INTL FCSTONE FINANCIAL INC. · PDF fileConditions. A complete list of ... the firm?...

BrokerCheck Report

INTL FCSTONE FINANCIAL INC.

Section Title

Report Summary

Firm History

CRD# 45993

1

10

Firm Profile 2 - 9

Page(s)

Firm Operations 11 - 22

Disclosure Events 23

http://www.finra.org

About BrokerCheck®

BrokerCheck offers information on all current, and many former, registered securities brokers, and all current and formerregistered securities firms. FINRA strongly encourages investors to use BrokerCheck to check the background ofsecurities brokers and brokerage firms before deciding to conduct, or continue to conduct, business with them.

· What is included in a BrokerCheck report?· BrokerCheck reports for individual brokers include information such as employment history, professional

qualifications, disciplinary actions, criminal convictions, civil judgments and arbitration awards. BrokerCheckreports for brokerage firms include information on a firm’s profile, history, and operations, as well as many of thesame disclosure events mentioned above.

· Please note that the information contained in a BrokerCheck report may include pending actions orallegations that may be contested, unresolved or unproven. In the end, these actions or allegations may beresolved in favor of the broker or brokerage firm, or concluded through a negotiated settlement with noadmission or finding of wrongdoing.

· Where did this information come from?· The information contained in BrokerCheck comes from FINRA’s Central Registration Depository, or

CRD® and is a combination of: o information FINRA and/or the Securities and Exchange Commission (SEC) require brokers and

brokerage firms to submit as part of the registration and licensing process, and o information that regulators report regarding disciplinary actions or allegations against firms or brokers.

· How current is this information?· Generally, active brokerage firms and brokers are required to update their professional and disciplinary

information in CRD within 30 days. Under most circumstances, information reported by brokerage firms, brokersand regulators is available in BrokerCheck the next business day.

· What if I want to check the background of an investment adviser firm or investment adviserrepresentative?

· To check the background of an investment adviser firm or representative, you can search for the firm orindividual in BrokerCheck. If your search is successful, click on the link provided to view the available licensingand registration information in the SEC's Investment Adviser Public Disclosure (IAPD) website athttps://www.adviserinfo.sec.gov. In the alternative, you may search the IAPD website directly or contact yourstate securities regulator at http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/P455414.

· Are there other resources I can use to check the background of investment professionals?· FINRA recommends that you learn as much as possible about an investment professional before

deciding to work with them. Your state securities regulator can help you research brokers and investment adviserrepresentatives doing business in your state.

·Thank you for using FINRA BrokerCheck.

For more information aboutFINRA, visit www.finra.org.

Using this site/information meansthat you accept the FINRABrokerCheck Terms andConditions. A complete list ofTerms and Conditions can befound at

For additional information aboutthe contents of this report, pleaserefer to the User Guidance orwww.finra.org/brokercheck. Itprovides a glossary of terms and alist of frequently asked questions,as well as additional resources.

brokercheck.finra.org


https://www.AdviserInfo.sec.gov

http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/P455414


http://brokercheck.finra.org/Support/Terms


CRD# 45993

SEC# 8-51269

Main Office Location

329 PARK AVENUE NORTHSUITE 350WINTER PARK, FL 32789Regulated by FINRA Florida Office

Mailing Address

329 PARK AVENUE NORTHSUITE 350WINTER PARK, FL 32789

Business Telephone Number

407-741-5300

Report Summary for this Firm

This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.

Disclosure Events

Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.

Are there events disclosed about this firm? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 14

Firm Profile

This firm is classified as a corporation.

This firm was formed in Florida on 05/29/1998.

Its fiscal year ends in September.

Firm History

Information relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.

Firm Operations

Is this brokerage firm currently suspended with anyregulator? No

This firm conducts 15 types of businesses.

This firm is affiliated with financial or investmentinstitutions.

This firm has referral or financial arrangements withother brokers or dealers.

This firm is registered with:

• the SEC• 4 Self-Regulatory Organizations• 53 U.S. states and territories

www.finra.org/brokercheck User Guidance

1©2018 FINRA. All rights reserved. Report about INTL FCSTONE FINANCIAL INC.


http://www.finra.org/brokercheck

http://www.finra.org/brokercheck_reports


This firm is classified as a corporation.

This firm was formed in Florida on 05/29/1998.

CRD#

This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.

Firm Profile

Firm Names and Locations

Its fiscal year ends in September.


SEC#

45993

8-51269

Main Office Location

Mailing Address

Business Telephone Number

Doing business as INTL FCSTONE FINANCIAL INC.

407-741-5300

Regulated by FINRA Florida Office



Other Names of this Firm

Name Where is it used

INTL FCSTONE SECURITIES INC. AK, AL, AR, AZ, CA,CO, CT, DC, DE, FL,GA, HI, IA, ID, IL, IN,KS, KY, LA, MA, MD,MI, MN, MO, MS, MT,NC, ND, NE, NH, NJ,NM, NV, NY, OH, OK,OR, PA, RI, SC, SD,TN, TX, UT, VA, VT,WA, WI, WV, WY






AK, AL, AR, AZ, CA,CO, CT, DC, DE, FL,GA, HI, IA, ID, IL, IN,KS, KY, LA, MA, MD,MI, MN, MO, MS, MT,NC, ND, NE, NH, NJ,NM, NV, NY, OH, OK,OR, PA, RI, SC, SD,TN, TX, UT, VA, VT,WA, WI, WV, WY





This section provides information relating to all direct owners and executive officers of the brokerage firm.

Direct Owners and Executive Officers

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

INTL FCSTONE INC

OWNER

75% or more

Yes

Domestic Entity

05/1998

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


DUNAWAY, WILLIAM JOHN

DIRECTOR/CFO

Less than 5%

No

Individual

07/2015

Yes

6505923



Position


Position Start Date

HARROD, PATRICIA MARIE

DIRECTOR/CHIEF RISK OFFICER

Less than 5%

Individual

12/2015

6180887








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


HUYNH, KIET TUAN

DEPUTY CHIEF OPERATING OFFICER-BD DIVISION

Less than 5%

No

Individual

12/2015

Yes

4302847



Position



Position Start Date


LING, PHILIP JASON

HEAD OF SECURITIES OPERATIONS

Less than 5%

No

Individual

10/2016

Yes

2805165



LYON, CHARLES MARTIN

4000852








Firm Profile

Position



Position Start Date


DIRECTOR/EXEC VP -BD DIVISION

Less than 5%

No

Individual

07/2015

Yes

4000852


Position



Position Start Date


NGUYEN, XUONG THO

DIRECTOR/CHIEF OPERATING OFFICER

Less than 5%

Individual

12/2015

Yes

2249867



Position


Position Start Date


O'CONNOR, SEAN MICHAEL

DIRECTOR/CEO/PRESIDENT

Less than 5%

Individual

07/2015

Yes

2534352









Firm Profile



No

Yes

Position



Position Start Date


PAVERMAN, MARK ELLIOT

CCO-BD DIVISION

Less than 5%

No

Individual

01/2015

Yes

1046105



Position



Position Start Date


PTASINSKI, STEVE FRANK

DIRECTOR OF REGULATORY ACCOUNTING/FINOP

Less than 5%

No

Individual

05/2015

Yes

2415923



SEPHTON, BRIAN TRIGGER

Individual

4141441









Firm Profile

Position



Position Start Date


DIRECTOR/EXECUTIVE V P

Less than 5%

No

Individual

11/2009

Yes


Position



Position Start Date


SMITH, PHILIP ANDREW MR

DIRECTOR

Less than 5%

No

Individual

12/2015

No

4999097








This section provides information relating to any indirect owners of the brokerage firm.

Indirect Owners

Firm Profile

No information reported.






Firm History

This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

No information reported.






Firm Operations

RegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.

