m holdings securities, inc. · 2020-06-30 · m holdings securities, inc. crd# 43285 sec# 8-50214...

BrokerCheck Report

M HOLDINGS SECURITIES, INC.

Section Title

Report Summary

Firm History

CRD# 43285

1

9

Firm Profile 2 - 8

Page(s)

Firm Operations 10 - 21

Disclosure Events 22

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CRD# 43285

SEC# 8-50214

Main Office Location

1125 N.W. COUCH STREETSUITE 900PORTLAND, OR 97209Regulated by FINRA Denver Office

Mailing Address

P.O. BOX 2207PORTLAND, OR 97208-2207

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

800-656-6960

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 4

Firm Profile

This firm is classified as a corporation.

This firm was formed in Oregon on 03/21/1997.

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 9 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• 1 Self-Regulatory Organization• 53 U.S. states and territories

www.finra.org/brokercheck User Guidance

1©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.

https://adviserinfo.sec.gov/firm/summary/43285


http://www.finra.org/brokercheck

http://www.finra.org/brokercheck_reports


This firm is classified as a corporation.

This firm was formed in Oregon on 03/21/1997.

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#

43285

8-50214

Main Office Location

Mailing Address

Business Telephone Number

Doing business as M HOLDINGS SECURITIES, INC.

800-656-6960

Regulated by FINRA Denver Office

1125 N.W. COUCH STREETSUITE 900PORTLAND, OR 97209

P.O. BOX 2207PORTLAND, OR 97208-2207






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?

M FINANCIAL HOLDINGS INCORPORATED

EQUITY OWNER

75% or more

No

Domestic Entity

03/1997

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


BECKLEY, DEAN JAMES

CHIEF INFORMATION SECURITY OFFICER

Less than 5%

No

Individual

03/2019

No



Position


Position Start Date


DOUGHERTY, CASEY WILLIAM

CHIEF COMPLIANCE OFFICER

Less than 5%

Individual

05/2020

Yes

4031339








Direct Owners and Executive Officers (continued)

Firm Profile



No

Yes

Position



Position Start Date


KRAMER, ANDREW JOHN

DIRECTOR

Less than 5%

No

Individual

02/2020

No



Position



Position Start Date


KUKAR, KEVIN BRUCE

TREASURER

Less than 5%

No

Individual

06/2006

Yes

4605225



Position

LUNDIN, STEPHEN ALEXANDER

DIRECTOR

IndividualIs this a domestic or foreignentity or an individual?








Firm Profile

Position



Position Start Date


DIRECTOR

Less than 5%

No

02/2020

No

Position



Position Start Date


MCNAMARA-FENESY, BRIDGET MARY

PRESIDENT AND CHIEF EXECUTIVE OFFICER

Less than 5%

No

Individual

04/2017

Yes

2233939



Position



Position Start Date


PIMENTA, VALERIE RACHELLE BOLCH

VP, COO

Less than 5%

No

Individual

06/2017

Yes









Firm Profile

Position



Position Start Date


ROGERS, MARIA RENEE

FINANCIAL PRINCIPAL

Less than 5%

No

Individual

09/2007

No

2442526



Position



Position Start Date


SCHUTT, DAVID WALTER

SECRETARY

Less than 5%

No

Individual

02/2004

No

2736264



Position


Position Start Date

STRUTHERS, JEFF P

VICE PRESIDENT

Less than 5%

Individual

02/2020

4705114









Firm Profile




Less than 5%

No

No






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, 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

