORDS OF WHEN FIRM TRADERS BYPASSED SUCH SOFT BLOCKS. THUS, THE FIRM FAILED TO ESTABLISH, DOCUMENT, AND MAINTAIN RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO REGULARLY REVIEW THE EFFECTIVENESS OF ITS RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES. THE FIRM CONSIDERED ONLY WHETHER ITS CONTROLS WERE FUNCTIONING, NOT WHETHER THEY WERE APPROPRIATE OR EFFECTIVE GIVEN THE FIRM'S BUSINESS. IN ADDITION, THE FIRM'S MARKET ACCESS RULE REVIEWS FAILED TO INCLUDE AN ANALYSIS OF CUSTOMER CREDIT LIMITS OR AUTOMATED PRE-TRADE BLOCKS.
Sanction detail — filed text
THE FIRM WAS CENSURED AND FINED $400,000.00 PAID NOVEMBER 30, 2018.
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 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 11/16/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2016-07-01067 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): WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN VIOLATION OF SEC RULE 15C3-5 AND NYSE RULE 3110(B)(1), THE FIRM FAILED TO ESTABLISH, DOCUMENT, AND MAINTAIN A SYSTEM OF RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES REASONABLY DESIGNED TO MANAGE THE FINANCIAL AND REGULATORY RISKS OF ITS BUSINESS ACTIVITY. THE FINDINGS STATED THAT THIS MATTER CONCERNS THE ESTABLISHMENT AND IMPLEMENTATION OF CREDIT LIMITS FOR THE ORDERS OF INSTITUTIONAL COUNTERPARTIES THAT WERE EFFECTED ON AN AGENCY BASIS (THE "CUSTOMER ORDERS"). THE FIRM DID NOT PROVIDE THESE CUSTOMERS DIRECT MARKET ACCESS, AND FIRM TRADERS MANUALLY ENTERED THE CUSTOMER ORDERS INTO THE NYSE SUPERDOT. THE FIRM DID NOT ALLOW CUSTOMERS TO ENTER ORDERS INTO NYSE SUPERDOT. THE FIRM FAILED TO SATISFY THE MARKET ACCESS RULE CREDIT THRESHOLD REQUIREMENTS WITH RESPECT TO THE CUSTOMER ORDERS BY ADOPTING AN UNREASONABLE METHODOLOGY FOR DETERMINING CUSTOMER CREDIT THRESHOLDS AND FAILING TO REASONABLY IMPLEMENT ITS CUSTOMER CREDIT THRESHOLDS. THE FIRM'S IMPLEMENTATION OF ITS PRE-TRADE CREDIT THRESHOLDS WAS ALSO UNREASONABLE. THE FIRM FAILED TO UNDERTAKE THE ANALYSIS NECESSARY FOR IT TO DETERMINE AN APPROPRIATE RISK RATING AND CORRESPONDING CREDIT LIMIT FOR CERTAIN FIRM CUSTOMERS. THE FIRM FAILED TO IMPLEMENT AN AUTOMATED PRE-TRADE BLOCK FOR CUSTOMERS NOTWITHSTANDING THAT THE FIRM HAD ASSIGNED SUCH CUSTOMERS A RISK RATING AND CREDIT LIMIT. THE FIRM ALSO FAILED ON CERTAIN INSTANCES TO CORRECTLY ENTER AUTOMATED PRE-TRADE CREDIT THRESHOLDS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO SATISFY BROKER-DEALERS REQUIREMENTS BY FAILING TO IMPLEMENT CERTAIN HARD LIMIT ERRONEOUS ORDER CONTROLS BASED ON THE INDIVIDUAL TRADING CHARACTERISTICS OF THE RELEVANT SECURITY, SHARE QUANTITY, OR A REASONABLE NOTIONAL QUANTITY, AND FAILING TO REASONABLY SUPERVISE THE OVERRIDING OF SOFT LIMIT ERRONEOUS ORDER CONTROLS. THE FIRM USED CERTAIN SOFT LIMITS. HOWEVER, THE FIRM FAILED TO TRAIN OR SUPERVISE ITS TRADERS WITH RESPECT TO THE OVERRIDING OF SUCH LIMITS, AND FAILED TO MAINTAIN ANY RECORDS OF WHEN FIRM TRADERS BYPASSED SUCH SOFT BLOCKS. THUS, THE FIRM FAILED TO ESTABLISH, DOCUMENT, AND MAINTAIN RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO REGULARLY REVIEW THE EFFECTIVENESS OF ITS RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES. THE FIRM CONSIDERED ONLY WHETHER ITS CONTROLS WERE FUNCTIONING, NOT WHETHER THEY WERE APPROPRIATE OR EFFECTIVE GIVEN THE FIRM'S BUSINESS. IN ADDITION, THE FIRM'S MARKET ACCESS RULE REVIEWS FAILED TO INCLUDE AN ANALYSIS OF CUSTOMER CREDIT LIMITS OR AUTOMATED PRE-TRADE BLOCKS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 11/16/2018 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 400,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS CENSURED AND FINED $400,000.00 PAID NOVEMBER 30, 2018. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). THE ACTION WAS SETTLED PURSUANT TO AN ACCEPTANCE, WAIVER AND CONSENT WITH THE NYSE FINALIZED ON NOVEMBER 16, 2018. PURSUANT TO THE AWC, THE FIRM CONSENTED TO THE IMPOSITION OF A CENSURE AND FINE IN THE AMOUNT OF $400,000.
regulatory · block 27PDF pages 111–112
- Regulator name — filed text
- FLORIDA OFFICE OF FINANCIAL REGULATION
- Monetary/Fine Amount — filed text
- $ 1,000,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
ON OCTOBER 8, 2018, THE OFFICE OF FINANCIAL REGULATION ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THE MATTER OF RAYMOND JAMES & ASSOCIATES, INC. RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE FINDINGS BUT CONSENTED TO THE ENTRY OF FINDINGS BY THE OFFICE. THE OFFICE FOUND THAT RAYMOND JAMES & ASSOCIATES, INC. FAILED TO: MAINTAIN ACCURATE BOOKS AND RECORDS; ESTABLISH AND MAINTAIN A SYSTEM TO SUPERVISE THE ACTIVITIES OF REGISTERED REPRESENTATIVES AND PRINCIPALS THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECURITIES LAWS AND REGULATIONS; ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECURITIES LAWS AND REGULATIONS; HAVE AND CONDUCT INTERNAL INSPECTIONS THAT ARE REASONABLY DESIGNED TO DETECT AND PREVENT VIOLATIONS OF SECURITIES LAWS AND REGULATIONS; AND OBSERVE HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE. IN ADDITION, RAYMOND JAMES & ASSOCIATES, INC. MADE DISCRETIONARY TRANSACTIONS IN CUSTOMERS' ACCOUNTS WITHOUT WRITTEN AUTHORIZATION. PURSUANT TO THE FINAL ORDER, RAYMOND JAMES & ASSOCIATES, INC. AGREED TO CEASE AND DESIST FROM ALL PRESENT AND FUTURE VIOLATIONS OF CHAPTER 517, F. S. AND THE ADMINISTRATIVE RULES THEREUNDER; TO PAY AN ADMINISTRATIVE FINE IN THE AMOUNT OF $1,000,000.00; AND TO FULLY COOPERATE IN ANY ADDITIONAL INVESTIGATIONS OR ADMINISTRATIVE ACTIONS RELATED TO THE EMPLOYEES OF THE RAYMOND JAMES & ASSOCIATES, INC. BRANCH LOCATED IN SUN CITY CENTER, FL THAT ARE RELATED TO THIS PROCEEDING TO TESTIFY AND ASSIST IN ANY FURTHER INVESTIGATION OR ADMINISTRATIVE PROCEEDING UPON THE REASONABLE REQUEST OF THE OFFICE, WITHOUT A SUBPOENA, AND AT RAYMOND JAMES'S EXPENSE OR THE EMPLOYEE'S EXPENSE.
Other filed details
Description of allegations — filed text
N/A
Sanction detail — filed text
$1,000,000.00 ADMINISTRATIVE FINE PAID 10/8/2018
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): 10/08/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 69581-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): N/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: Order 11. Resolution Date (MM/DD/YYYY): 10/08/2018 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 1,000,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: FULL COOPERATION IN ANY ADDITIONAL INVESTIGATIONS OR ADMINISTRATIVE ACTIONS RELATED TO THE EMPLOYEES OF THE RAYMOND JAMES & ASSOCIATES, INC. BRANCH LOCATED IN SUN CITY CENTER, FL THAT ARE RELATED TO THIS PROCEEDING TO TESTIFY AND ASSIST IN ANY FURTHER INVESTIGATION OR ADMINISTRATIVE PROCEEDING UPON THE REASONABLE REQUEST OF THE OFFICE, WITHOUT A SUBPOENA, AND AT RAYMOND JAMES'S EXPENSE OR THE EMPLOYEE'S EXPENSE. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: $1,000,000.00 ADMINISTRATIVE FINE PAID 10/8/2018 13. Provide a brief summary of 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 OCTOBER 8, 2018, THE OFFICE OF FINANCIAL REGULATION ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THE MATTER OF RAYMOND JAMES & ASSOCIATES, INC. RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE FINDINGS BUT CONSENTED TO THE ENTRY OF FINDINGS BY THE OFFICE. THE OFFICE FOUND THAT RAYMOND JAMES & ASSOCIATES, INC. FAILED TO: MAINTAIN ACCURATE BOOKS AND RECORDS; ESTABLISH AND MAINTAIN A SYSTEM TO SUPERVISE THE ACTIVITIES OF REGISTERED REPRESENTATIVES AND PRINCIPALS THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECURITIES LAWS AND REGULATIONS; ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECURITIES LAWS AND REGULATIONS; HAVE AND CONDUCT INTERNAL INSPECTIONS THAT ARE REASONABLY DESIGNED TO DETECT AND PREVENT VIOLATIONS OF SECURITIES LAWS AND REGULATIONS; AND OBSERVE HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE. IN ADDITION, RAYMOND JAMES & ASSOCIATES, INC. MADE DISCRETIONARY TRANSACTIONS IN CUSTOMERS' ACCOUNTS WITHOUT WRITTEN AUTHORIZATION. PURSUANT TO THE FINAL ORDER, RAYMOND JAMES & ASSOCIATES, INC. AGREED TO CEASE AND DESIST FROM ALL PRESENT AND FUTURE VIOLATIONS OF CHAPTER 517, F. S. AND THE ADMINISTRATIVE RULES THEREUNDER; TO PAY AN ADMINISTRATIVE FINE IN THE AMOUNT OF $1,000,000.00; AND TO FULLY COOPERATE IN ANY ADDITIONAL INVESTIGATIONS OR ADMINISTRATIVE ACTIONS RELATED TO THE EMPLOYEES OF THE RAYMOND JAMES & ASSOCIATES, INC. BRANCH LOCATED IN SUN CITY CENTER, FL THAT ARE RELATED TO THIS PROCEEDING TO TESTIFY AND ASSIST IN ANY FURTHER INVESTIGATION OR ADMINISTRATIVE PROCEEDING UPON THE REASONABLE REQUEST OF THE OFFICE, WITHOUT A SUBPOENA, AND AT RAYMOND JAMES'S EXPENSE OR THE EMPLOYEE'S EXPENSE.
regulatory · block 28RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 113–115
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- FINRA
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
IN RESOLVING THIS MATTER WITHOUT A MONETARY FINE, FINRA RECOGNIZES THE FIRM'S EXTRAORDINARY COOPERATION. THE FIRM PROVIDED SUBSTANTIAL ASSISTANCE TO FINRA IN ITS INVESTIGATION, INCLUDING PROVIDING FINRA WITH DETAILED INFORMATION ABOUT THE CHALLENGES ASSOCIATED WITH COLLECTING AND ASSESSING DATA CONCERNING 529 PLANS. IN ADDITION, THE FIRM ENGAGED AN OUTSIDE CONSULTING FIRM TO CONDUCT A COMPLEX ANALYSIS TO IDENTIFY POTENTIALLY DISADVANTAGED CUSTOMERS ON AN EXPEDITED BASIS. THE FIRM THEN ESTABLISHED A PLAN TO PROVIDE BROAD REMEDIATION TO CUSTOMERS HARMED DURING THE RELEVANT PERIOD.