This firm is currently registered with the SEC, 4 SROs and 53 U.S. states and territories.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

This firm has ceased activity as a government securities broker or dealer:

Yes

Yes

No

No

Federal Regulator Status Date Effective

SEC Approved 03/22/1999

Self-Regulatory Organization Status Date Effective

FINRA Approved 03/22/1999

Investors' Exchange LLC Approved 08/10/2016

NYSE Arca, Inc. Approved 12/16/2010

Nasdaq Stock Market Approved 07/12/2006






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 12/17/2013

Alaska Approved 01/11/2013

Arizona Approved 01/24/2013

Arkansas Approved 02/11/2013

California Approved 10/22/1999

Colorado Approved 01/25/2013

Connecticut Approved 11/17/1999

Delaware Approved 11/19/2012

District of Columbia Approved 02/05/2013

Florida Approved 03/25/1999

Georgia Approved 01/22/2013

Hawaii Approved 09/05/2014

Idaho Approved 01/04/2013

Illinois Approved 03/29/1999

Indiana Approved 01/25/2013

Iowa Approved 01/04/2013

Kansas Approved 02/11/2013

Kentucky Approved 04/15/2013

Louisiana Approved 01/02/2013

Maine Approved 06/30/2017

Maryland Approved 11/26/2003

Massachusetts Approved 10/28/1999

Michigan Approved 12/22/1999

Minnesota Approved 08/20/2012

Mississippi Approved 01/10/2013

Missouri Approved 03/11/2013

Montana Approved 01/08/2013

Nebraska Approved 01/25/2013

Nevada Approved 02/06/2013

New Hampshire Approved 04/12/2013

New Jersey Approved 12/16/1999

New Mexico Approved 02/22/2013

New York Approved 12/21/1999

U.S. States &Territories

Status Date Effective

North Carolina Approved 01/03/2013

North Dakota Approved 01/03/2014

Ohio Approved 01/25/2013

Oklahoma Approved 01/07/2013

Oregon Approved 03/27/2013

Pennsylvania Approved 01/14/2011

Puerto Rico Approved 04/11/2018

Rhode Island Approved 01/03/2013

South Carolina Approved 01/30/2013

South Dakota Approved 01/07/2013

Tennessee Approved 02/12/2013

Texas Approved 10/26/1999

Utah Approved 01/17/2013

Vermont Approved 03/06/2013

Virgin Islands Approved 03/23/2018

Virginia Approved 05/12/2005

Washington Approved 01/09/2013

West Virginia Approved 03/19/2013

Wisconsin Approved 02/01/2013

Wyoming Approved 01/22/2013






Firm Operations

Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.

Other Types of Business

This firm does effect transactions in commodities, commodity futures, or commodity options.This firm does engage in other non-securities business.

Non-Securities Business Description: FCM DIVISION OF INTL FCSTONE FINANCIAL INC CONDUCTS ACOMMODITIES BUSINESS AND ENGAGES IN:EXCHANGE MEMBER ENGAGED IN EXCHANGE COMMISSIONBUSINESS OTHER THAN FLOOR ACTIVITIES.

EXCHANGE MEMBER ENGAGED IN FLOOR ACTIVITIES

COMMODITY TRADING ADVISOR

This firm currently conducts 15 types of businesses.

Types of Business

Exchange member engaged in exchange commission business other than floor activities

Broker or dealer making inter-dealer markets in corporation securities over-the-counter

Broker or dealer retailing corporate equity securities over-the-counter

Broker or dealer selling corporate debt securities

Underwriter or selling group participant (corporate securities other than mutual funds)

Mutual fund retailer

U S. government securities dealer

U S. government securities broker

Municipal securities dealer

Municipal securities broker

Put and call broker or dealer or option writer

Non-exchange member arranging for transactions in listed securities by exchange member

Trading securities for own account

Private placements of securities

Other - -PIGGYBACKING ARRANGEMENTS-CLEARING, SETTLEMENT AND CUSTODY SERVICES FOR BROKER-DEALERS AND FOREIGN FINANCIALINSTITUTIONS.-PRINCIPAL U.S. LIAISON TO INTERNATIONAL ISSUERS SEEKING LISTING ON THE OTCQX.-PREPARE AND DISTRIBUTE EQUITY RESEARCH TO INSTITUTIONS AND BROKER-DEALERS.-MONEY MARKET SECURITIES BROKER OR DEALER.-STOCK BORROWING AND STOCK LOAN CONDUIT BUSINESS.-OPERATION OF SOFT DOLLARS PROGRAM UNDER SECTION 28(E).-REPURCHASE AND REVERSE REPURCHASE TRANSACTIONS.






FCM DIVISION OF INTL FCSTONE FINANCIAL INC CONDUCTS ACOMMODITIES BUSINESS AND ENGAGES IN:EXCHANGE MEMBER ENGAGED IN EXCHANGE COMMISSIONBUSINESS OTHER THAN FLOOR ACTIVITIES.

EXCHANGE MEMBER ENGAGED IN FLOOR ACTIVITIES

COMMODITY TRADING ADVISOR





Firm Operations

Clearing Arrangements

This firm does hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does refer or introduce customers to other brokers and dealers.

Name: PERSHING LLC

Business Address: ONE PERSHING PLAZA10TH FLOORJERSEY CITY, NJ 07399

CRD #: 7560

Effective Date: 10/09/2012

Description: PERSHING WILL CARRY THE PROPRIETARY ACCOUNTS OF INTL ANDTHE CASH AND MARGIN ACCOUNTS OF THE CUSTOMERS OF INTLINTRODUCED BY INTL AND ACCEPTED BY PERSHING, AND SHALLCLEAR TRANSACTIONS ON A FULLY DISCLOSED BASIS FOR SUCHACCOUNTS.

Name: MERRILL LYNCH PIERCE FENNER & SMITH BROADCORT DIVISION

Business Address: 101 HUDSON STREETJERSEY CITY, NJ 07302


Description: INTL TRADING INTRODUCES FULLY DISCLOSED INSTITUTIONALCLIENTS FOR DEBT AND EQUITY TRADING ACCOUNTS.






Firm Operations

Industry Arrangements

This firm does have books or records maintained by a third party.

Name: BLOOMBERG L.P.

Business Address: 731 LEXINGTON AVENEW YORK, NY 10022


Description: BLOOMBERG VAULT MAINTAINS LEGACY ELECTRONICCOMMUNICATIONS FOR GX CLARK/INTL FCSTONE PARTNERS.

Name: QUEST CE

Business Address: 10850 WEST PARK PLACESUITE 1000MILWAUKEE, WI 53224


Description: QUEST CE MAINTAINS OUR FIRM ELEMENT COMPLETION REPORTSWHICH INCLUDE BUT ARE NOT LIMITED TO, ACQ, ACM AND FECOURSES.

Name: GLOBAL RELAY COMMUNICATIONS INC.

Business Address: 220 CAMBIE STREET, 2ND FLOORVANCOUVER, BC, CANADA V6B 2M9


Description: GLOBAL RELAY PROVIDES ARCHIVING FOR OUR ELECTRONICCOMMUNICATIONS, INCLUDING BUT NOT LIMITED TO, EMAIL, INSTANTMESSAGING AND TEXT MESSAGING.

Name: PERSHING LLC


CRD #: 7560








Firm Operations

Industry Arrangements (continued)

This firm does have accounts, funds, or securities maintained by a third party.

PERSHING WILL CARRY THE PROPRIETARY ACCOUNTS OF INTL ANDTHE CASH AND MARGIN ACCOUNTS OF THE CUSTOMERS OF INTLINTRODUCED BY INTL AND ACCEPTED BY PERSHING, AND SHALLCLEAR TRANSACTIONS ON A FULLY DISCLOSED BASIS FOR SUCHACCOUNTS.




Description: BY AGREEMENT, BROADCORT PROVIDES CLEARING AND CUSTODYSERVICES FOR FIXED INCOME AND EQUITY TRANSACTIONS FOR INTLTRADING. PURUSANT TO THE AGREEMENT BROADCORT MAINTAINSCLIENT RECORDS AND TRANSACTION RECORDS.

Name: MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED

Business Address: 4 WORLD FINANCIAL CENTER250 VESEY STREETNEW YORK, NY 10080

CRD #: 7691


Description: INTL FCSTONE FINANCIAL WILL UTILIZE MERRILL LYNCH GLOBALCUSTODY SERVICES TO CLEAR, SETTLE, AND CUSTODY OUR FOREIGNSECURITIES BUSINESS.

Name: PERSHING LLC


CRD #: 7560






Description: PURSUANT TO AN AGREEMENT FOR CLEARING AND CUSTODYSERVICES FOR FIXED INCOME TRANSACTIONS AND EQUITYTRANSACTIONS BROADCORT MAINTAINS ACCOUNTS FOR THETRADING ACTIVITIES OF THE FIRM AND CUSTODIES BOTH FUNDS ANDSECURITIES WITHIN THOSE ACCOUNTS.






Firm Operations

Industry Arrangements (continued)

This firm does have customer accounts, funds, or securities maintained by a third party.

This firm does not have individuals who control its management or policies through agreement.

This firm does not have individuals who wholly or partly finance the firm's business.