Yes

No

No

Federal Regulator Status Date Effective

SEC Approved 10/30/1997

Self-Regulatory Organization Status Date Effective

FINRA Approved 10/30/1997






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 08/17/1998

Alaska Approved 07/23/1998

Arizona Approved 05/29/1998

Arkansas Approved 11/10/1998

California Approved 05/19/1998

Colorado Approved 05/29/1998

Connecticut Approved 06/12/1998

Delaware Approved 02/25/1999

District of Columbia Approved 08/31/1998

Florida Approved 07/01/1998

Georgia Approved 07/31/1998

Hawaii Approved 08/31/1998

Idaho Approved 05/21/1998

Illinois Approved 06/10/1998

Indiana Approved 04/07/1999

Iowa Approved 08/03/1998

Kansas Approved 09/09/1998

Kentucky Approved 07/14/1998

Louisiana Approved 02/26/1999

Maine Approved 10/16/1998

Maryland Approved 06/17/1998

Massachusetts Approved 06/26/1998

Michigan Approved 09/25/1998

Minnesota Approved 11/02/1999

Mississippi Approved 09/30/1998

Missouri Approved 04/23/1999

Montana Approved 05/20/1998

Nebraska Approved 07/14/1998

Nevada Approved 06/08/1998

New Hampshire Approved 07/30/1999

New Jersey Approved 10/21/1998

New Mexico Approved 05/28/1998

New York Approved 08/14/1998

U.S. States &Territories

Status Date Effective

North Carolina Approved 07/31/1998

North Dakota Approved 08/20/1998

Ohio Approved 08/13/1998

Oklahoma Approved 08/04/1998

Oregon Approved 10/30/1997

Pennsylvania Approved 07/14/1998

Puerto Rico Approved 04/12/2011

Rhode Island Approved 08/18/1998

South Carolina Approved 08/10/1998

South Dakota Approved 08/04/1998

Tennessee Approved 09/02/1998

Texas Approved 09/09/1998

Utah Approved 05/26/1998

Vermont Approved 09/02/1998

Virgin Islands Approved 06/15/2009

Virginia Approved 07/17/1998

Washington Approved 05/20/1998

West Virginia Approved 07/31/1998

Wisconsin Approved 08/05/1998

Wyoming Approved 08/04/1998






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 not effect transactions in commodities, commodity futures, or commodity options.This firm does engage in other non-securities business.

Non-Securities Business Description: INVESTMENT ADVISORY BUSINESS APPLICANT IS ALSO REGISTEREDWITH SEC AS AN INVESTMENT ADVISOR AND PROVIDES ADVISORYSERVICES TO CLIENTS.

This firm currently conducts 9 types of businesses.

Types of Business

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

Broker or dealer selling corporate debt securities

Mutual fund retailer

U S. government securities broker

Municipal securities broker

Broker or dealer selling variable life insurance or annuities

Put and call broker or dealer or option writer

Investment advisory services

Private placements of securities






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 refer or introduce customers to other brokers and dealers.

Name: PERSHING LLC

Business Address: 1 PERSHING PLAZAJERSEY CITY, NJ 07399

CRD #: 7560

Effective Date: 09/06/1999

Description: APPLICANT INTRODUCES ITS GENERAL SECURITIES CUSTOMERACCOUNTS TO PERSHING, LLC ("PERSHING") ON A FULLY DISCLOSEDBASIS FOR EXECUTIION, SETTLEMENT AND CLEARANCE OFTRANSACTIONS. ALL CUSTOMER FUNDS AND SECURITIES ARE HELDBY PERSHING. ANY CUSTOMER FUNDS OR SECURITIES DELIVERED TOAPPLICANT ARE PROMPTLY DELIVERED TO PERSHING.






Firm Operations

Industry Arrangements

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

Name: WORLD SOFTWARE CORPORATION

Business Address: 266 HARRISTOWN ROADSUITE 201GLEN ROCK, NJ 07452


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH WORLDSOFTWARE CORPORATION TO PROVIDE A DOCUMENT MANAGMENTSOLUTION.

Name: RED TAIL TECHNOLOGY

Business Address: 11285 PYRITES WAYGOLD RIVER, CA 95670


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH RED TAILTECHNOLOGY TO PROVIDE A CRM TO HOUSE RELATED BOOKS ANDRECORDS.

Name: ONE SOURCE DOCUMENT SOLUTIONS

Business Address: 311-D POMONA DRIVEGREENSBORO, NC 27407


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH ONESOURCE DOCUMENT SOLUTIONS TO PROVIDE A DOCUMENTMANAGMENT SOLUTION.

Name: NETDOCUMENTS.COM

Business Address: 2500 EXECUTIVE PARKWAYSUITE 300LEHI, UT 84043


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITHNETDOCUMENTS.COM TO PROVIDE A DOCUMENT MANAGMENTSOLUTION.

Name: MUNIMETRIX

Business Address: 1575 DELUCCHI AVENUESUITE 223RENO, NV 89502-6582






Firm Operations

Industry Arrangements (continued)

Business Address: 1575 DELUCCHI AVENUESUITE 223RENO, NV 89502-6582


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITHMUNIMETRIX TO PROVIDE A DOCUMENT MANAGMENT SOLUTION.

Name: MOSAIC

Business Address: 3250-H PEACHTREE CORNERS CIRCLENORCROSS, GA 30092


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH MOSAIC TOPROVIDE A DOCUMENT MANAGMENT SOLUTION.

Name: KNOWLEDGELAKE

Business Address: 6 CITY PLACESUITE 500SAINT LOUIS, MO 63141


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITHKNOWLEDGELAKE TO PROVIDE A DOCUMENT MANAGMENT SOLUTION.

Name: VERTAFORTE

Business Address: 999 18TH STREETDENVER, CO 80202


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITHVERTAFORTE TO PROVIDE A DOCUMENT MANAGMENT SOLUTION.

Name: DOCUWARE CORPORATION

Business Address: 4 CROTTY LANESUITE 200NEW WINDSOR, NY 12553


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH DOCUWARECORPORATION TO PROVIDE A DOCUMENT MANAGMENT SOLUTION.

