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BrokerCheck Report WELLS FARGO CLEARING SERVICES, LLC Section Title Report Summary Firm History CRD# 19616 1 14 Firm Profile 2 - 13 Page(s) Firm Operations 15 - 31 Disclosure Events 32

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Page 1: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

BrokerCheck Report

WELLS FARGO CLEARING SERVICES, LLC

Section Title

Report Summary

Firm History

CRD# 19616

1

14

Firm Profile 2 - 13

Page(s)

Firm Operations 15 - 31

Disclosure Events 32

Page 2: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

About BrokerCheck®

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

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

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

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

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

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

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

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

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

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

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

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

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

·Thank you for using FINRA BrokerCheck.

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

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

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

brokercheck.finra.org

Page 3: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

WELLS FARGO CLEARINGSERVICES, LLC

CRD# 19616

SEC# 8-37180

Main Office Location

ONE NORTH JEFFERSON AVENUEMAIL CODE: H0004-050ST. LOUIS, MO 63103Regulated by FINRA Kansas City Office

Mailing Address

ONE NORTH JEFFERSON AVENUEMAIL CODE: H0004-050ST. LOUIS, MO 63103

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

314-875-3000

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 159

Civil Event 2

Arbitration 337

Firm Profile

This firm is classified as a limited liability company.

This firm was formed in Delaware on 03/12/2003.

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 24 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• 11 Self-Regulatory Organizations• 53 U.S. states and territories

www.finra.org/brokercheck User Guidance

1©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 4: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

This firm is classified as a limited liability company.

This firm was formed in Delaware on 03/12/2003.

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.

WELLS FARGO CLEARING SERVICES, LLC

SEC#

19616

8-37180

Main Office Location

Mailing Address

Business Telephone Number

Doing business as WELLS FARGO CLEARING SERVICES, LLC

314-875-3000

Regulated by FINRA Kansas City Office

ONE NORTH JEFFERSON AVENUEMAIL CODE: H0004-050ST. LOUIS, MO 63103

ONE NORTH JEFFERSON AVENUEMAIL CODE: H0004-050ST. LOUIS, MO 63103

Other Names of this Firm

Name Where is it used

FIRST CLEARING AK, AL, AR, AZ, CA,CO, CT, DC, DE, FL,GA, HI, IA, ID, IL, IN,KS, KY, LA, MA, MD,ME, MI, MN, MO,MS, MT, NC, ND, NE,NH, NJ, NM, NV, NY,OH, OK, OR, PA, PR,RI, SC, SD, TN, TX,UT, VA, VI, VT, WA,WI, WV, WY 2©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 5: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

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

3©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 6: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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?

WACHOVIA SECURITIES FINANCIAL HOLDINGS, LLC

SOLE MEMBER

75% or more

No

Domestic Entity

12/2003

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

ALEXANDER, JOHN WADE

HEAD OF ADVISOR LED BUSINESS WEST

Less than 5%

No

Individual

03/2017

Yes

2327561

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position

Percentage of Ownership

Position Start Date

BARNEY, KATHLEEN ELLEN

CHIEF FINANCIAL OFFICER

Less than 5%

Individual

07/2013

6168269

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

4©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 7: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Direct Owners and Executive Officers (continued)

Firm Profile

Percentage of Ownership

Is this a public reportingcompany?

Does this owner direct themanagement or policies ofthe firm?

Less than 5%

No

Yes

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

CHRISTIAN, CHARLIE KENT

HEAD OF INDEPENDENT CHANNEL

Less than 5%

No

Individual

03/2017

Yes

1465883

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

GETZOFF, RICHARD JAY

HEAD OF ADVISOR LED BUSINESS EAST

Less than 5%

No

Individual

03/2017

Yes

2269931

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

HAYS, JAMES EDWARD

1569212

Legal Name & CRD# (if any):

5©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 8: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

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Direct Owners and Executive Officers (continued)

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

HEAD OF WEALTH BROKERAGE SERVICES

Less than 5%

No

Individual

11/2012

Yes

1569212

Is this a domestic or foreignentity or an individual?

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

HUBBERT, MARK WILLIAM

CHIEF RISK AND CREDIT OFFICER

Less than 5%

No

Individual

09/2015

Yes

1802805

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position

Percentage of Ownership

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

HUNTRUDDY, HEATHER ANNE

HEAD OF CLIENT EXPERIENCE AND GROWTH

Less than 5%

Individual

03/2017

Yes

2091956

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

6©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 9: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Direct Owners and Executive Officers (continued)

Firm Profile

Is this a public reportingcompany?

Does this owner direct themanagement or policies ofthe firm?

No

Yes

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

HURLEY, KEVIN BRADY

CHIEF COMPLIANCE OFFICER (IA ONLY)

Less than 5%

No

Individual

12/2008

Yes

1293748

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

KARANIK, ERIK ANTHONY

HEAD OF OPERATIONS AND BRANCH INFRASTRUCTURE/CHIEFOPERATIONS OFFICER/ BOARD OF MANAGERS

Less than 5%

No

Individual

03/2017

Yes

2260890

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

KELLY, DOUGLAS LAIRD

2428802

Legal Name & CRD# (if any):

7©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 10: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Direct Owners and Executive Officers (continued)

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

CHIEF LEGAL OFFICER / SECRETARY

Less than 5%

No

Individual

03/2008

Yes

2428802

Is this a domestic or foreignentity or an individual?

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

KITCHIN, KEVIN THOMAS

DESIGNATED STATE PRINCIPAL

Less than 5%

No

Individual

07/2014

Yes

1841815

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position

Percentage of Ownership

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

KOWACH, DAVID JOHN

PRESIDENT - CHIEF EXECUTIVE OFFICER / BOARD OF MANAGERS

Less than 5%

Individual

08/2016

Yes

2154665

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

8©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 11: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Direct Owners and Executive Officers (continued)

Firm Profile

Is this a public reportingcompany?

Does this owner direct themanagement or policies ofthe firm?

No

Yes

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

MCHALE, JAMES TIEBOUT

CHIEF COMPLIANCE OFFICER

Less than 5%

No

Individual

12/2014

Yes

6052977

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

METZ, KELLY MARIE

CHIEF OPERATIONS OFFICER/BACK OFFICE OPERATIONS

Less than 5%

No

Individual

06/2018

Yes

2251657

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

MEYER, BRAND FREDERICK

Individual

808629

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

9©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 12: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Direct Owners and Executive Officers (continued)

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

BOARD OF MANAGERS

Less than 5%

No

Individual

08/2016

Yes

Is this a domestic or foreignentity or an individual?

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

NADREAU, JOSEPH PETER

HEAD OF WFA INNOVATION & STRATEGY

Less than 5%

No

Individual

04/2014

Yes

2382449

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position

Percentage of Ownership

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

QUEEN, EDUARDO SAMPAIO

HEAD OF DIGITAL AND AUTOMATED INVESTING

Less than 5%

Individual

06/2017

Yes

4934698

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

10©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 13: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Direct Owners and Executive Officers (continued)

Firm Profile

Is this a public reportingcompany?

Does this owner direct themanagement or policies ofthe firm?

No

Yes

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

VORLOP, ROBERT WILLIAM

HEAD OF WFA PRODUCTS & ADVICE

Less than 5%

No

Individual

04/2014

Yes

1146770

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

11©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 14: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Indirect Owners

Firm Profile

EVEREN CAPITAL CORPORATION

SHARE HOLDER

WACHOVIA SECURITIES FINANCIAL HOLDINGS, LLC

75% or more

No

Domestic Entity

08/2010

Yes

Legal Name & CRD# (if any):

Is this a domestic or foreignentity or an individual?

Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established

Percentage of Ownership

Does this owner direct themanagement or policies ofthe firm?

Is this a public reportingcompany?

WELLS FARGO & COMPANY

SHARE HOLDER

WFC HOLDINGS, LLC

75% or more

Yes

Domestic Entity

09/1998

Yes

Legal Name & CRD# (if any):

Is this a domestic or foreignentity or an individual?

Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established

Percentage of Ownership

Does this owner direct themanagement or policies ofthe firm?

Is this a public reportingcompany?

WFC HOLDINGS, LLC

EVEREN CAPITAL CORPORATION

Domestic Entity

Legal Name & CRD# (if any):

Is this a domestic or foreignentity or an individual?

Company through whichindirect ownership isestablished

12©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 15: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Indirect Owners (continued)

Firm Profile

SHARE HOLDER

EVEREN CAPITAL CORPORATION

75% or more

No

12/2017

Yes

Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established

Percentage of Ownership

Does this owner direct themanagement or policies ofthe firm?

Is this a public reportingcompany?

13©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 16: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

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Firm History

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

No information reported.

14©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 17: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

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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, 11 SROs and 53 U.S. states and territories.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

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

Yes

Yes

No

No

Federal Regulator Status Date Effective

SEC Approved 04/03/1987

Self-Regulatory Organization Status Date Effective

FINRA Approved 07/09/1987

Cboe BZX Exchange, Inc. Approved 07/01/2016

Cboe Exchange, Inc. Approved 11/14/2016

Chicago Stock Exchange Approved 09/05/1990

NYSE American LLC Approved 12/31/2008

NYSE Arca, Inc. Approved 08/03/2016

Nasdaq GEMX, LLC Approved 09/16/2016

Nasdaq ISE, LLC Approved 03/12/2003

Nasdaq PHLX LLC Approved 04/03/1987

Nasdaq Stock Market Approved 07/12/2006

New York Stock Exchange Approved 08/31/1990

15©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 18: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

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Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 07/28/1989

Alaska Approved 08/21/1989

Arizona Approved 09/04/1990

Arkansas Approved 01/05/1990

California Approved 07/11/1989

Colorado Approved 02/13/1989

Connecticut Approved 05/16/1989

Delaware Approved 04/17/1989

District of Columbia Approved 03/15/1989

Florida Approved 04/09/1990

Georgia Approved 04/11/1989

Hawaii Approved 08/30/1990

Idaho Approved 06/16/1989

Illinois Approved 06/14/1989

Indiana Approved 11/15/1989

Iowa Approved 05/22/1989

Kansas Approved 08/03/1989

Kentucky Approved 12/07/1989

Louisiana Approved 04/04/1989

Maine Approved 01/16/1990

Maryland Approved 07/05/1989

Massachusetts Approved 01/09/1990

Michigan Approved 01/02/1990

Minnesota Approved 11/09/1989

Mississippi Approved 09/28/1989

Missouri Approved 04/16/1990

Montana Approved 04/11/1989

Nebraska Approved 05/07/1990

Nevada Approved 08/30/1989

New Hampshire Approved 01/01/1990

New Jersey Approved 09/07/1990

New Mexico Approved 07/12/1989

New York Approved 12/19/1989

U.S. States &Territories

Status Date Effective

North Carolina Approved 09/21/1989

North Dakota Approved 11/06/1989

Ohio Approved 04/11/1989

Oklahoma Approved 04/11/1989

Oregon Approved 09/06/1989

Pennsylvania Approved 06/01/1989

Puerto Rico Approved 01/16/1990

Rhode Island Approved 05/17/1989

South Carolina Approved 12/08/1989

South Dakota Approved 05/04/1989

Tennessee Approved 04/03/1989

Texas Approved 11/01/1989

Utah Approved 02/16/1990

Vermont Approved 05/01/1990

Virgin Islands Approved 06/14/2005

Virginia Approved 12/01/1989

Washington Approved 08/31/1989

West Virginia Approved 01/10/1990

Wisconsin Approved 08/31/1990

Wyoming Approved 10/05/1989

16©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 19: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

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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 24 types of businesses.

Types of Business

Exchange member engaged in exchange commission business other than floor activities

Exchange member engaged in floor activities

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

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

Broker or dealer selling corporate debt securities

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

Mutual fund retailer

U S. government securities dealer

U S. government securities broker

Municipal securities dealer

Municipal securities broker

Broker or dealer selling variable life insurance or annuities

Solicitor of time deposits in a financial institution

Broker or dealer selling oil and gas interests

Put and call broker or dealer or option writer

Broker or dealer selling securities of non-profit organizations (e.g., churches, hospitals)

Investment advisory services

Broker or dealer selling tax shelters or limited partnerships in primary distributions

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

Trading securities for own account

Private placements of securities

Broker or dealer selling interests in mortgages or other receivables

Broker or dealer involved in a networking, kiosk or similar arrangment with a: bank, savings bank or association, orcredit union

Other - APPLICANT SOLICITS AND EFFECTS TRANSACTIONS IN REPURCHASE AGREEMENTS, REVERSEPURCHASE AGREEMENTS, CERTIFICATES OF DEPOSIT, BANKER'S ACCEPTANCE, DEPOSIT NOTES ANDOTHER EXEMPT SECURITIES TRANSACTIONS FOR AFFILIATED AND NON-AFFILIATED ENTITIES.