Control Persons/Financing

Description: PURSUANT TO AN AGREEMENT FOR CLEARING AND CUSTODYSERVICES FOR FIXED INCOME TRANSACTIONS AND EQUITYTRANSACTIONS BROADCORT MAINTAINS ACCOUNTS FOR THETRADING ACTIVITIES OF THE FIRM AND CUSTODIES BOTH FUNDS ANDSECURITIES WITHIN THOSE ACCOUNTS.

Name: PERSHING LLC


CRD #: 7560






Description: PURSUANT TO AN AGREEMENT BROADCORT PROVIDES CLEARING ANDCUSTODY SERVICES FOR FIXED INCOME AND EQUITY TRANSACTIONSFOR INTL TRADING AND MAINTAINS FUNDS AND SECURITIES IN CLIENTACCOUNTS FOR ITS CUSTOMERS.






Firm Operations

Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.

This firm is, directly or indirectly:

· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.

Yes

No

No

07/01/2016

2 PERIMETER PARK SOUTHSUITE 100 EASTBIRMINGHAM, AL 35243

174182

SA STONE INVESTMENT ADVISORS INC. is under common control with the firm.

WE ARE BOTH WHOLLY OWNED SUBSIDIARIES OF INTL FCSTONE INCDescription:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

No

07/01/2016

2 PERIMETER PARK SOUTHSUITE 100 EASTBIRMINGHAM, AL 35243

18456

SA STONE WEALTH MANAGEMENT INC. is under common control with the firm.

WE ARE BOTH WHOLLY OWNED SUBSIDIARIES OF INTL FCSTONE INC.Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations

Organization Affiliates (continued)

No

Yes

No

07/01/2016

2 PERIMETER PARK SOUTHSUITE 100 WESTBIRMINGHAM, AL 35243

23952

INTL CUSTODY & CLEARING SOLUTIONS INC. is under common control with the firm.

WE ARE BOTH WHOLLY OWNED SUBSIDIARIES OF INTL FCSTONE INC.Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

BRAZIL

Yes

05/31/2012

RUA JOAQUIM FLORIANO413-14 ANDAR - ITAIMSAO PAULO, BRAZIL 04534-000

INTL FCSTONE DVTM LTDA is under common control with the firm.

INTL FCSTONE DVTM LTDA IS UNDER COMMON CONTROL WITH INTLFCSTONE FINANCIAL INC. INTL FCSTONE INC.IS THEIR PARENT COMPANY.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

ENGLAND

Yes

09/01/2011

MOOR HOUSE120 LONDON WALLLONDON, ENGLAND EC2Y 5ET

INTL FCSTONE LTD. is under common control with the firm.

Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations


No

Yes

INTL FCSTONE LTD. IS UNDER COMMON CONTROL WITH INTL FCSTONEFINANCIAL INC. INTL FCSTONE INC. IS THEIR PARENT COMPANY. THISAFFILATE CONDUCTS PRIMARILY COMMODITIES AND SECURITIESBROKERAGE IN LONDON.

Description:



No

Yes

ARGENTINA

Yes

02/19/2004

SARMIENTO 4599º Y 10º PISOBUENOS AIRES, ARGENTINA C1041AAI

INTL CIBSA S.A. is under common control with the firm.

INTL CIBSA IS UNDER THE COMMON CONTROL WITH INTL FCSTONEFINANCIAL INC. INTL FCSTONE INC.IS THEIR PARENT COMPANY.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

No

ARGENTINA

Yes

05/14/2007

SARMIENTO 4599º Y 10º PISOBUENOS AIRES, ARGENTINA C1041AAI

GAINVEST SOCIETE GERENTE DE FONDOS CUMUNES DE INVERSION S.A is under common control with thefirm.

GAINVEST SOCIETE GENERENTE DE FONDOS CUMUNES DE INVERSIONS.A. IS UNDER COMMON CONTROL WITH INTL FCSTONE FINANCIAL. INTLFCSTONE, INC. IS THEIR PARENT COMPANY.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations


This firm is not directly or indirectly, controlled by the following:

· bank holding company· national bank· state member bank of the Federal Reserve System· state non-member bank· savings bank or association· credit union· or foreign bank






Disclosure Events

All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.

Final On AppealPending

Regulatory Event 0 14 0






Disclosure Event Details

What you should know about reported disclosure events:

1. BrokerCheck provides details for any disclosure event that was reported in CRD. It also includessummary information regarding FINRA arbitration awards in cases where the brokerage firm wasnamed as a respondent.

2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a brokerage firm is required to disclose a

particular criminal event.3. Disclosure events in BrokerCheck reports come from different sources:

o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firmand a regulator report information for the same event, both versions of the event will appear in theBrokerCheck report. The different versions will be separated by a solid line with the reporting sourcelabeled.

4. There are different statuses and dispositions for disclosure events: o A disclosure event may have a status of pending, on appeal, or final.

§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently

being appealed.§ A "final" event has been concluded and its resolution is not subject to change.

o A final event generally has a disposition of adjudicated, settled or otherwise resolved.§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter,

or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.

§ A "settled" matter generally involves an agreement by the parties to resolve the matter.Please note that firms may choose to settle customer disputes or regulatory matters forbusiness or other reasons.

§ A "resolved" matter usually involves no payment to the customer and no finding ofwrongdoing on the part of the individual broker. Such matters generally involve customerdisputes.

5. You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure events contained in this BrokerCheck report.

Regulatory - Final

This type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission,foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation orsuspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federalcontractor.

Disclosure 1 of 14

Reporting Source: Regulator

Allegations: CFTC PRESS RELEASE 7644-17, NOVEMBER 14, 2017: THE COMMODITYFUTURES TRADING COMMISSION (CFTC) TODAY ISSUED AN ORDER FILINGAND SETTLING CHARGES AGAINST A COMPANY (THE "COMPANY") FORENTERING INTO MULTIPLE NONCOMPETITIVE TRADES AND AGAINST INTLFCSTONE FINANCIAL INC. (FCSTONE FINANCIAL), A REGISTERED FUTURESCOMMISSION MERCHANT BASED IN CHICAGO, ILLINOIS, FOR REPORTINGNON-BONA FIDE PRICES TO THE CHICAGO MERCANTILE EXCHANGE (CME)BETWEEN DECEMBER 2013 AND MARCH 2014. THE CFTC ORDER ALSOFINDS THAT FCSTONE FINANCIAL FAILED TO HAVE AN ADEQUATESUPERVISORY SYSTEM IN PLACE WITH REGARD TO THE EXECUTION,HANDLING, AND REPORTING OF EXCHANGE FOR RELATED POSITIONTRANSACTIONS (EFRPS). THE CFTC ORDER FINDS THAT ON NUMEROUSOCCASIONS BETWEEN DECEMBER 2013 AND MARCH 2014, THE COMPANYENTERED INTO MULTIPLE EXCHANGE OF FUTURES FOR PHYSICALTRANSACTIONS (EFPS)-ONE TYPE OF EFRP-WITH A COUNTERPARTYWHEREBY CANADIAN DOLLAR (CAD) FUTURES WERE EXCHANGED FORPHYSICAL CANOLA SEED, AND FCSTONE FINANCIAL REPORTED THESETRADES TO THE CME AS EXCHANGE FOR EFRPS. HOWEVER, THE CFTCORDER STATES THAT THOSE EFPS WERE INVALID BECAUSE CADFUTURES AND CANOLA SEED ARE NOT SUFFICIENTLY RELATED ASREQUIRED BY EXCHANGE RULES. ACCORDING TO THE CFTC ORDER,BECAUSE THE FUTURES TRADES WERE EXECUTED NONCOMPETITIVELYAND NOT IN ACCORDANCE WITH EXCHANGE RULES GOVERNING EFRPS,THEY CONSTITUTED "FICTITIOUS SALES" AND RESULTED IN THEREPORTING OF NON-BONA FIDE PRICES IN VIOLATION OF THE CEA ANDCFTC REGULATIONS. THE CFTC ORDER ALSO FINDS THAT FCSTONEFINANCIAL FAILED TO HAVE ADEQUATE COMPLIANCE CONTROLS TOIDENTIFY TRADES IMPROPERLY DESIGNATED AS EFRPS. ACCORDING TOTHE CFTC ORDER, FCSTONE FINANCIAL FAILED TO DETERMINE THAT THEEFPS AT ISSUE HAD THE NECESSARY CORRESPONDING AND RELATEDCASH OR OTC DERIVATIVE POSITION REQUIRED FOR EFRPS. THE CFTCORDER ALSO FINDS THAT FCSTONE FINANCIAL FAILED TO ENSURE THATTHE EFPS AT ISSUE WERE DOCUMENTED PROPERLY. FINALLY, FCSTONEFINANCIAL FAILED TO ENSURE THAT ITS EMPLOYEES INVOLVED IN THEEXECUTION, HANDLING, AND PROCESSING OF EFRPS UNDERSTOOD THEREQUIREMENTS FOR EXECUTING, HANDING, AND PROCESSING VALIDEFRPS.