Name: EGNYTE

Business Address: 1350 WEST MIDDLEFIELD ROADMOUNTAIN VIEW, CA 94043 15©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.





Firm Operations


Business Address: 1350 WEST MIDDLEFIELD ROADMOUNTAIN VIEW, CA 94043


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH EGNYTE TOPROVIDE A DOCUMENT MANAGMENT AND GOVERNANCE SOLUTION.

Name: EFILE CABINET, INC.

Business Address: 2989 WEST MAPLE LOOP DRIVESUITE 300LEHI, UT 84043


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH EFILECABINET, INC., TO PROVIDE A DOCUMENT MANAGMENT SOLUTION.

Name: DOCUPACE TECHNOLOGIES, INC.

Business Address: 2001 SOUTH BARRINGTON AVENUESUITE 215LOS ANGELES, CA 90025


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH DOCUPACETECHNOLOGIES, INC., TO PROVIDE A DOCUMENT MANAGMENTSOLUTION.

Name: DOCS IMAGING, LLC

Business Address: 7547 MENTOR DRIVESUITE 302MENTOR, OH 44060


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH DOCSIMAGING, LLC TO PROVIDE A DOCUMENT MANAGEMENT SOLUTION.

Name: COMPETITIVE ADVANTAGE SYSTEMS, LLC

Business Address: 740 ALFRED NOBEL DRIVEHERCULES, CA 94547


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITHCOMPETITIVE ADVANTAGE SYSTEMS, LLC TO PROVIDE INFORMATIONTECHOLOGY SERVICES.






Firm Operations


Name: CITRIX

Business Address: 701 CORPORATE CENTERSUITE 300RALEIGH, NC 27607


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH CITRIX TOPROVIDE SHAREFILE SOLUTION.

Name: CABINET, INC.

Business Address: 500 LANIER ROADSUITE BMADISON, AL 35758


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH CABINET,INC., TO PROVIDE DOCUMENT MANAGEMENT SYSTEMS.

Name: BOX, INC.

Business Address: 900 JEFFERSON AVENUEREDWOOD CITY, CA 94063


Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH BOX, INC.,TO PROVIDE GOVERNANCE DOCUMENT MANAGEMENT SOFTWARE.

Name: REGED, INC.

Business Address: 2100 GATEWAY CENTRE BLVD., SUITE 200MORRISVILLE, NC 27560


Description: REGED, INC. IS A COMPLIANCE SUPPORT SYSTEM VENDOR WHO ALSOPROVIDES STORAGE FOR RELATED M HOLDINGS SECURITIES, INC.BOOKS AND RECORDS.

Name: GLOBAL RELAY COMMUNICATIONS, INC.

Business Address: 220 CAMBIE STREET2ND FLOORVANCOUVER, BC V6B 2M9, CANADA V6B 2M9


Description: ELECTRONIC CORRESPONDENCE IS MAINTAINED BY GLOBAL RELAYCOMMUNICATIONS, INC. IN ACCORDANCE WITH APPLICABLE BOOKS &RECORDS RULES.






Firm Operations


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

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

ELECTRONIC CORRESPONDENCE IS MAINTAINED BY GLOBAL RELAYCOMMUNICATIONS, INC. IN ACCORDANCE WITH APPLICABLE BOOKS &RECORDS RULES.

Name: FINANCIAL DATABASE SERVICES

Business Address: 9920 PACIFIC HEIGHTS BLVD#430SAN DIEGO, CA 92121


Description: FINANCIAL DATABASE SERVICES (FDS) IS THE VENDOR THATPROVIDES THE SOFTWARE AND STORAGE FOR M HOLDINGSSECURITIES BOOKS AND RECORDS.

Name: PERSHING LLC


CRD #: 7560


Description: PURSUANT TO THE FULLY DISCLOSED CLEARING AGMT PERSHINGMAINTAINS STOCK RECORDS & OTHER PRESCRIBED BOOKS &RECORDS OF ALL TRANSACTIONS EXECUTED OR CLEARED THROUGHIT. ALSO APPLICANT HAS AGMTS WITH FIRMS THAT ARE "MEMBERFIRMS" OF APPLICANT'S PARENT CO TO MAINTAIN CERTAIN OFAPPLICANT'S BOOKS & RECORDS, INCLUDING CUSTOMER FILES, INSUCH FORM AS REQUIRED BY APPLICANT. THE LOCATIONS OF SUCHMEMBER FIRMS AT WHICH APPLICANT'S BOOKS AND RECORDS AREMAINTAINED AT EITHER APPLICANT'S BRANCH OR NON-BRANCHLOCATION.

Name: PERSHING LLC


CRD #: 7560


Description: PERSHING MAINTAINS APPLICANT'S COMMISSION ACCOUNT IN WHICHCOMMISSIONS PAID BY CUSTOMERS ARE HELD UNTIL PAID TOAPPLICANT BY PERSHING.