ENGAGING IN MULTI-CURRENCY FIXED INCOME BUSINESS AND FOREIGN EXCHANGE TRANSACTIONSANCILLARY TO THIS BUSINESS.

TRADE SETTLEMENT AND SECURITIES CLEARANCE, AND CORRESPONDENT CLEARING SERVICES; PRIMEBROKERAGE SERVICES; AND SECURITIES LENDING.

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Other Types of Business

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

Non-Securities Business Description: APPICANT SOLICITS AND EFFECTS TRANSACTIONS IN REPURCHASEAGREEMENTS, REVERSE PURCHASE AGREEMENTS, CERTIFICATES OFDEPOSIT, BANKER'S ACCEPTANCES, DEPOSIT NOTES AND OTHEREXEMPT SECURITIES TRANSACTIONS FOR AFFILATED AND NON-AFFILIATED ENTITIES.

Other - APPLICANT SOLICITS AND EFFECTS TRANSACTIONS IN REPURCHASE AGREEMENTS, REVERSEPURCHASE AGREEMENTS, CERTIFICATES OF DEPOSIT, BANKER'S ACCEPTANCE, DEPOSIT NOTES ANDOTHER EXEMPT SECURITIES TRANSACTIONS FOR AFFILIATED AND NON-AFFILIATED ENTITIES.

ENGAGING IN MULTI-CURRENCY FIXED INCOME BUSINESS AND FOREIGN EXCHANGE TRANSACTIONSANCILLARY TO THIS BUSINESS.

TRADE SETTLEMENT AND SECURITIES CLEARANCE, AND CORRESPONDENT CLEARING SERVICES; PRIMEBROKERAGE SERVICES; AND SECURITIES LENDING.

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Firm Operations

Clearing Arrangements

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

Introducing Arrangements

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

Name: ADM INVESTOR SERVICES, INC.

Business Address: CHICAGO BOARD OF TRADE BUILDING141 WEST JACKSON BOULEVARDCHICAGO, IL 60604

Effective Date: 07/13/2012

Description: TRANSACTIONS EFFECTED IN FUTURES OR COMMODITIES FOR RETAILCUSTOMER ACCOUNTS OF WELLS FARGO ADVISORS WILL BECARRIED, CLEARED AND SETTLED ON A FULLY DISCLOSED BASIS.

19©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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

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

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

Control Persons/Financing

Name: ADM INVESTOR SERVICES, INC.

Business Address: CHICAGO BOARD OF TRADE BUILDING141 WEST JACKSON BOULEVARDCHICAGO, IL 60604

Effective Date: 07/13/2012

Description: TRANSACTIONS EFFECTED IN FUTURES OR COMMODITIES FOR RETAILCUSTOMER ACCOUNTS OF WELLS FARGO ADVISORS WILL BECARRIED, CLEARED AND SETTLED ON A FULLY DISCLOSED BASIS.

Name: WELLS FARGO & COMPANY

Business Address: 1 NORTH JEFFERSONST. LOUIS, MO 63103

Effective Date: 03/20/2010

Description: WELLS FARGO & COMPANY PROVIDES OPERATIONAL FACILITIES ANDSUPPORT, DATA PROCESSING AND RECORDKEEPING FUNCTIONS FORAPPLICANT.

Name: ADM INVESTOR SERVICES, INC.

Business Address: CHICAGO BOARD OF TRADE BUILDING141 WEST JACKSON BOULEVARDCHICAGO, IL 60604

Effective Date: 07/13/2012

Description: TRANSACTIONS EFFECTED IN FUTURES OR COMMODITIES FOR RETAILCUSTOMER ACCOUNTS OF WELLS FARGO ADVISORS WILL BECARRIED, CLEARED AND SETTLED ON A FULLY DISCLOSED BASIS.

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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

10/01/2016

555 WEST FIFTH STREET50TH FLOORLOS ANGELES, CA 90013

104963

ANALYTIC INVESTORS, LLC is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY WELLS CAPITAL MANAGEMENT, INC.,WHICH IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENTHOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITALCORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

No

12/14/2012

1133 CONNECTICUT AVE.,WASHINGTON, DC 20036

125409

THE ROCK CREEK GROUP, LP is under common control with the firm.

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

21©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Firm Operations

Organization Affiliates (continued)

Yes

THE AFFILIATE IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENTHOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITALCORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Yes

Yes

No

12/14/2012

1133 CONNECTICUT AVENUE NWWASHINGTON,, DC 20036

117246

THE ROCK CREEK GROUP, LLC is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENTHOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITALCORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

CANADA

Yes

08/01/2012

1235 BAY STREETSUITE 400TORONTO, CANADA M5R 3K4

WELLS FARGO SECURITIES CANADA, LTD. is under common control with the firm.

WELLS FARGO SECURITIES CANADA, LTD. IS WHOLLY OWNED BY EVERENCAPITAL CORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC,WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THEULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

22©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Firm Operations

Organization Affiliates (continued)WELLS FARGO SECURITIES CANADA, LTD. IS WHOLLY OWNED BY EVERENCAPITAL CORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC,WHICH IS 100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THEULTIMATE PARENT OF THE AFFILIATE AND THE APPLICANT.

Description:

No

Yes

No

08/01/2012

101 CALIFORNIA STREETSUITE 3050SAN FRANCISCO, CA 94111

133068

WELLS FARGO PRIME SERVICES, LLC is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY EVEREN CAPITAL CORPORATION,WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNEDBY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THEAFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

Yes

JAPAN

No

05/11/2007

MARUNOUCHI TRUST TOWER MAIN, 24TH FLOOR1-8-3, MARUNOUCHI, CHIYODA-KUTOKYO, JAPAN

WELLS FARGO SECURITIES (JAPAN) CO., LTD. is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY WELLS FARGO INTERNATIONALBANKING CORPORATION, WHICH IS 100% OWNED BY WELLS FARGO BANK,N.A., WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100%OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENTOF THE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

23©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Firm Operations

Organization Affiliates (continued)

Yes

Yes

CHINA

Yes

09/18/2007

23F/AIA CENTRAL1 CONNAUGHT ROAD, CENTRALHONG KONG, HONG KONG

WELLS FARGO SECURITIES ASIA LIMITED is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY WELLS FARGO INTERNATIONALBANKING CORPORATION, WHICH IS 100% OWNED BY WELLS FARGO BANK,N.A., WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100%OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENTOF THE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

01/01/2009

525 MARKET STREET12TH FLOORSAN FRANCISCO, CA 94105

133366

WELLS FARGO FUNDS DISTRIBUTOR, LLC is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENTHOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITALCORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

106487

GALLIARD CAPITAL MANAGEMENT INC is under common control with the firm.

CRD #:

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Firm Operations

Organization Affiliates (continued)

Yes

No

No

01/01/2009

SIXTH & MARQUETTEMINNEAPOLIS, MN 55479

THE AFFILIATE IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENTHOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITALCORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

No

No

01/01/2009

525 MARKET STREET10TH FLOORSAN FRANCISCO, CA 94105

104973

WELLS CAPITAL MANAGEMENT INC is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENTHOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITALCORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

525 MARKET STREET12TH FLOORSAN FRANCISCO, CA 94105

110841

WELLS FARGO FUNDS MANAGEMENT, LLC is under common control with the firm.

Business Address:

CRD #:

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Firm Operations

Organization Affiliates (continued)

Yes

No

No

01/01/2009

525 MARKET STREET12TH FLOORSAN FRANCISCO, CA 94105

THE AFFILIATE IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENTHOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITALCORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Yes

No

ENGLAND

Yes

03/20/2010

34 GROSVENOR STREETLONDON, ENGLAND W1K 4QU

132377

ECM is under common control with the firm.

THE AFFILIATE IS OWNED 25% BY HADBO INVESTMENTS C.V. AND 75% BYISLAND FINANCE HOLDING COMPANY, BOTH OF WHICH ARE OWNEDDIRECTLY AND INDIRECTLY BY WELLS FARGO FINANCIAL, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE SUBSIDIARY AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

03/20/2010

10715 DAVID TAYLOR DRIVESUITE 150CHARLOTTE, NC 28262

110667

GOLDEN CAPITAL MANAGEMENT, LLC is under common control with the firm.

Effective Date:

Business Address:

CRD #:

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Firm Operations

Organization Affiliates (continued)

Yes

No

No

THE AFFILIATE IS 100% OWNED BY WELLS CAPITAL MANAGEMENT, INC.,WHICH IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENTHOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITALCORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Yes

No

No

03/20/2010

301 SOUTH COLLEGE STREET, TW-8CHARLOTTE, NC 28288

131539

STRUCTURED ASSET INVESTORS, LLC is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY WELLS FARGO & COMPANY. WELLSFARGO & COMPANY IS THE ULTIMATE PARENT OF THE AFFILIATE AND THEAPPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

No

03/20/2010

301 SOUTH COLLEGE STREET7TH FLOORCHARLOTTE, NC 28288

112660

STRUCTURED CREDIT PARTNERS LLC is under common control with the firm.

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

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Firm Operations

Organization Affiliates (continued)

Yes

No

STRUCTURED CREDIT PARTNERS, LLC IS 100% OWNED BY WELLS FARGO& COMPANY. WELLS FARGO & COMPANY IS THE ULTIMATE PARENT OFTHE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Yes

No

No

03/20/2010

401 SOUTH TRYON STREETCHARLOTTE, NC 28202

133204

WELLS FARGO INVESTMENT INSTITUTE, INC. is under common control with the firm.

THE AFFILIATE IS OWNED 100% BY WELLS FARGO BANK, N.A., WHICH ISOWNED 100% BY WFC HOLDINGS, LLC, WHICH IS 100% OWNED BY WELLSFARGO & COMPANY, THE ULTIMATE PARENT OF THE AFFILIATE AND THEAPPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

No

03/20/2010

301 S COLLEGE STREETCHARLOTTE, NC 28288-0601

126292

WELLS FARGO SECURITIES, LLC is under common control with the firm.

THE AFFILIATE IS WHOLLY OWNED BY EVEREN CAPITAL CORPORATION,WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNEDBY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THEAFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

28©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Firm Operations

Organization Affiliates (continued)THE AFFILIATE IS WHOLLY OWNED BY EVEREN CAPITAL CORPORATION,WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100% OWNEDBY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THEAFFILIATE AND THE APPLICANT.

No

Yes

No

03/20/2010

200 BERKELEY STREETBOSTON, MA 02116

487

GLOBAL ALTERNATIVE INVESTMENT SERVICES, INC. is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY WELLS FARGO BANK, N.A., WHICH IS100% OWNED BY WFC HOLDINGS, LLC WHICH IS 100% OWNED BY WELLSFARGO & COMPANY, WHICH IS THE ULTIMATE PARENT OF THE AFFILIATEAND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

ENGLAND

Yes

03/20/2010

LECONFIELD HOUSECURZON STREETLONDON, ENGLAND WIJ-5JA

WELLS FARGO SECURITIES INTERNATIONAL LIMITED is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY WELLS FARGO INTERNATIONALBANKING CORPORATION, WHICH IS 100% OWNED BY WELLS FARGO BANK,N.A., WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100%OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATE PARENTOF THE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

11025

WELLS FARGO ADVISORS FINANCIAL NETWORK, LLC is under common control with the firm.

CRD #:29©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Firm Operations

Organization Affiliates (continued)

Yes

Yes

No

08/01/2010

ONE NORTH JEFFERSON AVENUEST. LOUIS, MO 63103

11025

THE AFFILIATE IS 100% OWNED BY WACHOVIA SECURITIES FINANCIALHOLDINGS, LLC WHICH IS 100% OWNED BY EVEREN CAPITALCORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

ENGLAND

Yes

03/20/2010

CENTURION HOUSE24 MONUMENT STREET, 4TH FLOORLONDON, ENGLAND EC3R 8A2

109192

FIRST INTERNATIONAL ADVISORS, LLC is under common control with the firm.

THE AFFILIATE IS 100% OWNED BY WELLS FARGO ASSET MANAGEMENTHOLDINGS, LLC, WHICH IS 100% OWNED BY EVEREN CAPITALCORPORATION, WHICH IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS100% OWNED BY WELLS FARGO & COMPANY, WHICH IS THE ULTIMATEPARENT OF THE AFFILIATE AND THE APPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

This firm is directly or indirectly, controlled by the following:

· bank holding company· national bank

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Firm Operations

Organization Affiliates (continued)

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

Effective Date:

Business Address:

Description: THE AFFILIATE IS 100% OWNED BY WFC HOLDINGS, LLC, WHICH IS 100%OWNED BY WELLS FARGO & COMPANY, THE ULTIMATE PARENT OF THEAFFILIATE AND THE APPLICANT.