Current Status: Final






Initiated By: COMMODITY FUTURES TRADING COMMISSION

Principal Sanction(s)/ReliefSought:

Other

Date Initiated: 11/14/2017

Docket/Case Number: 18-05

Principal Product Type: Futures - Commodity

Other Product Type(s):








Other

Other Sanction(s)/ReliefSought:

N/A

Resolution Date: 11/14/2017

Resolution:

Other Sanctions Ordered: UNDERTAKINGS

Sanction Details: THE CFTC ORDER REQUIRES FCSTONE FINANCIAL AND THE COMPANY,JOINTLY AND SEVERALLY, TO PAY A $280,000 CIVIL MONETARY PENALTY, TOCOMPLY WITH CERTAIN UNDERTAKINGS REGARDING THEIR RESPECTIVEPRACTICES REGARDING EFRPS, AND TO CEASE AND DESIST FROMFURTHER VIOLATIONS OF THE COMMODITY EXCHANGE ACT (CEA) ANDCFTC REGULATIONS, AS CHARGED.

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Sanctions Ordered: Monetary/Fine $280,000.00Cease and Desist/Injunction

Order

iReporting Source: Firm








Initiated By: COMMODITY FUTURES TRADING COMMISSION


Other


N/A



Principal Product Type: Futures - Commodity


CFTC PRESS RELEASE 7644-17, NOVEMBER 14, 2017: THE COMMODITYFUTURES TRADING COMMISSION (CFTC) TODAY ISSUED AN ORDER FILINGAND SETTLING CHARGES AGAINST A COMPANY (THE "COMPANY") FORENTERING INTO MULTIPLE NONCOMPETITIVE TRADES AND AGAINST INTLFCSTONE FINANCIAL INC. (FCSTONE FINANCIAL), A REGISTERED FUTURESCOMMISSION MERCHANT BASED IN CHICAGO, ILLINOIS, FOR REPORTINGNON-BONA FIDE PRICES TO THE CHICAGO MERCANTILE EXCHANGE (CME)BETWEEN DECEMBER 2013 AND MARCH 2014. THE CFTC ORDER ALSOFINDS THAT FCSTONE FINANCIAL FAILED TO HAVE AN ADEQUATESUPERVISORY SYSTEM IN PLACE WITH REGARD TO THE EXECUTION,HANDLING, AND REPORTING OF EXCHANGE FOR RELATED POSITIONTRANSACTIONS (EFRPS). THE CFTC ORDER FINDS THAT ON NUMEROUSOCCASIONS BETWEEN DECEMBER 2013 AND MARCH 2014, THE COMPANYENTERED INTO MULTIPLE EXCHANGE OF FUTURES FOR PHYSICALTRANSACTIONS (EFPS)-ONE TYPE OF EFRP-WITH A COUNTERPARTYWHEREBY CANADIAN DOLLAR (CAD) FUTURES WERE EXCHANGED FORPHYSICAL CANOLA SEED, AND FCSTONE FINANCIAL REPORTED THESETRADES TO THE CME AS EXCHANGE FOR EFRPS. HOWEVER, THE CFTCORDER STATES THAT THOSE EFPS WERE INVALID BECAUSE CADFUTURES AND CANOLA SEED ARE NOT SUFFICIENTLY RELATED ASREQUIRED BY EXCHANGE RULES. ACCORDING TO THE CFTC ORDER,BECAUSE THE FUTURES TRADES WERE EXECUTED NONCOMPETITIVELYAND NOT IN ACCORDANCE WITH EXCHANGE RULES GOVERNING EFRPS,THEY CONSTITUTED "FICTITIOUS SALES" AND RESULTED IN THEREPORTING OF NON-BONA FIDE PRICES IN VIOLATION OF THE CEA ANDCFTC REGULATIONS. THE CFTC ORDER ALSO FINDS THAT FCSTONEFINANCIAL FAILED TO HAVE ADEQUATE COMPLIANCE CONTROLS TOIDENTIFY TRADES IMPROPERLY DESIGNATED AS EFRPS. ACCORDING TOTHE CFTC ORDER, FCSTONE FINANCIAL FAILED TO DETERMINE THAT THEEFPS AT ISSUE HAD THE NECESSARY CORRESPONDING AND RELATEDCASH OR OTC DERIVATIVE POSITION REQUIRED FOR EFRPS. THE CFTCORDER ALSO FINDS THAT FCSTONE FINANCIAL FAILED TO ENSURE THATTHE EFPS AT ISSUE WERE DOCUMENTED PROPERLY. FINALLY, FCSTONEFINANCIAL FAILED TO ENSURE THAT ITS EMPLOYEES INVOLVED IN THEEXECUTION, HANDLING, AND PROCESSING OF EFRPS UNDERSTOOD THEREQUIREMENTS FOR EXECUTING, HANDING, AND PROCESSING VALIDEFRPS.


Resolution:

Other Sanctions Ordered: UNDERTAKINGS

Sanction Details: THE CFTC ORDER REQUIRES FCSTONE FINANCIAL AND THE COMPANY,JOINTLY AND SEVERALLY, TO PAY A $280,000 CIVIL MONETARY PENALTY, TOCOMPLY WITH CERTAIN UNDERTAKINGS REGARDING THEIR RESPECTIVEPRACTICES REGARDING EFRPS, AND TO CEASE AND DESIST FROMFURTHER VIOLATIONS OF THE COMMODITY EXCHANGE ACT (CEA) ANDCFTC REGULATIONS, AS CHARGED.

Sanctions Ordered: Monetary/Fine $280,000.00Cease and Desist/Injunction

Order






THE CFTC ORDER REQUIRES FCSTONE FINANCIAL AND THE COMPANY,JOINTLY AND SEVERALLY, TO PAY A $280,000 CIVIL MONETARY PENALTY, TOCOMPLY WITH CERTAIN UNDERTAKINGS REGARDING THEIR RESPECTIVEPRACTICES REGARDING EFRPS, AND TO CEASE AND DESIST FROMFURTHER VIOLATIONS OF THE COMMODITY EXCHANGE ACT (CEA) ANDCFTC REGULATIONS, AS CHARGED.

Disclosure 2 of 14

i


Initiated By: FINRA




Docket/Case Number: 2013038552201

Principal Product Type: Equity Listed (Common & Preferred Stock)


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOCOMPLY WITH REGULATION SHO'S CLOSE-OUT AND PRE-BORROWREQUIREMENTS. THE FINDINGS STATED THAT IN EIGHT INSTANCES, THEFIRM FAILED TO CLOSE OUT FAIL TO DELIVER POSITIONS BY PURCHASINGOR BORROWING SECURITIES OF LIKE KIND AND QUANTITY WITHIN THETIME FRAME PRESCRIBED BY RULE 204(A) OF REGULATION SHO. INSTEADOF PURCHASING OR BORROWING SHARES, THE FIRM CONVERTED ITSLONG POSITIONS IN ORDINARY SHARES INTO AMERICAN DEPOSITARYRECEIPTS (ADRS). THE FINDINGS ALSO STATED THAT IN 273 INSTANCESINVOLVING AN EQUITY SECURITY, THE FIRM, WHICH HAD FAILED TOCLOSE OUT A FAIL TO DELIVER POSITION IN ACCORDANCE WITH RULE204(A) OF REGULATION SHO, ACCEPTED A SHORT SALE ORDER FROMANOTHER PERSON, OR EFFECTED A SHORT SALE FOR ITS OWN ACCOUNT,WITHOUT FIRST BORROWING THE SECURITY, OR ENTERING INTO A BONA-FIDE ARRANGEMENT TO BORROW THE SECURITY, AND DID NOT NOTIFYTHE PARTICIPANT THAT IT WAS SUBJECT TO THE APPLICABLE PRE-BORROW REQUIREMENTS.



Resolution:


No

Acceptance, Waiver & Consent(AWC)





https://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2013038552201


Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND FINED $17,500. FINES PAID IN FULL ONAUGUST 5, 2017.


