PFS INVESTMENTS INC. · 1 PRIMERICA PARKWAY DULUTH, GA 30099-0001 Regulated by FINRA Atlanta Office...

BrokerCheck Report

PFS INVESTMENTS INC.

Section Title

Report Summary

Firm History

CRD# 10111

1

10

Firm Profile 2 - 9

Page(s)

Firm Operations 11 - 17

Disclosure Events 18

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CRD# 10111

SEC# 8-26486

Main Office Location

1 PRIMERICA PARKWAYDULUTH, GA 30099-0001Regulated by FINRA Atlanta Office

Mailing Address

1 PRIMERICA PARKWAYDULUTH, GA 30099-0001

This firm is a brokerage firm and an investmentadviser firm. For more information aboutinvestment adviser firms, visit the SEC'sInvestment Adviser Public Disclosure website at:

Business Telephone Number

770-381-1000

https://www.adviserinfo.sec.gov

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 18

Arbitration 2

Bond 2

Firm Profile

This firm is classified as a corporation.

This firm was formed in Georgia on 07/07/1981.

Its fiscal year ends in December.

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 3 types of businesses.

This firm is affiliated with financial or investmentinstitutions.

This firm does not have referral or financialarrangements with other brokers or dealers.

This firm is registered with:

• the SEC• 1 Self-Regulatory Organization• 53 U.S. states and territories

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1©2020 FINRA. All rights reserved. Report about PFS INVESTMENTS INC.

https://adviserinfo.sec.gov/firm/summary/10111


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This firm is classified as a corporation.

This firm was formed in Georgia on 07/07/1981.

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 December.


SEC#

10111

8-26486

Main Office Location

Mailing Address

Business Telephone Number

Doing business as PFS INVESTMENTS INC.

770-381-1000

Regulated by FINRA Atlanta Office








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?

PRIMERICA FINANCE CORPORATION

DIRECT OWNER

75% or more

No

Domestic Entity

10/1995

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


FARANDA, ESTELLE DIANE

DIRECTOR AND CHIEF EXECUTIVE OFFICER

Less than 5%

No

Individual

03/2020

Yes

2485373



Position


Position Start Date

FENDLER, JEFFREY SCOTT

EXECUTIVE VICE PRESIDENT

Less than 5%

Individual

08/2016

1241839








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


GRUBENHOFF, SHARON KING

SENIOR VICE PRESIDENT, TREASURER, AND CHIEF FINANCIAL OFFICER

Less than 5%

No

Individual

07/2011

Yes

2234267



Position



Position Start Date


KELLY, WILLIAM ADDAMS


Less than 5%

No

Individual

03/2020

Yes



KYLE-MITCHELL, CYNTHIA EILEEN

IndividualIs this a domestic or foreignentity or an individual?








Firm Profile

Position



Position Start Date


DIRECTOR; EXECUTIVE VICE PRESIDENT-OPERATIONS

Less than 5%

No

Individual

09/2005

Yes


Position



Position Start Date


MILLER, DEBORAH


Less than 5%

No

Individual

05/2010

Yes

3036949



Position


Position Start Date


NEMETZ, WILLIAM JAMES


Less than 5%

Individual

05/2014

Yes

4589878









Firm Profile



No

Yes

Position



Position Start Date


RIVET, LORI ALLISON


Less than 5%

No

Individual

03/2017

Yes

4496273



Position



Position Start Date


SIEGEL, DAVID HOWARD

DIRECTOR AND PRESIDENT

Less than 5%

No

Individual

01/2005

Yes



SUKIN, KAREN LYNN

Individual

6292138









Firm Profile

Position



Position Start Date


EXECUTIVE VICE PRESIDENT AND GENERAL COUNSEL

Less than 5%

No

Individual

06/2015

Yes


Position



Position Start Date


WATTS, JOHN SIMMERMAN III

SENIOR VICE PRESIDENT AND CHIEF COUNSEL

Less than 5%

No

Individual

03/2005

Yes



Position



Position Start Date


WOODRING, DANIEL AARON

EXECUTIVE VICE PRESIDENT AND CHIEF COMPLIANCE OFFICER

Less than 5%

No

Individual

01/2011

Yes

4028705









Firm Profile


No






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

Indirect Owners

Firm Profile

PRIMERICA, INC.

SOLE SHAREHOLDER

PRIMERICA FINANCE CORPORATION

75% or more

Yes

Domestic Entity

04/2010

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established









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, 1 SRO 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

No

No

No

Federal Regulator Status Date Effective

SEC Approved 09/01/1981

Self-Regulatory Organization Status Date Effective

FINRA Approved 09/15/1981






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 10/29/1981

Alaska Approved 08/21/1981

Arizona Approved 09/15/1981

Arkansas Limited 02/06/1986

California Approved 10/05/1981

Colorado Approved 02/01/1983

Connecticut Approved 07/07/1983

Delaware Approved 10/26/1982

District of Columbia Approved 08/19/1981

Florida Approved 04/27/1983

Georgia Approved 10/26/1981

Hawaii Approved 10/01/1981

Idaho Approved 11/03/1981

Illinois Approved 10/01/1981

Indiana Approved 01/04/1982

Iowa Approved 07/14/1983

Kansas Approved 09/08/1981

Kentucky Approved 07/16/1982

Louisiana Approved 04/20/1983

Maine Approved 02/08/1984

Maryland Approved 02/05/1982

Massachusetts Approved 10/29/1981

Michigan Approved 02/02/1983

Minnesota Approved 07/15/1982

Mississippi Approved 10/14/1981

Missouri Approved 07/15/1983

Montana Approved 04/20/1983

Nebraska Approved 10/08/1981

Nevada Approved 07/14/1983

New Hampshire Limited 09/07/1995

New Jersey Approved 07/12/1983

New Mexico Approved 10/21/1981

New York Approved 06/09/1983

U.S. States &Territories

Status Date Effective

North Carolina Approved 07/15/1982

North Dakota Limited 10/21/1981

Ohio Approved 07/16/1982

Oklahoma Approved 07/17/1982

Oregon Approved 10/24/1981

Pennsylvania Approved 09/23/1981

Puerto Rico Approved 09/01/1984

Rhode Island Approved 02/01/1983

South Carolina Approved 11/19/1981

South Dakota Approved 07/15/1982

Tennessee Approved 01/28/1982

Texas Limited 07/22/1983

Utah Approved 04/21/1983

Vermont Approved 02/13/1984

Virgin Islands Approved 03/10/2006

Virginia Approved 12/31/1981

Washington Limited 04/20/1983

West Virginia Approved 10/02/1981

Wisconsin Approved 10/19/1981

Wyoming Approved 07/21/1981






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.

This firm currently conducts 3 types of businesses.

Types of Business

Mutual fund retailer

Broker or dealer selling variable life insurance or annuities

Investment advisory services






Firm Operations

Clearing Arrangements

This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does not refer or introduce customers to other brokers and dealers.






Firm Operations

Industry Arrangements

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

This firm does not have accounts, funds, or securities maintained by a third party.

This firm does not 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.

Control Persons/Financing

Name: RED OAK COMPLIANCE SOFTWARE

Business Address: 1101 ARROW POINT DRIVESUITE 301CEDAR PARK, TX 78613

Effective Date: 10/01/2017

Description: RED OAK COMPLIANCE SOFTWARE INC. KEEPS CERTAIN BOOKS ANDRECORDS OF PFS INVESTMENTS INC.

Name: PRIMERICA LIFE INSURANCE COMPANY, INC.

Business Address: 1 PRIMERICA PARKWAYDULUTH, GA 30099


Description: PRIMERICA LIFE INSURANCE COMPANY, INC. KEEPS CERTAIN BOOKSAND RECORDS OF PFS INVESTMENTS INC.

Name: BUSINESS INFORMATION GROUP, INC.

Business Address: 1105 INDUSTRIAL BLVD.SOUTHHAMPTON, PA 18966


Description: BUSINESS INFORMATION GROUP, INC. KEEPS CERTAIN BOOKS ANDRECORDS OF PFS INVESTMENTS INC.

Name: BNY MELLON INVESTMENT SERVICING (US) INC.

Business Address: 100 FREIGHT STREETCOMMERCE PARKPAWTUCKET, RI 02860


Description: BNY MELLON INVESTMENT SERVICING (US) INC. KEEPS CERTAINBOOKS AND RECORDS OF PFS INVESTMENTS INC.






Firm Operations

Industry Arrangements (continued)

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.






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

Yes

CANADA

Yes

08/22/1991

SUITE 300 PLAZA V2000 ARGENTIA ROADMISSISSAUGA, ONTARIO, CANADA L5N 2R7

PFSL INVESTMENTS CANADA LTD. is under common control with the firm.

APPLICANT AND THIS AFFILIATE ARE INVOLVED IN SECURITIES AND/ORINVESTMENT ADVISORY ACTIVITIES AND ARE OWNED BY THE SAMEPARENT COMPANY,PRIMERICA, INC.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

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 18 0

Arbitration N/A 2 N/A

Bond N/A 2 N/A






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 18

Reporting Source: Regulator

Allegations: UNREGISTERED ACTIVITY

Current Status: Final






Initiated By: MASSACHUSETTS

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

CENSURE, CIVIL AND ADMINISTRATIVE FINE

Date Initiated: 11/26/2019

Docket/Case Number: R-2019-0095

URL for Regulatory Action:

Principal Product Type: No Product

Other Product Type(s):

Allegations: UNREGISTERED ACTIVITY

Resolution Date: 11/26/2019

Resolution:

Other Sanctions Ordered: UNDERTAKINGS

Sanction Details: CEASE AND DESIST, CENSURE, SEEK REGISTRATION OF EMPLOYEES ANDSUPERVISORS THAT MEET THE MASSACHUSETTS DEFINITION OF ANAGENT, REVIEW POLICIES AND PROCEDURES RELATED TO REGISTERINGAGENTS IN MASSACHUSETTS BEFORE PERFORMING THE ACTIVITIES OFAN AGENT.

Sanctions Ordered: CensureMonetary/Fine $75,000.00Cease and Desist/Injunction

Consent

iReporting Source: Firm

Initiated By: MASSACHUSETTS SECURITIES DIVISION OF THE OFFICE OF THESECRETARY OF THE COMMONWEALTH


Docket/Case Number: R-2019-0095

Allegations: IT WAS ALLEGED THAT THE APPLICANT ALLOWED BRANCH MANAGERS (OFOFFICES LOCATED OUTSIDE OF MASSACHUSETTS) WHO WERE NOTTHEMSELVES REGISTERED IN MASSACHUSETTS TO SUPERVISE PFSAGENTS TRANSACTING SECURITIES BUSINESS WITH MASSACHUSETTSRESIDENTS, IN VIOLATION OF THE MASSACHUSETTS SECURITIES ACT.








Cease and Desist


CENSURE, ADMINISTRATIVE PENALTY, UNDERTAKINGS




Resolution:


Sanction Details: $75,000 ADMINISTRATIVE PENALTY WAS PAID IN FULL ON 12/3/2019

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE APPLICANTCONSENTED TO THE ENTRY OF THE ORDER; AGREED TO UNDERTAKE ANDCORRECT DEFICIENCIES; AGREED TO BE CENSURED AND PAY $75,000 INAN ADMINISTRATIVE PENALTY.