WELLS FARGO BANK, N. A. is a National Bank and controls the firm.

01/01/2008

420 MONTGAMERY STREETSAN FRANCISCO, CA 94104

Effective Date:

Business Address:

Description: ULTIMATE PARENT OF APPLICANT

WELLS FARGO & COMPANY is a Bank Holding Company and controls the firm.

01/01/2009

420 MONTGOMERY STREETSAN FRANCISCO, CA 94163

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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 1 158 0

Civil Event 0 2 0

Arbitration N/A 337 N/A

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Disclosure Event Details

What you should know about reported disclosure events:

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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.

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

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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 158

Reporting Source: Regulator

Allegations: SEC ADMIN RELEASE 33-10511; 34-83508; IA RELEASE 4947, JUNE 25, 2018:THE SECURITIES AND EXCHANGE COMMISSION (COMMISSION) DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, ANDHEREBY ARE, INSTITUTED PURSUANT TO SECTION 8A OF THE SECURITIESACT OF 1933 (SECURITIES ACT), SECTION 15(B) OF THE SECURITIESEXCHANGE ACT OF 1934 (EXCHANGE ACT), AND SECTION 203(E) OF THEINVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AGAINST WELLSFARGO ADVISORS, LLC. FROM AT LEAST JANUARY 2009 THROUGH JUNE2013, CERTAIN REGISTERED REPRESENTATIVES AT WELLS FARGOADVISORS, LLC (WFA) AND ITS PREDECESSOR WELLS FARGOINVESTMENTS, LLC (WFI) IMPROPERLY SOLICITED CUSTOMERS TOREDEEM THEIR MARKET-LINKED INVESTMENTS (MLI) EARLY ANDPURCHASE NEW MLIS WITHOUT ADEQUATE ANALYSIS ORCONSIDERATION OF THE SUBSTANTIAL COSTS ASSOCIATED WITH SUCHTRANSACTIONS. AN MLI IS A FIXED MATURITY FINANCIAL PRODUCTWHOSE INTEREST IS DETERMINED BY THE PERFORMANCE OF AREFERENCE ASSET OR MARKET MEASURE SUCH AS AN EQUITY ORCOMMODITY INDEX OVER THE TERM OF THE PRODUCT. MLIS HAVELIMITED LIQUIDITY AND SIGNIFICANT UPFRONT FEES, AND ACCORDINGLYWFA CONSIDERED THEM TO BE PRODUCTS INTENDED TO BE HELD TOMATURITY AND IN 2011 IMPLEMENTED A POLICY PROHIBITINGREPRESENTATIVES FROM ENGAGING IN "SHORT-TERM TRADING" OR "FLIPPING" OF MLIS. NOTWITHSTANDING WFA'S INTERNAL GUIDANCE ANDPOLICY, AND DESPITE THE ADVERSE ECONOMIC CONSEQUENCES TO WFACUSTOMERS, CERTAIN WFA REPRESENTATIVES DID NOT REASONABLYINVESTIGATE OR UNDERSTAND THE SIGNIFICANT COSTS OF MLIEXCHANGES. NEVERTHELESS, THEY RECOMMENDED TO THEIRCUSTOMERS THAT THEY REDEEM THEIR MLIS EARLY, TYPICALLY TOREALIZE PROFITS, AND TO USE THE PROCEEDS FROM THOSEREDEMPTIONS TO PURCHASE NEW MLIS. SUPERVISORS ROUTINELYAPPROVED THE RECOMMENDATIONS OR THE EXCHANGES. THISPRACTICE CAUSED CERTAIN WFA CUSTOMERS TO INCUR SIGNIFICANTCOSTS AND IMPAIRED THE CUSTOMERS' ABILITY TO ACHIEVE THEIRINVESTMENT OBJECTIVES. AS A CONSEQUENCE, WFA OBTAINEDCOMMISSIONS BY MEANS OF RECOMMENDATIONS THAT CONTAINEDIMPLIED REPRESENTATIONS THAT WFA PERSONNEL HAD FORMED AREASONABLE BASIS FOR THE RECOMMENDATIONS WHEN THEY HAD NOT,IN FACT, DONE SO. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE,WFA WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THESECURITIES ACT.

Current Status: Final

33©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Date Initiated: 06/25/2018

Docket/Case Number: 3-18556

Allegations: SEC ADMIN RELEASE 33-10511; 34-83508; IA RELEASE 4947, JUNE 25, 2018:THE SECURITIES AND EXCHANGE COMMISSION (COMMISSION) DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, ANDHEREBY ARE, INSTITUTED PURSUANT TO SECTION 8A OF THE SECURITIESACT OF 1933 (SECURITIES ACT), SECTION 15(B) OF THE SECURITIESEXCHANGE ACT OF 1934 (EXCHANGE ACT), AND SECTION 203(E) OF THEINVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AGAINST WELLSFARGO ADVISORS, LLC. FROM AT LEAST JANUARY 2009 THROUGH JUNE2013, CERTAIN REGISTERED REPRESENTATIVES AT WELLS FARGOADVISORS, LLC (WFA) AND ITS PREDECESSOR WELLS FARGOINVESTMENTS, LLC (WFI) IMPROPERLY SOLICITED CUSTOMERS TOREDEEM THEIR MARKET-LINKED INVESTMENTS (MLI) EARLY ANDPURCHASE NEW MLIS WITHOUT ADEQUATE ANALYSIS ORCONSIDERATION OF THE SUBSTANTIAL COSTS ASSOCIATED WITH SUCHTRANSACTIONS. AN MLI IS A FIXED MATURITY FINANCIAL PRODUCTWHOSE INTEREST IS DETERMINED BY THE PERFORMANCE OF AREFERENCE ASSET OR MARKET MEASURE SUCH AS AN EQUITY ORCOMMODITY INDEX OVER THE TERM OF THE PRODUCT. MLIS HAVELIMITED LIQUIDITY AND SIGNIFICANT UPFRONT FEES, AND ACCORDINGLYWFA CONSIDERED THEM TO BE PRODUCTS INTENDED TO BE HELD TOMATURITY AND IN 2011 IMPLEMENTED A POLICY PROHIBITINGREPRESENTATIVES FROM ENGAGING IN "SHORT-TERM TRADING" OR "FLIPPING" OF MLIS. NOTWITHSTANDING WFA'S INTERNAL GUIDANCE ANDPOLICY, AND DESPITE THE ADVERSE ECONOMIC CONSEQUENCES TO WFACUSTOMERS, CERTAIN WFA REPRESENTATIVES DID NOT REASONABLYINVESTIGATE OR UNDERSTAND THE SIGNIFICANT COSTS OF MLIEXCHANGES. NEVERTHELESS, THEY RECOMMENDED TO THEIRCUSTOMERS THAT THEY REDEEM THEIR MLIS EARLY, TYPICALLY TOREALIZE PROFITS, AND TO USE THE PROCEEDS FROM THOSEREDEMPTIONS TO PURCHASE NEW MLIS. SUPERVISORS ROUTINELYAPPROVED THE RECOMMENDATIONS OR THE EXCHANGES. THISPRACTICE CAUSED CERTAIN WFA CUSTOMERS TO INCUR SIGNIFICANTCOSTS AND IMPAIRED THE CUSTOMERS' ABILITY TO ACHIEVE THEIRINVESTMENT OBJECTIVES. AS A CONSEQUENCE, WFA OBTAINEDCOMMISSIONS BY MEANS OF RECOMMENDATIONS THAT CONTAINEDIMPLIED REPRESENTATIONS THAT WFA PERSONNEL HAD FORMED AREASONABLE BASIS FOR THE RECOMMENDATIONS WHEN THEY HAD NOT,IN FACT, DONE SO. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE,WFA WILLFULLY VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THESECURITIES ACT.

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Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Docket/Case Number: 3-18556

Principal Product Type: Other

Other Product Type(s): MARKET-LINKED INVESTMENTS

Resolution Date: 06/25/2018

Resolution:

Other Sanctions Ordered: PREJUDGMENT INTEREST

Sanction Details: WFA IS CENSURED, ORDERED TO CEASE AND DESIST FROM COMMITTINGOR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OFSECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT, AND SHALL PAYDISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL MONETARYPENALTY TOTALING $5,108,441.27.

Regulator Statement IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THEFIRM HAS SUBMITTED AN OFFER OF SETTLEMENT (THE OFFER) WHICHTHE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTIONOVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICHARE ADMITTED, THE FIRM CONSENTS TO THE ENTRY OF THIS ORDERINSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS,PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933, SECTION15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, AND SECTION 203(E)OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, ANDIMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER(ORDER). AS A RESULT OF THE CONDUCT DESCRIBED, WFA WILLFULLYVIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. INVIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATEAND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INWFA'S OFFER. ACCORDINGLY, PURSUANT TO SECTION 8A OF THESECURITIES ACT, SECTION 15(B) OF THE EXCHANGE ACT, AND SECTION203(E) OF THE ADVISERS ACT IT IS HEREBY ORDERED THAT WFA ISCENSURED, ORDERED TO CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT, AND SHALL PAYDISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL MONETARYPENALTY TOTALING $5,108,441.27 AS FOLLOWS: WFA SHALL PAYDISGORGEMENT OF $930,377, WHICH REPRESENTS THE COMMISSIONSWFA EARNED ON REPRESENTATIVES RECURRENT MLI EXCHANGESBETWEEN JANUARY 1, 2009 AND AUGUST 31, 2012, PREJUDGMENTINTEREST THEREON OF $178,064.27, AND A CIVIL MONEY PENALTY IN THEAMOUNT OF $4,000,000, CONSISTENT WITH THE PROVISIONS OF THEORDER.

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

Yes

Sanctions Ordered: CensureMonetary/Fine $4,000,000.00Disgorgement/RestitutionCease and Desist/Injunction

Order

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IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THEFIRM HAS SUBMITTED AN OFFER OF SETTLEMENT (THE OFFER) WHICHTHE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTIONOVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICHARE ADMITTED, THE FIRM CONSENTS TO THE ENTRY OF THIS ORDERINSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS,PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933, SECTION15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, AND SECTION 203(E)OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, ANDIMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER(ORDER). AS A RESULT OF THE CONDUCT DESCRIBED, WFA WILLFULLYVIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. INVIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATEAND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INWFA'S OFFER. ACCORDINGLY, PURSUANT TO SECTION 8A OF THESECURITIES ACT, SECTION 15(B) OF THE EXCHANGE ACT, AND SECTION203(E) OF THE ADVISERS ACT IT IS HEREBY ORDERED THAT WFA ISCENSURED, ORDERED TO CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT, AND SHALL PAYDISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL MONETARYPENALTY TOTALING $5,108,441.27 AS FOLLOWS: WFA SHALL PAYDISGORGEMENT OF $930,377, WHICH REPRESENTS THE COMMISSIONSWFA EARNED ON REPRESENTATIVES RECURRENT MLI EXCHANGESBETWEEN JANUARY 1, 2009 AND AUGUST 31, 2012, PREJUDGMENTINTEREST THEREON OF $178,064.27, AND A CIVIL MONEY PENALTY IN THEAMOUNT OF $4,000,000, CONSISTENT WITH THE PROVISIONS OF THEORDER.

Disclosure 2 of 158

i

Reporting Source: Firm

Initiated By: STATE OF NEVADA SECURITIES DIVISION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 04/13/2018

Docket/Case Number: CI15-011 AND CI15-013

Principal Product Type: No Product

Other Product Type(s):

Allegations: ALLEGED THAT WFCS HAS VIOLATED NRS 90.360(2) AND NAC 90.392 BYMAINTAINING THREE (3) BRANCH OFFICE LOCATIONS IN THE STATE OFNEVADA WITHOUT OBTAINING A LICENSE FROM THE DIVISION

Current Status: Final

Resolution Date: 04/13/2018

Resolution:

Other Sanctions Ordered:

Sanctions Ordered: Monetary/Fine $8,500.00

Consent

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Other Sanctions Ordered:

Sanction Details: IN ADDITION TO THE MONETARY PENALTY OF $8500, WFCS IS ORDEREDTO PAY $1446.13 FOR COSTS OF INSPECTING TWO BRANCH OFFICES

Disclosure 3 of 158

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Reporting Source: Regulator

Initiated By: STATE OF ILLINOIS, ILLINOIS SECURITIES DEPARTMENT

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

NOTICE OF HEARING

Date Initiated: 12/17/2017

Docket/Case Number: 1500252

URL for Regulatory Action:

Principal Product Type: Other

Other Product Type(s): SEPARATELY MANAGED ACCOUNT PRODUCT

Allegations: SEEING NOTICE OF HEARING AND CONSENT ORDER.