Name: PERSHING LLC

CRD #: 756018©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.





Firm Operations


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


CRD #: 7560


Description: ACCOUNTS, FUNDS AND SECURITIES OF CUSTOMERS OF APPLICANTARE HELD BY PERSHING PURSUANT TO THE FULLY DISCLOSEDCLEARING AGREEMENT.






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

06/20/2005

1125 NW COUCH ST., STE. 900PORTLAND, OR 97209

136694

M FINANCIAL ASSET MANAGEMENT, INC. is under common control with the firm.

BOTH M FINANCIAL ASSET MANAGEMENT, INC. AND M HOLDINGSSECURITIES, INC. ARE EACH WHOLLY OWNED SUBSIDIARIES OF MFINANCIAL HOLDINGS INCORPORATED.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

No

06/20/2005

1125 N.W. COUCH ST., STE. 900PORTLAND, OR 97209

139304

M FINANCIAL SECURITIES MARKETING, INC. is under common control with the firm.

BOTH M FINANCIAL SECURITIES MARKETING, INC. AND M HOLDINGSSECURITIES, INC. ARE EACH WHOLLY OWNED SUBSIDIARIES OF MFINANCIAL HOLDINGS INCORPORATED.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations

Organization Affiliates (continued)BOTH M FINANCIAL SECURITIES MARKETING, INC. AND M HOLDINGSSECURITIES, INC. ARE EACH WHOLLY OWNED SUBSIDIARIES OF MFINANCIAL HOLDINGS INCORPORATED.

Description:

Yes

No

No

03/21/1997

1125 NW COUCH ST., STE. 900PORTLAND, OR 97209

M FINANCIAL INVESTMENT ADVISERS, INC. is under common control with the firm.

M HOLDINGS SECURITIES, INC. AND M FINANCIAL INVESTMENT ADVISERS,INC. ARE EACH WHOLLY OWNED SUBSIDIARIES OF M FINANCIALHOLDINGS INCORPORATED.

Description:



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 4 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 4

Reporting Source: Regulator

Allegations: IA RELEASE 5193, MARCH 11, 2019: THE SECURITIES AND EXCHANGECOMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THATPUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BEINSTITUTED AGAINST M HOLDINGS SECURITIES, INC. ("RESPONDENT"). ONTHE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THECOMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OFBREACHES OF FIDUCIARY DUTY AND INADEQUATE DISCLOSURES BY THERESPONDENT IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASSSELECTION PRACTICES AND THE FEES IT RECEIVED. AT TIMES DURINGTHE RELEVANT PERIOD, RESPONDENT PURCHASED, RECOMMENDED, ORHELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THATCHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THESAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. RESPONDENTRECEIVED 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS.RESPONDENT FAILED TO DISCLOSE IN ITS FORM ADV OR OTHERWISE THECONFLICTS OF INTEREST RELATED TO (A) ITS RECEIPT OF 12B-1 FEES,AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAYSUCH FEES. DURING THE RELEVANT PERIOD, RESPONDENT RECEIVED12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH MUTUALFUND SHARE CLASSES. AS A RESULT OF THE CONDUCT, RESPONDENTWILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT.

Current Status: Final






Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 03/11/2019

Docket/Case Number: 3-19096

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations: IA RELEASE 5193, MARCH 11, 2019: THE SECURITIES AND EXCHANGECOMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THATPUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BEINSTITUTED AGAINST M HOLDINGS SECURITIES, INC. ("RESPONDENT"). ONTHE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THECOMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OFBREACHES OF FIDUCIARY DUTY AND INADEQUATE DISCLOSURES BY THERESPONDENT IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASSSELECTION PRACTICES AND THE FEES IT RECEIVED. AT TIMES DURINGTHE RELEVANT PERIOD, RESPONDENT PURCHASED, RECOMMENDED, ORHELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THATCHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THESAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. RESPONDENTRECEIVED 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS.RESPONDENT FAILED TO DISCLOSE IN ITS FORM ADV OR OTHERWISE THECONFLICTS OF INTEREST RELATED TO (A) ITS RECEIPT OF 12B-1 FEES,AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAYSUCH FEES. DURING THE RELEVANT PERIOD, RESPONDENT RECEIVED12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH MUTUALFUND SHARE CLASSES. AS A RESULT OF THE CONDUCT, RESPONDENTWILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT.

Resolution Date: 03/11/2019

Resolution:

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

Yes

Sanctions Ordered: CensureDisgorgement/RestitutionCease and Desist/Injunction

Order






Other Sanctions Ordered: UNDERTAKINGS AND PREJUDGMENT INTEREST

Sanction Details: THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED,SHALL PAY DISGORGEMENT OF $923,202.35 AND PREJUDGMENT INTERESTOF $98,846.14, AND SHALL COMPLY WITH THE UNDERTAKINGSENUMERATED IN THE OFFER OF SETTLEMENT.