No

Sanctions Ordered: CensureMonetary/Fine $17,500.00


Initiated By: FINRA






Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOCOMPLY WITH REGULATION SHO'S CLOSE-OUT AND PRE-BORROWREQUIREMENTS. THE FINDINGS STATED THAT IN EIGHT INSTANCES, THEFIRM FAILED TO CLOSE OUT FAIL TO DELIVER POSITIONS BY PURCHASINGOR BORROWING SECURITIES OF LIKE KIND AND QUANTITY WITHIN THETIME FRAME PRESCRIBED BY RULE 204(A) OF REGULATION SHO. INSTEADOF PURCHASING OR BORROWING SHARES, THE FIRM CONVERTED ITSLONG POSITIONS IN ORDINARY SHARES INTO AMERICAN DEPOSITARYRECEIPTS (ADRS). THE FINDINGS ALSO STATED THAT IN 273 INSTANCESINVOLVING AN EQUITY SECURITY, THE FIRM, WHICH HAD FAILED TOCLOSE OUT A FAIL TO DELIVER POSITION IN ACCORDANCE WITH RULE204(A) OF REGULATION SHO, ACCEPTED A SHORT SALE ORDER FROMANOTHER PERSON, OR EFFECTED A SHORT SALE FOR ITS OWN ACCOUNT,WITHOUT FIRST BORROWING THE SECURITY, OR ENTERING INTO A BONA-FIDE ARRANGEMENT TO BORROW THE SECURITY, AND DID NOT NOTIFYTHE PARTICIPANT THAT IT WAS SUBJECT TO THE APPLICABLE PRE-BORROW REQUIREMENTS.











Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $17,500.



Disclosure 3 of 14

i


Initiated By: FINRA

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TODISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN OVER-THE-COUNTER(OTC) SECURITIES IN ITS PUBLIC QUOTATION, WHEN EACH SUCH ORDERWAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OR OFFERIN EACH SUCH SECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TOTHE FIRM'S BID OR OFFER FOR EACH SUCH SECURITY, AND THE SIZE OFTHE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE INRELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER INEACH SUCH SECURITY. THE FINDINGS STATED THAT THE FIRM ACCEPTEDAND HELD CUSTOMER ORDERS, AND FAILED TO EXECUTE ORIMMEDIATELY EXECUTE CUSTOMER ORDERS IN OTC SECURITIES UP TOTHE SIZE AND/OR AT THE SAME OR A BETTER PRICE THAT THE FIRMEXECUTED OR SATISFIED THE CUSTOMER ORDERS. THE FIRM FAILED TOMAKE AN EFFORT TO CROSS MARKETABLE CUSTOMER ORDERS WITHANOTHER ORDER RECEIVED BY THE FIRM ON THE OTHER SIDE OF THEMARKET. THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLESECURITIES LAWS AND REGULATIONS, AND FINRA RULES, CONCERNINGLIMIT ORDER DISPLAY AND TRADING AHEAD OF CUSTOMER ORDERS. THEFIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) FAILED TOPROVIDE FOR ONE OR MORE OF THE MINIMUM REQUIREMENTS FORADEQUATE WSPS REGARDING LIMIT ORDER DISPLAY AND TRADINGAHEAD OF CUSTOMER ORDERS.







Initiated By: FINRA





Principal Product Type: Equity - OTC



Resolution:

Other Sanctions Ordered: INTEREST; UNDERTAKING: REQUIRED TO REVISE THE FIRM'S WRITTENSUPERVISORY PROCEDURES

Sanction Details: THE FIRM WAS CENSURED, FINED $42,500, ORDERED TO PAY $691.85,PLUS INTEREST, IN RESTITUTION TO INVESTORS, AND UNDERTAKES TOREVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES. FINE PAID INFULL ON 3/28/17.


No

Sanctions Ordered: CensureMonetary/Fine $42,500.00Disgorgement/Restitution



Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TODISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN OVER-THE-COUNTER(OTC) SECURITIES IN ITS PUBLIC QUOTATION, WHEN EACH SUCH ORDERWAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OR OFFERIN EACH SUCH SECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TOTHE FIRM'S BID OR OFFER FOR EACH SUCH SECURITY, AND THE SIZE OFTHE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE INRELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER INEACH SUCH SECURITY. THE FINDINGS STATED THAT THE FIRM ACCEPTEDAND HELD CUSTOMER ORDERS, AND FAILED TO EXECUTE ORIMMEDIATELY EXECUTE CUSTOMER ORDERS IN OTC SECURITIES UP TOTHE SIZE AND/OR AT THE SAME OR A BETTER PRICE THAT THE FIRMEXECUTED OR SATISFIED THE CUSTOMER ORDERS. THE FIRM FAILED TOMAKE AN EFFORT TO CROSS MARKETABLE CUSTOMER ORDERS WITHANOTHER ORDER RECEIVED BY THE FIRM ON THE OTHER SIDE OF THEMARKET. THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLESECURITIES LAWS AND REGULATIONS, AND FINRA RULES, CONCERNINGLIMIT ORDER DISPLAY AND TRADING AHEAD OF CUSTOMER ORDERS. THEFIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) FAILED TOPROVIDE FOR ONE OR MORE OF THE MINIMUM REQUIREMENTS FORADEQUATE WSPS REGARDING LIMIT ORDER DISPLAY AND TRADINGAHEAD OF CUSTOMER ORDERS.








Initiated By: FINRA


Civil and Administrative Penalt(ies) /Fine(s)






WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TODISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN OVER-THE-COUNTER(OTC) SECURITIES IN ITS PUBLIC QUOTATION, WHEN EACH SUCH ORDERWAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OR OFFERIN EACH SUCH SECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TOTHE FIRM'S BID OR OFFER FOR EACH SUCH SECURITY, AND THE SIZE OFTHE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE INRELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER INEACH SUCH SECURITY. THE FINDINGS STATED THAT THE FIRM ACCEPTEDAND HELD CUSTOMER ORDERS, AND FAILED TO EXECUTE ORIMMEDIATELY EXECUTE CUSTOMER ORDERS IN OTC SECURITIES UP TOTHE SIZE AND/OR AT THE SAME OR A BETTER PRICE THAT THE FIRMEXECUTED OR SATISFIED THE CUSTOMER ORDERS. THE FIRM FAILED TOMAKE AN EFFORT TO CROSS MARKETABLE CUSTOMER ORDERS WITHANOTHER ORDER RECEIVED BY THE FIRM ON THE OTHER SIDE OF THEMARKET. THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLESECURITIES LAWS AND REGULATIONS, AND FINRA RULES, CONCERNINGLIMIT ORDER DISPLAY AND TRADING AHEAD OF CUSTOMER ORDERS. THEFIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) FAILED TOPROVIDE FOR ONE OR MORE OF THE MINIMUM REQUIREMENTS FORADEQUATE WSPS REGARDING LIMIT ORDER DISPLAY AND TRADINGAHEAD OF CUSTOMER ORDERS.


Resolution:

Other Sanctions Ordered: INTEREST; UNDERTAKING: REQUIRED TO REVISE THE FIRM'S WRITTENSUPERVISORY PROCEDURES

Sanction Details: THE FIRM WAS CENSURED, FINED $42,500, ORDERED TO PAY $691.85,PLUS INTEREST, IN RESTITUTION TO INVESTORS, AND UNDERTAKES TOREVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES.



Disclosure 4 of 14

i







Disclosure 4 of 14


Initiated By: FINRA







Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN 57INSTANCES, THE FIRM ACCEPTED AND HELD 19 CUSTOMER ORDERS,TRADED FOR ITS OWN ACCOUNT AT PRICES THAT WOULD HAVE SATISFIEDTHE CUSTOMER ORDERS, AND FAILED TO EXECUTE OR IMMEDIATELYEXECUTE THE CUSTOMER ORDERS IN OVER-THE-COUNTER (OTC)SECURITIES UP TO THE SIZE AND AT THE SAME PRICE AT WHICH ITTRADED FOR ITS OWN ACCOUNT OR AT A BETTER PRICE. THE FINDINGSSTATED THAT THE FIRM FAILED TO IMPLEMENT POLICIES ANDPROCEDURES THAT REASONABLY AVOID DISPLAYING, OR ENGAGING IN APATTERN OR PRACTICE OF DISPLAYING, LOCKING OR CROSSINGQUOTATIONS IN ANY OTC EQUITY SECURITY. THE FINDING ALSO STATEDTHAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHRESPECT TO CERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS,AND/OR FINRA RULES. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES(WSPS) FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS FORADEQUATE WSPS REGARDING FINRA RULE 6437.