Current Status: Final

Resolution Date: 12/21/2017

Resolution:

Other Sanctions Ordered:

Sanction Details: MONETARY PAYMENT $270,000.00

Regulator Statement NOTICE OF HEARING WAS ISSUED DECEMBER 21, 2017. CONSENT ORDERWAS ISSUED DECEMBER 21, 2017. CONTACT 217-782-2256.

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

No

Sanctions Ordered:

Consent

iReporting Source: Firm

37©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Initiated By: STATE OF ILLINOIS, ILLINOIS SECURITIES DEPARTMENT

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

NOTICE OF HEARING

Date Initiated: 12/17/2017

Docket/Case Number: 1500252

Principal Product Type: Other

Other Product Type(s): SEPARATELY MANAGED ACCOUNT PRODUCT

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND THE ENTRY OF FINDINGS THAT IT RECEIVED,REVIEWED AND/OR ANALYZED DOCUMENTS AND INFORMATION FROM AFINANCIAL ADVISORY FIRM CONCERNING CERTAIN MONEY MANAGERSTRATEGIES THAT CONTAINED INFORMATION THAT WAS LATER FOUND TOBE FALSE AND MISLEADING. THE FINDINGS STATED THAT THE FIRMINCLUDED THE FINANCIAL ADVISORY FIRM'S MONEY MANAGERSTRATEGIES IN CERTAIN OF ITS EXTERNALLY MANAGED SEPARATELYMANAGED ACCOUNT PROGRAMS, BUT THE FIRM DID NOT UTILIZEINACCURATE HISTORICAL PERFORMANCE DATA IN CONNECTION WITH ITSDECISION TO ONBOARD THE MONEY MANAGER STRATEGIES AND THEFIRM DID NOT INCORPORATE INACCURATE PERFORMANCE DATA IN ITSADVERTISEMENTS OR PROGRAM MARKETING MATERIALS.

Current Status: Final

Resolution Date: 12/21/2017

Resolution:

Other Sanctions Ordered:

Sanction Details: MONETARY PAYMENT $270,000.00

Firm Statement NOTICE OF HEARING WAS ISSUED DECEMBER 21, 2017. CONSENT ORDERWAS ISSUED DECEMBER 21, 2017.

Sanctions Ordered:

Consent

Disclosure 4 of 158

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Reporting Source: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EXECUTEDSHORT SALE ORDERS IN OVER-THE-COUNTER (OTC) EQUITY SECURITIESAND IMPROPERLY MARKED THE ORDERS AS SHORT EXEMPT. THEFINDINGS STATED THAT THE FIRM EXECUTED SHORT SALETRANSACTIONS IN OTC EQUITY SECURITIES AND INCORRECTLYREPORTED THE TRANSACTIONS TO THE OTC REPORTING FACILITY WITHSHORT EXEMPT MODIFIERS.

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 12/07/2017

Docket/Case Number: 2016049334801

Principal Product Type: Equity - OTC

Other Product Type(s):

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EXECUTEDSHORT SALE ORDERS IN OVER-THE-COUNTER (OTC) EQUITY SECURITIESAND IMPROPERLY MARKED THE ORDERS AS SHORT EXEMPT. THEFINDINGS STATED THAT THE FIRM EXECUTED SHORT SALETRANSACTIONS IN OTC EQUITY SECURITIES AND INCORRECTLYREPORTED THE TRANSACTIONS TO THE OTC REPORTING FACILITY WITHSHORT EXEMPT MODIFIERS.

Resolution Date: 12/07/2017

Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND FINED $20,000. FINES PAID IN FULL ONJANUARY 6, 2018.

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

No

Sanctions Ordered: CensureMonetary/Fine $20,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EXECUTEDSHORT SALE ORDERS IN OVER-THE-COUNTER (OTC) EQUITY SECURITIESAND IMPROPERLY MARKED THE ORDERS AS SHORT EXEMPT. THEFINDINGS STATED THAT THE FIRM EXECUTED SHORT SALETRANSACTIONS IN OTC EQUITY SECURITIES AND INCORRECTLYREPORTED THE TRANSACTIONS TO THE OTC REPORTING FACILITY WITHSHORT EXEMPT MODIFIERS.

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 12/07/2017

Docket/Case Number: 2016049334801

Principal Product Type: Equity - OTC

Other Product Type(s):

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EXECUTEDSHORT SALE ORDERS IN OVER-THE-COUNTER (OTC) EQUITY SECURITIESAND IMPROPERLY MARKED THE ORDERS AS SHORT EXEMPT. THEFINDINGS STATED THAT THE FIRM EXECUTED SHORT SALETRANSACTIONS IN OTC EQUITY SECURITIES AND INCORRECTLYREPORTED THE TRANSACTIONS TO THE OTC REPORTING FACILITY WITHSHORT EXEMPT MODIFIERS.

Resolution Date: 12/07/2017

Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND FINED $20,000.

Firm Statement THE FIRM WAS CENSURED AND FINED $20,000.

Sanctions Ordered: CensureMonetary/Fine $20,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 5 of 158

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Reporting Source: Regulator

Allegations: SEC ADMIN RELEASE 34-82054, NOVEMBER 13, 2017: THE SEC DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, ANDHEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THESECURITIES EXCHANGE ACT OF 1934 AGAINST WELLS FARGO ADVISORS,LLC. IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THECOMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSEOF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BYOR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION ISA PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN,EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THESUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934,MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. ON THE BASIS OF THIS ORDER AND RESPONDENT'SOFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUTOF WELLS FARGO ADVISORS' FAILURE TO FILE OR TIMELY FILE A NUMBEROF SUSPICIOUS ACTIVITY REPORTS ("SARS") FROM APPROXIMATELYMARCH 2012 THROUGH JUNE 2013. THE MAJORITY OF THESE FAILURESINVOLVED THE FAILURE TO TIMELY FILE SARS ON ONGOING SUSPICIOUSACTIVITY THAT CONTINUED AFTER AN INITIAL SAR FILING BY WELLSFARGO ADVISORS ON RELATED SUSPICIOUS ACTIVITY. AT THE TIME,WELLS FARGO ADVISORS' ANTI-MONEY LAUNDERING ("AML") POLICIESAND PROCEDURES REQUIRED THE FILING OF SARS PURSUANT TO THEREQUIREMENTS OF THE BANK SECRECY ACT ("BSA"), INCLUDING THEFILING OF SARS RELATED TO CONTINUING SUSPICIOUS ACTIVITY.DESPITE THESE REQUIREMENTS, WELLS FARGO ADVISORS FAILED TOFILE OR TIMELY FILE AT LEAST 50 SARS, A MAJORITY OF WHICH RELATEDTO CONTINUING SUSPICIOUS ACTIVITY OCCURRING IN ACCOUNTS HELDAT WELLS FARGO ADVISORS' U.S. BRANCH OFFICES THAT FOCUSED ONINTERNATIONAL CUSTOMERS. AS A RESULT OF THIS CONDUCT, WELLSFARGO ADVISORS WILLFULLY VIOLATED SECTION 17(A) OF THEEXCHANGE ACT AND RULE 17A-8 THEREUNDER.

Current Status: Final

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Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

Date Initiated: 11/13/2017

Docket/Case Number: 3-18279

Principal Product Type: No Product

Other Product Type(s):

SEC ADMIN RELEASE 34-82054, NOVEMBER 13, 2017: THE SEC DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, ANDHEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THESECURITIES EXCHANGE ACT OF 1934 AGAINST WELLS FARGO ADVISORS,LLC. IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THECOMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSEOF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BYOR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION ISA PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN,EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THESUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934,MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. ON THE BASIS OF THIS ORDER AND RESPONDENT'SOFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUTOF WELLS FARGO ADVISORS' FAILURE TO FILE OR TIMELY FILE A NUMBEROF SUSPICIOUS ACTIVITY REPORTS ("SARS") FROM APPROXIMATELYMARCH 2012 THROUGH JUNE 2013. THE MAJORITY OF THESE FAILURESINVOLVED THE FAILURE TO TIMELY FILE SARS ON ONGOING SUSPICIOUSACTIVITY THAT CONTINUED AFTER AN INITIAL SAR FILING BY WELLSFARGO ADVISORS ON RELATED SUSPICIOUS ACTIVITY. AT THE TIME,WELLS FARGO ADVISORS' ANTI-MONEY LAUNDERING ("AML") POLICIESAND PROCEDURES REQUIRED THE FILING OF SARS PURSUANT TO THEREQUIREMENTS OF THE BANK SECRECY ACT ("BSA"), INCLUDING THEFILING OF SARS RELATED TO CONTINUING SUSPICIOUS ACTIVITY.DESPITE THESE REQUIREMENTS, WELLS FARGO ADVISORS FAILED TOFILE OR TIMELY FILE AT LEAST 50 SARS, A MAJORITY OF WHICH RELATEDTO CONTINUING SUSPICIOUS ACTIVITY OCCURRING IN ACCOUNTS HELDAT WELLS FARGO ADVISORS' U.S. BRANCH OFFICES THAT FOCUSED ONINTERNATIONAL CUSTOMERS. AS A RESULT OF THIS CONDUCT, WELLSFARGO ADVISORS WILLFULLY VIOLATED SECTION 17(A) OF THEEXCHANGE ACT AND RULE 17A-8 THEREUNDER.

Resolution Date: 11/13/2017

Resolution:

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

No

Order

41©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Other Sanctions Ordered:

Sanction Details: RESPONDENT IS ORDERED TO CEASE AND DESIST; IS CENSURED; ANDSHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $3,500,000.00.

Regulator Statement IN DETERMINING TO ACCEPT WELLS FARGO ADVISORS' OFFER, THECOMMISSION CONSIDERED VOLUNTARY REMEDIAL ACTS PROMPTLYUNDERTAKEN BY RESPONDENT, INCLUDING THE FIRM'S RETAINING ATHIRD PARTY AML COMPLIANCE FIRM TO REVIEW CERTAIN OF ITS SARINVESTIGATIONS DURING THE SUMMER OF 2014. IN DETERMININGWHETHER TO ACCEPT THE OFFER, THE COMMISSION HAS ALSOCONSIDERED THE UNDERTAKINGS ENUMERATED IN THE ORDER.

IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATEAND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INRESPONDENT WELLS FARGO ADVISORS' OFFER. ACCORDINGLY,PURSUANT TO SECTIONS 15(B) AND 21C OF THE EXCHANGE ACT IT ISHEREBY ORDERED THAT: RESPONDENT CEASE AND DESIST FROMCOMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONSOF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-8PROMULGATED THEREUNDER; RESPONDENT IS CENSURED; ANDRESPONDENT SHALL, WITHIN 30 DAYS OF THE ENTRY OF THIS ORDER,PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $3,500,000.00 TO THESEC.

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

No

Sanctions Ordered: CensureMonetary/Fine $3,500,000.00Cease and Desist/Injunction

iReporting Source: Firm

Allegations: SEC ADMIN RELEASE 34-82054, NOVEMBER 13, 2017: THE SEC DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, ANDHEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THESECURITIES EXCHANGE ACT OF 1934 AGAINST WELLS FARGO ADVISORS,LLC. IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THECOMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSEOF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BYOR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION ISA PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN,EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THESUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934,MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. ON THE BASIS OF THIS ORDER AND RESPONDENT'SOFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUTOF WELLS FARGO ADVISORS' FAILURE TO FILE OR TIMELY FILE A NUMBEROF SUSPICIOUS ACTIVITY REPORTS ("SARS") FROM APPROXIMATELYMARCH 2012 THROUGH JUNE 2013. THE MAJORITY OF THESE FAILURESINVOLVED THE FAILURE TO TIMELY FILE SARS ON ONGOING SUSPICIOUSACTIVITY THAT CONTINUED AFTER AN INITIAL SAR FILING BY WELLSFARGO ADVISORS ON RELATED SUSPICIOUS ACTIVITY. AT THE TIME,WELLS FARGO ADVISORS' ANTI-MONEY LAUNDERING ("AML") POLICIESAND PROCEDURES REQUIRED THE FILING OF SARS PURSUANT TO THEREQUIREMENTS OF THE BANK SECRECY ACT ("BSA"), INCLUDING THEFILING OF SARS RELATED TO CONTINUING SUSPICIOUS ACTIVITY.DESPITE THESE REQUIREMENTS, WELLS FARGO ADVISORS FAILED TOFILE OR TIMELY FILE AT LEAST 50 SARS, A MAJORITY OF WHICH RELATEDTO CONTINUING SUSPICIOUS ACTIVITY OCCURRING IN ACCOUNTS HELDAT WELLS FARGO ADVISORS' U.S. BRANCH OFFICES THAT FOCUSED ONINTERNATIONAL CUSTOMERS. AS A RESULT OF THIS CONDUCT, WELLSFARGO ADVISORS WILLFULLY VIOLATED SECTION 17(A) OF THEEXCHANGE ACT AND RULE 17A-8 THEREUNDER.