Regulator Statement RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THECOMMISSION HAS DETERMINED TO ACCEPT. IN VIEW OF THE FOREGOING,THE COMMISSION DEEMS IT APPROPRIATE IN THE PUBLIC INTEREST TOIMPOSE THE SANCTIONS AGREED TO IN THE RESPONDENT'S OFFER.RESPONDENT SELF-REPORTED TO THE COMMISSION THE VIOLATIONSDISCUSSED IN THIS ORDER PURSUANT TO THE DIVISION OFENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE("SCSD INITIATIVE"). ACCORDINGLY, THIS ORDER AND RESPONDENT'SOFFER ARE BASED ON THE INFORMATION SELF-REPORTED BYRESPONDENT.


iReporting Source: Firm

Initiated By: SECURITIES AND EXCHANGE COMMISSION

Allegations: ON MARCH 11, 2019, THE SECURITIES AND EXCHANGE COMMISSION (SEC)PUBLISHED IA RELEASE NO. 5193, AN ORDER INSTITUTINGADMINISTRATIVE AND CEASE AND DESIST PROCEEDINGS, PURSUANT TOSECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940(ADVISERS ACT), AGAINST M HOLDINGS SECURITIES, INC. (RESPONDENT).RESPONDENT SELF-REPORTED THE VIOLATIONS TO THE SEC. THEPROCEEDINGS ARISE OUT OF BREACHES OF FIDUCIARY DUTY ANDINADEQUATE DISCLOSURES BY RESPONDENT IN CONNECTION WITH ITSMUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE 12B-1FEES IT AND/OR ITS ASSOCIATED PERSONS RECEIVED. AT TIMES DURINGTHE RELEVANT PERIOD, RESPONDENT PURCHASED FOR, RECOMMENDEDTO, OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSESTHAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSESOF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE.RESPONDENT FAILED TO DISCLOSE IN ITS FORM ADV OR OTHERWISECONFLICTS OF INTEREST RELATED TO THE COLLECTION OF SUCH FEES.AS A RESULT OF THE CONDUCT, RESPONDENT WILLFULLY VIOLATEDSECTIONS 206(2) AND 207 OF THE ADVISERS ACT.








Cease and Desist



Docket/Case Number: FILE NO. 3-19096

Principal Product Type: Mutual Fund(s)



Resolution:

Other Sanctions Ordered:

Sanction Details: RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED,SHALL PAY DISGORGEMENT PLUS INTEREST OF $1,022,048.49 AND SHALLCOMPLY WITH THE UNDERTAKINGS DESCRIBED IN THE OFFER OFSETTLEMENT.

Firm Statement WITHIN 30 DAYS OF THE ORDER'S ISSUANCE, M SECURITIES IS REQUIREDTO: DEPOSIT THE MONEY IN AN ESCROW ACCOUNT, UPDATE ITSDISCLOSURES, UPDATE ITS POLICIES AND PROCEDURES, CONVERTELIGIBLE FUNDS TO A LOWER-COST SHARE CLASS AND PROVIDEAFFECTED CLIENTS WITH NOTIFICATION.


Order

Disclosure 2 of 4

i


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM,INCLUDING WRITTEN SUPERVISORY PROCEDURES (WSPS), REASONABLYDESIGNED TO SUPERVISE REPRESENTATIVES' USE OF CONSOLIDATEDREPORTS. THE FINDINGS STATED THAT DURING A PERIOD, ASSOCIATEDPERSONS OF THE FIRM CREATED AND DISSEMINATED CONSOLIDATEDREPORTS TO CUSTOMERS, YET, IT HAD NO WSPS DIRECTLY ADDRESSINGTHE SUPERVISION OF CONSOLIDATED REPORTS. FURTHER, THE FIRM DIDNOT MAINTAIN OR REVIEW CONSOLIDATED REPORTS ASCOMMUNICATIONS WITH CUSTOMERS AND DID NOT MAINTAIN OR REVIEWTHE SUPPORTING DOCUMENTS RELATED TO ASSETS AND ASSET VALUESENTERED MANUALLY BY REGISTERED REPRESENTATIVES IN THECONSOLIDATED REPORTS. FOLLOWING FINRA'S EXAMINATION, THE FIRMCREATED WSPS ADDRESSING THE USE AND DISSEMINATION OFCONSOLIDATED REPORTS BY ITS REPRESENTATIVES. THE WSPSINCLUDED THE FIRM'S REQUIREMENTS FOR REVIEW AND APPROVALBEFORE SUBMITTING OF CONSOLIDATED REPORTS TO FIRM CUSTOMERSOR PROSPECTIVE CUSTOMERS, AND PROHIBITED THE DISSEMINATION OFCONSOLIDATED REPORTS UNLESS AND UNTIL APPROVAL WAS PROVIDEDBY THE FIRM. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TORECORD AND REVIEW SALES OF PRIVATE OFFERING TO INVESTORS BYITS REGISTERED REPRESENTATIVE, PRIOR TO FINRA'S DISCOVERY OFTHE ACTIVITY. ONE OF THE FIRM'S REGISTERED REPRESENTATIVESREQUESTED THE FIRM'S APPROVAL TO ENGAGE IN PRIVATE SECURITIESTRANSACTIONS INVOLVING A PRIVATE OFFERING OF LIMITEDPARTNERSHIP INTERESTS IN A COMMERCIAL REAL ESTATE PROJECT. THEFIRM APPROVED REPRESENTATIVE'S REQUEST AND THEN FAILED TOSUPERVISE TRANSACTIONS INVOLVING SALES OF THE PRIVATEOFFERING BY THE REPRESENTATIVE TO INVESTORS, TOTALING$18,755,000 IN INTERESTS IN THE COMMERCIAL REAL ESTATEINVESTMENT. ALSO, THE FIRM DID NOT RECORD ANY OF THESETRANSACTIONS ON ITS BOOKS AND RECORDS, AS REQUIRED. AS ARESULT OF FINRA'S INQUIRIES, THE FIRM EVENTUALLY CONDUCTED DUEDILIGENCE ON THE COMMERCIAL REAL ESTATE PROJECT, REVIEWED THETRANSACTIONS, AND LATER RECORDED THE TRANSACTIONS ON ITSBOOKS AND RECORDS.