Resolution:


No









Other Sanctions Ordered: INTEREST; UNDERTAKING: REVISE THE FIRM'S WRITTEN SUPERVISORYPROCEDURES

Sanction Details: THE FIRM WAS CENSURED, FINED $22,500, UNDERTAKES TO PAYRESTITUTION IN THE AMOUNT OF $436.98, PLUS INTEREST, TOCUSTOMERS, AND UNDERTAKES TO REVISE ITS WRITTEN SUPERVISORYPROCEDURES. FINE PAID IN FULL ON SEPTEMBER 28, 2015.



Initiated By: FINRA


Other






Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN 57INSTANCES, THE FIRM ACCEPTED AND HELD 19 CUSTOMER ORDERS,TRADED FOR ITS OWN ACCOUNT AT PRICES THAT WOULD HAVE SATISFIEDTHE CUSTOMER ORDERS, AND FAILED TO EXECUTE OR IMMEDIATELYEXECUTE THE CUSTOMER ORDERS IN OVER-THE-COUNTER (OTC)SECURITIES UP TO THE SIZE AND AT THE SAME PRICE AT WHICH ITTRADED FOR ITS OWN ACCOUNT OR AT A BETTER PRICE. THE FINDINGSSTATED THAT THE FIRM FAILED TO IMPLEMENT POLICIES ANDPROCEDURES THAT REASONABLY AVOID DISPLAYING, OR ENGAGING IN APATTERN OR PRACTICE OF DISPLAYING, LOCKING OR CROSSINGQUOTATIONS IN ANY OTC EQUITY SECURITY. THE FINDING ALSO STATEDTHAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHRESPECT TO CERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS,AND/OR FINRA RULES. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES(WSPS) FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS FORADEQUATE WSPS REGARDING FINRA RULE 6437.










Resolution:

Other Sanctions Ordered: INTEREST; UNDERTAKING: REVISE THE FIRM'S WRITTEN SUPERVISORYPROCEDURES

Sanction Details: THE FIRM WAS CENSURED, FINED $22,500, UNDERTAKES TO PAYRESTITUTION IN THE AMOUNT OF $436.98, PLUS INTEREST, TOCUSTOMERS, AND UNDERTAKES TO REVISE ITS WRITTEN SUPERVISORYPROCEDURES.



Disclosure 5 of 14

i


Initiated By: FINRA





Principal Product Type: No Product


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOIMMEDIATELY DISPLAY, ROUTE, EXECUTE, OR CANCEL CUSTOMER LIMITORDERS, WHEN THE PRICE AND THE FULL SIZE OF EACH CUSTOMERLIMIT ORDER WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN SUCHSECURITY.



Resolution:


No









Sanction Details: THE FIRM WAS CENSURED AND FINED $20,000.FINE PAID IN FULL ON NOVEMBER 7, 2014.


No



Initiated By: FINRA







Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOIMMEDIATELY DISPLAY, ROUTE, EXECUTE, OR CANCEL CUSTOMER LIMITORDERS, WHEN THE PRICE AND THE FULL SIZE OF EACH CUSTOMERLIMIT ORDER WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN SUCHSECURITY.



Resolution:












Firm Statement THE FIRM IS AWAITING THE INVOICE FROM FINRA TO PAY THE FINE.

Disclosure 6 of 14

i


Initiated By: FINRA







Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOTRANSMIT REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDITTRAIL SYSTEM (OATS) ON 27 BUSINESS DAYS.



Resolution:


Sanction Details: SEE ABOVE

Regulator Statement FINE PAID IN FULL ON JULY 30, 2014.


No



iReporting Source:







Reporting Source: Firm

Initiated By: FINRA


Censure


FINE





Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOTRANSMIT REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDITTRAIL SYSTEM (OATS) ON 27 BUSINESS DAYS.



Resolution:

Other Sanctions Ordered: NONE

Sanction Details: $13,500.00 WILL BE PAID ONCE THE INVOICE IS RECEIVED FROM THEFINANCE DEPARTMENT AT FINRA.

Firm Statement SEE ABOVE



Disclosure 7 of 14

i


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOCONTEMPORANEOUSLY OR PARTIALLY EXECUTE CUSTOMER LIMITORDERS IN OVER-THE-COUNTER (OTC) SECURITIES AFTER IT TRADEDEACH SUBJECT SECURITY FOR ITS OWN MARKET-MAKING ACCOUNT AT APRICE THAT WOULD HAVE SATISFIED EACH CUSTOMER'S LIMIT ORDER.THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS, AND FINRA RULES, CONCERNING CUSTOMER LIMIT ORDERPROTECTION.








Initiated By: FINRA







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOCONTEMPORANEOUSLY OR PARTIALLY EXECUTE CUSTOMER LIMITORDERS IN OVER-THE-COUNTER (OTC) SECURITIES AFTER IT TRADEDEACH SUBJECT SECURITY FOR ITS OWN MARKET-MAKING ACCOUNT AT APRICE THAT WOULD HAVE SATISFIED EACH CUSTOMER'S LIMIT ORDER.THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS, AND FINRA RULES, CONCERNING CUSTOMER LIMIT ORDERPROTECTION.


Resolution:

Other Sanctions Ordered: RESTITUTION OF $62,297.13, PLUS INTEREST; UNDERTAKING: REQUIREDTO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES


Regulator Statement FINE PAID IN FULL ON MAY 21, 2014.


No




Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOCONTEMPORANEOUSLY OR PARTIALLY EXECUTE CUSTOMER LIMITORDERS IN OVER-THE-COUNTER (OTC) SECURITIES AFTER IT TRADEDEACH SUBJECT SECURITY FOR ITS OWN MARKET-MAKING ACCOUNT AT APRICE THAT WOULD HAVE SATISFIED EACH CUSTOMER'S LIMIT ORDER.THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS, AND FINRA RULES, CONCERNING CUSTOMER LIMIT ORDERPROTECTION.








Initiated By: FINRA


Censure


FINES, UNDERTAKING AND RESTITUTION





WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOCONTEMPORANEOUSLY OR PARTIALLY EXECUTE CUSTOMER LIMITORDERS IN OVER-THE-COUNTER (OTC) SECURITIES AFTER IT TRADEDEACH SUBJECT SECURITY FOR ITS OWN MARKET-MAKING ACCOUNT AT APRICE THAT WOULD HAVE SATISFIED EACH CUSTOMER'S LIMIT ORDER.THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS, AND FINRA RULES, CONCERNING CUSTOMER LIMIT ORDERPROTECTION.


Resolution:

Other Sanctions Ordered: RESTITUTION OF $62,297.13, PLUS INTEREST; UNDERTAKING: REQUIREDTO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES


Firm Statement WHEN LIMIT ORDER PROTECTION WAS AMENDED TO INCLUDE OTCEQUITIES THE FIRM'S THIRD PARTY VENDORS' ORDER MANAGEMENTSYSTEM, BRASS, POPULATED THE ALERTS WITH THE LIMIT PRICE ANDNOT THE TRIGGER PRICE CAUSING SOME CUSTOMER ORDERS TORECEICE A WORSE PRICE THAN THEY WERE DO. IN ADDITION TO THEWRONG PRICE BEING POPULATED BRASS ALSO SURPRESSED ALLPRINCIPAL TRADES FROM THE EXCEPTIONS REPORTS CAUSING THE FIRMTO MISS THE INFERIOR PRICES.



Disclosure 8 of 14

i


Allegations: RULES 204T(A)(3), 204T(B) OF REGULATION SHO, FINRA RULE 2010, NASDRULES 2110, 3010 - INTL FCSTONE SECURITIES INC. HAD FAIL-TO-DELIVERPOSITIONS AT A REGISTERED CLEARING AGENCY IN AN EQUITY SECURITYTHAT WAS ATTRIBUTABLE TO MARKET MAKING ACTIVITIES, AND DID NOTCLOSE OUT THE FAIL-TO-DELIVER POSITIONS BY PURCHASINGSECURITIES OF LIKE KIND AND QUANTITY WITHIN THE TIME FRAMEPRESCRIBED. THE FIRM ACCEPTED SHORT SALE ORDERS FROMANOTHER PERSON, OR EFFECTED SHORT SALES FOR ITS OWN ACCOUNTIN AN EQUITY SECURITY, WITHOUT FIRST BORROWING THE SECURITY, ORENTERING INTO A BONA FIDE ARRANGEMENT TO BORROW THE SECURITY,AND HAD FAIL-TO-DELIVER POSITIONS AT A REGISTERED CLEARINGAGENCY IN SUCH SECURITY THAT HAD NOT BEEN CLOSED OUT INACCORDANCE WITH THE REQUIREMENTS OF PARAGRAPHS (A) AND (B) OFRULE 204T OF REGULATION SHO. THE FIRM'S SUPERVISORY SYSTEM DIDNOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDFINRA RULES CONCERNING RULES 203(B)(3) (THRESHOLD CLOSE OUTREQUIREMENT) AND 204T (CLOSE OUT AND PRE-BORROWREQUIREMENTS) OF REGULATION SHO.