Current Status: Final

42©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 45: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

CENSURE, CIVIL MONEY PENALTY

Date Initiated: 11/13/2017

Docket/Case Number: 3-18279

Principal Product Type: No Product

Other Product Type(s):

SEC ADMIN RELEASE 34-82054, NOVEMBER 13, 2017: THE SEC DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, ANDHEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THESECURITIES EXCHANGE ACT OF 1934 AGAINST WELLS FARGO ADVISORS,LLC. IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THECOMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSEOF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BYOR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION ISA PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN,EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THESUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934,MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. ON THE BASIS OF THIS ORDER AND RESPONDENT'SOFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUTOF WELLS FARGO ADVISORS' FAILURE TO FILE OR TIMELY FILE A NUMBEROF SUSPICIOUS ACTIVITY REPORTS ("SARS") FROM APPROXIMATELYMARCH 2012 THROUGH JUNE 2013. THE MAJORITY OF THESE FAILURESINVOLVED THE FAILURE TO TIMELY FILE SARS ON ONGOING SUSPICIOUSACTIVITY THAT CONTINUED AFTER AN INITIAL SAR FILING BY WELLSFARGO ADVISORS ON RELATED SUSPICIOUS ACTIVITY. AT THE TIME,WELLS FARGO ADVISORS' ANTI-MONEY LAUNDERING ("AML") POLICIESAND PROCEDURES REQUIRED THE FILING OF SARS PURSUANT TO THEREQUIREMENTS OF THE BANK SECRECY ACT ("BSA"), INCLUDING THEFILING OF SARS RELATED TO CONTINUING SUSPICIOUS ACTIVITY.DESPITE THESE REQUIREMENTS, WELLS FARGO ADVISORS FAILED TOFILE OR TIMELY FILE AT LEAST 50 SARS, A MAJORITY OF WHICH RELATEDTO CONTINUING SUSPICIOUS ACTIVITY OCCURRING IN ACCOUNTS HELDAT WELLS FARGO ADVISORS' U.S. BRANCH OFFICES THAT FOCUSED ONINTERNATIONAL CUSTOMERS. AS A RESULT OF THIS CONDUCT, WELLSFARGO ADVISORS WILLFULLY VIOLATED SECTION 17(A) OF THEEXCHANGE ACT AND RULE 17A-8 THEREUNDER.

Resolution Date: 11/13/2017

Resolution:

Sanctions Ordered: CensureMonetary/Fine $3,500,000.00Cease and Desist/Injunction

Order

43©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Other Sanctions Ordered:

Sanction Details: RESPONDENT IS ORDERED TO CEASE AND DESIST; IS CENSURED; ANDSHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $3,500,000.00.

Firm Statement IN DETERMINING TO ACCEPT WELLS FARGO ADVISORS' OFFER, THECOMMISSION CONSIDERED VOLUNTARY REMEDIAL ACTS PROMPTLYUNDERTAKEN BY RESPONDENT, INCLUDING THE FIRM'S RETAINING ATHIRD PARTY AML COMPLIANCE FIRM TO REVIEW CERTAIN OF ITS SARINVESTIGATIONS DURING THE SUMMER OF 2014. IN DETERMININGWHETHER TO ACCEPT THE OFFER, THE COMMISSION HAS ALSOCONSIDERED THE UNDERTAKINGS ENUMERATED IN THE ORDER. IN VIEWOF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND INTHE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INRESPONDENT WELLS FARGO ADVISORS' OFFER. ACCORDINGLY,PURSUANT TO SECTIONS 15(B) AND 21C OF THE EXCHANGE ACT IT ISHEREBY ORDERED THAT: RESPONDENT CEASE AND DESIST FROMCOMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONSOF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-8PROMULGATED THEREUNDER; RESPONDENT IS CENSURED; ANDRESPONDENT SHALL, WITHIN 30 DAYS OF THE ENTRY OF THIS ORDER,PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $3,500,000.00 TO THESEC.

Sanctions Ordered: CensureMonetary/Fine $3,500,000.00Cease and Desist/Injunction

Disclosure 6 of 158

i

Reporting Source: Regulator

Initiated By: FINRA

Date Initiated: 11/06/2017

Docket/Case Number: 2016051812801

Principal Product Type: Other

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO TRACE THE CORRECT TIME OF TRADE EXECUTION FOR 88TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS. THEFINDINGS STATED THAT THE FIRM FAILED TO REPORT TO TRACE 148TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS WITHIN 15MINUTES OF THE TIME OF EXECUTION.

Current Status: Final

44©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 47: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Other Product Type(s): SECURITIZED PRODUCTS

Resolution Date: 11/06/2017

Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND FINED $30,000. FINES PAID IN FULL ONNOVEMBER 17, 2017.

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

No

Sanctions Ordered: CensureMonetary/Fine $30,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 11/06/2017

Docket/Case Number: 2016051812801

Principal Product Type: Other

Other Product Type(s): SECURITIZED PRODUCTS

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO TRACE THE CORRECT TIME OF TRADE EXECUTION FOR 88TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS. THEFINDINGS STATED THAT THE FIRM FAILED TO REPORT TO TRACE 148TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS WITHIN 15MINUTES OF THE TIME OF EXECUTION.

Current Status: Final

45©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 48: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Other Sanction(s)/ReliefSought:

N/A

Resolution Date: 11/06/2017

Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND FINED $30,000. FINES PAID IN FULL ONNOVEMBER 17, 2017.

Firm Statement THE FIRM WAS CENSURED AND FINED $30,000. FINES PAID IN FULL ONNOVEMBER 17, 2017.

Sanctions Ordered: CensureMonetary/Fine $30,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 7 of 158

i

Reporting Source: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT CERTAIN FIRMREGISTERED REPRESENTATIVES RECOMMENDED VOLATILITY-LINKEDEXCHANGE-TRADED PRODUCTS (VOLATILITY ETPS) TO BROKERAGECUSTOMERS WITHOUT FULLY UNDERSTANDING THEIR RISKS ANDFEATURES. THE FINDINGS STATED THAT THE FIRM FAILED TO VET ORPLACE RESTRICTIONS ON RECOMMENDATIONS AND PURCHASES OFVOLATILITY ETPS, AND AS A RESULT, THESE PRODUCTS WERE MADEAVAILABLE TO RETAIL BROKERAGE CUSTOMERS REGARDLESS OF RISKPROFILE AND INVESTMENT OBJECTIVE. CERTAIN FIRM REPRESENTATIVESMISTAKENLY BELIEVED THAT VOLATILITY ETPS COULD BE USED AS ALONG-TERM HEDGE ON THEIR CUSTOMERS' EQUITY POSITIONS IN THEEVENT OF A MARKET DOWNTURN. IN FACT, VOLATILITY ETPS AREGENERALLY SHORT-TERM TRADING PRODUCTS THAT DEGRADESIGNIFICANTLY OVER TIME AND SHOULD NOT BE USED AS PART OF ALONG-TERM BUY-AND-HOLD INVESTMENT STRATEGY. ACCORDINGLY, INTHOSE INSTANCES, THE REPRESENTATIVES DID NOT HAVE AREASONABLE BASIS TO RECOMMEND VOLATILITY ETPS AS SUITABLE TOCUSTOMERS WITH CONSERVATIVE OR MODERATE RISK PROFILES ANDINVESTMENT OBJECTIVES AND THE REPRESENTATIVES FURTHER FAILEDTO APPROPRIATELY RECOMMEND THE EXIT OF THESE POSITIONS WITHINA TIMELY MANNER. IN SOME INSTANCES, CUSTOMERS INCURREDSIGNIFICANT LOSSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILEDTO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDINGWRITTEN POLICIES AND PROCEDURES, REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH NASD RULE 2310 IN CONNECTION WITH ITSSALE OF VOLATILITY ETPS. ALTHOUGH THE FIRM SHOULD HAVE BEENAWARE OF THE COMPLEXITY AND UNIQUE RISKS AND FEATURESASSOCIATED WITH VOLATILITY ETPS, THE FIRM FAILED TO IMPLEMENT AREASONABLE SYSTEM TO SUPERVISE ITS REPRESENTATIVES' SOLICITEDSALES OF VOLATILITY ETPS. THE FINDINGS ALSO INCLUDED THAT THEFIRM'S SUPERVISORY SYSTEMS ALSO DID NOT INCLUDE REASONABLETRAINING FOR REGISTERED REPRESENTATIVES AND SUPERVISORSREGARDING THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITYETPS. BECAUSE THE FIRM FAILED TO ESTABLISH AND PROVIDEREASONABLE GUIDANCE, TRAINING OR TOOLS TO EDUCATE ITSREGISTERED REPRESENTATIVES AND SUPERVISORS ABOUT VOLATILITYETPS, CERTAIN RETAIL BROKERAGE CUSTOMERS WERE UNINFORMEDABOUT THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITY ETPSPRIOR TO PURCHASING THEM.

Current Status: Final

46©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 10/16/2017

Docket/Case Number: 2014042465601

Principal Product Type: Other

Other Product Type(s): VOLATILITY-LINKED EXCHANGE-TRADED PRODUCTS

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT CERTAIN FIRMREGISTERED REPRESENTATIVES RECOMMENDED VOLATILITY-LINKEDEXCHANGE-TRADED PRODUCTS (VOLATILITY ETPS) TO BROKERAGECUSTOMERS WITHOUT FULLY UNDERSTANDING THEIR RISKS ANDFEATURES. THE FINDINGS STATED THAT THE FIRM FAILED TO VET ORPLACE RESTRICTIONS ON RECOMMENDATIONS AND PURCHASES OFVOLATILITY ETPS, AND AS A RESULT, THESE PRODUCTS WERE MADEAVAILABLE TO RETAIL BROKERAGE CUSTOMERS REGARDLESS OF RISKPROFILE AND INVESTMENT OBJECTIVE. CERTAIN FIRM REPRESENTATIVESMISTAKENLY BELIEVED THAT VOLATILITY ETPS COULD BE USED AS ALONG-TERM HEDGE ON THEIR CUSTOMERS' EQUITY POSITIONS IN THEEVENT OF A MARKET DOWNTURN. IN FACT, VOLATILITY ETPS AREGENERALLY SHORT-TERM TRADING PRODUCTS THAT DEGRADESIGNIFICANTLY OVER TIME AND SHOULD NOT BE USED AS PART OF ALONG-TERM BUY-AND-HOLD INVESTMENT STRATEGY. ACCORDINGLY, INTHOSE INSTANCES, THE REPRESENTATIVES DID NOT HAVE AREASONABLE BASIS TO RECOMMEND VOLATILITY ETPS AS SUITABLE TOCUSTOMERS WITH CONSERVATIVE OR MODERATE RISK PROFILES ANDINVESTMENT OBJECTIVES AND THE REPRESENTATIVES FURTHER FAILEDTO APPROPRIATELY RECOMMEND THE EXIT OF THESE POSITIONS WITHINA TIMELY MANNER. IN SOME INSTANCES, CUSTOMERS INCURREDSIGNIFICANT LOSSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILEDTO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDINGWRITTEN POLICIES AND PROCEDURES, REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH NASD RULE 2310 IN CONNECTION WITH ITSSALE OF VOLATILITY ETPS. ALTHOUGH THE FIRM SHOULD HAVE BEENAWARE OF THE COMPLEXITY AND UNIQUE RISKS AND FEATURESASSOCIATED WITH VOLATILITY ETPS, THE FIRM FAILED TO IMPLEMENT AREASONABLE SYSTEM TO SUPERVISE ITS REPRESENTATIVES' SOLICITEDSALES OF VOLATILITY ETPS. THE FINDINGS ALSO INCLUDED THAT THEFIRM'S SUPERVISORY SYSTEMS ALSO DID NOT INCLUDE REASONABLETRAINING FOR REGISTERED REPRESENTATIVES AND SUPERVISORSREGARDING THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITYETPS. BECAUSE THE FIRM FAILED TO ESTABLISH AND PROVIDEREASONABLE GUIDANCE, TRAINING OR TOOLS TO EDUCATE ITSREGISTERED REPRESENTATIVES AND SUPERVISORS ABOUT VOLATILITYETPS, CERTAIN RETAIL BROKERAGE CUSTOMERS WERE UNINFORMEDABOUT THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITY ETPSPRIOR TO PURCHASING THEM.