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 ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, AND FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WSPS, REASONABLY DESIGNED TO SUPERVISE REPRESENTATIVES' SHARE-CLASS RECOMMENDATIONS TO CUSTOMERS OF 529 SAVINGS PLANS. THE FINDINGS STATED THAT THE MATTER INVOLVES THE FIRM'S RESPECTIVE FAILURE TO SUPERVISE ITS ACTIVITIES TO ACHIEVE COMPLIANCE WITH ITS SUITABILITY OBLIGATIONS IN CONNECTION WITH ITS REPRESENTATIVES' 529 PLAN SHARE-CLASS RECOMMENDATIONS. UNTIL 2016, THE FIRM'S TRAINING MATERIALS SIMILARLY DID NOT PROVIDE ANY GUIDANCE TO REPRESENTATIVES REGARDING 529 PLAN SHARE CLASSES. ALTHOUGH THE FIRM MAINTAINED AN AUTOMATED SURVEILLANCE SYSTEM DESIGNED TO GENERATE EXCEPTION REPORTS TO IDENTIFY POTENTIALLY UNSUITABLE 529 PLAN SHARE-CLASS RECOMMENDATIONS, IT DID NOT HAVE ANY SYSTEM OR PROCEDURES TO TEST THIS SYSTEM AND IT FAILED TO DETECT A BREAKDOWN IN THE SYSTEM. AS A RESULT, THE FIRM FAILED TO CONDUCT A SUPERVISORY REVIEW OF APPROXIMATELY 1.6 MILLION 529 PLAN PURCHASES. IN ADDITION, EVEN WHEN THE SYSTEM GENERATED REPORTS AS INTENDED, THE FIRM DID NOT CONSISTENTLY USE THE REPORTS AND TOOK NO ACTION WHEN A POTENTIALLY UNSUITABLE TRANSACTION WAS FLAGGED. THE FINDINGS ALSO STATED THAT THE FIRM HAS AGREED TO PAY RESTITUTION RELATING TO THE SALE OF CLASS C SHARES TO CERTAIN 529 PLAN CUSTOMERS IN THE ESTIMATED AMOUNT OF $4,203,182.
Sanction detail — filed text
THE FIRM WAS CENSURED AND ORDERED TO PAY RESTITUTION IN THE ESTIMATED TOTAL AMOUNT OF $4,203,182, PLUS INTEREST, TO ELIGIBLE CUSTOMERS THAT INCURRED EXCESS FEES DUE TO THEIR INVESTMENTS IN CLASS C SHARES. IN RESOLVING THIS MATTER WITHOUT A MONETARY FINE, FINRA RECOGNIZES THE FIRM'S EXTRAORDINARY COOPERATION
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FINRA 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 11/06/2019 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2018058041101 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: SHARE CLASSES OF 529 SAVINGS PLANS 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 ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, AND FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WSPS, REASONABLY DESIGNED TO SUPERVISE REPRESENTATIVES' SHARE-CLASS RECOMMENDATIONS TO CUSTOMERS OF 529 SAVINGS PLANS. THE FINDINGS STATED THAT THE MATTER INVOLVES THE FIRM'S RESPECTIVE FAILURE TO SUPERVISE ITS ACTIVITIES TO ACHIEVE COMPLIANCE WITH ITS SUITABILITY OBLIGATIONS IN CONNECTION WITH ITS REPRESENTATIVES' 529 PLAN SHARE-CLASS RECOMMENDATIONS. UNTIL 2016, THE FIRM'S TRAINING MATERIALS SIMILARLY DID NOT PROVIDE ANY GUIDANCE TO REPRESENTATIVES REGARDING 529 PLAN SHARE CLASSES. ALTHOUGH THE FIRM MAINTAINED AN AUTOMATED SURVEILLANCE SYSTEM DESIGNED TO GENERATE EXCEPTION REPORTS TO IDENTIFY POTENTIALLY UNSUITABLE 529 PLAN SHARE-CLASS RECOMMENDATIONS, IT DID NOT HAVE ANY SYSTEM OR PROCEDURES TO TEST THIS SYSTEM AND IT FAILED TO DETECT A BREAKDOWN IN THE SYSTEM. AS A RESULT, THE FIRM FAILED TO CONDUCT A SUPERVISORY REVIEW OF APPROXIMATELY 1.6 MILLION 529 PLAN PURCHASES. IN ADDITION, EVEN WHEN THE SYSTEM GENERATED REPORTS AS INTENDED, THE FIRM DID NOT CONSISTENTLY USE THE REPORTS AND TOOK NO ACTION WHEN A POTENTIALLY UNSUITABLE TRANSACTION WAS FLAGGED. THE FINDINGS ALSO STATED THAT THE FIRM HAS AGREED TO PAY RESTITUTION RELATING TO THE SALE OF CLASS C SHARES TO CERTAIN 529 PLAN CUSTOMERS IN THE ESTIMATED AMOUNT OF $4,203,182. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 11/06/2019 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: PLUS 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 ORDERED TO PAY RESTITUTION IN THE ESTIMATED TOTAL AMOUNT OF $4,203,182, PLUS INTEREST, TO ELIGIBLE CUSTOMERS THAT INCURRED EXCESS FEES DUE TO THEIR INVESTMENTS IN CLASS C SHARES. IN RESOLVING THIS MATTER WITHOUT A MONETARY FINE, FINRA RECOGNIZES THE FIRM'S EXTRAORDINARY COOPERATION 13. Provide a brief summary of 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 WITHOUT A MONETARY FINE, FINRA RECOGNIZES THE FIRM'S EXTRAORDINARY COOPERATION. THE FIRM PROVIDED SUBSTANTIAL ASSISTANCE TO FINRA IN ITS INVESTIGATION, INCLUDING PROVIDING FINRA WITH DETAILED INFORMATION ABOUT THE CHALLENGES ASSOCIATED WITH COLLECTING AND ASSESSING DATA CONCERNING 529 PLANS. IN ADDITION, THE FIRM ENGAGED AN OUTSIDE CONSULTING FIRM TO CONDUCT A COMPLEX ANALYSIS TO IDENTIFY POTENTIALLY DISADVANTAGED CUSTOMERS ON AN EXPEDITED BASIS. THE FIRM THEN ESTABLISHED A PLAN TO PROVIDE BROAD REMEDIATION TO CUSTOMERS HARMED DURING THE RELEVANT PERIOD.
regulatory · block 29PDF pages 115–116
- Regulator name — filed text
- STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS CORPORATIONS, SECURITIES & COMMERCIAL LICENSING BUREAU
- Monetary/Fine Amount — filed text
- $ 50,000.00
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE ENTRY OF AN ORDER TO RESOLVE THE ALLEGATIONS AND A MONETARY FINE IN THE AMOUNT OF $50,000. THE FIRM ALSO AGREED TO COMPLY WITH THE MICHIGAN UNIFORM SECURITIES ACT IN CONNECTION WITH ALL FUTURE CONDUCT AND ACTIVITIES, INCLUDING BUT NOT LIMITED TO ENSURING THAT IT REASONABLY SUPERVISES ITS AGENTS.
Other filed details
Description of allegations — filed text
THE ADMINISTRATOR INTENDS TO CENSURE AND FINE RAYMOND JAMES & ASSOCIATES, INC. UNDER SECTION 412(3) OF THE SECURITIES ACT, MCL 451.2412(3), BECAUSE IT HAS FAILED TO SUPERVISE ITS AGENTS, WHICH SUPPORTS THE IMPOSITION OF A CENSURE AND A FINE UNDER THE ABOVE- CITED PROVISIONS OF THE MICHIGAN UNIFORM SECURITIES ACT (2002), 2008 PA 551, MCL 451.2101 ET SEQ.
Sanction detail — filed text
$50,000 CIVIL FINE
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 MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS CORPORATIONS, SECURITIES & COMMERCIAL LICENSING BUREAU 2. Principal Sanction: Censure Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 10/25/2019 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 339092 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES 6. Principal Product Type: Unit Investment Trust(s) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE ADMINISTRATOR INTENDS TO CENSURE AND FINE RAYMOND JAMES & ASSOCIATES, INC. UNDER SECTION 412(3) OF THE SECURITIES ACT, MCL 451.2412(3), BECAUSE IT HAS FAILED TO SUPERVISE ITS AGENTS, WHICH SUPPORTS THE IMPOSITION OF A CENSURE AND A FINE UNDER THE ABOVE- CITED PROVISIONS OF THE MICHIGAN UNIFORM SECURITIES ACT (2002), 2008 PA 551, MCL 451.2101 ET SEQ. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 03/27/2020 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: $ 50,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: $50,000 CIVIL FINE 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE ENTRY OF AN ORDER TO RESOLVE THE ALLEGATIONS AND A MONETARY FINE IN THE AMOUNT OF $50,000. THE FIRM ALSO AGREED TO COMPLY WITH THE MICHIGAN UNIFORM SECURITIES ACT IN CONNECTION WITH ALL FUTURE CONDUCT AND ACTIVITIES, INCLUDING BUT NOT LIMITED TO ENSURING THAT IT REASONABLY SUPERVISES ITS AGENTS.
regulatory · block 30PDF pages 116–118
- Regulator name — filed text
- NYSE AMERICAN LLC
- Monetary/Fine Amount — filed text
- $ 31,666.67
- 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 ACCURATELY RECORD THE ORDER RECEIPT TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO NYSE AMERICAN AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(I) OF THE EXCHANGE ACT AND NYSE AMERICAN RULE 956NY. THE FIRM ALSO VIOLATED NYSE AMERICAN RULE 320 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WSPS AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE FEDERAL SECURITIES LAWS AND NYSE AMERICAN RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF ORDER RECEIPT AND TRANSMISSION TIMES. ADDITIONALLY, THE FIRM ALSO VIOLATED NYSE AMERICAN RULE 320 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLE SYSTEM OF SUPERVISION BY FAILING TO REVIEW THE ELECTRONIC COMMUNICATIONS OF FOUR FIRM EMPLOYEES WHO WERE RESPONSIBLE FOR TAKING RETAIL ORDERS RECEIVED FROM THE FIRM'S FINANCIAL ADVISERS.
Sanction detail — filed text
THE FIRM WAS CENSURED AND FINED $95,000, OF WHICH $31,666.67 SHALL BE PAID TO THE EXCHANGE.