Sanctions Ordered: CensureMonetary/Fine $75,000.00Cease and Desist/Injunction

Consent

Disclosure 2 of 18

i


Initiated By: NEVADA


Docket/Case Number: CI12-126


Allegations: REGARDING CHRIS HOWARD'S (CRD #1523819) CONDUCT AND ACTIVITIESCONTAINED WITHIN ADMINISTRATIVE CONSENT ORDER CI12-126-MCF, PFSINVESTMENTS, INC., IS SUBJECT TO THIS ORDER BY THE DIVISION,PURSUANT TO NRS 90.420.1(B), BECAUSE PFS INVESTMENTS, INC., (1)ACCEPTED CHRIS HOWARD'S CHARACTERIZATION OF HIS ROLE INFIDELISOFT AS A PASSIVE INVESTMENT WHEN, IN FACT, IT HAD EVOLVEDOVER TIME, AND (2) PFS INVESTMENTS, INC., DID NOT HAVE APROCEDURE REQUIRING ITS REPRESENTATIVES TO DISCLOSE TO THEFIRM COMPENSATION RECEIVED FROM OUTSIDE MOTIVATIONALSPEAKERS IN CONNECTION WITH SEMINARS THAT PRIMERICA/PFSREPRESENTATIVES MUST PAY A FEE TO ATTEND.








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





Resolution:

Other Sanctions Ordered: PFS INVESTMENTS, INC., WAS ORDERED TO PAY $40,000.00 TOREIMBURSE THE DIVISION FOR ITS SUBSTANTIAL INVESTIGATORY TIME,ATTORNEYS FEES AND COSTS, PURSUANT TO NRS 90.630 AND NRS 90.851;PFS INVESTMENTS, INC. WILL, WITHIN NINETY (90)DAYS, CONDUCT AMANDATORY TRAINING SEMINAR FOR PFSI REGISTEREDREPRESENTATIVES AND SUPERVISORY PERSONNEL WHO ARE DOMICILEDIN OR OPERATE FROM THE STATE OF NEVADA; PFS INVESTMENTS, INC.,WILL, WITHIN NINETY (90) DAYS, AMEND ITS WRITTEN POLICIES ANDPROCEDURES TO REQUIRE ITS REGISTERED REPRESENTATIVESDISCLOSE TO PFS THE RECEIPT OF COMPENSATION FROM OUTSIDEMOTIVATIONAL SPEAKERS IN CONNECTION WITH SEMINARS FOR WHICHPRIMERICA REPRESENTATIVES MUST PAY A FEE TO ATTEND.

Sanction Details: FINE PAID IN FULL.

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

No

Sanctions Ordered: Monetary/Fine $9,000.00

Consent


Initiated By: STATE OF NEVADA OFFICE OF THE SECRETARY OF STATE SECURITIESDIVISION

Allegations: PFSI ACCEPTED A REGISTERED REPRESENTATIVE'S CHARACTERIZATIONOF HIS ROLE WITH A COMPANY AS A PASSIVE INVESTMENT WHEN IT HADEVOLVED OVER TIME. PFSI DID NOT HAVE A PROCEDURE REQUIRING ITSREPRESENTATIVES TO DISCLOSE TO THE FIRM COMPENSATIONRECEIVED FROM OUTSIDE MOTIVATIONAL SPEAKERS IN CONNECTIONWITH SEMINARS THAT PRIMERICA REPRESENTATIVES MUST PAY A FEE TOATTEND.







Initiated By: STATE OF NEVADA OFFICE OF THE SECRETARY OF STATE SECURITIESDIVISION




PAY COSTS OF INVESTIGATION AND ATTORNEY FEES


Docket/Case Number: C112-126-MCF




Resolution:

Other Sanctions Ordered: (1) PAYMENT OF $20,000 TO REIMBURSE THE DIVISION FORINVESTIGATORY TIME AND COST. (2) PAYMENT OF $20,000 TO REIMBURSETHE DIVISION FOR ATTORNEY'S FEES AND COSTS. (3) PAYMENT OF $1000FOR INSPECTION OF RECORDS. (4) CONDUCT TRAINING FOR PFSI'SREGISTERED REPS IN NEVADA. (5) AMEND PFSI MANUAL.

Sanction Details: FINE OF $9000 LEVIED AGAINST PFSI. FINE PAID 06/28/2013.

Firm Statement PAYMENT IN FULL MADE ON 06/28/2013.PFSI MANUAL WILL BE AMENDED WITHIN 60 DAYS OF ORDER.TRAINING WILL BE CONDUCTED WITHIN 60 DAYS OF ORDER (PLANNEDFOR BETWEEN AUGUST 1 AND SEPTEMBER 26, 2013).

Sanctions Ordered: Monetary/Fine $9,000.00Cease and Desist/Injunction

Consent

Disclosure 3 of 18

i


Allegations: SECURITIES EXCHANGE ACT (SEA) SECTION 17(A), SEA RULE 17A-3(A)(17),FINRA RULE 2010, NASD RULES 2110, 3010, 3010(A), 3010(B), 3110, MSRBRULES G-8, G-17, G-27 - PFS INVESTMENTS, INC. ESTABLISHEDPROCEDURES TO COMPLY WITH THE SEC REQUIREMENT TO PROVIDECUSTOMERS WITH A COPY OF THEIR ACCOUNT RECORD, OR ANALTERNATE DOCUMENT WITH THE INFORMATION WITHIN 30 DAYS OF THEOPENING OF THE ACCOUNT AND AT LEAST EVERY 36 MONTHSTHEREAFTER FOR THOSE ACCOUNTS REQUIRING A SUITABILITYDETERMINATION. PRIOR TO RECOMMENDING ANY MUTUAL FUNDPURCHASES, FIRM REGISTERED REPRESENTATIVES OBTAINEDCUSTOMER BACKGROUND INFORMATION AND RECORDED IT ON ANACCOUNT APPLICATION-CLIENT PROFILE FORMS. THE FIRMIMPLEMENTED A NEW SYSTEM TO EFFECT ITS PROCEDURE FORCOMPLIANCE BUT DUE TO PROGRAMMING, DESIGN AND HUMAN ERRORS,THE SYSTEM FAILED TO DETECT THAT CERTAIN CUSTOMERS WERE NOTPROVIDED WITH A COPY OF THEIR ACCOUNT RECORD, OR AN ALTERNATEDOCUMENT, WITHIN 30 DAYS OF THE ACCOUNT AND AT LEAST EVERY 36MONTHS THEREAFTER. THE IMPAIRED SYSTEM WAS LIMITED TO USE FORONLY NON-PLATFORM CUSTOMERS, INCLUDING CUSTOMERS WITH 529PLANS, VARIABLE ANNUITIES AND A SUBSET OF CUSTOMERS WITHMUTUAL FUNDS HELD AT A NON-AFFILIATED TRANSFER AGENT WHICHCONSTITUTED APPROXIMATELY 10 PERCENT OF THE FIRM'S CUSTOMERS.BECAUSE THE FIRM WAS UNABLE TO DETERMINE WITH CERTAINTY WHICHACCOUNTS DID NOT RECEIVE THE ACCOUNT INFORMATION, IT SENTACCOUNT RECORDS TO ALL OF THE NON-PLATFORM CUSTOMERS. THEFIRM'S SUPERVISORY SYSTEM AND WRITTEN SUPERVISORYPROCEDURES DID NOT UNCOVER THE OMISSION AND THEREFORE DIDNOT ACHIEVE COMPLIANCE WITH SECURITIES LAWS AND REGULATIONS,IN THAT THE SUPERVISORY SYSTEM DID NOT REVEAL THAT LETTERS FORNON-PLATFORM TRANSACTIONS HAD NOT BEEN SENT AS REQUIRED. INLIMITED INSTANCES, CUSTOMERS INDICATED ON THEIR INVESTMENTPROFILE QUESTIONNAIRE THAT THEY HAD A SHORT INVESTMENT TIMEHORIZON BUT NEVERTHELESS MADE A MUTUAL FUND INVESTMENT. THEFIRM'S RECORDS OMITTED TO FURTHER DOCUMENT THE CUSTOMERS'RATIONALE FOR INVESTING IN MUTUAL FUNDS SO THAT THE FIRM DIDNOT HAVE A RECORD OF SPECIFIC INVESTMENT RATIONALE FOR THESEINSTANCES.







Initiated By: FINRA




Docket/Case Number: 2011025791201

Principal Product Type: Debt - Municipal

Other Product Type(s): VARIABLE ANNUITIES, 529 PLANS

SECURITIES EXCHANGE ACT (SEA) SECTION 17(A), SEA RULE 17A-3(A)(17),FINRA RULE 2010, NASD RULES 2110, 3010, 3010(A), 3010(B), 3110, MSRBRULES G-8, G-17, G-27 - PFS INVESTMENTS, INC. ESTABLISHEDPROCEDURES TO COMPLY WITH THE SEC REQUIREMENT TO PROVIDECUSTOMERS WITH A COPY OF THEIR ACCOUNT RECORD, OR ANALTERNATE DOCUMENT WITH THE INFORMATION WITHIN 30 DAYS OF THEOPENING OF THE ACCOUNT AND AT LEAST EVERY 36 MONTHSTHEREAFTER FOR THOSE ACCOUNTS REQUIRING A SUITABILITYDETERMINATION. PRIOR TO RECOMMENDING ANY MUTUAL FUNDPURCHASES, FIRM REGISTERED REPRESENTATIVES OBTAINEDCUSTOMER BACKGROUND INFORMATION AND RECORDED IT ON ANACCOUNT APPLICATION-CLIENT PROFILE FORMS. THE FIRMIMPLEMENTED A NEW SYSTEM TO EFFECT ITS PROCEDURE FORCOMPLIANCE BUT DUE TO PROGRAMMING, DESIGN AND HUMAN ERRORS,THE SYSTEM FAILED TO DETECT THAT CERTAIN CUSTOMERS WERE NOTPROVIDED WITH A COPY OF THEIR ACCOUNT RECORD, OR AN ALTERNATEDOCUMENT, WITHIN 30 DAYS OF THE ACCOUNT AND AT LEAST EVERY 36MONTHS THEREAFTER. THE IMPAIRED SYSTEM WAS LIMITED TO USE FORONLY NON-PLATFORM CUSTOMERS, INCLUDING CUSTOMERS WITH 529PLANS, VARIABLE ANNUITIES AND A SUBSET OF CUSTOMERS WITHMUTUAL FUNDS HELD AT A NON-AFFILIATED TRANSFER AGENT WHICHCONSTITUTED APPROXIMATELY 10 PERCENT OF THE FIRM'S CUSTOMERS.BECAUSE THE FIRM WAS UNABLE TO DETERMINE WITH CERTAINTY WHICHACCOUNTS DID NOT RECEIVE THE ACCOUNT INFORMATION, IT SENTACCOUNT RECORDS TO ALL OF THE NON-PLATFORM CUSTOMERS. THEFIRM'S SUPERVISORY SYSTEM AND WRITTEN SUPERVISORYPROCEDURES DID NOT UNCOVER THE OMISSION AND THEREFORE DIDNOT ACHIEVE COMPLIANCE WITH SECURITIES LAWS AND REGULATIONS,IN THAT THE SUPERVISORY SYSTEM DID NOT REVEAL THAT LETTERS FORNON-PLATFORM TRANSACTIONS HAD NOT BEEN SENT AS REQUIRED. INLIMITED INSTANCES, CUSTOMERS INDICATED ON THEIR INVESTMENTPROFILE QUESTIONNAIRE THAT THEY HAD A SHORT INVESTMENT TIMEHORIZON BUT NEVERTHELESS MADE A MUTUAL FUND INVESTMENT. THEFIRM'S RECORDS OMITTED TO FURTHER DOCUMENT THE CUSTOMERS'RATIONALE FOR INVESTING IN MUTUAL FUNDS SO THAT THE FIRM DIDNOT HAVE A RECORD OF SPECIFIC INVESTMENT RATIONALE FOR THESEINSTANCES.