Resolution Date: 10/16/2017

Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND ORDERED TO JOINTLY AND SEVERALLYPAY $3,411,478.78 IN RESTITUTION TO CUSTOMERS.

Regulator Statement IN DETERMINING TO RESOLVE THIS MATTER WITHOUT THE IMPOSITIONOF A FINE, FINRA TOOK THE FOLLOWING INTO CONSIDERATION: (I) PRIORTO DETECTION BY FINRA, THE FIRM CORRECTED ITS SUPERVISORYDEFICIENCIES RELATING TO VOLATILITY ETPS; (II) THE FIRM WASPREVIOUSLY FINED $2.1 MILLION - AFTER THE MISCONDUCT AND ITSREMEDIATION HEREIN - FOR SIMILAR VIOLATIONS RELATING TO NON-TRADITIONAL ETPS; AND, (III) THE FIRM PROVIDED SUBSTANTIALASSISTANCE TO FINRA BY, AMONG OTHER THINGS, ENGAGING AT ITS OWNEXPENSE A CONSULTING FIRM TO REVIEW, COMPILE, AND CALCULATELARGE AMOUNTS OF DATA PERTAINING TO SALES OF VOLATILITY ETPSFOR USE IN DETERMINING THE APPROPRIATE RESTITUTION TO BEPROVIDED.

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

No

Sanctions Ordered: CensureDisgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

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Regulator Statement IN DETERMINING TO RESOLVE THIS MATTER WITHOUT THE IMPOSITIONOF A FINE, FINRA TOOK THE FOLLOWING INTO CONSIDERATION: (I) PRIORTO DETECTION BY FINRA, THE FIRM CORRECTED ITS SUPERVISORYDEFICIENCIES RELATING TO VOLATILITY ETPS; (II) THE FIRM WASPREVIOUSLY FINED $2.1 MILLION - AFTER THE MISCONDUCT AND ITSREMEDIATION HEREIN - FOR SIMILAR VIOLATIONS RELATING TO NON-TRADITIONAL ETPS; AND, (III) THE FIRM PROVIDED SUBSTANTIALASSISTANCE TO FINRA BY, AMONG OTHER THINGS, ENGAGING AT ITS OWNEXPENSE A CONSULTING FIRM TO REVIEW, COMPILE, AND CALCULATELARGE AMOUNTS OF DATA PERTAINING TO SALES OF VOLATILITY ETPSFOR USE IN DETERMINING THE APPROPRIATE RESTITUTION TO BEPROVIDED.

iReporting Source: Firm

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT CERTAIN FIRMREGISTERED REPRESENTATIVES RECOMMENDED VOLATILITY-LINKEDEXCHANGE-TRADED PRODUCTS (VOLATILITY ETPS) TO BROKERAGECUSTOMERS WITHOUT FULLY UNDERSTANDING THEIR RISKS ANDFEATURES. THE FINDINGS STATED THAT THE FIRM FAILED TO VET ORPLACE RESTRICTIONS ON RECOMMENDATIONS AND PURCHASES OFVOLATILITY ETPS, AND AS A RESULT, THESE PRODUCTS WERE MADEAVAILABLE TO RETAIL BROKERAGE CUSTOMERS REGARDLESS OF RISKPROFILE AND INVESTMENT OBJECTIVE. CERTAIN FIRM REPRESENTATIVESMISTAKENLY BELIEVED THAT VOLATILITY ETPS COULD BE USED AS ALONG-TERM HEDGE ON THEIR CUSTOMERS' EQUITY POSITIONS IN THEEVENT OF A MARKET DOWNTURN. IN FACT, VOLATILITY ETPS AREGENERALLY SHORT-TERM TRADING PRODUCTS THAT DEGRADESIGNIFICANTLY OVER TIME AND SHOULD NOT BE USED AS PART OF ALONG-TERM BUY-AND-HOLD INVESTMENT STRATEGY. ACCORDINGLY, INTHOSE INSTANCES, THE REPRESENTATIVES DID NOT HAVE AREASONABLE BASIS TO RECOMMEND VOLATILITY ETPS AS SUITABLE TOCUSTOMERS WITH CONSERVATIVE OR MODERATE RISK PROFILES ANDINVESTMENT OBJECTIVES AND THE REPRESENTATIVES FURTHER FAILEDTO APPROPRIATELY RECOMMEND THE EXIT OF THESE POSITIONS WITHINA TIMELY MANNER. IN SOME INSTANCES, CUSTOMERS INCURREDSIGNIFICANT LOSSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILEDTO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDINGWRITTEN POLICIES AND PROCEDURES, REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH NASD RULE 2310 IN CONNECTION WITH ITSSALE OF VOLATILITY ETPS. ALTHOUGH THE FIRM SHOULD HAVE BEENAWARE OF THE COMPLEXITY AND UNIQUE RISKS AND FEATURESASSOCIATED WITH VOLATILITY ETPS, THE FIRM FAILED TO IMPLEMENT AREASONABLE SYSTEM TO SUPERVISE ITS REPRESENTATIVES' SOLICITEDSALES OF VOLATILITY ETPS. THE FINDINGS ALSO INCLUDED THAT THEFIRM'S SUPERVISORY SYSTEMS ALSO DID NOT INCLUDE REASONABLETRAINING FOR REGISTERED REPRESENTATIVES AND SUPERVISORSREGARDING THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITYETPS. BECAUSE THE FIRM FAILED TO ESTABLISH AND PROVIDEREASONABLE GUIDANCE, TRAINING OR TOOLS TO EDUCATE ITSREGISTERED REPRESENTATIVES AND SUPERVISORS ABOUT VOLATILITYETPS, CERTAIN RETAIL BROKERAGE CUSTOMERS WERE UNINFORMEDABOUT THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITY ETPSPRIOR TO PURCHASING THEM.

Current Status: Final

48©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 51: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 10/16/2017

Docket/Case Number: 2014042465601

Principal Product Type: Other

Other Product Type(s): VOLATILITY-LINKED EXCHANGE-TRADED PRODUCTS

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT CERTAIN FIRMREGISTERED REPRESENTATIVES RECOMMENDED VOLATILITY-LINKEDEXCHANGE-TRADED PRODUCTS (VOLATILITY ETPS) TO BROKERAGECUSTOMERS WITHOUT FULLY UNDERSTANDING THEIR RISKS ANDFEATURES. THE FINDINGS STATED THAT THE FIRM FAILED TO VET ORPLACE RESTRICTIONS ON RECOMMENDATIONS AND PURCHASES OFVOLATILITY ETPS, AND AS A RESULT, THESE PRODUCTS WERE MADEAVAILABLE TO RETAIL BROKERAGE CUSTOMERS REGARDLESS OF RISKPROFILE AND INVESTMENT OBJECTIVE. CERTAIN FIRM REPRESENTATIVESMISTAKENLY BELIEVED THAT VOLATILITY ETPS COULD BE USED AS ALONG-TERM HEDGE ON THEIR CUSTOMERS' EQUITY POSITIONS IN THEEVENT OF A MARKET DOWNTURN. IN FACT, VOLATILITY ETPS AREGENERALLY SHORT-TERM TRADING PRODUCTS THAT DEGRADESIGNIFICANTLY OVER TIME AND SHOULD NOT BE USED AS PART OF ALONG-TERM BUY-AND-HOLD INVESTMENT STRATEGY. ACCORDINGLY, INTHOSE INSTANCES, THE REPRESENTATIVES DID NOT HAVE AREASONABLE BASIS TO RECOMMEND VOLATILITY ETPS AS SUITABLE TOCUSTOMERS WITH CONSERVATIVE OR MODERATE RISK PROFILES ANDINVESTMENT OBJECTIVES AND THE REPRESENTATIVES FURTHER FAILEDTO APPROPRIATELY RECOMMEND THE EXIT OF THESE POSITIONS WITHINA TIMELY MANNER. IN SOME INSTANCES, CUSTOMERS INCURREDSIGNIFICANT LOSSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILEDTO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDINGWRITTEN POLICIES AND PROCEDURES, REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH NASD RULE 2310 IN CONNECTION WITH ITSSALE OF VOLATILITY ETPS. ALTHOUGH THE FIRM SHOULD HAVE BEENAWARE OF THE COMPLEXITY AND UNIQUE RISKS AND FEATURESASSOCIATED WITH VOLATILITY ETPS, THE FIRM FAILED TO IMPLEMENT AREASONABLE SYSTEM TO SUPERVISE ITS REPRESENTATIVES' SOLICITEDSALES OF VOLATILITY ETPS. THE FINDINGS ALSO INCLUDED THAT THEFIRM'S SUPERVISORY SYSTEMS ALSO DID NOT INCLUDE REASONABLETRAINING FOR REGISTERED REPRESENTATIVES AND SUPERVISORSREGARDING THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITYETPS. BECAUSE THE FIRM FAILED TO ESTABLISH AND PROVIDEREASONABLE GUIDANCE, TRAINING OR TOOLS TO EDUCATE ITSREGISTERED REPRESENTATIVES AND SUPERVISORS ABOUT VOLATILITYETPS, CERTAIN RETAIL BROKERAGE CUSTOMERS WERE UNINFORMEDABOUT THE FEATURES AND RISKS ASSOCIATED WITH VOLATILITY ETPSPRIOR TO PURCHASING THEM.

Resolution Date: 10/16/2017

Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND ORDERED TO JOINTLY AND SEVERALLYPAY $3,411,478.78 IN RESTITUTION TO CUSTOMERS.

Firm Statement IN DETERMINING TO RESOLVE THIS MATTER WITHOUT THE IMPOSITIONOF A FINE, FINRA TOOK THE FOLLOWING INTO CONSIDERATION: (I) PRIORTO DETECTION BY FINRA, THE FIRM CORRECTED ITS SUPERVISORYDEFICIENCIES RELATING TO VOLATILITY ETPS; (II) THE FIRM WASPREVIOUSLY FINED $2.1 MILLION - AFTER THE MISCONDUCT AND ITSREMEDIATION HEREIN - FOR SIMILAR VIOLATIONS RELATING TO NON-TRADITIONAL ETPS; AND, (III) THE FIRM PROVIDED SUBSTANTIALASSISTANCE TO FINRA BY, AMONG OTHER THINGS, ENGAGING AT ITS OWNEXPENSE A CONSULTING FIRM TO REVIEW, COMPILE, AND CALCULATELARGE AMOUNTS OF DATA PERTAINING TO SALES OF VOLATILITY ETPSFOR USE IN DETERMINING THE APPROPRIATE RESTITUTION TO BEPROVIDED.

Sanctions Ordered: CensureDisgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

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IN DETERMINING TO RESOLVE THIS MATTER WITHOUT THE IMPOSITIONOF A FINE, FINRA TOOK THE FOLLOWING INTO CONSIDERATION: (I) PRIORTO DETECTION BY FINRA, THE FIRM CORRECTED ITS SUPERVISORYDEFICIENCIES RELATING TO VOLATILITY ETPS; (II) THE FIRM WASPREVIOUSLY FINED $2.1 MILLION - AFTER THE MISCONDUCT AND ITSREMEDIATION HEREIN - FOR SIMILAR VIOLATIONS RELATING TO NON-TRADITIONAL ETPS; AND, (III) THE FIRM PROVIDED SUBSTANTIALASSISTANCE TO FINRA BY, AMONG OTHER THINGS, ENGAGING AT ITS OWNEXPENSE A CONSULTING FIRM TO REVIEW, COMPILE, AND CALCULATELARGE AMOUNTS OF DATA PERTAINING TO SALES OF VOLATILITY ETPSFOR USE IN DETERMINING THE APPROPRIATE RESTITUTION TO BEPROVIDED.

Disclosure 8 of 158

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Reporting Source: Regulator

Initiated By: MISSOURI

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

MONETARY FINE - $24,672.17 TO THE MISSOURI SECRETARY OF STATEINVESTOR EDUCATION AND PROTECTION FUND

Date Initiated: 02/16/2017

Docket/Case Number: AP-17-01

URL for Regulatory Action: HTTP://WWW.SOS.MO.GOV/CMSIMAGES/SECURITIES/ORDERS/AP-17-01.PDF

Principal Product Type: Other

Other Product Type(s):

Allegations: RESPONDENT FAILED TO REASONABLY SUPERVISE THE IRADISTRIBUTIONS IN VIOLATION OF SECTION 409.4-412(D)(9)

Current Status: Final

Resolution Date: 02/16/2017

Resolution:

Other Sanctions Ordered:

Sanction Details: RESPONDENT SHALL MAINTAIN AND ENFORCE PROCEDURES ANDSYSTEMS FOR SUPERVISING THE ACTIVITIES OF AGENTS, EMPLOYEES,AND MISSOURI OFFICE OPERATIONS IN A MANNER REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE STATE ANDFEDERAL SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THEFINANCIAL INDUSTRY REGULATORY AUTHORITY.