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) NYSE AMERICAN LLC 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 01/13/2020 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2017053129504 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 THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ACCURATELY RECORD THE ORDER RECEIPT TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO NYSE AMERICAN AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(I) OF THE EXCHANGE ACT AND NYSE AMERICAN RULE 956NY. THE FIRM ALSO VIOLATED NYSE AMERICAN RULE 320 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WSPS AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE FEDERAL SECURITIES LAWS AND NYSE AMERICAN RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF ORDER RECEIPT AND TRANSMISSION TIMES. ADDITIONALLY, THE FIRM ALSO VIOLATED NYSE AMERICAN RULE 320 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLE SYSTEM OF SUPERVISION BY FAILING TO REVIEW THE ELECTRONIC COMMUNICATIONS OF FOUR FIRM EMPLOYEES WHO WERE RESPONSIBLE FOR TAKING RETAIL ORDERS RECEIVED FROM THE FIRM'S FINANCIAL ADVISERS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 01/13/2020 Exact Explanation If not exact, provide explanation: FIRM NOTIFIED VIA U6 FILING ON 1-17-2020. 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 31,666.67 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 $95,000, OF WHICH $31,666.67 SHALL BE PAID TO THE EXCHANGE. 13. Provide a brief summary of 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 118–120
- Regulator name — filed text
- NASDAQ ISE, LLC
- Monetary/Fine Amount — filed text
- $ 7,500.00
- 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 VIOLATED ISE RULE 401 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WSPS AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH THE APPLICABLE FEDERAL SECURITIES LAWS AND ISE RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF ORDER RECEIPT AND TRANSMISSION TIMES. ADDITIONALLY, THE FIRM VIOLATED ISE RULE 401 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLE SYSTEM OF SUPERVISION BY FAILING TO REVIEW THE ELECTRONIC COMMUNICATIONS OF CERTAIN EMPLOYEES WHO WERE RESPONSIBLE FOR TAKING RETAIL ORDERS RECEIVED FROM THE FIRM'S FINANCIAL ADVISERS.
Sanction detail — filed text
THE FIRM WAS CENSURED AND FINED $95,000, OF WHICH $7,500 SHALL BE PAID TO THE EXCHANGE.
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 ISE, LLC 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 01/13/2020 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2017053129502 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 THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED ISE RULE 401 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WSPS AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH THE APPLICABLE FEDERAL SECURITIES LAWS AND ISE RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF ORDER RECEIPT AND TRANSMISSION TIMES. ADDITIONALLY, THE FIRM VIOLATED ISE RULE 401 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLE SYSTEM OF SUPERVISION BY FAILING TO REVIEW THE ELECTRONIC COMMUNICATIONS OF CERTAIN EMPLOYEES WHO WERE RESPONSIBLE FOR TAKING RETAIL ORDERS RECEIVED FROM THE FIRM'S FINANCIAL ADVISERS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 01/13/2020 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: $ 7,500.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS CENSURED AND FINED $95,000, OF WHICH $7,500 SHALL BE PAID TO THE EXCHANGE. 13. Provide a brief summary of 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 32PDF pages 120–122
- Regulator name — filed text
- NYSE ARCA, INC.
- Monetary/Fine Amount — filed text
- $ 31,666.66
- 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 ACCURATELY RECORD THE ORDER RECEIPT TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO NYSE ARCA AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(I) OF THE EXCHANGE ACT, AND NYSE ARCA RULE 6.68. THE FIRM ALSO VIOLATED NYSE ARCA RULE 11.18 BY FAILING TO ESTABLISH AND MAINTAIN WSPS AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE APPLICABLE FEDERAL SECURITIES LAWS AND NYSE ARCA RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF ORDER RECEIPT AND TRANSMISSION TIMES. ADDITIONALLY, THE FIRM ALSO VIOLATED NYSE ARCA RULE 11.18 BY FAILING TO ESTABLISH AND MAINTAIN A REASONABLE SYSTEM OF SUPERVISION BY FAILING TO REVIEW THE ELECTRONIC COMMUNICATIONS OF FOUR FIRM EMPLOYEES WHO WERE RESPONSIBLE FOR TAKING RETAIL ORDERS RECEIVED FROM THE FIRM'S FINANCIAL ADVISERS.
Sanction detail — filed text
THE FIRM WAS CENSURED AND FINED $95,000, OF WHICH $31,666.66 SHALL BE PAID TO THE EXCHANGE.
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) NYSE ARCA, INC. 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 01/13/2020 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2017053129503 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 THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ACCURATELY RECORD THE ORDER RECEIPT TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO NYSE ARCA AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(I) OF THE EXCHANGE ACT, AND NYSE ARCA RULE 6.68. THE FIRM ALSO VIOLATED NYSE ARCA RULE 11.18 BY FAILING TO ESTABLISH AND MAINTAIN WSPS AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE APPLICABLE FEDERAL SECURITIES LAWS AND NYSE ARCA RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF ORDER RECEIPT AND TRANSMISSION TIMES. ADDITIONALLY, THE FIRM ALSO VIOLATED NYSE ARCA RULE 11.18 BY FAILING TO ESTABLISH AND MAINTAIN A REASONABLE SYSTEM OF SUPERVISION BY FAILING TO REVIEW THE ELECTRONIC COMMUNICATIONS OF FOUR FIRM EMPLOYEES WHO WERE RESPONSIBLE FOR TAKING RETAIL ORDERS RECEIVED FROM THE FIRM'S FINANCIAL ADVISERS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 01/13/2020 Exact Explanation If not exact, provide explanation: FIRM NOTIFIED VIA U6 FILING ON 1-17-2020. 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 31,666.66 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 $95,000, OF WHICH $31,666.66 SHALL BE PAID TO THE EXCHANGE. 13. Provide a brief summary of 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 33PDF pages 122–123
- Regulator name — filed text
- NASDAQ PHLX LLC
- Monetary/Fine Amount — filed text
- $ 24,166.67
- 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 ACCURATELY RECORD THE ORDER RECEIPT TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO PHLX AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(I) OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED (THE "EXCHANGE ACT"), AND PHLX RULE 760. THE FIRM ALSO VIOLATED PHLX RULE 748(H) BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WSPS AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATIONS OF, THE APPLICABLE FEDERAL SECURITIES LAWS AND PHLX RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF ORDER RECEIPT AND TRANSMISSION TIMES. ADDITIONALLY, THE FIRM ALSO VIOLATED PHLX RULE 748(H) BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLE SYSTEM OF SUPERVISION BY FAILING TO REVIEW THE ELECTRONIC COMMUNICATIONS OF FOUR FIRM EMPLOYEES WHO WERE RESPONSIBLE FOR TAKING RETAIL ORDERS RECEIVED FROM THE FIRM'S FINANCIAL ADVISERS.
Sanction detail — filed text
THE FIRM WAS CENSURED AND FINED $95,000, OF WHICH $24,166.67, SHALL BE PAID TO THE EXCHANGE.
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 PHLX LLC 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 01/13/2020 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2017053129501 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 THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ACCURATELY RECORD THE ORDER RECEIPT TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO PHLX AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(I) OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED (THE "EXCHANGE ACT"), AND PHLX RULE 760. THE FIRM ALSO VIOLATED PHLX RULE 748(H) BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WSPS AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATIONS OF, THE APPLICABLE FEDERAL SECURITIES LAWS AND PHLX RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF ORDER RECEIPT AND TRANSMISSION TIMES. ADDITIONALLY, THE FIRM ALSO VIOLATED PHLX RULE 748(H) BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLE SYSTEM OF SUPERVISION BY FAILING TO REVIEW THE ELECTRONIC COMMUNICATIONS OF FOUR FIRM EMPLOYEES WHO WERE RESPONSIBLE FOR TAKING RETAIL ORDERS RECEIVED FROM THE FIRM'S FINANCIAL ADVISERS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 01/13/2020 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: $ 24,166.67 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 $95,000, OF WHICH $24,166.67, SHALL BE PAID TO THE EXCHANGE. 13. Provide a brief summary of 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 34PDF pages 124–125
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 47,500.00
- 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, AS A REMARKETING AGENT FOR VARIABLE RATE DEMAND OBLIGATIONS, SUBMITTED INFORMATION REGARDING THE RESULT OF INTEREST RATE RESETS TO THE MSRB'S SHORT-TERM OBLIGATION RATE TRANSPARENCY (SHORT) SYSTEM, BUT IN CERTAIN INSTANCES, MOST OF WHICH RELATED TO ITS ACQUISITION OF THE BOOK OF ANOTHER BROKER DEALER, FAILED TO INCLUDE THE MINIMUM DENOMINATION OR MAXIMUM INTEREST RATE. THE FINDINGS STATED THAT SPECIFICALLY, THE FIRM FAILED TO REPORT THE MINIMUM DENOMINATION IN 2,925 SUBMISSIONS (APPROXIMATELY 6.36% ERROR RATE), AND FAILED TO REPORT THE MAXIMUM INTEREST RATE IN 3,133 SUBMISSIONS (APPROXIMATELY 6.81% ERROR RATE). THE REPORTING FAILURES OCCURRED BECAUSE THE FIRM'S REPORTING SYSTEM, WHICH TRANSMITS DATA TO SHORT FOR THE MSRB'S EMMA SYSTEM, DID NOT REQUIRE THE ENTRY OF THE MINIMUM DENOMINATION AND MAXIMUM INTEREST RATE FIELDS. FIRM TRADERS MISTAKENLY LEFT THE MINIMUM DENOMINATION AND MAXIMUM INTEREST RATE FIELDS BLANK. THE FINDINGS ALSO STATED THAT THE FIRM DID NOT MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WSPS, THAT WAS REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH MSRB REPORTING REQUIREMENTS. THE FIRM'S SUPERVISORY SYSTEM FAILED TO INCLUDE A REVIEW DESIGNED TO DETERMINE WHETHER IT HAD SUBMITTED ALL REQUIRED INFORMATION TO THE SHORT SYSTEM, AND WHETHER THAT SUBMITTED INFORMATION, INCLUDING THE MINIMUM DENOMINATION AND MAXIMUM INTEREST RATE, WAS ACCURATE. EVEN AFTER THE FIRM UPDATED ITS SUPERVISORY SYSTEM TO INCLUDE A REVIEW TO VERIFY THAT THE MINIMUM DENOMINATION AND MAXIMUM INTEREST RATES HAD BEEN REPORTED TO SHORT, THE FIRM'S WSPS DID NOT INCLUDE REFERENCE TO THIS REVIEW.
Sanction detail — filed text
THE FIRM WAS CENSURED AND FINED $47,500. FINE PAID IN FULL ON 10/27/2020.
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) FINRA 2. Principal Sanction: Censure Other Sanctions: MONETARY FINE 3. Date Initiated (MM/DD/YYYY): 10/07/2020 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2018057742301 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: VARIABLE RATE DEMAND OBLIGATIONS 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, AS A REMARKETING AGENT FOR VARIABLE RATE DEMAND OBLIGATIONS, SUBMITTED INFORMATION REGARDING THE RESULT OF INTEREST RATE RESETS TO THE MSRB'S SHORT-TERM OBLIGATION RATE TRANSPARENCY (SHORT) SYSTEM, BUT IN CERTAIN INSTANCES, MOST OF WHICH RELATED TO ITS ACQUISITION OF THE BOOK OF ANOTHER BROKER DEALER, FAILED TO INCLUDE THE MINIMUM DENOMINATION OR MAXIMUM INTEREST RATE. THE FINDINGS STATED THAT SPECIFICALLY, THE FIRM FAILED TO REPORT THE MINIMUM DENOMINATION IN 2,925 SUBMISSIONS (APPROXIMATELY 6.36% ERROR RATE), AND FAILED TO REPORT THE MAXIMUM INTEREST RATE IN 3,133 SUBMISSIONS (APPROXIMATELY 6.81% ERROR RATE). THE REPORTING FAILURES OCCURRED BECAUSE THE FIRM'S REPORTING SYSTEM, WHICH TRANSMITS DATA TO SHORT FOR THE MSRB'S EMMA SYSTEM, DID NOT REQUIRE THE ENTRY OF THE MINIMUM DENOMINATION AND MAXIMUM INTEREST RATE FIELDS. FIRM TRADERS MISTAKENLY LEFT THE MINIMUM DENOMINATION AND MAXIMUM INTEREST RATE FIELDS BLANK. THE FINDINGS ALSO STATED THAT THE FIRM DID NOT MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WSPS, THAT WAS REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH MSRB REPORTING REQUIREMENTS. THE FIRM'S SUPERVISORY SYSTEM FAILED TO INCLUDE A REVIEW DESIGNED TO DETERMINE WHETHER IT HAD SUBMITTED ALL REQUIRED INFORMATION TO THE SHORT SYSTEM, AND WHETHER THAT SUBMITTED INFORMATION, INCLUDING THE MINIMUM DENOMINATION AND MAXIMUM INTEREST RATE, WAS ACCURATE. EVEN AFTER THE FIRM UPDATED ITS SUPERVISORY SYSTEM TO INCLUDE A REVIEW TO VERIFY THAT THE MINIMUM DENOMINATION AND MAXIMUM INTEREST RATES HAD BEEN REPORTED TO SHORT, THE FIRM'S WSPS DID NOT INCLUDE REFERENCE TO THIS REVIEW. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 10/07/2020 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: $ 47,500.00 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 $47,500. FINE PAID IN FULL ON 10/27/2020. 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).
regulatory · block 35PDF pages 125–127
- Regulator name — filed text
- SOUTH CAROLINA SECURITIES DIVISION
- Monetary/Fine Amount — filed text
- $ 50,000.00
- How was matter resolved — filed text
- Consent
Other filed details
Description of allegations — filed text
FAILURE TO SUPERVISE 2 SOUTH CAROLINA AGENTS.