Initiated By: FINRA




Docket/Case Number: 2017052293001

Principal Product Type: Other

Other Product Type(s): PRIVATE SECURITIES TRANSACTIONS

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM,INCLUDING WRITTEN SUPERVISORY PROCEDURES (WSPS), REASONABLYDESIGNED TO SUPERVISE REPRESENTATIVES' USE OF CONSOLIDATEDREPORTS. THE FINDINGS STATED THAT DURING A PERIOD, ASSOCIATEDPERSONS OF THE FIRM CREATED AND DISSEMINATED CONSOLIDATEDREPORTS TO CUSTOMERS, YET, IT HAD NO WSPS DIRECTLY ADDRESSINGTHE SUPERVISION OF CONSOLIDATED REPORTS. FURTHER, THE FIRM DIDNOT MAINTAIN OR REVIEW CONSOLIDATED REPORTS ASCOMMUNICATIONS WITH CUSTOMERS AND DID NOT MAINTAIN OR REVIEWTHE SUPPORTING DOCUMENTS RELATED TO ASSETS AND ASSET VALUESENTERED MANUALLY BY REGISTERED REPRESENTATIVES IN THECONSOLIDATED REPORTS. FOLLOWING FINRA'S EXAMINATION, THE FIRMCREATED WSPS ADDRESSING THE USE AND DISSEMINATION OFCONSOLIDATED REPORTS BY ITS REPRESENTATIVES. THE WSPSINCLUDED THE FIRM'S REQUIREMENTS FOR REVIEW AND APPROVALBEFORE SUBMITTING OF CONSOLIDATED REPORTS TO FIRM CUSTOMERSOR PROSPECTIVE CUSTOMERS, AND PROHIBITED THE DISSEMINATION OFCONSOLIDATED REPORTS UNLESS AND UNTIL APPROVAL WAS PROVIDEDBY THE FIRM. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TORECORD AND REVIEW SALES OF PRIVATE OFFERING TO INVESTORS BYITS REGISTERED REPRESENTATIVE, PRIOR TO FINRA'S DISCOVERY OFTHE ACTIVITY. ONE OF THE FIRM'S REGISTERED REPRESENTATIVESREQUESTED THE FIRM'S APPROVAL TO ENGAGE IN PRIVATE SECURITIESTRANSACTIONS INVOLVING A PRIVATE OFFERING OF LIMITEDPARTNERSHIP INTERESTS IN A COMMERCIAL REAL ESTATE PROJECT. THEFIRM APPROVED REPRESENTATIVE'S REQUEST AND THEN FAILED TOSUPERVISE TRANSACTIONS INVOLVING SALES OF THE PRIVATEOFFERING BY THE REPRESENTATIVE TO INVESTORS, TOTALING$18,755,000 IN INTERESTS IN THE COMMERCIAL REAL ESTATEINVESTMENT. ALSO, THE FIRM DID NOT RECORD ANY OF THESETRANSACTIONS ON ITS BOOKS AND RECORDS, AS REQUIRED. AS ARESULT OF FINRA'S INQUIRIES, THE FIRM EVENTUALLY CONDUCTED DUEDILIGENCE ON THE COMMERCIAL REAL ESTATE PROJECT, REVIEWED THETRANSACTIONS, AND LATER RECORDED THE TRANSACTIONS ON ITSBOOKS AND RECORDS.