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

No

Sanctions Ordered: CensureMonetary/Fine $25,672.17

Consent

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www.finra.org/brokercheck User Guidance

iReporting Source: Firm

Initiated By: MISSOURI

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

MONETARY FINE - $24,672.17 TO THE MISSOURI SECRETARY OF STATEINVESTOR EDUCATION AND PROTECTION FUND

Date Initiated: 02/16/2017

Docket/Case Number: AP-17-01

Principal Product Type: Other

Other Product Type(s):

Allegations: RESPONDENT FAILED TO REASONABLY SUPERVISE THE IRADISTRIBUTIONS FROM 08/07/2001 TO 07/29/2007 IN VIOLATION OF SECTION409.4-412(D)(9)

Current Status: Final

Resolution Date: 02/16/2017

Resolution:

Other Sanctions Ordered:

Sanction Details: RESPONDENT SHALL MAINTAIN AND ENFORCE PROCEDURES ANDSYSTEMS FOR SUPERVISING THE ACTIVITIES OF AGENTS, EMPLOYEES,AND MISSOURI OFFICE OPERATIONS IN A MANNER REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE STATE ANDFEDERAL SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THEFINANCIAL INDUSTRY REGULATORY AUTHORITY.

Firm Statement RESPONDENT SHALL MAINTAIN AND ENFORCE PROCEDURES ANDSYSTEMS FOR SUPERVISING THE ACTIVITIES OF AGENTS, EMPLOYEES,AND MISSOURI OFFICE OPERATIONS IN A MANNER REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE STATE ANDFEDERAL SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THEFINANCIAL INDUSTRY REGULATORY AUTHORITY.

Sanctions Ordered: CensureMonetary/Fine $25,672.17

Consent

Disclosure 9 of 158

i

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Reporting Source: Regulator

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 04/07/2017

Docket/Case Number: 2016049925401

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

Other Product Type(s):

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOEXECUTE 50 MARKET ORDERS IN PREFERRED SECURITIES FULLY ANDPROMPTLY. THE FINDINGS STATED THAT IN 19 OF THOSE 50TRANSACTIONS, THE FIRM FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY ORSELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS.

Current Status: Final

Resolution Date: 04/07/2017

Resolution:

Other Sanctions Ordered: INTEREST

Sanction Details: THE FIRM WAS CENSURED, FINED $20,000 AND REQUIRED TO PAYRESTITUTION IN THE TOTAL AMOUNT OF $4,543.08, PLUS INTEREST. FINESPAID IN FULL ON MAY 11, 2017.

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

No

Sanctions Ordered: CensureMonetary/Fine $20,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

iReporting Source: 52©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Reporting Source: Firm

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 04/07/2017

Docket/Case Number: 2016049925401

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

Other Product Type(s):

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOEXECUTE 50 MARKET ORDERS IN PREFERRED SECURITIES FULLY ANDPROMPTLY. THE FINDINGS STATED THAT IN 19 OF THOSE 50TRANSACTIONS, THE FIRM FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY ORSELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS.

Current Status: Final

Resolution Date: 04/07/2017

Resolution:

Other Sanctions Ordered: INTEREST

Sanction Details: THE FIRM WAS CENSURED, FINED $20,000 AND REQUIRED TO PAYRESTITUTION IN THE TOTAL AMOUNT OF $4,543.08, PLUS INTEREST.

Firm Statement THE FIRM WAS CENSURED, FINED $20,000 AND REQUIRED TO PAYRESTITUTION IN THE TOTAL AMOUNT OF $4,543.08, PLUS INTEREST.

Sanctions Ordered: CensureMonetary/Fine $20,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

Disclosure 10 of 158

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Reporting Source: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, WITH TWOOTHER FIRMS, FAILED TO MAINTAIN APPROXIMATELY ONE MILLIONELECTRONIC BROKERAGE RECORDS IN NON-ERASABLE AND NON-REWRITABLE FORMAT, KNOWN AS WORM "WRITE ONCE, READ MANY"FORMAT. THE FINDINGS STATED THAT WORM IS INTENDED TO PREVENTTHE ALTERATION OR DESTRUCTION OF BROKER-DEALER RECORDSSTORED ELECTRONICALLY. THE FINDINGS ALSO STATED THAT FORAPPROXIMATELY 1.5 MILLION ACCOUNTS, THE FIRM, WITH THE OTHERTWO FIRMS, FAILED TO PRESERVE CUSTOMER ACCOUNT FORMTEMPLATES CONTAINING THE TERMS AND CONDITIONS RELATED TO THEOPENING AND MAINTENANCE OF THE ACCOUNTS. THE FINDINGS ALSOINCLUDED THAT THE FIRM, WITH ONE OF THE OTHER FIRMS, FAILED TORETAIN CERTAIN COMMUNICATIONS, INCLUDING 77,280 REJECT LETTERSAND 78,200 FULFILLMENT LETTERS. FINRA FOUND THAT THE FIRM FAILEDTO NOTIFY FINRA, ITS DESIGNATED EXAMINING AUTHORITY, AT LEAST 90DAYS PRIOR TO USING NEW STORAGE MEDIA TO STORE ELECTRONICBROKER-DEALER RECORDS. FINRA ALSO FOUND THAT THE FIRM FAILEDTO IMPLEMENT AN AUDIT SYSTEM FOR THOSE RECORDS THEY FAILED TOMAINTAIN IN WORM FORMAT. IN ADDITION, FINRA DETERMINED THAT THEFIRM FAILED TO PROVIDE ITS THIRD-PARTY VENDORS FULL ACCESS TO,AND THE ABILITY TO DOWNLOAD INFORMATION FROM, ITS ELECTRONICSTORAGE SYSTEMS. MOREOVER, FINRA FOUND THAT THE FIRM FAILEDTO IMPLEMENT AN ADEQUATE SUPERVISORY SYSTEM, AND FAILED TOENFORCE WRITTEN PROCEDURES, CONCERNING THE FIRM'S READYACCESS TO ELECTRONIC BROKER-DEALER RECORDS AND ITS STORAGEOF SUCH RECORDS IN WORM FORMAT.

Current Status: Final

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www.finra.org/brokercheck User Guidance

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 12/21/2016

Docket/Case Number: 2016050274801

Principal Product Type: No Product

Other Product Type(s):

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, WITH TWOOTHER FIRMS, FAILED TO MAINTAIN APPROXIMATELY ONE MILLIONELECTRONIC BROKERAGE RECORDS IN NON-ERASABLE AND NON-REWRITABLE FORMAT, KNOWN AS WORM "WRITE ONCE, READ MANY"FORMAT. THE FINDINGS STATED THAT WORM IS INTENDED TO PREVENTTHE ALTERATION OR DESTRUCTION OF BROKER-DEALER RECORDSSTORED ELECTRONICALLY. THE FINDINGS ALSO STATED THAT FORAPPROXIMATELY 1.5 MILLION ACCOUNTS, THE FIRM, WITH THE OTHERTWO FIRMS, FAILED TO PRESERVE CUSTOMER ACCOUNT FORMTEMPLATES CONTAINING THE TERMS AND CONDITIONS RELATED TO THEOPENING AND MAINTENANCE OF THE ACCOUNTS. THE FINDINGS ALSOINCLUDED THAT THE FIRM, WITH ONE OF THE OTHER FIRMS, FAILED TORETAIN CERTAIN COMMUNICATIONS, INCLUDING 77,280 REJECT LETTERSAND 78,200 FULFILLMENT LETTERS. FINRA FOUND THAT THE FIRM FAILEDTO NOTIFY FINRA, ITS DESIGNATED EXAMINING AUTHORITY, AT LEAST 90DAYS PRIOR TO USING NEW STORAGE MEDIA TO STORE ELECTRONICBROKER-DEALER RECORDS. FINRA ALSO FOUND THAT THE FIRM FAILEDTO IMPLEMENT AN AUDIT SYSTEM FOR THOSE RECORDS THEY FAILED TOMAINTAIN IN WORM FORMAT. IN ADDITION, FINRA DETERMINED THAT THEFIRM FAILED TO PROVIDE ITS THIRD-PARTY VENDORS FULL ACCESS TO,AND THE ABILITY TO DOWNLOAD INFORMATION FROM, ITS ELECTRONICSTORAGE SYSTEMS. MOREOVER, FINRA FOUND THAT THE FIRM FAILEDTO IMPLEMENT AN ADEQUATE SUPERVISORY SYSTEM, AND FAILED TOENFORCE WRITTEN PROCEDURES, CONCERNING THE FIRM'S READYACCESS TO ELECTRONIC BROKER-DEALER RECORDS AND ITS STORAGEOF SUCH RECORDS IN WORM FORMAT.

Resolution Date: 12/21/2016

Resolution:

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

No

Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered: UNDERTAKING

Sanction Details: THE FIRM WAS CENSURED, FINED $1,500,000, JOINTLY AND SEVERALLY,AND IS REQUIRED TO REVIEW ITS POLICIES AND PROCEDURES RELATEDTO THE ADEQUACY OF ITS RELEVANT POLICIES AND PROCEDURES(WRITTEN OR OTHERWISE), INCLUDING A DESCRIPTION OF THE REMEDIALMEASURES LEADING TO FULL COMPLIANCE, RELATING TO THE CONDUCTADDRESSED IN THE AWC. FINES PAID IN FULL ON 12/28/16.

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

No

Sanctions Ordered: CensureMonetary/Fine $1,500,000.00

iReporting Source: Firm

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, WITH TWOOTHER FIRMS, FAILED TO MAINTAIN APPROXIMATELY ONE MILLIONELECTRONIC BROKERAGE RECORDS IN NON-ERASABLE AND NON-REWRITABLE FORMAT, KNOWN AS WORM "WRITE ONCE, READ MANY"FORMAT. THE FINDINGS STATED THAT WORM IS INTENDED TO PREVENTTHE ALTERATION OR DESTRUCTION OF BROKER-DEALER RECORDSSTORED ELECTRONICALLY. THE FINDINGS ALSO STATED THAT FORAPPROXIMATELY 1.5 MILLION ACCOUNTS, THE FIRM, WITH THE OTHERTWO FIRMS, FAILED TO PRESERVE CUSTOMER ACCOUNT FORMTEMPLATES CONTAINING THE TERMS AND CONDITIONS RELATED TO THEOPENING AND MAINTENANCE OF THE ACCOUNTS. THE FINDINGS ALSOINCLUDED THAT THE FIRM, WITH ONE OF THE OTHER FIRMS, FAILED TORETAIN CERTAIN COMMUNICATIONS, INCLUDING 77,280 REJECT LETTERSAND 78,200 FULFILLMENT LETTERS. FINRA FOUND THAT THE FIRM FAILEDTO NOTIFY FINRA, ITS DESIGNATED EXAMINING AUTHORITY, AT LEAST 90DAYS PRIOR TO USING NEW STORAGE MEDIA TO STORE ELECTRONICBROKER-DEALER RECORDS. FINRA ALSO FOUND THAT THE FIRM FAILEDTO IMPLEMENT AN AUDIT SYSTEM FOR THOSE RECORDS THEY FAILED TOMAINTAIN IN WORM FORMAT. IN ADDITION, FINRA DETERMINED THAT THEFIRM FAILED TO PROVIDE ITS THIRD-PARTY VENDORS FULL ACCESS TO,AND THE ABILITY TO DOWNLOAD INFORMATION FROM, ITS ELECTRONICSTORAGE SYSTEMS. MOREOVER, FINRA FOUND THAT THE FIRM FAILEDTO IMPLEMENT AN ADEQUATE SUPERVISORY SYSTEM, AND FAILED TOENFORCE WRITTEN PROCEDURES, CONCERNING THE FIRM'S READYACCESS TO ELECTRONIC BROKER-DEALER RECORDS AND ITS STORAGEOF SUCH RECORDS IN WORM FORMAT.