Resolution:


No

Acceptance, Waiver & Consent(AWC)





https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2011025791201


Other Sanctions Ordered: UNDERTAKING

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 $100,000, OF WHICH $50,000IS FOR MSRB RULE VIOLATIONS, REQUIRED TO CORRECT THE CITEDDEFICIENCIES AND WITHIN 90 DAYS OF THE DATE OF THE AWC, AREGISTERED PRINCIPAL ON BEHALF OF THE FIRM SHALL SUBMITWRITTEN CERTIFICATION TO FINRA THAT THE DEFICIENCIES HAVE BEENCORRECTED. FINE PAID IN FULL ON SEPTEMBER 17, 2012.


No

Sanctions Ordered: CensureMonetary/Fine $100,000.00


Initiated By: FINRA




CENSURE; UNDERTAKING



Principal Product Type: Mutual Fund(s)

Other Product Type(s): VARIABLE ANNUITIES; 529 COLLEGE SAVINGS PLANS

Allegations: FINRA ALLEGED THAT PFSI DID NOT PROVIDE CERTAIN CLIENTS WITHCOPIES OF THEIR ACCOUNT INFORMATION WITHIN 30 DAYS AFTER THEACCOUNT BEING OPENED AND EVERY 36 MONTHS THEREAFTER ANDTHAT PFSI'S INVESTOR PROFILE QUESTIONNAIRE FORM HADDEFICIENCIES AS TO CERTAIN PFSI CUSTOMERS WHO MADE SHORT-TERMINVESTMENTS IN MUTUAL FUNDS. FURTHER FINRA ALLEGED THAT THEFIRM'S SUPERVISORY SYSTEM AND WRITTEN SUPERVISORYPROCEDURES FAILED TO DETECT THE DEFICIENCIES. WITHOUTADMITTING OR DENYING ANY OF THE ALLEGATIONS, AND SOLELY FORTHE PURPOSES OF THAT FINRA PROCEEDING, PFSI ENTERED INTO ANAGREEMENT WITH FINRA ON THOSE MATTERS.









CENSURE; UNDERTAKING


Resolution:


Sanction Details: $100,000 FINE PAID 09/17/2012. NONE WAIVED.

Firm Statement FINE HAS BEEN PAID. REQUIRED UNDERTAKING TO CORRECT ISSUESCITED IN AWC IS DUE 90 DAYS AFTER DATE OF AWC. A REGISTEREDPRINCIPAL OF PFSI MUST CERTIFY, IN WRITING, TO FINRA'S ATLANTADISTRICT OFFICE, THAT THE DEFICIENCIES NOTED IN THE AWC HAVEBEEN CORRECTED.



Disclosure 4 of 18

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Reporting Source: Firm

Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY


Censure


$35,000 FINE AND UNDERTAKING.





Allegations: PFS INVESTMENTS INC. FAILED TO RETAIN COPIES OF A PRE-PRINTEDFORM RECEIPT CONTAINED IN ITS STANDARD ACCOUNT APPLICATIONPACKAGE AS REQUIRED BY SEC RULE 17A-4(B)(4).



Resolution:

Other Sanctions Ordered: UNDERTAKING.










Sanction Details: $35,000.00 FINE PAID ON 03/23/2010.

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO SANCTIONS AND ENTRY OF FINDINGS; AGREED TOUNDERTAKE AND CORRECT DEFICIENCIES; AND AGREED THAT THE FIRM'SCOMPLIANCE DIRECTOR WILL CERTIFY, IN WRITING, TO FINRA STAFF, THATDEFICIENCIES HAVE BEEN CORRECTED. CERTIFICATIONS TO BY MADEWITHIN 90 DAYS OF AWC OR SUCH LATER DATE FINRA STAFF MAYAPPROVE.

Disclosure 5 of 18

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Initiated By: FINRA







Allegations: RULE 17A-4 OF THE SECURITIES EXCHANGE ACT OF 1934, FINRA RULE2010 AND NASD RULES 2110 AND 3110: RESPONDENT PFS INVESTMENTS,INC. FAILED TO RETAIN COPIES OF A PRE-PRINTED FORM RECEIPTCONTAINED IN ITS STANDARD ACCOUNT APPLICATION PACKET, ASREQUIRED BY SEC RULE 17A-4(B)(4).



Resolution:


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 $35,000 AND CONSENTS TOUNDERTAKE AND CORRECT THE DEFICIENCIES CONCERNING THERETENTION OF COMPLETED FORM RECEIPTS BY RETAINING COPIES OFCUSTOMER RECEIPTS PROVIDED TO CUSTOMERS AFTER THE NOTICE OFACCEPTANCE OF THIS AWC, AND WITHIN 90 DAYS OF NOTICE OFACCEPTANCE OF THIS AWC, THE FIRM'S COMPLIANCE DIRECTOR SHALLSO CERTIFY IN WRITING TO FINRA STAFF.



Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY


Censure


$35,000 FINE AND UNDERTAKING.





Allegations: PFS INVESTMENTS INC. FAILED TO RETAIN COPIES OF A PRE-PRINTEDFORM RECEIPT CONTAINED IN ITS STANDARD ACCOUNT APPLICATIONPACKAGE AS REQUIRED BY SEC RULE 17A-4(B)(4).



Resolution:


Sanction Details: $35,000.00 FINE PAID ON 03/23/2010.

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO SANCTIONS AND ENTRY OF FINDINGS; AGREED TOUNDERTAKE AND CORRECT DEFICIENCIES; AND AGREED THAT THE FIRM'SCOMPLIANCE DIRECTOR WILL CERTIFY, IN WRITING, TO FINRA STAFF, THATDEFICIENCIES HAVE BEEN CORRECTED. CERTIFICATIONS TO BY MADEWITHIN 90 DAYS OF AWC OR SUCH LATER DATE FINRA STAFF MAYAPPROVE.









WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO SANCTIONS AND ENTRY OF FINDINGS; AGREED TOUNDERTAKE AND CORRECT DEFICIENCIES; AND AGREED THAT THE FIRM'SCOMPLIANCE DIRECTOR WILL CERTIFY, IN WRITING, TO FINRA STAFF, THATDEFICIENCIES HAVE BEEN CORRECTED. CERTIFICATIONS TO BY MADEWITHIN 90 DAYS OF AWC OR SUCH LATER DATE FINRA STAFF MAYAPPROVE.

Disclosure 6 of 18

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Initiated By: FLORIDA


Cease and Desist



Docket/Case Number: 0193-S-3/05




Allegations: FAILURE TO SUPOERVISE



Resolution:

Other Sanctions Ordered:

Sanction Details: NA

Regulator Statement FAILURE TO SUPERVISE


No


Stipulation and Consent

iReporting Source: 29©2020 FINRA. All rights reserved. Report about PFS INVESTMENTS INC.






Initiated By: STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION




CEASE AND DESIST


Docket/Case Number: 0193-S-3/05



Allegations: FAILURE TO SUPERVISE IN CONNECTION WITH A SINGLE MUTUAL FUNDTRANSACTION



Resolution:


Sanction Details: $5,000 FINE PAID ON AUGUST 19, 2005.

Firm Statement IN CONNECTION WITH A SINGLE MUTUAL FUND TRANSACTION INVOLVINGA FORMER REGISTERED REPRESENTATIVE THAT OCCURRED ON ORABOUT NOVEMBER 8, 2001, FLORIDA OFFICE OF FINANCIAL REGULATIONFOUND THE PFS INVESTMENTS VIOLATED NASD RULE 3010 BY FAILING TOADEQUATELY SUPERVISE THE REGISTERED REPRESENTATIVE. PFSINVESTMENTS WAS ORDERED TO CEASE AND DESIST FROM ALL FUTUREAND PRESENT VIOLATIONS OF CHAPTER 517, FLORIDA STATUTES ANDCHAPTER 69W FLORIDA ADMINISTRATIVE CODE. THE FIRM WAS ALSOFINED $5,000. THE FINAL ORDER WAS ENTERED ON FEBRUARY 7, 2006.


Stipulation and Consent

Disclosure 7 of 18

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Allegations: ARTICLE V, SECTIONS 2(C) AND 3(B) OF NASD'S BY-LAWS, NASD RULES2110, 3010 - PFS INVESTMENTS INC. FILED AT LEAST 390 LATEAMENDMENTS TO FORMS U4 AND U5, REPRESENTING APPROXIMATELY64% OF THE REQUIRED AMENDMENTS RELATING TO REPORTABLECUSTOMER COMPLAINTS, TERMINATIONS, REGULATORY ACTIONS, ANDCRIMINAL DISCLOSURES. THE FIRM'S SUPERVISORY SYSTEM ANDPROCEDURES WERE NOT REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH ITS ARTICLE V REPORTING OBLIGATIONS.