Sanction detail — filed text
FINE PAID IN FULL ON 10/14/2022.
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) SOUTH CAROLINA SECURITIES DIVISION 2. Principal Sanction: Censure Other Sanctions: CIVIL PENALTY 3. Date Initiated (MM/DD/YYYY): 09/28/2022 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 20186982 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Unit Investment Trust(s) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FAILURE TO SUPERVISE 2 SOUTH CAROLINA AGENTS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 09/28/2022 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: $ 50,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: FINE PAID IN FULL ON 10/14/2022. 13. Provide a brief summary of 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 127–129
- Regulator name — filed text
- SECURITIES EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 500,000.00
- How was matter resolved — filed text
- Order
Other filed details
Description of allegations — filed text
THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT RAYMOND JAMES & ASSOCIATES, INC. ("RJA") VIOLATED SECTION 15(B)(4)(E) OF THE EXCHANGE ACT BY FAILING TO SUPERVISE REGISTERED REPRESENTATIVE FRED STOW IN THAT RJA FAILED TO DEVELOP POLICIES AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT STOW'S VIOLATIONS OF SECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER.
Sanction detail — filed text
THE FIRM IS CENSURED AND SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THE SECURITIES AND EXCHANGE COMMISSION FOR TRANSFER TO THE GENERAL FUND OF THE UNITED STATES TREASURY. FINE PAID IN FULL ON 10/4/2022.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
SECURITIES EXCHANGE COMMISSION
2.
Principal Sanction:
Other
Other Sanctions:
N/A
3.
Date Initiated (MM/DD/YYYY):
09/22/2022
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-21133
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
INDIVIDUAL RETIREMENT ACCOUNT
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT RAYMOND JAMES & ASSOCIATES, INC. ("RJA") VIOLATED SECTION 15(B)(4)(E) OF
THE EXCHANGE ACT BY FAILING TO SUPERVISE REGISTERED REPRESENTATIVE FRED STOW IN THAT RJA FAILED TO DEVELOP POLICIES AND
PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT STOW'S VIOLATIONS OF SECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5
THEREUNDER.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
09/22/2022
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: $ 500,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
THE FIRM IS CENSURED AND SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THE SECURITIES AND EXCHANGE
COMMISSION FOR TRANSFER TO THE GENERAL FUND OF THE UNITED STATES TREASURY. FINE PAID IN FULL ON 10/4/2022.
13. Provide a brief summary of 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 129–131
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 300,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT AND AN AFFILIATED COMPANY FAILED TO HAVE A QUALIFIED AND REGISTERED PRINCIPAL AUTHORIZE CHANGES TO THE ACCOUNT NAME OR DESIGNATION ON MORE THAN 7,500 EQUITY ORDERS. THE MATTER ORIGINATED WHEN THE FIRM REPORTED ON A FINRA RULE 4530 FILING THAT IT FAILED TO UNDERTAKE THE PRINCIPAL REVIEW REQUIRED BY FINRA RULE 4515. THE FIRMS HAVE SINCE DESIGNATED REGISTERED PRINCIPALS ON THE TRADE DESKS TO REVIEW AND AUTHORIZE CHANGES TO ACCOUNT NAME AND DESIGNATION ON ORDERS.
Sanction detail — filed text
THE FIRM WAS CENSURED AND FINED $300,000.
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: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 10/20/2022 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2018058633501 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES 6. Principal Product Type: Other Other Product Types: EQUITY 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT AND AN AFFILIATED COMPANY FAILED TO HAVE A QUALIFIED AND REGISTERED PRINCIPAL AUTHORIZE CHANGES TO THE ACCOUNT NAME OR DESIGNATION ON MORE THAN 7,500 EQUITY ORDERS. THE MATTER ORIGINATED WHEN THE FIRM REPORTED ON A FINRA RULE 4530 FILING THAT IT FAILED TO UNDERTAKE THE PRINCIPAL REVIEW REQUIRED BY FINRA RULE 4515. THE FIRMS HAVE SINCE DESIGNATED REGISTERED PRINCIPALS ON THE TRADE DESKS TO REVIEW AND AUTHORIZE CHANGES TO ACCOUNT NAME AND DESIGNATION ON ORDERS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 10/20/2022 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: $ 300,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS CENSURED AND FINED $300,000. 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 38PDF pages 131–132
- Regulator name — filed text
- NYSE AMERICAN LLC
- Monetary/Fine Amount — filed text
- $ 200,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
THE FINDINGS INCLUDE A VIOLATION OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3(A)(6)(I) THEREUNDER, NYSE AMERICAN RULE 324, AND NYSE AMERICAN RULE 956NY FOR FAILURE BY THE FIRM TO MAINTAIN ACCURATE AND COMPLETE RECORDS FOR OVER 5000 OPTIONS ORDERS MANUALLY HANDLED BY THE FIRM AND ROUTED TO NYSE FOR EXECUTION. SPECIFICALLY, NYSE FOUND THAT THE FIRM'S TRADE MEMORANDA: (1) CONTAINED INACCURATE ORDER RECEIPT TIME, (2) FAILED TO INDICATE WHETHER AN ORDER IS A MARKET ORDER, AND (3) FAILED TO RECORD MODIFICATIONS TO PRICE AND QUANTITY. THE STAFF ALSO FOUND THERE TO BE VIOLATIONS OF NYSE AMERICAN RULE 320(E) FOR FAILURE TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WSPS, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS BOOKS AND RECORDS OBLIGATIONS.
Sanction detail — filed text
THE FIRM WAS CENSURED AND FINED $200,000.
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) NYSE AMERICAN LLC 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CENSURE 3. Date Initiated (MM/DD/YYYY): 12/08/2022 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2021-02-23-00034 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Options Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE FINDINGS INCLUDE A VIOLATION OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3(A)(6)(I) THEREUNDER, NYSE AMERICAN RULE 324, AND NYSE AMERICAN RULE 956NY FOR FAILURE BY THE FIRM TO MAINTAIN ACCURATE AND COMPLETE RECORDS FOR OVER 5000 OPTIONS ORDERS MANUALLY HANDLED BY THE FIRM AND ROUTED TO NYSE FOR EXECUTION. SPECIFICALLY, NYSE FOUND THAT THE FIRM'S TRADE MEMORANDA: (1) CONTAINED INACCURATE ORDER RECEIPT TIME, (2) FAILED TO INDICATE WHETHER AN ORDER IS A MARKET ORDER, AND (3) FAILED TO RECORD MODIFICATIONS TO PRICE AND QUANTITY. THE STAFF ALSO FOUND THERE TO BE VIOLATIONS OF NYSE AMERICAN RULE 320(E) FOR FAILURE TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WSPS, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS BOOKS AND RECORDS 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): 12/08/2022 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: $ 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: THE FIRM WAS CENSURED AND FINED $200,000. 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 39PDF pages 132–134
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 300,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT SENT CUSTOMERS INACCURATE TRADE CONFIRMATIONS. THE FINDINGS STATED THAT THE FIRM SENT ITS CUSTOMERS AT LEAST 1,850,000 CONFIRMATIONS THAT INACCURATELY DISCLOSED THE FIRM'S EXECUTION CAPACITY OR WHETHER THE TRADE WAS EXECUTED AT AN AVERAGE PRICE, OR INACCURATELY DISCLOSED OR OMITTED ITS STATUS AS A MARKET MAKER IN THE SECURITY. FIRST, WHEN THE FIRM ACTED IN MORE THAN ONE CAPACITY IN EXECUTING ORDERS, IT DID NOT PROVIDE EACH SPECIFIC CAPACITY IN WHICH THE FIRM ACTED ON THE CUSTOMER CONFIRMATIONS. INSTEAD, THE FIRM DISCLOSED THAT IT ACTED IN A MIXED CAPACITY AND THAT THE BREAKDOWN OF EXECUTION CAPACITY IS AVAILABLE UPON REQUEST. THE FIRM'S SYSTEM PREVENTED THE FIRM FROM POPULATING THE SPECIFIC CAPACITIES IN WHICH THE FIRM ACTED IF THE FIRM ACTED IN MORE THAN ONE CAPACITY ON A TRANSACTION. THIS ISSUE AFFECTED APPROXIMATELY 750,000 CONFIRMATIONS. SECOND, DUE TO A PROGRAMING ERROR, THE FIRM SENT CUSTOMERS TRADE CONFIRMATIONS THAT INCORRECTLY DISCLOSED TRANSACTIONS AS AVERAGE PRICE EXECUTIONS WHEN THE FIRM FILLED THE ORDER IN A SINGLE EXECUTION. A REVIEW OF TWO OF THE FIRM'S SIX ORDER MANAGEMENT SYSTEMS REVEALED THAT THE FIRM INCORRECTLY IDENTIFIED SINGLE EXECUTIONS AS AVERAGE PRICE EXECUTIONS ON APPROXIMATELY 1,050,000 CONFIRMATIONS ISSUED TO CUSTOMERS. THIRD, THE FIRM FAILED TO DISCLOSE OR INACCURATELY DISCLOSED THAT IT WAS A MARKET MAKER ON APPROXIMATELY 52,350 CONFIRMATIONS SENT TO CUSTOMERS. THIS ISSUE STEMMED FROM A PROGRAMING ERROR THAT IMPACTED THE INPUT THAT IDENTIFIED THE ACCURATE MARKET MAKER STATUS ON TRADE CONFIRMATIONS. THE FIRM HAS SINCE UPDATED ITS SYSTEMS TO SPECIFY EACH CAPACITY IN WHICH THE FIRM ACTED AND PROPERLY IDENTIFY WHETHER TRANSACTIONS WERE AVERAGE PRICE EXECUTIONS, AS WELL AS CORRECTED THE PROGRAMMING ERROR.
Sanction detail — filed text
THE FIRM WAS CENSURED AND FINED $300,000.