Resolution: Acceptance, Waiver & Consent(AWC)





https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2017052293001




Sanction Details: THE FIRM WAS CENSURED AND FINED $135,000. FINES PAID IN FULL ONJULY 26, 2018.


No

Sanctions Ordered: CensureMonetary/Fine $135,000.00


Initiated By: FINRA


Censure




Principal Product Type: Other

Other Product Type(s): CONSOLIDATED REPORTS, PRIVATE SECURITIES TRANSACTION

Allegations: FAILURE TO SUPERVISE



Resolution:


Sanction Details: $135,000 WAS PAID IN SANCTIONS IN JULY, 2018.

Firm Statement M SECURITIES WAS IMPOSED A CENSURE AND FINE IN THE AMOUNT OF$135,000 AS SANCTIONS.

Sanctions Ordered: CensureMonetary/Fine $135,000.00

Acceptance, Waiver & Consent(AWC)







Disclosure 3 of 4

i


Initiated By: KENTUCKY DEPARTMENT OF FINANCIAL INSTITUTIONS


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



Docket/Case Number: 2018-AH-00003

URL for Regulatory Action:

Principal Product Type: No Product


Allegations: ON FEBRUARY 1-2, 2017, DFI CONDUCTED A ROUTINE COMPLIANCEEXAMINATION OF THE M HOLDINGS LOUISVILLE BRANCH. DURING THEEXAMINATION, DFI DISCOVERED THAT AN IAR OF M HOLDINGS HADALTERED CLIENT DOCUMENTS. SPECIFICALLY, THE IAR CUT AND TAPED ACLIENT'S SIGNATURE ON A 1035 EXCHANGE FORM. M HOLDINGSVIOLATED 808 KAR 10:030 SECTION 3 BY FAILING TO SUPERVISE THE IAR.



Resolution:


Sanction Details: $5,000 FINE WAS PAID 5/31/2018


No

Sanctions Ordered: Monetary/Fine $5,000.00

Order








Initiated By: STATE OF KENTUCKY, DEPARTMENT OF FINANCIAL INSTITUTIONS


Other


AGREED ORDER


Docket/Case Number: 2018-AH-0003

Principal Product Type: Insurance


Allegations: FAILURE TO SUPERVISE AN RR WHO ALTERED A CLIENT'S 1035 EXCHANGEFORM BY CUTTING AND TAPING CLIENT'S SIGNATURE ON THE FORM.CLIENT FILES CONTAINED MULTIPLE IMPROPERLY COMPLETED FORMS.


Resolution:


Sanction Details: M HOLDINGS SECURITIES, INC. AGREED TO MONETARY FINE AND REVIEWOF WRITTEN SUPERVISORY PROCEDURES TO ENSURE RELEVANCY ANDREASONABLENESS.

Firm Statement A PAYMENT WAS MADE TO THE STATE OF KENTUCKY BY M HOLDINGSSECURITIES, INC.

Sanctions Ordered: Monetary/Fine $5,000.00

Decision & Order of Offer of Settlement

Disclosure 4 of 4

i


Allegations: NASD RULES 2110, 2440, 3010, INTERPRETATIVE MATERIAL 2440 - MHOLDINGS SECURITIES, INC. SOLD CORPORATE BONDS TO A CUSTOMERAND FAILED TO SELL SUCH BONDS AT A PRICE THAT WAS FAIR, TAKINGINTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDINGMARKET CONDITIONS WITH RESPECT TO EACH BOND AT THE TIME OF THETRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WASENTITLED TO A PROFIT. IN EACH INSTANCE, THE BONDS WERE SOLD BYTHE SAME REGISTERED REPRESENTATIVE WHO WAS EMPLOYED IN ABRANCH OFFICE. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDEFOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITH APPLICABLE SECURITIES LAWS, REGULATIONS AND/OR NASD RULESADDRESSING QUALITY OF MARKET TOPICS. THE FIRM'S WRITTENSUPERVISORY PROCEDURES FAILED TO PROVIDE FOR MINIMUMREQUIREMENTS FOR ADEQUATE WRITTEN SUPERVISORY PROCEDURESIN FAIR PRICING REVIEWS OF FIXED INCOME TRANSACTIONS ANDQUALIFYING SUPERVISORY PERSONNEL.