Initiated By: NASD




Docket/Case Number: CAF040092



ARTICLE V, SECTIONS 2(C) AND 3(B) OF NASD'S BY-LAWS, NASD RULES2110, 3010 - PFS INVESTMENTS INC. FILED AT LEAST 390 LATEAMENDMENTS TO FORMS U4 AND U5, REPRESENTING APPROXIMATELY64% OF THE REQUIRED AMENDMENTS RELATING TO REPORTABLECUSTOMER COMPLAINTS, TERMINATIONS, REGULATORY ACTIONS, ANDCRIMINAL DISCLOSURES. THE FIRM'S SUPERVISORY SYSTEM ANDPROCEDURES WERE NOT REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH ITS ARTICLE V REPORTING OBLIGATIONS.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, PFS INVESTMENTSINC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, THE FIRM IS CENSURED, FINED $450,000 WHICHSHALL BE PAID WITHIN 10 DAYS OF NOTICE OF ACCEPTANCE OF THISAWC. PROMPTLY FOLLOWING NOTICE OF ACCEPTANCE OF THIS AWC, THEFIRM'S INTERNAL AUDIT DEPT. OR PERSONNEL NOT DIRECTLYRESPONSIBLE FOR THE FIRM'S ARTICLE V REPORTING OBLIGATIONS ANDTHEIR IMMEDIATE SUPERVISORS SHALL CONDUCT AN AUDIT FOR THEPERIOD JANUARY 1, 2004 THROUGH SEPTEMBER 30, 2004 TO ASSESS THEEFFECTIVENESS OF ITS SYSTEM AND PROCEDURES FOR ENSURINGTIMELY FILING OF FORM U4 AND U5 AMENDMENTS AND SHALL PREPARE AWRITTEN REPORT SUMMARIZING FINDINGS AND RECOMMENDATIONS ANDSHALL FOR THE NEXT FOUR CALENDAR QUARTERS BEGINNING FOURTHQUARTER 2004, CONDUCT A SIMILAR AUDIT AND PREPARE A SIMILARWRITTEN AUDIT REPORT. NO LATER THAN 90 DAYS AFTER NOTICE OFACCEPTANCE OF THIS AWC, AN OFFICER OF THE FIRM SHALL CERTIFY INWRITING TO NASD THAT AN AUDIT WAS CONDUCTED AND THE OFFICERHAS REVIEWED THE CURRENT AUDIT REPORT. NO LATER THAN 60 DAYSAFTER THE DATE OF THE REPORT, AN OFFICER SHALL CERTIFY INWRITING TO NASD THAT THE FIRM HAS IMPLEMENTED, OR HAS BEGUN TOIMPLEMENT, ANY RECOMMENDATIONS WITHIN A SPECIFIED TIME PERIOD.NO LATER THAN 60 DAYS AFTER THE LAST DAY OF THE NEXT FOURQUARTERS, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT ANAUDIT WAS CONDUCTED, THE CURRENT AUDIT REPORT WAS REVIEWED,AND RECOMMENDATIONS IMPLEMENTED, OR BEGUN TO BEIMPLEMENTED. NO LATER THAN SIX MONTHS AFTER NOTICE OFACCEPTANCE OF THIS AWC, AN OFFICER SHALL CERTIFY IN WRITING TONASD THAT THE FIRM HAS REVIEWED ITS SYSTEM AND PROCEDURESFOR COMPLYING WITH ITS ARTICLE V REPORTING OBLIGATIONS AND HASESTABLISHED A SYSTEM AND PROCEDURES REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH REPORTING REQUIREMENTS SET FORTHTHEREIN.


No








WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, PFS INVESTMENTSINC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, THE FIRM IS CENSURED, FINED $450,000 WHICHSHALL BE PAID WITHIN 10 DAYS OF NOTICE OF ACCEPTANCE OF THISAWC. PROMPTLY FOLLOWING NOTICE OF ACCEPTANCE OF THIS AWC, THEFIRM'S INTERNAL AUDIT DEPT. OR PERSONNEL NOT DIRECTLYRESPONSIBLE FOR THE FIRM'S ARTICLE V REPORTING OBLIGATIONS ANDTHEIR IMMEDIATE SUPERVISORS SHALL CONDUCT AN AUDIT FOR THEPERIOD JANUARY 1, 2004 THROUGH SEPTEMBER 30, 2004 TO ASSESS THEEFFECTIVENESS OF ITS SYSTEM AND PROCEDURES FOR ENSURINGTIMELY FILING OF FORM U4 AND U5 AMENDMENTS AND SHALL PREPARE AWRITTEN REPORT SUMMARIZING FINDINGS AND RECOMMENDATIONS ANDSHALL FOR THE NEXT FOUR CALENDAR QUARTERS BEGINNING FOURTHQUARTER 2004, CONDUCT A SIMILAR AUDIT AND PREPARE A SIMILARWRITTEN AUDIT REPORT. NO LATER THAN 90 DAYS AFTER NOTICE OFACCEPTANCE OF THIS AWC, AN OFFICER OF THE FIRM SHALL CERTIFY INWRITING TO NASD THAT AN AUDIT WAS CONDUCTED AND THE OFFICERHAS REVIEWED THE CURRENT AUDIT REPORT. NO LATER THAN 60 DAYSAFTER THE DATE OF THE REPORT, AN OFFICER SHALL CERTIFY INWRITING TO NASD THAT THE FIRM HAS IMPLEMENTED, OR HAS BEGUN TOIMPLEMENT, ANY RECOMMENDATIONS WITHIN A SPECIFIED TIME PERIOD.NO LATER THAN 60 DAYS AFTER THE LAST DAY OF THE NEXT FOURQUARTERS, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT ANAUDIT WAS CONDUCTED, THE CURRENT AUDIT REPORT WAS REVIEWED,AND RECOMMENDATIONS IMPLEMENTED, OR BEGUN TO BEIMPLEMENTED. NO LATER THAN SIX MONTHS AFTER NOTICE OFACCEPTANCE OF THIS AWC, AN OFFICER SHALL CERTIFY IN WRITING TONASD THAT THE FIRM HAS REVIEWED ITS SYSTEM AND PROCEDURESFOR COMPLYING WITH ITS ARTICLE V REPORTING OBLIGATIONS AND HASESTABLISHED A SYSTEM AND PROCEDURES REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH REPORTING REQUIREMENTS SET FORTHTHEREIN.


Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS




CENSURE/UNDERTAKING


Docket/Case Number: NASD AWC NO. CAF040092


Other Product Type(s): VARIABLE ANNUITIES

Allegations: FROM JANUARY, 2002 THROUGH MARCH, 2004, APPLICANT FAILED TO FILEIN A TIMELY MANNER CERTAIN AMENDMENTS TO FORMS U4 AND U5, ASREQUIRED BY NASD BY-LAWS, ARTICLE V, SECTIONS (2)(C) AND 3(B).DURING THIS PERIOD, APPLICANT'S SUPERVISORY SYSTEM ANDPROCEDURES WERE NOT REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH ITS ARTICLE V REPORTING OBLIGATIONS.


Appealed To and Date AppealFiled:

N/A







CENSURE/UNDERTAKING


Resolution:

Other Sanctions Ordered: APPLICANT AGREED TO CONDUCT A SERIES OF INTERNAL AUDITS TOEVALUATE THE EFFECTIVENESS OF ITS SYSTEM FOR ENSURING THETIMELY FILING OF AMENDMENTS TO FORM U4 (QUESTION 14) AND FORMU5 (QUESTION 7).

Sanction Details: FINE IN THE AMOUNT OF $450,000 WAS PAID BY THE APPLICANT ON12/07/2004.

Firm Statement TO RESOLVE THIS MATTER, APPLICANT AGREED TO CONDUCT A SERIESOF INTERNAL AUDITS TO EVALUATE THE EFFECTIVENESS OF ITS SYSTEMFOR ENSURING THE TIMELY FILING OF AMENDMENTS TO FORM U4(QUESTION 14)AND FORM U5 (QUESTION 7). IN ADDITION, AN OFFICER OFAPPLICANT MUST CERTIFY THAT SUCH AUDITS HAVE OCCURRED, THATRECOMMENDATIONS FROM THE AUDITS HAVE BEEN IMPLEMENTED ANDTHAT THE FIRM HAS ESTABLISHED SYSTEMS AND PROCEDURESREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASDREPORTING REQUIREMENTS.



Disclosure 8 of 18

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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.




Docket/Case Number: WA-579



Allegations: ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1 AND 21(C) ANDARTICLE IV, SECTION 5 OF THE RULES OF FAIR PRACTICE









Resolution:


Sanction Details: RESPONDENT MEMBER IS CENSURED, FINED $7,500.00 AND IS ORDEREDTO COMPLY WITH ITS VOLUNTARY UNDERTAKING TO IMPLEMENT ANDMAINTAIN PROCEDURES DESIGNED TO ASSURE COMPLIANCE WITH THEREGISTRATION PROVISIONS OF SCHEDULE C OF THE BY-LAWS OF THEASSOCIATION

Regulator Statement [TOP] COMPLAINT NO. WA-579 FILED 4/28/88 BY DISTRICT NO. 10 AGAINST RESPONDENTS FIRST AMERICAN NATIONAL SECURITIES, INC, ETAL, ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1 AND 21(C) ANDARTICLE IV, SECTION 5 OF THE RULES OF FAIR PRACTICE IN THATRESPONDENT MEMBER, ACTING THROUGH RESPONDENT CLAUSE, FAILEDTO HAVE TWO INDIVIDUALS QUALIFIED AND REGISTERED AS INVESTMENT COMPANY AND VARIABLE CONTRACTS PRODUCTS PRINCIPALS NOTWITHSTANDING THAT THESE INDIVIDUALS WERE FUNCTIONING AS PRINCIPALS; PERMITTED AN INDIVIDUAL WHO WAS NOT REGISTERED WITH THE ASSOCIATION IN ANYCAPACITY, TO ACCEPT APPROXIMATELY 50 CUSTOMER ACCOUNTS ONBEHALF OF RESPONDENT MEMBER AND THE MEMBER FAILED TO HAVETHE CUSTOMER ACCOUNTS ACCEPTED BY A PARTNER, OFFICER ORMANAGER AND, RESPONDENT COX FAILED TO RESPOND TO THEASSOCIATION'S REQUESTS FOR INFORMATION MADE PURSUANT TOARTICLE IV, SECTION 5 OF THE RULES OF FAIR PRACTICE. DECISIONRENDERED 3/9/89, WHEREIN THE OFFER OF SETTLEMENT SUBMITTED BYRESPONDENTS MEMBER AND CLAUSE WAS ACCEPTED; THEREFORE,RESPONDENT MEMBER IS CENSURED, FINED $7,500.00 AND IS ORDEREDTO COMPLY WITH ITS VOLUNTARY UNDERTAKING TO IMPLEMENT ANDMAINTAIN PROCEDURES DESIGNED TO ASSURE COMPLIANCE WITH THEREGISTRATION PROVISIONS OF SCHEDULE C OF THE BY-LAWS OF THEASSOCIATION; THE COMPLAINT IS DISMISSED AS TO RESPONDENTCLAUSE, BUT HE IS ORDERED TO COMPLY WITH HIS VOLUNTARY UNDERTAKING TOUSE HIS BEST EFFORTS TO ASSURE THAT RESPONDENT MEMBERIMPLEMENTS AND MAINTAINS PROCEDURES DESIGNED TO ASSURECOMPLIANCE WITH THE REGISTRATION PROVISIONS IN SCHEDULE C OFTHE BY-LAWS OF THE ASSOCIATION. A SEPARATE DECISION WASRENDERED IN REGARD TO RESPONDENT COX. DECISION RENDERED3/9/89, WHEREIN RESPONDENT COX IS CENSURED, FINED $2,500.00,ASSESSED COSTS OF $425.80 AND SUSPENDED FROM ASSOCIATION WITHANY MEMBER OF THE ASSOCIATION IN ANY CAPACITY FOR 6 MONTHS. DECISION IS FINAL 4/22/89. $7,500 PAIDJ&S 4/4/89 - DEPOSIT #729