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: MONETARY FINE 3. Date Initiated (MM/DD/YYYY): 01/30/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2019061061201 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT SENT CUSTOMERS INACCURATE TRADE CONFIRMATIONS. THE FINDINGS STATED THAT THE FIRM SENT ITS CUSTOMERS AT LEAST 1,850,000 CONFIRMATIONS THAT INACCURATELY DISCLOSED THE FIRM'S EXECUTION CAPACITY OR WHETHER THE TRADE WAS EXECUTED AT AN AVERAGE PRICE, OR INACCURATELY DISCLOSED OR OMITTED ITS STATUS AS A MARKET MAKER IN THE SECURITY. FIRST, WHEN THE FIRM ACTED IN MORE THAN ONE CAPACITY IN EXECUTING ORDERS, IT DID NOT PROVIDE EACH SPECIFIC CAPACITY IN WHICH THE FIRM ACTED ON THE CUSTOMER CONFIRMATIONS. INSTEAD, THE FIRM DISCLOSED THAT IT ACTED IN A MIXED CAPACITY AND THAT THE BREAKDOWN OF EXECUTION CAPACITY IS AVAILABLE UPON REQUEST. THE FIRM'S SYSTEM PREVENTED THE FIRM FROM POPULATING THE SPECIFIC CAPACITIES IN WHICH THE FIRM ACTED IF THE FIRM ACTED IN MORE THAN ONE CAPACITY ON A TRANSACTION. THIS ISSUE AFFECTED APPROXIMATELY 750,000 CONFIRMATIONS. SECOND, DUE TO A PROGRAMING ERROR, THE FIRM SENT CUSTOMERS TRADE CONFIRMATIONS THAT INCORRECTLY DISCLOSED TRANSACTIONS AS AVERAGE PRICE EXECUTIONS WHEN THE FIRM FILLED THE ORDER IN A SINGLE EXECUTION. A REVIEW OF TWO OF THE FIRM'S SIX ORDER MANAGEMENT SYSTEMS REVEALED THAT THE FIRM INCORRECTLY IDENTIFIED SINGLE EXECUTIONS AS AVERAGE PRICE EXECUTIONS ON APPROXIMATELY 1,050,000 CONFIRMATIONS ISSUED TO CUSTOMERS. THIRD, THE FIRM FAILED TO DISCLOSE OR INACCURATELY DISCLOSED THAT IT WAS A MARKET MAKER ON APPROXIMATELY 52,350 CONFIRMATIONS SENT TO CUSTOMERS. THIS ISSUE STEMMED FROM A PROGRAMING ERROR THAT IMPACTED THE INPUT THAT IDENTIFIED THE ACCURATE MARKET MAKER STATUS ON TRADE CONFIRMATIONS. THE FIRM HAS SINCE UPDATED ITS SYSTEMS TO SPECIFY EACH CAPACITY IN WHICH THE FIRM ACTED AND PROPERLY IDENTIFY WHETHER TRANSACTIONS WERE AVERAGE PRICE EXECUTIONS, AS WELL AS CORRECTED THE PROGRAMMING ERROR. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 01/30/2023 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 300,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement 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 $300,000. 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 40PDF pages 134–136
- Regulator name — filed text
- MASSACHUSETTS
- Monetary/Fine Amount — filed text
- $ 100,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF G.L. C. 110A, SEC. 204(A)(2)(J).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $100,000 TO MASSACHUSETTS AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MASSACHUSETTS CUSTOMERS IN AN AMOUNT OF NO LESS THAN $185,000. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,250,000.
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) MASSACHUSETTS 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 07/10/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: E-2023-0041 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 07/10/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $100,000 TO MASSACHUSETTS AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MASSACHUSETTS CUSTOMERS IN AN AMOUNT OF NO LESS THAN $185,000. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,250,000. 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). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF G.L. C. 110A, SEC. 204(A)(2)(J).
regulatory · block 41PDF pages 136–138
- Regulator name — filed text
- THE STATE OF MISSOURI
- Monetary/Fine Amount — filed text
- $ 150,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RESPONDENT SHALL PAY $150,000 TO THE MISSOURI SECRETARY OF STATE'S INVESTOR EDUCATION AND PROTECTION FUND. RESPONDENT, ITS AGENTS AND EMPLOYEES, AND ALL OTHER PERSONS PARTICIPATING IN THE ABOVE-DESCRIBED ALLEGED VIOLATIONS WITH KNOWLEDGE OF THIS ORDER, MUST CEASE AND DESIST FROM ENGAGING IN VIOLATIONS OF 15 CSR 30-51.171 AND CONDUCT AND ACTIVITIES SUBJECT TO DISCIPLINE UNDER SECTIONS 409.4-412(C) AND 409.4-412(D)(9).
Other filed details
Description of allegations — filed text
FROM 12/1/2018 TO 6/23/2020 (RELEVANT PERIOD), RESPONDENT ALLEGEDLY FAILED TO SUPERVISE AT LEAST ONE OF ITS FORMER BROKER-DEALER AGENTS WHO ENGAGED IN DISCRETIONARY TRADING IN AT LEAST FIVE NON-DISCRETIONARY CUSTOMER ACCOUNTS WITHOUT OBTAINING PRIOR CUSTOMER AUTHORIZATION. RESPONDENT IGNORED RED FLAGS AND FAILED TO REASONABLY TAKE CORRECTIVE ACTION AGAINST AGENT. RESPONDENT'S WRITTEN SUPERVISORY PROCEDURES IN EFFECT DURING THE RELEVANT PERIOD DID NOT ADEQUATELY COMMUNICATE TO SUPERVISORY STAFF STEPS TO BE TAKEN WHEN POTENTIAL REGULATORY ISSUES WERE IDENTIFIED.
Sanction detail — filed text
RESPONDENT SHALL PAY $150,000 TO THE MISSOURI SECRETARY OF STATE'S INVESTOR EDUCATION AND PROTECTION FUND. PAYMENT WAS PAID IN FULL ON 8/2/2023, UPON EXECUTION OF THE ORDER.
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 MISSOURI 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CEASE AND DESIST FROM ENGAGING IN VIOLATIONS OF 15 CSR 30-51.171 AND CONDUCT AND ACTIVITIES SUBJECT TO DISCIPLINE UNDER SECTIONS 409.4-412(C) AND 409.4-412(D)(9). 3. Date Initiated (MM/DD/YYYY): 08/02/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: AP-23-09 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FROM 12/1/2018 TO 6/23/2020 (RELEVANT PERIOD), RESPONDENT ALLEGEDLY FAILED TO SUPERVISE AT LEAST ONE OF ITS FORMER BROKER-DEALER AGENTS WHO ENGAGED IN DISCRETIONARY TRADING IN AT LEAST FIVE NON-DISCRETIONARY CUSTOMER ACCOUNTS WITHOUT OBTAINING PRIOR CUSTOMER AUTHORIZATION. RESPONDENT IGNORED RED FLAGS AND FAILED TO REASONABLY TAKE CORRECTIVE ACTION AGAINST AGENT. RESPONDENT'S WRITTEN SUPERVISORY PROCEDURES IN EFFECT DURING THE RELEVANT PERIOD DID NOT ADEQUATELY COMMUNICATE TO SUPERVISORY STAFF STEPS TO BE TAKEN WHEN POTENTIAL REGULATORY ISSUES WERE IDENTIFIED. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 08/02/2023 Exact 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: RESPONDENT SHALL PAY $150,000 TO THE MISSOURI SECRETARY OF STATE'S INVESTOR EDUCATION AND PROTECTION FUND. PAYMENT WAS PAID IN FULL ON 8/2/2023, UPON EXECUTION OF THE ORDER. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RESPONDENT SHALL PAY $150,000 TO THE MISSOURI SECRETARY OF STATE'S INVESTOR EDUCATION AND PROTECTION FUND. RESPONDENT, ITS AGENTS AND EMPLOYEES, AND ALL OTHER PERSONS PARTICIPATING IN THE ABOVE-DESCRIBED ALLEGED VIOLATIONS WITH KNOWLEDGE OF THIS ORDER, MUST CEASE AND DESIST FROM ENGAGING IN VIOLATIONS OF 15 CSR 30-51.171 AND CONDUCT AND ACTIVITIES SUBJECT TO DISCIPLINE UNDER SECTIONS 409.4-412(C) AND 409.4-412(D)(9).
regulatory · block 42RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 138–140
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- MONTANA STATE AUDITOR, COMMISSIONER OF SECURITIES AND INSURANCE
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF MONTANA CODE ANN. § 3010 201(13)(K).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO MONTANA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MONTANA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $37,027.99. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) MONTANA STATE AUDITOR, COMMISSIONER OF SECURITIES AND INSURANCE 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 11/16/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: SEC-2023-00197 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 11/16/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO MONTANA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MONTANA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $37,027.99. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF MONTANA CODE ANN. § 3010 201(13)(K).
regulatory · block 43RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 140–142
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- COLORADO SECURITIES COMMISSIONER
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF § 1151410(1)(I), C.R.S.
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO COLORADO AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN COLORADO CUSTOMERS IN AN AMOUNT OF NO LESS THAN $234,566.40. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) COLORADO SECURITIES COMMISSIONER 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS 3. Date Initiated (MM/DD/YYYY): 10/31/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2023-CDS-020 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 10/31/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO COLORADO AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN COLORADO CUSTOMERS IN AN AMOUNT OF NO LESS THAN $234,566.40. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF § 1151410(1)(I), C.R.S.
regulatory · block 44RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 142–144
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- CALIFORNIA DEPT. OF FINANCIAL PROTECTION AND INNOVATION
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF CSL SECTION 25218 AND CODE OF REGULATIONS, TITLE 10, SECTION 260.218.4
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO CALIFORNIA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CALIFORNIA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $465,000.FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,250,000.
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 CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) CALIFORNIA DEPT. OF FINANCIAL PROTECTION AND INNOVATION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 07/10/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 8663 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 07/10/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIRFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO CALIFORNIA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CALIFORNIA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $465,000.FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,250,000. 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). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF CSL SECTION 25218 AND CODE OF REGULATIONS, TITLE 10, SECTION 260.218.4
regulatory · block 45RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 144–146
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- WEST VIRGINIA SECURITIES COMMISSION
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF WEST VIRGINIA CODE SECTION 32-2-204(A)(J).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO WEST VIRGINIA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN WEST VIRGINIA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $41,361.14. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) WEST VIRGINIA SECURITIES COMMISSION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 11/17/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 23-0064 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 11/17/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO WEST VIRGINIA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN WEST VIRGINIA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $41,361.14. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF WEST VIRGINIA CODE SECTION 32-2-204(A)(J).
regulatory · block 46RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 146–147
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- INDIANA SECURITIES DIVISION
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF I.C.§2319412(D)(9) AND 710 I.A.C.§476.