Initiated By: FINRA









Resolution:

Other Sanctions Ordered: UNDERTAKING


No









Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $44,500, AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING RULES203(B)(3) (THRESHOLD CLOSE OUT REQUIREMENT) AND 204T (CLOSE OUTAND PRE-BORROW REQUIREMENTS) OF REGULATION SHO WITHIN 30BUSINESS DAYS OF ACCEPTANCE OF THE AWC BY THE NAC. FINE PAID INFULL ON NOVEMBER 18, 2013.


Initiated By: FINRA


Censure


FINE














Resolution:

Other Sanctions Ordered: UNDERTAKING-UPDATE PROCEDURES

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $44,500, AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING RULES203(B)(3) (THRESHOLD CLOSE OUT REQUIREMENT) AND 204T (CLOSE OUTAND PRE-BORROW REQUIREMENTS) OF REGULATION SHO WITHIN 30BUSINESS DAYS OF ACCEPTANCE OF THE AWC BY THE NAC.

Firm Statement PROCEDURES WERE UPDATED AND SUBMITTED TO FINRA PRIOR TO AWCBEING ISSUED. PAYMENT OF THE FINE IS PENDING NOTIFICATION FROMTHE FINRA FINANCE DEPARTMENT PER INSTRUCTIONS FROM FINRAENFORCEMENT.



Disclosure 9 of 14

i


Initiated By: FINRA







Allegations: FINRA RULE 7450 - INTL TRADING, INC. IMPROPERLY REPORTED ALL OFTHE SAMPLED EXECUTION OR COMBINED ORDER/EXECUTION REPORTSTO THE ORDER AUDIT TRAIL SYSTEM (OATS) WITH A REPORTINGEXCEPTION CODE OF "M.



Resolution: Acceptance, Waiver & Consent(AWC)








Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE THE FIRM IS CENSURED AND FINED $8,500. FINE PAID IN FULLON SEPTEMBER 10, 2012.


No



Initiated By: FINRA


Censure


FINE





Allegations: FINRA RULE 7450 - INTL TRADING, INC. IMPROPERLY REPORTED ALL OFTHE SAMPLED EXECUTION OR COMBINED ORDER/EXECUTION REPORTSTO THE ORDER AUDIT TRAIL SYSTEM (OATS) WITH A REPORTINGEXCEPTION CODE OF "M".



Resolution:










Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE THE FIRM IS CENSURED AND FINED $8,500.

Disclosure 10 of 14

i


Initiated By: FINRA





Principal Product Type: Other

Other Product Type(s): OVER-THE-COUNTER BULLETIN BOARD (OTCBB) SECURITIES

Allegations: NASD RULES 2110, 2320 - IN OTCBB TRANSACTIONS FOR OR WITHCUSTOMERS, INTL TRADING, INC. FAILED TO USE REASONABLEDILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILEDTO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMERS WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $10,000 AND ORDERED TOPAY $355.12, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. AREGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORYPROOF OF RESTITUTION OR OF REASONABLE AND DOCUMENTEDEFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATERTHAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. ANY UNDISTRIBUTEDRESTITUTION AND INTEREST SHALL BE FORWARDED TO THEAPPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED.


No









Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $10,000 AND ORDERED TOPAY $355.12, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. AREGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORYPROOF OF RESTITUTION OR OF REASONABLE AND DOCUMENTEDEFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATERTHAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. ANY UNDISTRIBUTEDRESTITUTION AND INTEREST SHALL BE FORWARDED TO THEAPPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED.


Initiated By: FINRA




CENSURE AND RESTITUTION OF $355.12.





Allegations: IN 19 OTCBB TRANSACTIONS FOR OR WITH A CUSTOMER, THE FIRMFAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET.



Resolution:


Sanction Details: FINE OF $10,000 WAS PAID TO FINRA ON JUNE 17, 2009. RESTITUTION OF$355.12 WAS PAID TO CLIENTS ON APRIL 30, 2009.








Disclosure 11 of 14

i


Initiated By: FINRA






Other Product Type(s): REPORTABLE SECURITIES, NASDAQ SECURITIES

Allegations: NASD RULES 2110, 2111(B), 3010, 6130(D), 6620, INTERPRETATIVE MATERIAL-2110-2 (FORMERLY NASD RULE 6541) - INTL TRADING, INC. FAILED TOREPORT TO THE NASDAQ MARKET CENTER (NMC)(NOW THEFINRA/NASDAQ TRADE REPORTING FACILITY) THE CORRECT SYMBOLINDICATING WHETHER THE FIRM EXECUTED TRANSACTIONS INREPORTABLE SECURITIES IN A PRINCIPAL OR AGENCY CAPACITY. THEFIRM INCORRECTLY REPORTED THE SECOND LEG OF "RISKLESS"PRINCIPAL TRANSACTION(S) AS "PRINCIPAL" TO THE NMC (NOW THEFINRA/NASDAQ TRADE REPORTING FACILITY). THE FIRM FAILED TOPARTIALLY EXECUTE CUSTOMER LIMIT ORDERS WITHIN FIVE MINUTES OFACTIVATION. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE SECURITIES LAWS, REGULATIONS AND/OR NASD RULESADDRESSING QUALITY OF MARKETS AND FAILED TO PROVIDE FORMINIMUM REQUIREMENTS FOR ADEQUATE WRITTEN SUPERVISORYPROCEDURES IN BEST EXECUTION, ORDER HANDLING, TRADEREPORTING AND OTHER TRADING RULES. THE FIRM FAILED TO PROVIDEDOCUMENTARY EVIDENCE THAT IT PERFORMED SUPERVISORY REVIEWSSET FORTH IN ITS WRITTEN SUPERVISORY PROCEDURES CONCERNINGORDER HANDLING, BEST EXECUTION, TRADE REPORTING AND OTHERTRADING RULES. THE FIRM TRADED NASDAQ SECURITIES FOR ITS OWNACCOUNT AT PRICES THAT WOULD SATISFY AN OPEN CUSTOMER MARKETORDER WITHOUT GIVING THE CUSTOMER ORDERS ACONTEMPORANEOUS FILL OR PARTIAL EXECUTION EITHER AT THE SAMEOR BETTER PRICE FOR THE NUMBER OF SHARES THAT WERE TRADEDAHEAD, OR FOR THE NUMBER OF SHARES THAT WERE TRADED AHEADWITHIN 60 SECONDS AND AT THE SAME PRICE RECEIVED BY THEPROPRIETARY TRANSACTIONS.










Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $40,000 AND REQUIRED TOPAY $105, PLUS INTEREST, IN RESTITUTION TO INVESTORS.SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OFREASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECTRESTITUTION SHALL BE SUBMITTED TO FINRA NO LATER THAN 120 DAYSAFTER ACCEPTANCE OF THIS AWC. ANY UNDISTRIBUTED RESTITUTIONAND INTEREST SHALL BE FORWARDED TO THE APPROPRIATE ESCHEAT,UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THESTATE IN WHICH THE CUSTOMER LAST RESIDED. THE FIRM SHALL REVISEITS WRITTEN SUPERVISORY PROCEDURES REGARDING BESTEXECUTION, ORDER HANDLING, TRADE REPORTING AND OTHER TRADINGRULES WITHIN 45 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THENAC.


No




Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY

Allegations: 38 TRANSACTIONS REPORTED IN ERROR AS TO PRINCIPAL OR AGENCY,INCORRECT REPORTING OF 4 RISKLESS PRINCIPAL TRANSACTIONS,FAILURE TO PARTIALLY EXECUTE 4 CUSTOMER LIMIT ORDERS WITHIN 5MINTUES, SUPERVISORY PROCEDURES WERE INADEQUATE TO COVERVIOLATIONS, INADEQUATE DOCUMENTATION OF SUPERVISION, 48INSTANCES OF PROPRIETARY TRADING WITHOUT A CONTEMPORANEOUSCUSTOMER FILL.







Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY




A CENSURE, RESTITUTION OF $105, AND AN UNDERTAKING TO REVISE THEFIRMS WRITTEN SUPERVISORY PROCEDURES.






Resolution:

Other Sanctions Ordered: AN UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORYPROCEDURES IN RESPECT TO SPECIFIC ITEMS.