Consent






[TOP] COMPLAINT NO. WA-579 FILED 4/28/88 BY DISTRICT NO. 10 AGAINST RESPONDENTS FIRST AMERICAN NATIONAL SECURITIES, INC, ETAL, ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1 AND 21(C) ANDARTICLE IV, SECTION 5 OF THE RULES OF FAIR PRACTICE IN THATRESPONDENT MEMBER, ACTING THROUGH RESPONDENT CLAUSE, FAILEDTO HAVE TWO INDIVIDUALS QUALIFIED AND REGISTERED AS INVESTMENT COMPANY AND VARIABLE CONTRACTS PRODUCTS PRINCIPALS NOTWITHSTANDING THAT THESE INDIVIDUALS WERE FUNCTIONING AS PRINCIPALS; PERMITTED AN INDIVIDUAL WHO WAS NOT REGISTERED WITH THE ASSOCIATION IN ANYCAPACITY, TO ACCEPT APPROXIMATELY 50 CUSTOMER ACCOUNTS ONBEHALF OF RESPONDENT MEMBER AND THE MEMBER FAILED TO HAVETHE CUSTOMER ACCOUNTS ACCEPTED BY A PARTNER, OFFICER ORMANAGER AND, RESPONDENT COX FAILED TO RESPOND TO THEASSOCIATION'S REQUESTS FOR INFORMATION MADE PURSUANT TOARTICLE IV, SECTION 5 OF THE RULES OF FAIR PRACTICE. DECISIONRENDERED 3/9/89, WHEREIN THE OFFER OF SETTLEMENT SUBMITTED BYRESPONDENTS MEMBER AND CLAUSE WAS ACCEPTED; THEREFORE,RESPONDENT MEMBER IS CENSURED, FINED $7,500.00 AND IS ORDEREDTO COMPLY WITH ITS VOLUNTARY UNDERTAKING TO IMPLEMENT ANDMAINTAIN PROCEDURES DESIGNED TO ASSURE COMPLIANCE WITH THEREGISTRATION PROVISIONS OF SCHEDULE C OF THE BY-LAWS OF THEASSOCIATION; THE COMPLAINT IS DISMISSED AS TO RESPONDENTCLAUSE, BUT HE IS ORDERED TO COMPLY WITH HIS VOLUNTARY UNDERTAKING TOUSE HIS BEST EFFORTS TO ASSURE THAT RESPONDENT MEMBERIMPLEMENTS AND MAINTAINS PROCEDURES DESIGNED TO ASSURECOMPLIANCE WITH THE REGISTRATION PROVISIONS IN SCHEDULE C OFTHE BY-LAWS OF THE ASSOCIATION. A SEPARATE DECISION WASRENDERED IN REGARD TO RESPONDENT COX. DECISION RENDERED3/9/89, WHEREIN RESPONDENT COX IS CENSURED, FINED $2,500.00,ASSESSED COSTS OF $425.80 AND SUSPENDED FROM ASSOCIATION WITHANY MEMBER OF THE ASSOCIATION IN ANY CAPACITY FOR 6 MONTHS. DECISION IS FINAL 4/22/89. $7,500 PAIDJ&S 4/4/89 - DEPOSIT #729


Initiated By: NASD DISTRICT 10 DBCC




CENSURE AND ORDER TO COMPLY WITH A VOLUNTARY UNDERTAKING TOIMPLEMENT AND MAINTAIN PROCEDURES DESIGNED TO ENSURECOMPLIANCE WITH THE RULES OF THE ASSOCIATION.


Docket/Case Number: WA-579



Allegations: THE COMPLAINT ALLEGED THAT THE COMPANY FAILED TO REGISTER TWOSUPERVISORS AS PRINCIPALS AND FAILED TO ACCEPT APPROXIMATELY50 CUSTOMER ACCOUNTS BY A PARTNER, OFFICER OR MANAGER OF THEFIRM.



Resolution:

Other Sanctions Ordered: AN ORDER TO COMPLY WITH A VOLUNTARY UNDERTAKING TO IMPLEMENTAND MAINTAIN PROCEDURES DESIGNED TO ENSURE COMPLIANCE WITHTHE RULES OF THE ASSOCIATION.

Sanction Details: A FINE IN THE AMOUNT OF $7500 WAS IMPOSED. DATE OF PAYMENT ISNOT KNOWN.

Firm Statement WITHOUT ADMITTING OR DENYING THAT IT VIOLATED ANY OF THE RULESOF THE ASSOCIATION AS ALLEGED IN THE COMPLAINT, THE FIRM AGREEDTO A CENSURE, A FINE OF $7500 AND AN ORDER TO COMPLY WITH AVOLUNTARY UNDERTAKING TO IMPLEMENT AND MAINTAIN PROCEDURESDESIGNED TO ENSURE COMPLIANCE WITH THE RULES OF THEASSOCIATION.


Settled





www.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THAT IT VIOLATED ANY OF THE RULESOF THE ASSOCIATION AS ALLEGED IN THE COMPLAINT, THE FIRM AGREEDTO A CENSURE, A FINE OF $7500 AND AN ORDER TO COMPLY WITH AVOLUNTARY UNDERTAKING TO IMPLEMENT AND MAINTAIN PROCEDURESDESIGNED TO ENSURE COMPLIANCE WITH THE RULES OF THEASSOCIATION.

Disclosure 9 of 18

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Docket/Case Number: NEW-725



Allegations: ALLEGED VIOLATIONS OF ARTICLE III, SECTIONS 1, 18, 27 AND 40 OF THERULES OF FAIR PRACTICE



Resolution:


Sanction Details: RESPONDENT MEMBER IS CENSURED AND FINED $7,500;

Regulator Statement [TOP] COMPLAINT NO. NEW-725 FILED 1/12/90 BY DISTRICT NO. 5 AGAINST RESPONDENTS FIRST AMERICAN NATIONAL SECURITIES.,INC.,ET AL, ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 18, 27 AND40 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENTS OSTER,BUTERA, FRANCIS AND ARSENEAUX ENGAGED IN THE SALE OFUNREGISTERED SECURITIES; FAILED TO EXAMINE THE OPERATIONS,ASSETS, AND GROUP TRAVEL BUSINESS OF AN INVESTMENT BEFOREOFFERING AND SELLING CONTRACTS; MADE FALSE REPRESENTATIONSTO INVESTORS; FAILED TO MAKE CERTAIN DISCLOSURES TO INVESTORS;AND, RESPONDENT MEMBER, ACTING THROUGH RESPONDENT CLAUSE,FAILED TO PROPERLYREGISTER RESPONDENT CRAWFORD WITH THE NASD WHO FUNCTIONEDIN THE CAPACITY OF A PRINCIPAL WITHOUT HAVING SUCCESSFULLYCOMPLETED THE EXAMINATION REQUIREMENTS. DECISION RENDERED9/17/90, WHEREIN THE OFFER OF SETTLEMENT SUBMITTED BYRESPONDENTS WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER ISCENSURED AND FINED $7,500; RESPONDENT OSTER IS CENSURED, FINED$15,000 AND BARRED FROM ASSOCIATION WITH ANY MEMBER OF THENASD IN ANY CAPACITY; THE COMMITTEE DETERMINED TO DISMISS THEALLEGATIONS IN THE FOURTH CAUSE OF THE COMPLAINT, THATRESPONDENT MEMBER FAILED AND NEGLECTED TO REASONABLYSUPERVISE RESPONDENTS CRAWFORD, OSTER, BUTERA, FRANCIS ANDARSENEAUX IN THAT THE FIRM CONDUCTED ITSELF IN AN APPROPRIATEMANNER IN REGARD TO THE SUPERVISION OF ITS REGISTEREDPERSONNEL. ALSO, THE COMMITTEE DETERMINED TO DISMISS ANY ANDALL ALLEGATIONS IN THE SIXTH CAUSE OF THE COMPLAINT AGAINSTRESPONDENT MEMBER AND RESPONDENT CLAUSE THAT RESPONDENTSFAILED TO PROPERLY REGISTER RESPONDENT CRAWFORD IN THAT THEFIRM DEMONISTRATED HOW IT HAS SIGNIFICANTLY UPGRADED ITSREGISTRATION SYSTEM. ***$7,500.00 PAID ON 10/19/90 INVOICE #90-05-1084***


Consent






[TOP] COMPLAINT NO. NEW-725 FILED 1/12/90 BY DISTRICT NO. 5 AGAINST RESPONDENTS FIRST AMERICAN NATIONAL SECURITIES.,INC.,ET AL, ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 18, 27 AND40 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENTS OSTER,BUTERA, FRANCIS AND ARSENEAUX ENGAGED IN THE SALE OFUNREGISTERED SECURITIES; FAILED TO EXAMINE THE OPERATIONS,ASSETS, AND GROUP TRAVEL BUSINESS OF AN INVESTMENT BEFOREOFFERING AND SELLING CONTRACTS; MADE FALSE REPRESENTATIONSTO INVESTORS; FAILED TO MAKE CERTAIN DISCLOSURES TO INVESTORS;AND, RESPONDENT MEMBER, ACTING THROUGH RESPONDENT CLAUSE,FAILED TO PROPERLYREGISTER RESPONDENT CRAWFORD WITH THE NASD WHO FUNCTIONEDIN THE CAPACITY OF A PRINCIPAL WITHOUT HAVING SUCCESSFULLYCOMPLETED THE EXAMINATION REQUIREMENTS. DECISION RENDERED9/17/90, WHEREIN THE OFFER OF SETTLEMENT SUBMITTED BYRESPONDENTS WAS ACCEPTED; THEREFORE, RESPONDENT MEMBER ISCENSURED AND FINED $7,500; RESPONDENT OSTER IS CENSURED, FINED$15,000 AND BARRED FROM ASSOCIATION WITH ANY MEMBER OF THENASD IN ANY CAPACITY; THE COMMITTEE DETERMINED TO DISMISS THEALLEGATIONS IN THE FOURTH CAUSE OF THE COMPLAINT, THATRESPONDENT MEMBER FAILED AND NEGLECTED TO REASONABLYSUPERVISE RESPONDENTS CRAWFORD, OSTER, BUTERA, FRANCIS ANDARSENEAUX IN THAT THE FIRM CONDUCTED ITSELF IN AN APPROPRIATEMANNER IN REGARD TO THE SUPERVISION OF ITS REGISTEREDPERSONNEL. ALSO, THE COMMITTEE DETERMINED TO DISMISS ANY ANDALL ALLEGATIONS IN THE SIXTH CAUSE OF THE COMPLAINT AGAINSTRESPONDENT MEMBER AND RESPONDENT CLAUSE THAT RESPONDENTSFAILED TO PROPERLY REGISTER RESPONDENT CRAWFORD IN THAT THEFIRM DEMONISTRATED HOW IT HAS SIGNIFICANTLY UPGRADED ITSREGISTRATION SYSTEM. ***$7,500.00 PAID ON 10/19/90 INVOICE #90-05-1084***


Initiated By: NASD DISTRICT #5 DBCC




CENSURE


Docket/Case Number: NEW-725



Allegations: THE COMPLAINT ALLEGED THAT 5 OF THE FIRM'S REGISTERED REPSENGAGED IN THE SALE OF UNREGISTERED SECURITIES AND ENGAGED INMANIPULATIVE, DECEPTIVE OR OTHER FRAUDULENT PRACTICES, ANDTHAT THEIR SUPERVISOR AND THE FIRM FAILED TO REASONABLY ANDPROPERLY SUPERVISE THEM; THAT SUCH SUPERVISOR ACTED AS APRINCIPAL WHILE NOT BEING PROPERLY REGISTERED.