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO INDIANA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN INDIANA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $238,117.87. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) INDIANA SECURITIES DIVISION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 09/27/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 23-0014CA 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 09/27/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO INDIANA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN INDIANA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $238,117.87. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF I.C.§2319412(D)(9) AND 710 I.A.C.§476.
regulatory · block 47RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 148–149
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- WISCONSIN DEPT. OF FINANCIAL INSTITUTIONS
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION WI ADMIN CODE DFI-SEC. 4.05(2).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO WISCONSIN AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN WISCONSIN CUSTOMERS IN AN AMOUNT OF NO LESS THAN $109,009.92. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) WISCONSIN DEPT. OF FINANCIAL INSTITUTIONS 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 10/18/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: S-248331 (LX) 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 10/18/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO WISCONSIN AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN WISCONSIN CUSTOMERS IN AN AMOUNT OF NO LESS THAN $109,009.92. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION WI ADMIN CODE DFI-SEC. 4.05(2).
regulatory · block 48RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 149–151
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- ARKANSAS SECURITIES COMMISSIONER
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION ARKANSAS CODE SECTION 23-42- 301(F) AND 23-42-308(A)(2)(J) AND RULE 301.01(C).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO ARKANSAS AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN ARKANSAS CUSTOMERS IN AN AMOUNT OF NO LESS THAN $129,802.26. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) ARKANSAS SECURITIES COMMISSIONER 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 10/03/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: S-23-0014 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 10/03/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO ARKANSAS AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN ARKANSAS CUSTOMERS IN AN AMOUNT OF NO LESS THAN $129,802.26. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION ARKANSAS CODE SECTION 23-42- 301(F) AND 23-42-308(A)(2)(J) AND RULE 301.01(C).
regulatory · block 49RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 151–153
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- UTAH DEPT. OF COMMERCE
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF UTAH UNIFORM SECURITIES ACT, SECTION 61-1-6(2)(A)(II)(J).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO UTAH AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN UTAH CUSTOMERS IN AN AMOUNT OF NO LESS THAN $56,000.23. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) UTAH DEPT. OF COMMERCE 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 10/16/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: SD-23-0027 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 10/16/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO UTAH AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN UTAH CUSTOMERS IN AN AMOUNT OF NO LESS THAN $56,000.23. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF UTAH UNIFORM SECURITIES ACT, SECTION 61-1-6(2)(A)(II)(J).
regulatory · block 50RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 153–155
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- STATE OF ILLINOIS, SECURITIES DIVISION
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF ILLINOIS SECURITIES ACT SECTION 8.E(1)(E)(IV).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO ILLINOIS AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN ILLINOIS CUSTOMERS IN AN AMOUNT OF NO LESS THAN $381,578.34. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) STATE OF ILLINOIS, SECURITIES DIVISION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS 3. Date Initiated (MM/DD/YYYY): 11/17/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2300108 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 11/17/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO ILLINOIS AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN ILLINOIS CUSTOMERS IN AN AMOUNT OF NO LESS THAN $381,578.34. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF ILLINOIS SECURITIES ACT SECTION 8.E(1)(E)(IV).
regulatory · block 51RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 155–157
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- SOUTH CAROLINA SECURITIES COMMISSIONER
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF SOUTH CAROLINA CODE ANN. SECTION 35-1-412(D)(9).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO SOUTH CAROLINA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN SOUTH CAROLINA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $178,212.19. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) SOUTH CAROLINA SECURITIES COMMISSIONER 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 10/17/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 20232794 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 10/17/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO SOUTH CAROLINA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN SOUTH CAROLINA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $178,212.19. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF SOUTH CAROLINA CODE ANN. SECTION 35-1-412(D)(9).
regulatory · block 52RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 157–159
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- STATE OF OKLAHOMA DEPT. OF SECURITIES
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF OKLAHOMA SECTION 1-411(D) (9).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO OKLAHOMA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN OKLAHOMA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $77,951.99. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) STATE OF OKLAHOMA DEPT. OF SECURITIES 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 11/28/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 24-014 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 11/28/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO OKLAHOMA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN OKLAHOMA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $77,951.99. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF OKLAHOMA SECTION 1-411(D) (9).
regulatory · block 53RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 159–161
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- STATE OF MICHIGAN, DEPT. OF LICENSING AND REGULATORY AFFAIRS
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF MCL 451.2412(4)(I).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO MICHIGAN AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MICHIGAN CUSTOMERS IN AN AMOUNT OF NO LESS THAN $539,950.22. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) STATE OF MICHIGAN, DEPT. OF LICENSING AND REGULATORY AFFAIRS 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 10/17/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: ENF-23-020104 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 10/17/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO MICHIGAN AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MICHIGAN CUSTOMERS IN AN AMOUNT OF NO LESS THAN $539,950.22. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF MCL 451.2412(4)(I).
regulatory · block 54RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 161–163
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- KENTUCKY DEPT. OF FINANCIAL INSTITUTIONS
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF KRS 292.337(2)(K) AND 808 KAR 10:030, SECTIONS 3 AND 4(1).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO KENTUCKY AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN KENTUCKY CUSTOMERS IN AN AMOUNT OF NO LESS THAN $212,150.59. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) KENTUCKY DEPT. OF FINANCIAL INSTITUTIONS 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 10/03/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2023-AH-0014 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 10/03/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO KENTUCKY AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN KENTUCKY CUSTOMERS IN AN AMOUNT OF NO LESS THAN $212,150.59. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF KRS 292.337(2)(K) AND 808 KAR 10:030, SECTIONS 3 AND 4(1).
regulatory · block 55RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 163–165
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- MISSISSIPPI SECRETARY OF STATE, SECURITIES DIVISION
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF MS SECURITIES ACT, SECTION 75-71-412(D)(9).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO MISSISSIPPI AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MISSISSIPPI CUSTOMERS IN AN AMOUNT OF NO LESS THAN $117,297.55. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) MISSISSIPPI SECRETARY OF STATE, SECURITIES DIVISION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 10/16/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: LS-23-6217 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 10/16/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO MISSISSIPPI AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MISSISSIPPI CUSTOMERS IN AN AMOUNT OF NO LESS THAN $117,297.55. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF MS SECURITIES ACT, SECTION 75-71-412(D)(9).
regulatory · block 56RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 165–167
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- NORTH DAKOTA SECURITIES DIVISION
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF N.D.C.C. SECTION 10-04-11(1).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO NORTH DAKOTA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN NORTH DAKOTA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $34,926.00. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) NORTH DAKOTA SECURITIES DIVISION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 10/05/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 23-1707 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 10/17/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO NORTH DAKOTA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN NORTH DAKOTA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $34,926.00. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF N.D.C.C. SECTION 10-04-11(1).
regulatory · block 57RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 167–168
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- SOUTH DAKOTA DEPT. OF INSURANCE
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF SDCL 47-31B-412(D)(9).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO SOUTH DAKOTA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN SOUTH DAKOTA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $29,136.11. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) SOUTH DAKOTA DEPT. OF INSURANCE 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 12/13/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 1019068 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 12/13/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO SOUTH DAKOTA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN SOUTH DAKOTA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $29,136.11. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF SDCL 47-31B-412(D)(9).
regulatory · block 58RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 169–170
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- DISTRICT OF COLUMBIA DEPT. OF INSURANCE, SECURITIES AND BANKING
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF D.C. OFFICIAL CODE SEC.31- 5602.07(A)(12).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO DISTRICT OF COLUMBIA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN D.C. CUSTOMERS IN AN AMOUNT OF NO LESS THAN $16,292.51. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) DISTRICT OF COLUMBIA DEPT. OF INSURANCE, SECURITIES AND BANKING 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 12/19/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: SB-CO-10-23 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 12/19/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO DISTRICT OF COLUMBIA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN D.C. CUSTOMERS IN AN AMOUNT OF NO LESS THAN $16,292.51. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF D.C. OFFICIAL CODE SEC.31- 5602.07(A)(12).
regulatory · block 59RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 170–172
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- NEW HAMPSHIRE BUREAU OF SECURITIES REGULATION
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF RSA 421-B:4-412(D)(9).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO NEW HAMPSHIRE AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATINEW HAMPSHIRE CUSTOMERS IN AN AMOUNT OF NO LESS THAN $39,303.73. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) NEW HAMPSHIRE BUREAU OF SECURITIES REGULATION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 12/18/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: INV-2023-000024 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 12/18/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO NEW HAMPSHIRE AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATINEW HAMPSHIRE CUSTOMERS IN AN AMOUNT OF NO LESS THAN $39,303.73. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF RSA 421-B:4-412(D)(9).
regulatory · block 60RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 172–174
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- TEXAS STATE SECURITIES BOARD
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF TEXAS BOARD RULE SECTION 115.10.
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO TEXAS AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN TEXAS CUSTOMERS IN AN AMOUNT OF NO LESS THAN $726,447.46. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) TEXAS STATE SECURITIES BOARD 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 12/21/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: IC23-CAF-08 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES FINANCIAL SERVICES, INC. 6. Principal Product Type: Equity - OTC Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 12/21/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO TEXAS AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN TEXAS CUSTOMERS IN AN AMOUNT OF NO LESS THAN $726,447.46. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF TEXAS BOARD RULE SECTION 115.10.
regulatory · block 61RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 174–176
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- DELAWARE DEPT. OF JUSTICE, INVESTOR PROTECTION UNIT
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF DELAWARE SECURITIES ACT 73- 304(A)(10).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO DELAWARE AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN DELAWARE CUSTOMERS IN AN AMOUNT OF NO LESS THAN $26,611.99. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) DELAWARE DEPT. OF JUSTICE, INVESTOR PROTECTION UNIT 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 12/22/2023 Exact Explanation If not exact, provide explanation: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 4. Docket/Case Number: 23-0173 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 12/22/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO DELAWARE AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN DELAWARE CUSTOMERS IN AN AMOUNT OF NO LESS THAN $26,611.99. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF DELAWARE SECURITIES ACT 73- 304(A)(10).
regulatory · block 62RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 176–178
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- MINNESOTA DEPT. OF COMMERCE
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF MINN. STAT. § 80A.67(D)(9).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO MINNESOTA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MINNESOTA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $117,577.70. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) MINNESOTA DEPT. OF COMMERCE 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 12/14/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 81981 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 12/14/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO MINNESOTA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MINNESOTA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $117,577.70. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF MINN. STAT. § 80A.67(D)(9).
regulatory · block 63RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 178–180
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- VERMONT DEPT. OF FINANCIAL REGULATION
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF V.S.R. SEC. 2-2(B)(2).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO VERMONT AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN VERMONT CUSTOMERS IN AN AMOUNT OF NO LESS THAN $28,198.46. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) VERMONT DEPT. OF FINANCIAL REGULATION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 11/03/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 23-017-S 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 11/03/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO VERMONT AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN VERMONT CUSTOMERS IN AN AMOUNT OF NO LESS THAN $28,198.46. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF V.S.R. SEC. 2-2(B)(2).
regulatory · block 64RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 180–182
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- NEW JERSEY BUREAU OF SECURITIES
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF N.J.S.A. 49:3-58(A)(2)(XI).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO NEW JERSEY AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN NEW JERSEY CUSTOMERS IN AN AMOUNT OF NO LESS THAN $241,814.73. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) NEW JERSEY BUREAU OF SECURITIES 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 12/20/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 12/20/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO NEW JERSEY AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN NEW JERSEY CUSTOMERS IN AN AMOUNT OF NO LESS THAN $241,814.73. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF N.J.S.A. 49:3-58(A)(2)(XI).
regulatory · block 65RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 182–184
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- PUERTO RICO COMMISSIONER OF FINANCIAL INSTITUTIONS
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF PRUSA ARTICLE 204(A)(2)(J) AND REGULATION 6078, ARTICLE 28, SECTION 28.2.