Sanction Details: THE FIRM WILL PAY ITS FINE UPON NOTIFICATION FROM THE FINANCEDEPARTMENT. FIRM MUST SHOW RESTITUTION OF $105.00 NO LATERTHAN 120 DAYS FOLLOWING 09/08/2008. THE FIRM MUST FULFILL ITSUNDERTAKING TO SUBMIT REVISED SUPERVISORY PROCEDURES WITHIN45 DAYS OF 09/08/2008.

Firm Statement ON AUGUST 13, 2008, THE FIRM SIGNED AN AWC AND SUBMITTED IT TOFINRA. THE AWC WAS ACCEPTED BY NAC AS OF SEPTEMBER 8, 2008.FIRM MUST SHOW RESTITUTION OF $105.00 NO LATER THAN 120 DAYSFOLLOWING 09/08/2008. THE FIRM MUST FULFILL ITS UNDERTAKING TOSUBMIT REVISED SUPERVISORY PROCEDURES WITHIN 45 DAYS OF09/08/2008.



Disclosure 12 of 14

i


Allegations: SEC RULE 15C2-11, NASD RULES 2110, 3010, 6740 - INTL TRADING, INC.SUBMITTED QUOTATIONS ON A QUOTATION MEDIUM AND DID NOT HAVETHE REQUIRED DOCUMENTATION AND DID NOT REPRESENT ACUSTOMER'S INDICATION OF UNSOLICITED CUSTOMER INTEREST; FOREACH QUOTATION, FAILED TO FILE A FORM 211 WITH NASD AT LEASTTHREE BUSINESS DAYS BEFORE THE FIRM'S QUOTATIONS WEREPUBLISHED OR DISPLAYED IN A QUOTATION MEDIUM. THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING SECRULE 15C2-11 AND NASD MARKETPLACE RULE 6740.







Initiated By: NASD






Other Product Type(s): UNKNOWN TYPE OF SECURITIES

SEC RULE 15C2-11, NASD RULES 2110, 3010, 6740 - INTL TRADING, INC.SUBMITTED QUOTATIONS ON A QUOTATION MEDIUM AND DID NOT HAVETHE REQUIRED DOCUMENTATION AND DID NOT REPRESENT ACUSTOMER'S INDICATION OF UNSOLICITED CUSTOMER INTEREST; FOREACH QUOTATION, FAILED TO FILE A FORM 211 WITH NASD AT LEASTTHREE BUSINESS DAYS BEFORE THE FIRM'S QUOTATIONS WEREPUBLISHED OR DISPLAYED IN A QUOTATION MEDIUM. THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING SECRULE 15C2-11 AND NASD MARKETPLACE RULE 6740.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $10,000 AND REQUIRED TOREVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES REGARDINGCOMPLIANCE WITH SEC RULE 15C2-11 AND NASD MARKETPLACE RULE6740 WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THENAC.


No












Initiated By: NASD


Censure


FINE







Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $10,000 AND REQUIRED TOREVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES REGARDINGCOMPLIANCE WITH SEC RULE 15C2-11 AND NASD MARKETPLACE RULE6740 WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THENAC.

Firm Statement ON 8/18/2006 APPLICANT SUBMITTED AN AWC CONSENTING TOSANCTIONS OF A CENSURE AND $10,000 FINE. AWC WAS ACCEPTED ONOCTOBER 5, 2006



Disclosure 13 of 14

i







Initiated By: NASD




Docket/Case Number: CLG050093



Allegations: NASD MARKETPLACE RULE 6130(B) AND NASD CONDUCT RULE 2110-RESPONDENT FIRM FAILED TO ACCEPT OR DECLINE IN ACTTRANSACTIONS IN ELIGIBLE SECURITIES WITHIN TWENTY MINUTES AFTEREXECUTION, APPROXIMATELY THREE PERCENT OF ALL TRANSACTIONSTHAT THE FIRM HAD AN OBLIGATION TO ACCEPT OR DECLINE IN ACT ASTHE OEID DURING THE REVIEW PERIOD.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRMCONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OFFINDINGS; THEREFORE, FIRM IS FINED $5,000.


No

Sanctions Ordered: Monetary/Fine $5,000.00



Allegations: INTL FAILED TO ACCEPT OR DECLINE IN ACT 110 TRANSACTIONS ORAPPROXIMATELY 3% OF ALL TRANSACTIONS IN ELEIGIBLE SECURITIESWITHIN 20 MINUTES THAT INTL HAD AN OBLIGATION TO ACCEPT ORDECLINE IN ACT AS THE OEID DURING THE PERIOD JULY 1, 2004 THROUGHSEPTEMBER 30, 2004.







Initiated By: NASD





Docket/Case Number: CLG050093 AWC



Allegations: INTL FAILED TO ACCEPT OR DECLINE IN ACT 110 TRANSACTIONS ORAPPROXIMATELY 3% OF ALL TRANSACTIONS IN ELEIGIBLE SECURITIESWITHIN 20 MINUTES THAT INTL HAD AN OBLIGATION TO ACCEPT ORDECLINE IN ACT AS THE OEID DURING THE PERIOD JULY 1, 2004 THROUGHSEPTEMBER 30, 2004.


Resolution:


Sanction Details: THE FIRM WAS FINED $5,000. THE FINE WAS PAID ON JULY 26, 2005.

Firm Statement ON MAY 9, 2005 INTL SUBMITTED TO THE NASD AN AWC FOR THEPURPOSE OF PROPOSING A SETTLEMENT OF THE ALLEGED RULEVIOLATIONS. THE SETTLEMENT WAS ACCEPTED ON JULY 7, 2005.

Sanctions Ordered: Monetary/Fine $5,000.00


Disclosure 14 of 14

i


Allegations: NASD CONDUCT RULES 2110, 6620, AND 3010 - RESPONDENT MEMBERFAILED WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGHACT 164 LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITYSECURITIES; RESPONDENT MEMBER FAILED TO DESIGNATE THROUGHACT 76 OF THESE TRANSACTIONS AS LATE; RESPONDENT MEMBERINCORRECTLY DESIGNATED AS "SLD" THROUGH ACT FOUR LAST SALEREPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES EXECUTEDOUTSIDE NORMAL MARKET HOURS; RESPONDENT MEMBER FAILED TOENFORCE SUPERVISORY PROCEDURES REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH NASD'S RULES REGARDING TRADEREPORTING.







Initiated By: NASD




Docket/Case Number: CMS030235



NASD CONDUCT RULES 2110, 6620, AND 3010 - RESPONDENT MEMBERFAILED WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT THROUGHACT 164 LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITYSECURITIES; RESPONDENT MEMBER FAILED TO DESIGNATE THROUGHACT 76 OF THESE TRANSACTIONS AS LATE; RESPONDENT MEMBERINCORRECTLY DESIGNATED AS "SLD" THROUGH ACT FOUR LAST SALEREPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES EXECUTEDOUTSIDE NORMAL MARKET HOURS; RESPONDENT MEMBER FAILED TOENFORCE SUPERVISORY PROCEDURES REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH NASD'S RULES REGARDING TRADEREPORTING.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENTMEMBER CONSENTED TO THE FINDING OF THE ALLEGATIONS AND TO THEFOLLOWING SANCTIONS: CENSURED AND FINED $35,000.00.


No




Initiated By: NASD


Allegations: PRIOR TO 11/01 THE TRADING DEPARTMENT OF INTL TRADING WAS PARTOF INTERNATIONAL ASSETS ADVISORY CORPORATION, A PREVIOUSLYAFFILIATED FIRM. DURING THE PERIOD 11/99 THROUGH 06/01 THE FIRMFAILED TO ENFORCE SUPERVISORY PROCEDURES RELATING TO TRADEREPORTING RULES AND FAILED TO PROPERLY REPORT A NUMBER OFTRANSACTIONS THROUGH ACT.










CENSURE

Docket/Case Number: CMS 030235 AWC




Resolution:


Sanction Details: THE $35,000 FINE WAS COMPOSED OF $20,000 FOR TRADE REPORTINGVIOLATIONS AND $15,000 FOR SUPEVISION VIOLATION.

Firm Statement AWC ACCEPTED BY THE NASD ON OCTOBER 14, 2003.








End of Report

This page is intentionally left blank.





INTL FCSTONE FINANCIAL INC. · PDF fileConditions. A complete list of ... the firm?...

Documents

Transcript of INTL FCSTONE FINANCIAL INC. · PDF fileConditions. A complete list of ... the firm?...