Resolution:


Decision & Order of Offer of Settlement






Other Sanctions Ordered: DISTRICT #5 FOUND THAT THE 5 REGISTERED REPRESENTATIVECHARGED HAD USED MANIPULATIVE, DECEPTIVE OR OTHERFRAUDULENT DEVICES, CENSURED EACH OF THEM AND LEVIED FINESAGAINST THEM AGGREGATING $32,500. ONE SUCH REP WAS BARRED;TWO WERE SUSPENDED FOR ONE WEEK; ONE WAS SUSPENDED FORTWO MONTHS AND ONE WAS SUSPENDED FOR THREE MONTHS.

Sanction Details: SPECIFIC DETAILS OF SUSPENSIONS AND BARRING OF THEREPRESENTATIVES IS UNAVAILABLE

Firm Statement DISTRICT #5 FOUND THAT THE FIRM CONDUCTED ITSELF APPROPRIATELYREGARDING ITS SUPERVISION OF REGISTERED REPS; DISMISSEDALLEGATIONS OF THE FIRM'S FAILURE TO REASONABLY SUPERVISE THEREPS AT ISSUE; DISMISSED CHARGES AGAINS THE CHIEF COMPLIANCEOFFICER; FOUND THAT ONE REP HAD ACTED AS A PRINCIPAL WITHOUTHAVING BEEN REGISTERED BY THE FIRM.


Disclosure 10 of 18

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Initiated By: STATE OF WISCONSIN, OFFICER OF THE COMMISSIONER OF SECURITIES





Docket/Case Number: N/A



Allegations: IT WAS ALLEGED THAT THE APPLICANT FAILED TO FILE TIMELY NOTICE OFA CHANGE TO ITS DESIGNATED SUPERVISOR AS REQUIRED BY SECTION4.05(6) AND 4.04(3)OF THE WISCONSIN ADMINISTRATIVE CODE.



Resolution:


Sanctions Ordered: Monetary/Fine $100.00

Other







Sanction Details: A DELIQUENT FILING FEE IN THE AMOUNT OF $100 WAS PAID IN FULL BYTHE APPLICANT.

Firm Statement THE APPLICANT PAID A DELINQUENT FILING FEE IN THE AMOUNT OF$100.00.

Disclosure 11 of 18

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Initiated By: STATE OF WISCONSIN OFFICE OF SECURITIES








Allegations: THE APPLICANT FAILED TO PROPERLY NOTIFY THE STATE OF WISCONSINREGARDING THE OPENINGS OR CLOSINGS OF SEVEN (7) BRANCHOFFICES IN THE STATE.



Resolution:


Sanction Details: A FINE IN THE AMOUNT OF $730.00 WAS PAID IN FULL BY THE APPLICANT.

Firm Statement THE APPLICANT FAILED TO PROPERLY NOTIFY THE STATE REGARDINGTHE OPENINGS OR CLOSINGS OF SEVEN (7) STATE BRANCH OFFICES. THEAPPLICANT PAID FINES AND FEES IN THE AMOUNT OF $730.00

Sanctions Ordered: Monetary/Fine $730.00

Other

Disclosure 12 of 18

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Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION




Docket/Case Number: SEC ADMIN FILE NO. 3-9658, REL 34-40269



Allegations: SEC ADMIN FILE NO. 3-9658, REL 34-40269, DATED JULY 28, 1998 - THESECURITIES AND EXCHANGE COMMISSION (COMMISSION) DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT ADMINISTRATIVEPROCEEDINGS BE INSTITUTED PURSUANT TO SECTIONS 15(B) AND 19(H)OF THE SECURITIES EXCHANGE ACT OF 1934 (EXCHANGE ACT) AGAINSTPFS INVESTMENTS, INC. (PFSI), A BROKER-DEALER REGISTERED WITHTHE COMMISSION. IN ANTICIPATION OF THE INSTITUTION OF THESEADMINISTRATIVE PROCEEDINGS, PFSI HAS SUBMITTED AN OFFER OFSETTLEMENT (OFFER)WHICH THE COMMISSION HAS DETERMINED TOACCEPT.



Resolution:


Sanction Details: SEC NEWS DIGEST, ISSUE NO. 98-145 DATED JULY 29, 1998ENFORCEMENT PROCEEDINGS DISCLOSED; "IN THE MATTER OF PFSINVESTMENTS, INC." ON JULY 28, THE COMMISSION ENTERED AN ORDERINSTITUTING PROCEEDINGS, MAKING FINDINGS AND IMPOSING REMEDIALSANCTIONS AGAINST PFS INVESTMENTS, INC. (PFS) (ORDER). PFSSUBMITTED TO AN OFFER OF SETTLEMENT, IN WHICH IT NEITHER ADMITSNOR DENIES THE FINDINGS CONTAINED IN THE ORDER, CONSENTING TOTHE ENTRY OF THE ORDER. THE ORDER FINDS THAT PFS FAILEDREASONABLY TO SUPERVISE FOUR REGISTERED REPRESENTATIVES,WITHIN THE MEANING OF SECTION 15(B) (4) (E) OF THE EXCHANGE ACT,WITH A VIEW TO PREVENTING VIOLATIONS OF THE ANTI-FRAUDPROVISIONS OF THE FEDERAL SECURITIES LAWS. SPECIFICALLY, THEORDER FINDSTHAT PFS FAILED TO ENACT EFFECTIVE POLICIES AND PROCEDURES TOFOLLOW UP ON THREE COMPLAINTS RECEIVED ABOUT SELLING AWAYACTIVITIES BY REGISTERED REPRESENTATIVES AND THAT THEPROCEDURES THAT WERE IN PLACE WERE INSUFFICIENT TO DETECTWRONGDOING BY THE REGISTERED REPRESENTATIVES. ADDITIONALLY,PFS' ON-SITE COMPLIANCE AUDIT OF THE REGISTEREDREPRESENTATIVES' OFFICES WAS DEFICIENT IN THAT IT DID NOTINCLUDE PROCEDURES TO FOLLOW UP ON COMPLAINTS RECEIVED BYITS COMPLIANCE DEPARTMENTS OR DETECT SELLING AWAY ACTIVITIESBY THE REGISTERED REPRESENTATIVES. THE ORDER CENSURES PFSAND IMPOSES A CIVIL PENALTY IN THE AMOUNT OF $175,000.


Order






SEC NEWS DIGEST, ISSUE NO. 98-145 DATED JULY 29, 1998ENFORCEMENT PROCEEDINGS DISCLOSED; "IN THE MATTER OF PFSINVESTMENTS, INC." ON JULY 28, THE COMMISSION ENTERED AN ORDERINSTITUTING PROCEEDINGS, MAKING FINDINGS AND IMPOSING REMEDIALSANCTIONS AGAINST PFS INVESTMENTS, INC. (PFS) (ORDER). PFSSUBMITTED TO AN OFFER OF SETTLEMENT, IN WHICH IT NEITHER ADMITSNOR DENIES THE FINDINGS CONTAINED IN THE ORDER, CONSENTING TOTHE ENTRY OF THE ORDER. THE ORDER FINDS THAT PFS FAILEDREASONABLY TO SUPERVISE FOUR REGISTERED REPRESENTATIVES,WITHIN THE MEANING OF SECTION 15(B) (4) (E) OF THE EXCHANGE ACT,WITH A VIEW TO PREVENTING VIOLATIONS OF THE ANTI-FRAUDPROVISIONS OF THE FEDERAL SECURITIES LAWS. SPECIFICALLY, THEORDER FINDSTHAT PFS FAILED TO ENACT EFFECTIVE POLICIES AND PROCEDURES TOFOLLOW UP ON THREE COMPLAINTS RECEIVED ABOUT SELLING AWAYACTIVITIES BY REGISTERED REPRESENTATIVES AND THAT THEPROCEDURES THAT WERE IN PLACE WERE INSUFFICIENT TO DETECTWRONGDOING BY THE REGISTERED REPRESENTATIVES. ADDITIONALLY,PFS' ON-SITE COMPLIANCE AUDIT OF THE REGISTEREDREPRESENTATIVES' OFFICES WAS DEFICIENT IN THAT IT DID NOTINCLUDE PROCEDURES TO FOLLOW UP ON COMPLAINTS RECEIVED BYITS COMPLIANCE DEPARTMENTS OR DETECT SELLING AWAY ACTIVITIESBY THE REGISTERED REPRESENTATIVES. THE ORDER CENSURES PFSAND IMPOSES A CIVIL PENALTY IN THE AMOUNT OF $175,000.


Initiated By: SECURITIES EXCHANGE COMMISSION





Docket/Case Number: 3-9658



Allegations: IT WAS ALLEGED THAT THE APPLICANT FAILED REASONABLY TOSUPERVISE CERTAIN REGISTERED REPRESENTATIVE WITH A VIEWTOWARDS PREVENTING UNAUTHORIZED PRIVATE SECURITIESTRANSACTIONS RESULTING IN VIOLATIONS OF THE SECURITIES LAWSWITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT.



Resolution:


Sanction Details: THE FINE IN THE AMOUNT OF $175,000.00 WAS PAID IN FULL BY THEAPPLICANT.

Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE APPLICANTCONSENTED TO THE ENTRY OF THE ORDER AND AGREED TO THEIMPOSITION OF A CONSURE AND $175,000.00 FINE. THE SUBJECTREPRESENTATIVE PARTICIPATED IN UNAPPROVED PRIVATE SECURITIESTRANSACTIONS ON BEHALF OF BASIC ENERGY AND AFFILIATEDRESOURCES (BEAR) WITHOUT GIVING PRIOR WRITTEN NOTICE ORRECEIVING PRIOR WRITTEN AUTHORIZATION TO ENGAGE IN SUCHACTIVITIES.


Order






Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE APPLICANTCONSENTED TO THE ENTRY OF THE ORDER AND AGREED TO THEIMPOSITION OF A CONSURE AND $175,000.00 FINE. THE SUBJECTREPRESENTATIVE PARTICIPATED IN UNAPPROVED PRIVATE SECURITIESTRANSACTIONS ON BEHALF OF BASIC ENERGY AND AFFILIATEDRESOURCES (BEAR) WITHOUT GIVING PRIOR WRITTEN NOTICE ORRECEIVING PRIOR WRITTEN AUTHORIZATION TO ENGAGE IN SUCHACTIVITIES.

Disclosure 13 of 18

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Initiated By: NEBRASKA DEPARTMENT OF BANKING AND FINANCE




Docket/Case Number:


Principal Product Type:


Allegations: PRIMERICA FINANCIAL SERVICES, INC. ("PFS"), ACORPORATION ORGANIZED UNDER THE LAWS OF NEVADA WAS NOTREGISTERED IN NEBRASKA AS A BROKER-DEALER OR ISSUER- DEALERPURSUANT OF THE SECURITIES ACT OF NEBRASKA ("ACT"). WHEN ANADVERTISEMENT APPEARED IN THE LINCOLN, NEBRASKA OFFICIALPHONEBOOK YELLOW PAGES IN DECEMBER, 1991 IN WHICH PFS, BY ANDTHROUGH ITS VARIOUS AGENTS OF FIRST AMERICAN NATIONALSECURITIES, INC. ("FANS"), A RELATED CORPORATION OF PFS,SOLICITED THE GENERAL PUBLIC FOR THE PURCHASE OR SALE OFSECURITIES.