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO PUERTO RICO AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN PUERTO RICO CUSTOMERS IN AN AMOUNT OF NO LESS THAN $2,388.73. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) PUERTO RICO COMMISSIONER OF FINANCIAL INSTITUTIONS 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 10/11/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 10/11/2023 Exact 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: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO PUERTO RICO AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN PUERTO RICO CUSTOMERS IN AN AMOUNT OF NO LESS THAN $2,388.73. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF PRUSA ARTICLE 204(A)(2)(J) AND REGULATION 6078, ARTICLE 28, SECTION 28.2.
regulatory · block 66RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 184–186
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- HAWAII DEPT. OF COMMERCE AND CONSUMER AFFAIRS
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF HAR SECTION 16-39-470(B)(9) AND HRS SECTION 485A-412(D)(9).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO HAWAII AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN HAWAII CUSTOMERS IN AN AMOUNT OF NO LESS THAN $50,418.64. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) HAWAII DEPT. OF COMMERCE AND CONSUMER AFFAIRS 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 01/11/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: SEB20230057 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 01/11/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO HAWAII AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN HAWAII CUSTOMERS IN AN AMOUNT OF NO LESS THAN $50,418.64. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF HAR SECTION 16-39-470(B)(9) AND HRS SECTION 485A-412(D)(9).
regulatory · block 67RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 186–188
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- OHIO DEPT. OF COMMERCE
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF OHIO REVISED CODE 1707.19(A) (1)(I).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO OHIO AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN OHIO CUSTOMERS IN AN AMOUNT OF NO LESS THAN $346,111.83. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) OHIO DEPT. OF COMMERCE 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 01/03/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 24-001 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 01/03/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO OHIO AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN OHIO CUSTOMERS IN AN AMOUNT OF NO LESS THAN $346,111.83. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF OHIO REVISED CODE 1707.19(A) (1)(I).
regulatory · block 68RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 188–189
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- OREGON DEPT. OF CONSUMER AND BUSINESS SERVICES
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE FIRM NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF ORS 59.205(13), AND OAR 441-205-0210(1).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO OREGON AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN OREGON CUSTOMERS IN AN AMOUNT OF NO LESS THAN $109,349.94. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) OREGON DEPT. OF CONSUMER AND BUSINESS SERVICES 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 01/16/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: S-23-0045 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 01/16/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO OREGON AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN OREGON CUSTOMERS IN AN AMOUNT OF NO LESS THAN $109,349.94. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of 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 NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF ORS 59.205(13), AND OAR 441-205-0210(1).
regulatory · block 69RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 189–191
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- STATE OF CONNECTICUT, DEPT. OF BANKING
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF SECTION 36B-31-6F(B)OF CT REGULATIONS.
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO CONNECTICUT AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CONNECTICUT CUSTOMERS IN AN AMOUNT OF NO LESS THAN $129,145.74. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) STATE OF CONNECTICUT, DEPT. OF BANKING 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 01/31/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: CO-24-202326-S 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 01/31/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO CONNECTICUT AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CONNECTICUT CUSTOMERS IN AN AMOUNT OF NO LESS THAN $129,145.74. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). RAYMOND JAMES & ASSOCIATES, INC. NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF SECTION 36B-31-6F(B)OF CT REGULATIONS.
regulatory · block 70RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 191–193
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- NEBRASKA DEPT. OF BANKING AND FINANCE
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE FIRM NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF NEB. REV. STAT. § 81103(9)(A)(XI) (REISSUE 2022).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO NEBRASKA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN NEBRASKA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $68,675.63. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) NEBRASKA DEPT. OF BANKING AND FINANCE 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 01/17/2024 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): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 01/17/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO NEBRASKA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN NEBRASKA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $68,675.63. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of 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 NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF NEB. REV. STAT. § 81103(9)(A)(XI) (REISSUE 2022).
regulatory · block 71RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 193–195
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- MAINE OFFICE OF SECURITIES
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE FIRM NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF MAINE UNIFORM SECURITIES ACT AND MAINE OFFICE OF SECURITIES RULES.
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO MAINE AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MAINE CUSTOMERS IN AN AMOUNT OF NO LESS THAN $58,042.65. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) MAINE OFFICE OF SECURITIES 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 01/18/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2023-21 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 01/18/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO MAINE AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MAINE CUSTOMERS IN AN AMOUNT OF NO LESS THAN $58,042.65. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of 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 NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF MAINE UNIFORM SECURITIES ACT AND MAINE OFFICE OF SECURITIES RULES.
regulatory · block 72RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 195–197
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- WASHINGTON DEPT. OF FINANCIAL INSTITUTIONS
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE FIRM NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF RCW 21.20.110(1)(J).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO WASHINGTON AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN WASHINGTON CUSTOMERS IN AN AMOUNT OF NO LESS THAN $112,506.29. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) WASHINGTON DEPT. OF FINANCIAL INSTITUTIONS 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 01/20/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: S-23-3590-23-CO01 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 01/20/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO WASHINGTON AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN WASHINGTON CUSTOMERS IN AN AMOUNT OF NO LESS THAN $112,506.29. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of 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 NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF RCW 21.20.110(1)(J).
regulatory · block 73RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 197–199
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- STATE OF ALASKA
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE FIRM NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION AS 45.55.060(B) AND 45.56.440(D)(9).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO ALASKA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN ALASKA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $25,223.09. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) STATE OF ALASKA 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 02/24/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 23-111-S 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 02/24/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO ALASKA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN ALASKA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $25,223.09. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of 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 NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION AS 45.55.060(B) AND 45.56.440(D)(9).
regulatory · block 74RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 199–201
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- FLORIDA OFFICE OF FINANCIAL REGULATION
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
THE FIRM NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF RULE 69W-600.013(1)(H)1.(2021).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO FLORIDA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN FLORIDA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $1,096,109.24. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FLORIDA OFFICE OF FINANCIAL REGULATION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 02/22/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 116857-S 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 02/22/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO FLORIDA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN FLORIDA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $1,096,109.24. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of 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 NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF RULE 69W-600.013(1)(H)1.(2021).
regulatory · block 75RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 201–203
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- STATE OF GEORGIA, COMMISSIONER OF SECURITIES
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE FIRM NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF O.C.G.A. SECTION 10-5-41(D)(9) OF THE GEORGIA UNIFORM SECURITIES ACT OF 2008.
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO GEORGIA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN GEORGIA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $343,914.40. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) STATE OF GEORGIA, COMMISSIONER OF SECURITIES 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 3. Date Initiated (MM/DD/YYYY): 02/28/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: N/A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 02/28/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO GEORGIA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN GEORGIA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $343,914.40. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of 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 NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF O.C.G.A. SECTION 10-5-41(D)(9) OF THE GEORGIA UNIFORM SECURITIES ACT OF 2008.
regulatory · block 76RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 203–205
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- STATE OF NEVADA, SECURITIES DIVISION
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE FIRM NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF NRS 90.420(1)(1).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO NEVADA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN NEVADA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $45,996.79. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) STATE OF NEVADA, SECURITIES DIVISION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 02/28/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: INV23-174 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 02/28/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO NEVADA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN NEVADA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $45,996.79. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of 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 NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF NRS 90.420(1)(1).
regulatory · block 77RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 205–207
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- TENNESSEE SECURITIES DIVISION
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE FIRM NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF TENN. CODE ANN. SECTION 48-1-112(A)(2)(J).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO TENNESSEE AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN TENNESSEE CUSTOMERS IN AN AMOUNT OF NO LESS THAN $336,118.70. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) TENNESSEE SECURITIES DIVISION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 02/28/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 23-01038 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 02/28/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO TENNESSEE AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN TENNESSEE CUSTOMERS IN AN AMOUNT OF NO LESS THAN $336,118.70. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of 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 NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF TENN. CODE ANN. SECTION 48-1-112(A)(2)(J).
regulatory · block 78RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 207–208
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- ( g g g y y ) NEW MEXICO REGULATION AND LICENSING DEPT.
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE FIRM NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF NMSA 1978, §5813C412(C)(9).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO NEW MEXICO AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN NEW MEXICO CUSTOMERS IN AN AMOUNT OF NO LESS THAN $53,951.01. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) ( g g g y y ) NEW MEXICO REGULATION AND LICENSING DEPT. 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS 3. Date Initiated (MM/DD/YYYY): 03/29/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: MS-23-7-18 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 03/29/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO NEW MEXICO AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN NEW MEXICO CUSTOMERS IN AN AMOUNT OF NO LESS THAN $53,951.01. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of 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 NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF NMSA 1978, §5813C412(C)(9).
regulatory · block 79RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 209–210
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- RHODE ISLAND DEPT. OF BUSINESS REGULATION
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE FIRM NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF RI GEN. LAWS SECTION 7-11-212(B)(11).
Other filed details
Description of allegations — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO RHODE ISLAND AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN RHODE ISLAND CUSTOMERS IN AN AMOUNT OF NO LESS THAN $12,954.52. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) RHODE ISLAND DEPT. OF BUSINESS REGULATION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 03/06/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2023-SC-004 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 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): RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 03/06/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO RHODE ISLAND AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN RHODE ISLAND CUSTOMERS IN AN AMOUNT OF NO LESS THAN $12,954.52. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of 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 NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF RI GEN. LAWS SECTION 7-11-212(B)(11).
regulatory · block 80RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 210–212
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- MISSOURI SECURITIES DIVISION
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE FIRM NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF 15 CSR 30-51.171(2)(A-C).
Other filed details
Description of allegations — filed text
THE STATE ALLEGED THAT RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO MISSOURI AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MISSOURI CUSTOMERS IN AN AMOUNT OF NO LESS THAN $138,887.37. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) ( ) ( ) ( ) ( ) ( ) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) MISSOURI SECURITIES DIVISION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 05/31/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: AP-23-16 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 6. Principal Product Type: Equity - OTC Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE STATE ALLEGED THAT RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 05/31/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO MISSOURI AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN MISSOURI CUSTOMERS IN AN AMOUNT OF NO LESS THAN $138,887.37. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of 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 NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF 15 CSR 30-51.171(2)(A-C).
regulatory · block 81RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 212–214
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- KANSAS SECURITIES COMMISSIONER
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE FIRM NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF K.A.R. 81-3-7(A)(4) AND K.S.A 17-12A412(D)(9).
Other filed details
Description of allegations — filed text
THE STATE ALLEGED RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO KANSAS AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN KANSAS CUSTOMERS IN AN AMOUNT OF NO LESS THAN $47,189.70. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) KANSAS SECURITIES COMMISSIONER 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 06/27/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 24E121 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 6. Principal Product Type: Equity - OTC Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE STATE ALLEGED RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 06/27/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO KANSAS AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN KANSAS CUSTOMERS IN AN AMOUNT OF NO LESS THAN $47,189.70. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. Provide a brief summary of 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 NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF K.A.R. 81-3-7(A)(4) AND K.S.A 17-12A412(D)(9).
regulatory · block 82PDF pages 214–216
- Regulator name — filed text
- UNITED STATES SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 50,000,000.00
- How was matter resolved — filed text
- Order
Other filed details
Description of allegations — filed text
THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ENTERED A SETTLED ADMINISTRATIVE ORDER IN CONNECTION WITH ITS OFF-CHANNEL COMMUNICATIONS INITIATIVE, FINDING THAT RAYMOND JAMES & ASSOCIATES, INC. ("RAYMOND JAMES") FAILED TO (1) MAINTAIN AND PRESERVE OFF- CHANNEL COMMUNICATIONS RELATED TO RAYMOND JAMES'S BROKER-DEALER BUSINESS, IN WILLFUL VIOLATION OF SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-4(B)(4) THEREUNDER, AS WELL AS COMMUNICATIONS RELATED TO, AMONG OTHER THINGS, RECOMMENDATIONS MADE OR PROPOSED TO BE MADE AND ADVICE GIVEN OR PROPOSED TO BE GIVEN WITH RESPECT TO RAYMOND JAMES'S INVESTMENT ADVISORY BUSINESS, IN WILLFUL VIOLATION OF SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AND RULE 204-2(A)(7) THEREUNDER; AND (2) REASONABLY SUPERVISE ITS PERSONNEL WITH A VIEW TO PREVENTING OR DETECTING CERTAIN OF ITS EMPLOYEES' AIDING AND ABETTING VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4) THEREUNDER; AND WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT, AND SECTION 204 OF THE ADVISERS ACT AND RULE 204-2(A)(7) THEREUNDER, WITHIN THE MEANING OF SECTION 203(E)(6) OF THE ADVISERS ACT.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGED ITS CONDUCT VIOLATED THE FEDERAL SECURITIES LAWS AND AGREED TO: (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OR ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A THEREUNDER AND SECTION 204 OF THE ADVISERS ACT AND RULE 204-2 THEREUNDER, (B) BE CENSURED, (C) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $50,000,000, WHICH WAS PAID IN FULL AND TIMELY ON AUGUST 26, 2024, AND (D) COMPLY WITH CERTAIN UNDERTAKINGS RELATED TO THE RETENTION OF ELECTRONIC COMMUNICATIONS, INCLUDING RETENTION OF AN INDEPENDENT COMPLIANCE CONSULTANT.