Initiated By: FINRA





Principal Product Type: Debt - Corporate


NASD RULES 2110, 2440, 3010, INTERPRETATIVE MATERIAL 2440 - MHOLDINGS SECURITIES, INC. SOLD CORPORATE BONDS TO A CUSTOMERAND FAILED TO SELL SUCH BONDS AT A PRICE THAT WAS FAIR, TAKINGINTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDINGMARKET CONDITIONS WITH RESPECT TO EACH BOND AT THE TIME OF THETRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WASENTITLED TO A PROFIT. IN EACH INSTANCE, THE BONDS WERE SOLD BYTHE SAME REGISTERED REPRESENTATIVE WHO WAS EMPLOYED IN ABRANCH OFFICE. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDEFOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITH APPLICABLE SECURITIES LAWS, REGULATIONS AND/OR NASD RULESADDRESSING QUALITY OF MARKET TOPICS. THE FIRM'S WRITTENSUPERVISORY PROCEDURES FAILED TO PROVIDE FOR MINIMUMREQUIREMENTS FOR ADEQUATE WRITTEN SUPERVISORY PROCEDURESIN FAIR PRICING REVIEWS OF FIXED INCOME TRANSACTIONS ANDQUALIFYING SUPERVISORY PERSONNEL.


Resolution:

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 $90,000, ORDERED TO PAY$30,963.26, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS ANDREQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURESREGARDING FAIR PRICING REVIEWS OF FIXED INCOME TRANSACTIONSAND QUALIFYING SUPERVISORY PERSONNEL WITHIN 30 BUSINESS DAYSOF ACCEPTANCE OF THIS AWC BY THE NAC. A REGISTERED PRINCIPAL OFTHE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THERESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTSUNDERTAKEN TO EFFECT RESTITUTION, TO FINRA NO LATER THAN 120DAYS AFTER ACCEPTANCE OF THIS AWC.


No

Sanctions Ordered: CensureMonetary/Fine $90,000.00Disgorgement/Restitution








WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $90,000, ORDERED TO PAY$30,963.26, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS ANDREQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURESREGARDING FAIR PRICING REVIEWS OF FIXED INCOME TRANSACTIONSAND QUALIFYING SUPERVISORY PERSONNEL WITHIN 30 BUSINESS DAYSOF ACCEPTANCE OF THIS AWC BY THE NAC. A REGISTERED PRINCIPAL OFTHE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THERESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTSUNDERTAKEN TO EFFECT RESTITUTION, TO FINRA NO LATER THAN 120DAYS AFTER ACCEPTANCE OF THIS AWC.


Initiated By: FINRA



OTHER SANCTIONS/RELIEF SOUGHT



Principal Product Type: Debt - Corporate


Allegations: NASD RULES 2110, 2440, 3010, INTERPRETATIVE MATERIAL 2440 - FINRASTAFF ALLEGED M HOLDINGS SECURITIES, INC. SOLD CERTAINCORPORATE BONDS TO A CUSTOMER AND FAILED TO SELL SUCH BONDSAT A PRICE THAT WAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANTCIRCUMSTANCES. IN EACH INSTANCE, THE BONDS WERE SOLD BY THESAME REGISTERED REPRESENTATIVE WHO WAS EMPLOYED IN A BRANCHOFFICE. FURTHER, FINRA STAFF CLAIMED THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH CERTAIN SECURITIES LAWS,REGULATIONS AND/OR NASD RULES ADDRESSING QUALITY OF MARKETTOPICS AND THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WEREINADEQUATE IN THE FOLLOWING SUBJECT AREAS: FAIR PRICINGREVIEWS OF FIXED INCOME TRANSACTIONS AND QUALIFYINGSUPERVISORY PERSONNEL.



Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: WITHOUT ADMITTING OR DENYING FINRA'S CLAIMS, THE FIRM SUBMITTEDAN AWC WHEREBY IT WAS CENSURED, FINED $90,000, ORDERED TO PAY$30,963.26, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS ANDREQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURESREGARDING FAIR PRICING REVIEWS OF FIXED INCOME TRANSACTIONSAND QUALIFYING SUPERVISORY PERSONNEL WITHIN 30 BUSINESS DAYSOF ACCEPTANCE OF THIS AWC BY THE NAC. A REGISTERED PRINCIPAL OFTHE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THERESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTSUNDERTAKEN TO EFFECT RESTITUTION, TO FINRA NO LATER THAN 120DAYS AFTER ACCEPTANCE OF THIS AWC.

Sanctions Ordered: CensureMonetary/Fine $90,000.00Disgorgement/Restitution








WITHOUT ADMITTING OR DENYING FINRA'S CLAIMS, THE FIRM SUBMITTEDAN AWC WHEREBY IT WAS CENSURED, FINED $90,000, ORDERED TO PAY$30,963.26, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS ANDREQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURESREGARDING FAIR PRICING REVIEWS OF FIXED INCOME TRANSACTIONSAND QUALIFYING SUPERVISORY PERSONNEL WITHIN 30 BUSINESS DAYSOF ACCEPTANCE OF THIS AWC BY THE NAC. A REGISTERED PRINCIPAL OFTHE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THERESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTSUNDERTAKEN TO EFFECT RESTITUTION, TO FINRA NO LATER THAN 120DAYS AFTER ACCEPTANCE OF THIS AWC.






End of Report

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