Resolution:


Sanction Details: PFS WAS IN VIOLATION OF THE SECURITIES ACT OFNEBRASKA AND WAS FINED $5000 AND ORDERED TO TAKE APPROPRIATEACTION TO ENSURE COMPLIANCE WITH THE ACT.


Order






Sanction Details: PFS WAS IN VIOLATION OF THE SECURITIES ACT OFNEBRASKA AND WAS FINED $5000 AND ORDERED TO TAKE APPROPRIATEACTION TO ENSURE COMPLIANCE WITH THE ACT.

Regulator Statement CONTACT: NEBRASKA DEPARTMENT OF BANKING ANDFINANCE, 402-471-3445.


Initiated By: NEBRASKA DEPARTMENT OF BANKING AND FINANCE








Allegations: PRIMERICA FINANCIAL SERVICES, INC. (A NEVADA CORPORATION)WASNOT REGISTERED AS A BROKER DEALER IN NEBRASKA. ANADVERTISEMENT APPEARED IN A PHONE BOOK YELLOW PAGES INDECEMBER 1991 IN WHICH PFS, BY AND THROUGH ITS AGENTS OF THEFIRM (A RELATED CORPORATION OF PFS) SOLICITED THE GENERALPUBLIC FOR THE PURCHASE OR SALE OF SECURITIES.



Resolution:

Other Sanctions Ordered: PFS WAS IN VIOLATION OF THE SECURITIES ACT OF NEBRASKA AND WASFINED $5000.00 AND ORDERED TO TAKE APPROPRIATE ACTION TOENSURE COMPLIANCE WITH THE ACT.

Sanction Details: SEE DETAILS ABOVE.

Firm Statement DETAILS ARE AVAILABLE FROM THE NEBRASKA DEPARTMENT OF BANKINGAND FINANCE (402) 471-3445.


Order

Disclosure 14 of 18

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Docket/Case Number: C8A960061



Allegations:



Resolution:


Sanction Details:

Regulator Statement COMPLAINT NO. C8A960061 FILED OCTOBER 10, 1996 BY DISTRICT NO.8 AGAINST PFS INVESTMENTS INC. ALLEGING VIOLATIONS OF NASDRULES 2110 AND 3010(b) OF THE RULES OF FAIR PRACTICE IN THATRESPONDENT MEMBER FAILED TO ESTABLISH, MAINTAIN, AND/ORENFORCEADEQUATE WRITTEN PROCEDURES WHICH WERE REASONABLYDESIGNED TOACHIEVE COMPLIANCE WITH THE NASD'S RULES CONCERNING PRIVATESECURITIES TRANSACTIONS, OR TO OTHERWISE ADEQUATELYSUPERVISETHE ACTIVITIES OF REPRESENTATIVES.

ON APRIL 17, 1997, THE DECISION AND ORDER OF ACCEPTANCE OFOFFER OF SETTLEMENT SUBMITTED BY RESPONDENT MEMBER WASISSUED;THEREFORE, RESPONDENT MEMBER IS CENSURED AND FINED $25,000.

***$25,000.00 WAS PAID ON 5/19/97, INVOICE #97-8A-319***









Initiated By: DISTRICT BUSINESS CONDUCT COMMITTEE-DISTRICT 8 NASD





Docket/Case Number: C8A960061



Allegations: IT WAS ALLEGED THAT THE APPLICANT FAILED TO ESTABLISH, MAINTAIN,AND/OR ENFORCE ADEQUATE WRITTEN PROCEDURES WHICH WEREREASONABLY DESIGNED TO ACHIEVE COMPLIANCE CONCERNINGPRIVATE SECURITIES TRANSACTIONS AND TO ADEQUATELY SUPERVISECERTAIN REPRESENTATIVES.



Resolution:


Sanction Details: A FINE IN THE AMOUNT OF $25000.00 WAS PAID IN FULL BY THEAPPLICANT.

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE APPLICANTCONSENTED TO THE ENTRY OF FINDINGS OF FACTS AND VIOLATIONS ASTO THE AFOREMENTIONED ALLEGATIONS. THE APPLICANT AGREED TOTHE IMPOSITION OF SANCTIONS OF A CENSURE AND A $25,000.00 FINE.THE SUBJECT REPRESENTATIVES IN THE PROCEEDING PARTICIPATED INTRANSACTIONS FOR COMPENSATION WITH PUBLIC CUSTOMERSINVOLVING APPROXIMATELY $1.7 MILLION IN SECURITIES ISSUED BYBASIC ENERGY AND AFFILIATED RESOURCES, INC. (BEAR) WITHOUTGIVING WRITTEN NOTICE OR RECEIVING PRIOR WRITTEN AUTHORIZATIONTO ENGAGE IN SUCH ACTIVITIES. OFFER OF SETTLEMENT WAS ACCEPTEDBY DISTRICT 8 ON JANUARY 30, 1997 AND BY THE NATIONAL BUSINESSCONDUCT COMMITTEE ON APRIL 17, 1997.








Disclosure 15 of 18

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Docket/Case Number: C05910087



Allegations:



Resolution:


Sanction Details:

Regulator Statement ON APRIL 28, 1992, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENTC05910087 (DISTRICT NO. 5) SUBMITTED BY FIRST AMERICAN NATIONALSECURITIES, INC., EDMOND H. RANDLE, JR. AND BARRY M. CLAUSE WASACCEPTED; THERFORE, RESPONDENT MEMBER AND RESPONDENTRANDLE ARECENSURED AND FINED $7,500, JOINTLY AND SEVERALLY; AND,RESPONDENT CLAUSE IS CENSURED AND FINED $2,500 - (ARTICLE III,SECTIONS 1, 21(c) AND 27 OF THE RULES OF FAIR PRACTICE -RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS RANDLE ANDCLAUSE, FAILED TO ADEQUATELY ENFORCE OR MONITOR THE TERMS OFASUSPENSION PLACED ON A REGISTERED REPRESENTATIVE BYRESPONDENTMEMBER AND FAILED TO TAKE ANY ADDITIONAL SUPERVISORY MEASURESDESPITE KNOWING THAT THE REPRESENTATIVE HAD ALREADYCOMMITTEDAN ACT FOR WHICH HE SHOULD HAVE BEEN TERMINATED; INCONTRAVENTION OF THE TERMS OF THE AFOREMENTIONEDSUSPENSION,THE SAME INDIVIDUAL WAS ALLOWED TO COMPLETE AN OFFICECOMPLIANCE CHECKLIST WITH RESPECT TO SECURITIES-RELATEDACTIVITIES TAKING PLACE IN THE BRANCH OFFICE; AND, RESPONDENTMEMBER, ACTING THROUGH RESPONDENT RANDLE, ACCEPTED A NEWACCOUNT APPLICATION FOR A PUBLIC CUSTOMER SUBMITTED BY THESAMEREPRESENATIVE DURING THE SUSPENSION PERIOD WHICH LISTEDANOTHERINDIVIDUAL AS THE REGISTERED REPRESENTATIVE IN ORDER TOCONCEALHIS SOLICIATION, ACCEPTANCE, AND MISUSE OF CUSTOMER FUNDSWHILEUNDER SUSPENSION. THIS APPLICATION WAS ACCEPTED BYRESPONDENTMEMBER WITHOUT THE REVIEW AND ENDORSEMENT OF THEDESIGNATEDBACK OFFICE PRINCIPAL). **$7,500.00 PAID ON 5/15/92 INVOICE #92-05-436**


Consent






ON APRIL 28, 1992, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENTC05910087 (DISTRICT NO. 5) SUBMITTED BY FIRST AMERICAN NATIONALSECURITIES, INC., EDMOND H. RANDLE, JR. AND BARRY M. CLAUSE WASACCEPTED; THERFORE, RESPONDENT MEMBER AND RESPONDENTRANDLE ARECENSURED AND FINED $7,500, JOINTLY AND SEVERALLY; AND,RESPONDENT CLAUSE IS CENSURED AND FINED $2,500 - (ARTICLE III,SECTIONS 1, 21(c) AND 27 OF THE RULES OF FAIR PRACTICE -RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS RANDLE ANDCLAUSE, FAILED TO ADEQUATELY ENFORCE OR MONITOR THE TERMS OFASUSPENSION PLACED ON A REGISTERED REPRESENTATIVE BYRESPONDENTMEMBER AND FAILED TO TAKE ANY ADDITIONAL SUPERVISORY MEASURESDESPITE KNOWING THAT THE REPRESENTATIVE HAD ALREADYCOMMITTEDAN ACT FOR WHICH HE SHOULD HAVE BEEN TERMINATED; INCONTRAVENTION OF THE TERMS OF THE AFOREMENTIONEDSUSPENSION,THE SAME INDIVIDUAL WAS ALLOWED TO COMPLETE AN OFFICECOMPLIANCE CHECKLIST WITH RESPECT TO SECURITIES-RELATEDACTIVITIES TAKING PLACE IN THE BRANCH OFFICE; AND, RESPONDENTMEMBER, ACTING THROUGH RESPONDENT RANDLE, ACCEPTED A NEWACCOUNT APPLICATION FOR A PUBLIC CUSTOMER SUBMITTED BY THESAMEREPRESENATIVE DURING THE SUSPENSION PERIOD WHICH LISTEDANOTHERINDIVIDUAL AS THE REGISTERED REPRESENTATIVE IN ORDER TOCONCEALHIS SOLICIATION, ACCEPTANCE, AND MISUSE OF CUSTOMER FUNDSWHILEUNDER SUSPENSION. THIS APPLICATION WAS ACCEPTED BYRESPONDENTMEMBER WITHOUT THE REVIEW AND ENDORSEMENT OF THEDESIGNATEDBACK OFFICE PRINCIPAL). **$7,500.00 PAID ON 5/15/92 INVOICE #92-05-436**


Initiated By: DISTRICT BUSINESS CONDUCT COMMITTEE-DISTRICT 5 OF THE NASD








Allegations: THE NASD ALLEGED THAT THE APPLICANT AND RANDLE HAD FAILED TOPROPERLY SUPERVISE A REGISTERED REPRESENTATIVE WHO ENGAGEDIN A SECURITIES RELATED ACTIVITY WHILE SUSPENDED.