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):
08/14/2024
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-22002
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
RAYMOND JAMES & ASSOCIATES, INC
6.
Principal Product Type:
No Product
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ENTERED A SETTLED ADMINISTRATIVE ORDER IN CONNECTION WITH ITS OFF-CHANNEL
COMMUNICATIONS INITIATIVE, FINDING THAT RAYMOND JAMES & ASSOCIATES, INC. ("RAYMOND JAMES") FAILED TO (1) MAINTAIN AND PRESERVE OFF-
CHANNEL COMMUNICATIONS RELATED TO RAYMOND JAMES'S BROKER-DEALER BUSINESS, IN WILLFUL VIOLATION OF SECTION 17(A) OF THE
SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-4(B)(4) THEREUNDER, AS WELL AS COMMUNICATIONS RELATED TO, AMONG
OTHER THINGS, RECOMMENDATIONS MADE OR PROPOSED TO BE MADE AND ADVICE GIVEN OR PROPOSED TO BE GIVEN WITH RESPECT TO RAYMOND
JAMES'S INVESTMENT ADVISORY BUSINESS, IN WILLFUL VIOLATION OF SECTION 204 OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT")
AND RULE 204-2(A)(7) THEREUNDER; AND (2) REASONABLY SUPERVISE ITS PERSONNEL WITH A VIEW TO PREVENTING OR DETECTING CERTAIN OF ITS
EMPLOYEES' AIDING AND ABETTING VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4) THEREUNDER; AND WITHIN THE
MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT, AND SECTION 204 OF THE ADVISERS ACT AND RULE 204-2(A)(7) THEREUNDER, WITHIN THE
MEANING OF SECTION 203(E)(6) OF THE ADVISERS ACT.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
08/14/2024
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: $ 50,000,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
RAYMOND JAMES & ASSOCIATES, INC. ADMITTED TO THE FACTS IN THE SETTLEMENT ORDER, ACKNOWLEDGED ITS CONDUCT VIOLATED THE
FEDERAL SECURITIES LAWS AND AGREED TO: (A) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OR ANY FUTURE
VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A THEREUNDER AND SECTION 204 OF THE ADVISERS ACT AND RULE 204-2
THEREUNDER, (B) BE CENSURED, (C) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $50,000,000, WHICH WAS PAID IN FULL AND TIMELY
ON AUGUST 26, 2024, AND (D) COMPLY WITH CERTAIN UNDERTAKINGS RELATED TO THE RETENTION OF ELECTRONIC COMMUNICATIONS,
INCLUDING RETENTION OF AN INDEPENDENT COMPLIANCE CONSULTANT.
13. Provide a brief summary of 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 83RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 216–218
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 525,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRMS CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THEY HAVE FAILED TO REASONABLY SUPERVISE THE FIRMS' REPORTING, AND TIMELY REPORTING, OF CUSTOMER COMPLAINTS VIA FINRA RULE 4530 FILINGS AND AMENDMENTS TO REGISTERED REPRESENTATIVES' FORMS U4 AND US. THE FINDINGS ALSO STATED THAT THE FIRMS FALLED TO REASONABLY SUPERVISE AT LEAST 4.7 MILLION MUTUAL FUND PURCHASES MADE DIRECTLY WITH MUTUAL FUND COMPANIES ON BEHALF OF FIRM CUSTOMERS. THE FIRMS INADVERTENTLY EMPLOYED A DATA FILTER THAT BLOCKED OVER A MILLION PURCHASES THAT WERE MADE PURSUANT TO PERIODIC INVESTMENT PLANS FROM BEING INGESTED INTO ITS AUTOMATED SURVEILLANCE SYSTEM. UPON DISCOVERING THE DATA FILTER, THE FIRMS DEACTIVATED IT. IN ADDITION, THE FIRMS FAILED TO REVIEW THROUGH ITS AUTOMATED SURVEILLANCE SYSTEM OVER A MILLION DIRECT BUSINESS TRANSACTIONS THAT REGISTERED REPRESENTATIVES FAILED TO TIMELY MATCH TO A FIRM ACCOUNT. THE FIRMS CONDUCTED A COMPREHENSIVE RETROSPECTIVE REVIEW OF DIRECT BUSINESS TRANSACTIONS THAT THEY FAILED TO SUPERVISE AND DETERMINED THAT CUSTOMERS INCURRED APPROXIMATELY $111,724 IN EXCESSIVE SALES CHARGES AND COMMISSIONS IN CONNECTION WITH THESE TRANSACTIONS.
Sanction detail — filed text
THE FIRM WAS CENSURED, FINED $525,000, ORDERED TO PAY $26,169.04, PLUS INTEREST, IN RESTITUTION TO ELIGIBLE CUSTOMERS, AND CERTIFY THAT THEY HAVE REMEDIATED THE ISSUES IDENTIFIED IN THE AWC.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FINRA 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 08/29/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2018059564801 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES FINANCIAL SERVICES, INC. 6. Principal Product Type: 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 FIRMS CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THEY HAVE FAILED TO REASONABLY SUPERVISE THE FIRMS' REPORTING, AND TIMELY REPORTING, OF CUSTOMER COMPLAINTS VIA FINRA RULE 4530 FILINGS AND AMENDMENTS TO REGISTERED REPRESENTATIVES' FORMS U4 AND US. THE FINDINGS ALSO STATED THAT THE FIRMS FALLED TO REASONABLY SUPERVISE AT LEAST 4.7 MILLION MUTUAL FUND PURCHASES MADE DIRECTLY WITH MUTUAL FUND COMPANIES ON BEHALF OF FIRM CUSTOMERS. THE FIRMS INADVERTENTLY EMPLOYED A DATA FILTER THAT BLOCKED OVER A MILLION PURCHASES THAT WERE MADE PURSUANT TO PERIODIC INVESTMENT PLANS FROM BEING INGESTED INTO ITS AUTOMATED SURVEILLANCE SYSTEM. UPON DISCOVERING THE DATA FILTER, THE FIRMS DEACTIVATED IT. IN ADDITION, THE FIRMS FAILED TO REVIEW THROUGH ITS AUTOMATED SURVEILLANCE SYSTEM OVER A MILLION DIRECT BUSINESS TRANSACTIONS THAT REGISTERED REPRESENTATIVES FAILED TO TIMELY MATCH TO A FIRM ACCOUNT. THE FIRMS CONDUCTED A COMPREHENSIVE RETROSPECTIVE REVIEW OF DIRECT BUSINESS TRANSACTIONS THAT THEY FAILED TO SUPERVISE AND DETERMINED THAT CUSTOMERS INCURRED APPROXIMATELY $111,724 IN EXCESSIVE SALES CHARGES AND COMMISSIONS IN CONNECTION WITH THESE 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): 08/29/2024 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 525,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKINGS Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS CENSURED, FINED $525,000, ORDERED TO PAY $26,169.04, PLUS INTEREST, IN RESTITUTION TO ELIGIBLE CUSTOMERS, AND CERTIFY THAT THEY HAVE REMEDIATED THE ISSUES IDENTIFIED IN THE AWC. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 84RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 218–220
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- ARIZONA CORPORATION COMMISSION
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Consent
Other filed details
Description of allegations — filed text
THE STATE ALLEGED RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO ARIZONA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN ARIZONA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $136,168.02. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. THE FIRM NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF A.R.S. § 44L96L (A)(3).
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) ARIZONA CORPORATION COMMISSION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: RESTITUTION; CENSURE; CEASE AND DESIST; AND UNDERTAKINGS. 3. Date Initiated (MM/DD/YYYY): 12/17/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: S-21333A-24-0245 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC. 6. Principal Product Type: Equity - OTC Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE STATE ALLEGED RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS AND DID NOT REASONABLY SURVEIL THESE TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and 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): 12/17/2024 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: IN ADDITION TO ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO ARIZONA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN ARIZONA CUSTOMERS IN AN AMOUNT OF NO LESS THAN $136,168.02. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT OF NO LESS THAN $8,383,167.46. 13. THE FIRM NEITHER ADMITTED NOR DENIED THE STATEMENT OF FACTS AND VIOLATION OF A.R.S. § 44L96L (A)(3). 13. Provide a brief summary of 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 85RAYMOND JAMES FINANCIAL SERVICES, INC.PDF pages 220–222
- Advisory affiliate name — filed text
- RAYMOND JAMES FINANCIAL SERVICES, INC.
- Regulator name — filed text
- COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
THE FIRM NEITHER ADMITTED NOR DENIED THE FACTS, ALLEGATIONS OR VIOLATIONS OF 21 VAC 5-20-260D AND 21 VAC 5-20-280 A9.
Other filed details
Description of allegations — filed text
THE COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION (COMMISSION) ALLEGED RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. (COLLECTIVELY, THE RESPONDENTS) CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE.
Sanction detail — filed text
RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO VIRGINIA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN VIRGINIA CUSTOMERS IN AN AMOUNT NO LESS THAN $216,401.88. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT NO LESS THAN $8,383,167.46.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 6694 This advisory affiliate is a Firm an Individual Registered: Yes No Name: RAYMOND JAMES FINANCIAL SERVICES, INC. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser s or advisory affiliate s favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CEASE AND DESIST, RESTITUTION, UNDERTAKING 3. Date Initiated (MM/DD/YYYY): 09/29/2025 Exact Explanation If not exact, provide explanation: DATE PUBLISHED 4. Docket/Case Number: SEC-2024-00004 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): RAYMOND JAMES & ASSOCIATES, INC 6. Principal Product Type: Equity - OTC Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION (COMMISSION) ALLEGED RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. (COLLECTIVELY, THE RESPONDENTS) CHARGED UNREASONABLE COMMISSIONS ON LOW-PRINCIPAL EQUITY TRANSACTIONS TO ENSURE THAT RESPONDENTS CHARGED CUSTOMERS A REASONABLE COMMISSION AND FEE. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Order 11. Resolution Date (MM/DD/YYYY): 09/29/2025 Exact Explanation If not exact, provide explanation: DATE PUBLISHED 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: IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN CUSTOMERS, CCO CERTIFICATIONS AND COMPREHENSIVE REVIEW OF POLICIES, PROCEDURES, AND COMPLIANCE SYSTEMS RELATED TO COMMISSIONS. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: RAYMOND JAMES & ASSOCIATES, INC. AND RAYMOND JAMES FINANCIAL SERVICES, INC. WERE ORDERED TO PAY AN ADMINISTRATIVE FINE OF $75,000 TO VIRGINIA AND, IN TOTAL, $4,200,000 TO PARTICIPATING STATES. IN ADDITION TO THE ADMINISTRATIVE FINE, RESTITUTION PAYMENTS TO CERTAIN VIRGINIA CUSTOMERS IN AN AMOUNT NO LESS THAN $216,401.88. FURTHER, TOTAL RESTITUTION TO PARTICIPATING STATES IN AN AMOUNT NO LESS THAN $8,383,167.46. 13. Provide a brief summary of 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 NEITHER ADMITTED NOR DENIED THE FACTS, ALLEGATIONS OR VIOLATIONS OF 21 VAC 5-20-260D AND 21 VAC 5-20-280 A9.
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