Resolution: Acceptance, Waiver & Consent(AWC)









Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINEDTHEREIN, THE APPLICANT ENTERED INTO A LETTER OF ACCEPTANCE,WAIVER AND CONSENT (AWC) WITH THE DISTRICT BUSINESS CONDUCTCOMMITTEE FOR DISTRICT 5 OF THE NASD ON MARCH 3, 1992. THEAPPLICANT WAS NOTIFIED ON APRIL 30, 1992 THAT THE AWC AHD BEENACCEPTED BY THE NATIONAL BUSINESS CONDUCT COMMITTEE OF THENASD. THE CONSENT WAS ENTERED AND A CENSURE AND A MONETARYFINE IN THE AMOUNT OF $7,500.00 WAS ASSESSED JOINTLY ANDSEVERALLY AGAINST THE APPLICANT AND EDMOND H. RANDLE, JR.


Disclosure 16 of 18

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Initiated By: VERMONT SECURITIES DIVISION




Docket/Case Number: 91-082-S




Allegations: EFFECTED SECURITIES TRANSACTIONS THROUGHUNREGISTERED AGENTS AND FAILED TO REASONABLY SUPERVISE ITSAGENTS.



Resolution:


Sanction Details: RESPONDENT ENTERED INTO CONSENT ORDER WHEREBY ITAGREED TO PAY A FINE OF $5000 AND INVESTIGATIVE COSTS OF $2000.RESPONDENT ALSO AGREED TO IMPLEMENT A NUMBER OF COMPLIANCEUNDERTAKINGS.


Consent






Sanction Details: RESPONDENT ENTERED INTO CONSENT ORDER WHEREBY ITAGREED TO PAY A FINE OF $5000 AND INVESTIGATIVE COSTS OF $2000.RESPONDENT ALSO AGREED TO IMPLEMENT A NUMBER OF COMPLIANCEUNDERTAKINGS.

Regulator Statement Not Provided


Initiated By: STATE OF VERMONT DEPARTMENT OF SECURITIES








Allegations: ALLEGATIONS AROSE OUT OF CIRCUMSTANCES INVOLVING AREGISTERED PRINCIPAL ALLOWING AN UNLICENSED (PENDING)REPRESENTATIVE TO SOLICIT SECURITIES SALES.



Resolution:



Firm Statement THE APPLICANT ENTERED INTO A CONSENT AGREEMENT WITH THE STATEOF VERMONT ON 10/01/1991. WITHOUT ADMITTING OR DENYINGALLEGATIONS CONTAINED THEREIN, THE APPLICANT PAID A $5,000.00FINE.EDITED DRP TO INCLUDE ITEM # 11D2 PER DEFICIENCY DETAILREPORT.


Consent

Disclosure 17 of 18

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Docket/Case Number: DEN-818-AWC



Allegations:



Resolution:


Sanction Details:

Regulator Statement ON JUNE 19, 1989, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENTNO. DEN-818-AWC (DISTRICT NO. 3) SUBMITTED BY RESPONDENTS FIRSTAMERICAN NATIONAL SECURITIES, INC. AND WALTER L. MORTENSEN WASACCEPTED; THEREFORE, THEY ARE CENSURED AND FINED $2,500.00,JOINTLY AND SEVERALLY - (ARTICLE III, SECTIONS 1 AND 27(c) OFTHE RULES OF FAIR PRACTICE - RESPONDENT MEMBER, OPERATINGTHROUGH RESPONDENT MORTENSEN, ALLOWED AN INDIVIDUAL SUBJECTTO ASTATUTORY DISQUALIFICATION TO EFFECT SECURITIES TRANSACTIONSWITHOUT PROPER SUPERVISION). ** $2,500.00 PAID J & S ON 7/19/89- INVOICE #89-03-180.**


Consent


Allegations: THE COMPANY, OPERATING THROUGH RESPONDENT, WALTER LAMARMORTENSEN, ALLEGEDLY ALLOWED BORIS JEREMENKO, AN INDIVIDUALSUBJECT TO A STATUTORY DISQUALIFICATION PERSUANT TO SEC RULE19H-1, TO EFFECT SECURITIES TRANSACTIONS WITHOUT PROPERSUPERVISION AS AGREED TO BY THE COMPANY IN ITS MEMBERSHIPCONTINUANCE APPLICATION FILED IN CONNECTION WITH JEREMENKO'SREGISTRATION WITH THE COMPANY.











CENSURE


Docket/Case Number: DEN-818



THE COMPANY, OPERATING THROUGH RESPONDENT, WALTER LAMARMORTENSEN, ALLEGEDLY ALLOWED BORIS JEREMENKO, AN INDIVIDUALSUBJECT TO A STATUTORY DISQUALIFICATION PERSUANT TO SEC RULE19H-1, TO EFFECT SECURITIES TRANSACTIONS WITHOUT PROPERSUPERVISION AS AGREED TO BY THE COMPANY IN ITS MEMBERSHIPCONTINUANCE APPLICATION FILED IN CONNECTION WITH JEREMENKO'SREGISTRATION WITH THE COMPANY.


Resolution:


Sanction Details: THE FIRM AND MORTENSEN AGREED TO A CENSURE AND A FINE IN THEAMOUNT OF $2,500.00 JOINTLY AND SEVERALLY.

Firm Statement WITHOUT ADMITTING OR DENYING THAT IT VIOLATED ANY OF THE RULESOF THE ASSOCIATION AS ALLEGED IN THE COMPLAINT, THE COMPANY ANDMORTENSEN AGREED TO A CENSURE AND FINE IN THE AMOUNT OF$2,500.00.



Disclosure 18 of 18

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Initiated By: ILLINOIS


Allegations: ON FEBRUARY 23, 1988, A NOTICE OF HEARING WAS ISSUED ALLEGINGTHAT PFS INVESTMENTS INC. F/K/A FIRST AMERICAN NATIONALSECURITIES, INC. ("RESPONDENT") FAILED TO SUPERVISE THESECURITIES ACTIVITIES OF CERTAIN SALESPERSONS OR HAS OFFEREDOR SOLD SECURITIES IN ILLINOIS THROUGH UNREGISTEREDSALESPERSONS IN VIOLATION OF SECTION 8.E(1)(E).








Censure



Docket/Case Number: 88-19


Principal Product Type: Other

Other Product Type(s): UNKNOWN TYPE OF SECURITIES


Resolution:


Sanction Details: BY MEANS OF A STIPULATION AND CONSENT, RESPONDENT HAS AGREEDTO THE ENTRY OF AN ORDER OF CENSURE.

Regulator Statement ILLINOIS DEPARTMENT OF SECURITIES' FINDINGS, WHICH RESPONDENTNEITHER ADMITTED NOR DENIED, ARE THAT RESPONDENT FAILED TOSUPERVISE ITS SALESPERSONS WHICH FACILITATED AVIOLATION BY THOSE SALESPERSONS OF THE ILLINOIS SECURITIES LAWOF 1953, AS AMENDED.

Sanctions Ordered: Censure

Consent


Initiated By: STATE OF ILLINOIS, SECRETARY OF STATE, SECURITIES DEPARTMENT




Docket/Case Number: #88-19



Allegations: THE SECRETARY OF STATE ALLEGED THAT CERTAIN REPRESENTATIVESFO THE FIRM SOLD CERTAIN SECURITIES TO ILLINOIS RESIDENTSWITHOUT BEING APPROPRIATELY REGISTERED, IN VIOLATION OF THEILLINOIS SECURITIES LAW OF 1953 AND THAT THE FIRM PERMITTED ORFACILITATED SUCH VIOLATIONS.










ORDER OF CENSURE REQUIRING FIRM TO (I) PAY FINE (II) OFFER OR SELLSECURITIES IN ILLINOIS IN COMPLIANCE WITH THE ILLINOIS SECURITIESLAW OF 1953 AND (III) NOTIFY AFFECTED CUSTOMERS THAT SALES TOTHEM MAY HAVE VIOLATED THE ACT AND CIVIL REMEDIES MAY BEAVAILABLE.


Resolution:

Other Sanctions Ordered: CONSENT ORDER OF CENSURE REQUIRED THE FIRM TO (I) PAY $3,305.45WHICH CONSTITUTES THE TOTAL REALLOWANCE THE FIRM RECEIVED (II)OFFER OR SELL SECURITIES IN ILLINOIS IN COMPLIANCE WITH THEILLINOIS SECURITIES LAW AND (III) NOTIFY AFFECTED CUSTOMERS THATSALES TO THEM MAY HAVE VIOLATED THE ACT AND CIVIL REMEDIES MAYBE AVAILABLE.

Sanction Details: SEE DETAILS ABOVE.

Firm Statement MATTER WAS RESOLVED WITH CONSENT ORDER OF CENSURE ASDESCRIBED ABOVE.


Consent






Arbitration Award - Award / Judgment

Brokerage firms are not required to report arbitration claims filed against them by customers; however, BrokerCheckprovides summary information regarding FINRA arbitration awards involving securities and commodities disputesbetween public customers and registered securities firms in this section of the report. The full text of arbitration awards issued by FINRA is available at www.finra.org/awardsonline.

Disclosure 1 of 2


Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

05/18/2004

04-03447

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-OTHER

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES

$205,132.00

AWARD AGAINST PARTY - VACATED IN WHOLE OR PART

07/12/2006

$200,625.00

There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.

Disclosure 2 of 2

i


Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

FINRA

02/05/2009

08-05016

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-NEGLIGENCE





www.finra.org/awardsonline

https://www.finra.org/arbitration-mediation/arbitration-awards-online?search=04-03447

https://www.finra.org/arbitration-mediation/arbitration-awards-online?search=08-05016


Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; VARIABLE ANNUITIES

$5,800,000.00

AWARD AGAINST PARTY

01/03/2011

$477,867.12

There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.






Civil Bond

This type of disclosure event involves a civil bond for the brokerage firm that has been denied, paid, or revoked by abonding company.

Disclosure 1 of 2


Policy Holder: PFS INVESTMENTS INC.

Bonding Company Name: UNKNOWN

Disposition: Payout

Disposition Date: 08/22/1989

Payout Details: ON AUGUST 22, 1989, APPLICANT'S FIDELITY BONDING COMPANY PAID ALOSS OUR FIRM HAD SUFFERED. APPLICANT'S DISCLOSURE FILED ONSEPTEMBER 5, 1989, USING SCHEDULE D DOES NOT PROVIDE SUFFICIENTDATA TO RECAPTURE DETAILED INFORMATION FOR THE CURRENTREPORTING REQUIREMENT.

Firm Statement THE LOSS RESULTED FROM THE MISAPPROPRIATION OF CUSTOMER'SFUNDS BY A REGISTERED REPRESENTATIVE OF THE FIRM.

Disclosure 2 of 2

i


Policy Holder: PFS INVESTMENTS INC.

Bonding Company Name: UNKNOWN

Disposition: Payout

Disposition Date: 02/01/1991

Payout Details: DURING THE PERIOD BEGINNING AUGUST, 1989 AND ENDING FEBRUARY,1991 APPLICANT'S BONDING COMPANY PAID ON FOUR LOSSES (A TOTALOF FIVE PAYMENTS).

Firm Statement LOSSES RESULTED FROM THE MISAPPROPRIATION OF CUSTOMER'SFUNDS BY REGISTERED REPRESENTATIVES OF OUR FIRM.






End of Report

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PFS INVESTMENTS INC. · 1 PRIMERICA PARKWAY DULUTH, GA 30099-0001 Regulated by FINRA Atlanta Office...

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