Current Status: Final

55©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 12/21/2016

Docket/Case Number: 2016050274801

Principal Product Type: No Product

Other Product Type(s):

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, WITH TWOOTHER FIRMS, FAILED TO MAINTAIN APPROXIMATELY ONE MILLIONELECTRONIC BROKERAGE RECORDS IN NON-ERASABLE AND NON-REWRITABLE FORMAT, KNOWN AS WORM "WRITE ONCE, READ MANY"FORMAT. THE FINDINGS STATED THAT WORM IS INTENDED TO PREVENTTHE ALTERATION OR DESTRUCTION OF BROKER-DEALER RECORDSSTORED ELECTRONICALLY. THE FINDINGS ALSO STATED THAT FORAPPROXIMATELY 1.5 MILLION ACCOUNTS, THE FIRM, WITH THE OTHERTWO FIRMS, FAILED TO PRESERVE CUSTOMER ACCOUNT FORMTEMPLATES CONTAINING THE TERMS AND CONDITIONS RELATED TO THEOPENING AND MAINTENANCE OF THE ACCOUNTS. THE FINDINGS ALSOINCLUDED THAT THE FIRM, WITH ONE OF THE OTHER FIRMS, FAILED TORETAIN CERTAIN COMMUNICATIONS, INCLUDING 77,280 REJECT LETTERSAND 78,200 FULFILLMENT LETTERS. FINRA FOUND THAT THE FIRM FAILEDTO NOTIFY FINRA, ITS DESIGNATED EXAMINING AUTHORITY, AT LEAST 90DAYS PRIOR TO USING NEW STORAGE MEDIA TO STORE ELECTRONICBROKER-DEALER RECORDS. FINRA ALSO FOUND THAT THE FIRM FAILEDTO IMPLEMENT AN AUDIT SYSTEM FOR THOSE RECORDS THEY FAILED TOMAINTAIN IN WORM FORMAT. IN ADDITION, FINRA DETERMINED THAT THEFIRM FAILED TO PROVIDE ITS THIRD-PARTY VENDORS FULL ACCESS TO,AND THE ABILITY TO DOWNLOAD INFORMATION FROM, ITS ELECTRONICSTORAGE SYSTEMS. MOREOVER, FINRA FOUND THAT THE FIRM FAILEDTO IMPLEMENT AN ADEQUATE SUPERVISORY SYSTEM, AND FAILED TOENFORCE WRITTEN PROCEDURES, CONCERNING THE FIRM'S READYACCESS TO ELECTRONIC BROKER-DEALER RECORDS AND ITS STORAGEOF SUCH RECORDS IN WORM FORMAT.

Resolution Date: 12/21/2016

Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: THE FIRM WAS CENSURED, FINED $1,500,000, JOINTLY AND SEVERALLY,AND IS REQUIRED TO REVIEW ITS POLICIES AND PROCEDURES RELATEDTO THE ADEQUACY OF ITS RELEVANT POLICIES AND PROCEDURES(WRITTEN OR OTHERWISE), INCLUDING A DESCRIPTION OF THE REMEDIALMEASURES LEADING TO FULL COMPLIANCE, RELATING TO THE CONDUCTADDRESSED IN THE AWC

Sanctions Ordered: CensureMonetary/Fine $1,500,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 11 of 158

i

Reporting Source: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AND ITSAFFILIATE CONSENTED TO THE SANCTIONS AND TO THE ENTRY OFFINDINGS THAT THEY FAILED TO ESTABLISH, MAINTAIN, AND ENFORCEREASONABLE SUPERVISORY SYSTEMS FOR THE USE OF CONSOLIDATEDREPORTS GENERATED BY THEIR REGISTERED REPRESENTATIVESTHROUGH A PARTICULAR APPLICATION (THE APPLICATION) THAT THEFIRMS MADE AVAILABLE TO THEIR REGISTERED REPRESENTATIVES. THEFINDINGS STATED THAT THE FIRM AND ITS AFFILIATE PERMITTED THEIRREGISTERED REPRESENTATIVES TO USE UP TO 10 OR MORE DIFFERENTAPPLICATIONS TO CREATE CONSOLIDATED REPORTS, INCLUDING THEAPPLICATION. THE APPLICATION WAS THE MOST WIDELY USEDCONSOLIDATED REPORTING APPLICATION AT THE FIRMS. THE FINDINGSALSO STATED THAT WHEN PREPARING APPLICATION REPORTS, THEFIRMS' REPRESENTATIVES WERE PERMITTED TO MANUALLY ENTERINFORMATION REGARDING CUSTOMERS' EXTERNAL ACCOUNTS, ASSETSAND LIABILITIES INTO A CENTRALIZED ASSETS AND LIABILITIES TABLE,WHICH THE FIRMS MAINTAINED. THE APPLICATION WOULD PULL THATINFORMATION FROM THE TABLE TO POPULATE THE APPLICATIONREPORTS, INCLUDING THOSE THAT WERE THEN SENT TO THE FIRMS'CUSTOMERS. THE FIRMS REVIEWED A RANDOM SAMPLING OF ONLY 2PERCENT OF THE APPLICATION REPORTS. THE FIRM AND ITS AFFILIATEDID NOT, AND HAD NO SYSTEM IN PLACE TO, REVIEW THE CONTENTS OFTHE APPLICATION REPORTS, INCLUDING INFORMATION ABOUTCUSTOMERS' HOLDINGS AWAY FROM THE FIRMS. THE FINDINGS ALSOINCLUDED THAT THE FIRMS' SUPERVISORY SYSTEMS AND PROCEDURESWERE INADEQUATE BECAUSE THERE WAS NO MECHANISM ALLOWINGTHEIR REPRESENTATIVES TO DESIGNATE WHICH APPLICATION REPORTSWERE ACTUALLY PROVIDED TO CUSTOMERS. THE FIRMS COULD NOTDISTINGUISH BETWEEN DRAFT APPLICATION REPORTS AND REPORTSTHAT WERE COMPLETED AND SENT TO CUSTOMERS, WHICH SHOULDHAVE BEEN SUBJECTED TO THE FIRMS' SUPERVISORY SYSTEMSDESIGNED TO REVIEW CUSTOMER COMMUNICATIONS.

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 12/05/2016

Docket/Case Number: 2015043740201

Principal Product Type: No Product

Other Product Type(s):

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AND ITSAFFILIATE CONSENTED TO THE SANCTIONS AND TO THE ENTRY OFFINDINGS THAT THEY FAILED TO ESTABLISH, MAINTAIN, AND ENFORCEREASONABLE SUPERVISORY SYSTEMS FOR THE USE OF CONSOLIDATEDREPORTS GENERATED BY THEIR REGISTERED REPRESENTATIVESTHROUGH A PARTICULAR APPLICATION (THE APPLICATION) THAT THEFIRMS MADE AVAILABLE TO THEIR REGISTERED REPRESENTATIVES. THEFINDINGS STATED THAT THE FIRM AND ITS AFFILIATE PERMITTED THEIRREGISTERED REPRESENTATIVES TO USE UP TO 10 OR MORE DIFFERENTAPPLICATIONS TO CREATE CONSOLIDATED REPORTS, INCLUDING THEAPPLICATION. THE APPLICATION WAS THE MOST WIDELY USEDCONSOLIDATED REPORTING APPLICATION AT THE FIRMS. THE FINDINGSALSO STATED THAT WHEN PREPARING APPLICATION REPORTS, THEFIRMS' REPRESENTATIVES WERE PERMITTED TO MANUALLY ENTERINFORMATION REGARDING CUSTOMERS' EXTERNAL ACCOUNTS, ASSETSAND LIABILITIES INTO A CENTRALIZED ASSETS AND LIABILITIES TABLE,WHICH THE FIRMS MAINTAINED. THE APPLICATION WOULD PULL THATINFORMATION FROM THE TABLE TO POPULATE THE APPLICATIONREPORTS, INCLUDING THOSE THAT WERE THEN SENT TO THE FIRMS'CUSTOMERS. THE FIRMS REVIEWED A RANDOM SAMPLING OF ONLY 2PERCENT OF THE APPLICATION REPORTS. THE FIRM AND ITS AFFILIATEDID NOT, AND HAD NO SYSTEM IN PLACE TO, REVIEW THE CONTENTS OFTHE APPLICATION REPORTS, INCLUDING INFORMATION ABOUTCUSTOMERS' HOLDINGS AWAY FROM THE FIRMS. THE FINDINGS ALSOINCLUDED THAT THE FIRMS' SUPERVISORY SYSTEMS AND PROCEDURESWERE INADEQUATE BECAUSE THERE WAS NO MECHANISM ALLOWINGTHEIR REPRESENTATIVES TO DESIGNATE WHICH APPLICATION REPORTSWERE ACTUALLY PROVIDED TO CUSTOMERS. THE FIRMS COULD NOTDISTINGUISH BETWEEN DRAFT APPLICATION REPORTS AND REPORTSTHAT WERE COMPLETED AND SENT TO CUSTOMERS, WHICH SHOULDHAVE BEEN SUBJECTED TO THE FIRMS' SUPERVISORY SYSTEMSDESIGNED TO REVIEW CUSTOMER COMMUNICATIONS.

Resolution Date: 12/05/2016

Resolution:

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

No

Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND FINED $1,000,000, JOINTLY ANDSEVERALLY. FINES PAID IN FULL ON 12/23/16.

Sanctions Ordered: CensureMonetary/Fine $1,000,000.00

iReporting Source: Firm

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM AND ITSAFFILIATE CONSENTED TO THE SANCTIONS AND TO THE ENTRY OFFINDINGS THAT THEY FAILED TO ESTABLISH, MAINTAIN,AND ENFORCE REASONABLE SUPERVISORY SYSTEMS FOR THE USE OFCONSOLIDATED REPORTS GENERATED BY THEIR REGISTEREDREPRESENTATIVES THROUGH A PARTICULAR APPLICATION (THEAPPLICATION) THAT THE FIRMS MADE AVAILABLE TO THEIR REGISTEREDREPRESENTATIVES. THE FINDINGS STATED THAT THE FIRM AND ITSAFFILIATE PERMITTED THEIR REGISTEREDREPRESENTATIVES TO USE UP TO 10 OR MORE DIFFERENT APPLICATIONSTO CREATE CONSOLIDATED REPORTS, INCLUDING THE APPLICATION. THEAPPLICATION WAS THE MOST WIDELY USED CONSOLIDATED REPORTINGAPPLICATION AT THE FIRMS. THE FINDINGS ALSO STATED THAT WHENPREPARING APPLICATION REPORTS, THE FIRMS' REPRESENTATIVESWERE PERMITTED TOMANUALLY ENTER INFORMATION REGARDING CUSTOMERS' EXTERNALACCOUNTS, ASSETS AND LIABILITIES INTO A CENTRALIZED ASSETS ANDLIABILITIES TABLE, WHICH THE FIRMS MAINTAINED. THE APPLICATIONWOULD PULL THAT INFORMATION FROM THE TABLE TO POPULATE THEAPPLICATION REPORTS, INCLUDING THOSE THAT WERE THEN SENT TOTHE FIRMS' CUSTOMERS. THE FIRMS REVIEWED A RANDOM SAMPLING OFONLY 2 PERCENT OF THE APPLICATION REPORTS. THE FIRM AND ITSAFFILIATE DID NOT, AND HAD NO SYSTEM IN PLACE TO, REVIEW THECONTENTS OF THE APPLICATION REPORTS, INCLUDING INFORMATIONABOUT CUSTOMERS' HOLDINGS AWAY FROM THE FIRMS. THE FINDINGSALSO INCLUDED THAT THE FIRMS' SUPERVISORY SYSTEMS ANDPROCEDURES WERE INADEQUATE BECAUSE THERE WAS NO MECHANISMALLOWING THEIR REPRESENTATIVES TO DESIGNATE WHICH APPLICATIONREPORTSWERE ACTUALLY PROVIDED TO CUSTOMERS. THE FIRMS COULD NOTDISTINGUISH BETWEEN DRAFT APPLICATION REPORTS AND REPORTSTHAT WERE COMPLETED AND SENT TO CUSTOMERS, WHICHSHOULD HAVE BEEN SUBJECTED TO THE FIRMS' SUPERVISORY SYSTEMSDESIGNED TO REVIEW CUSTOMER COMMUNICATIONS.

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 12/05/2016

Docket/Case Number: 2015043740201

Principal Product Type: No Product

Other Product Type(s):

Resolution Date: 12/05/2016

Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND FINED $1,000,000, JOINTLY ANDSEVERALLY.

Sanctions Ordered: CensureMonetary/Fine $1,000,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 12 of 158

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Reporting Source: Regulator

Initiated By: FINRA

Date Initiated: 10/20/2016

Docket/Case Number: 2015046578401

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EFFECTED39 CUSTOMER TRANSACTIONS IN A MUNICIPAL SECURITY IN AN AMOUNTLOWER THAN THE MINIMUM DENOMINATION OF THE ISSUE WHICH WERENOT SUBJECT TO AN EXCEPTION UNDER THE RULE. THE FINDINGSSTATED THAT THE FIRM FAILED TO DISCLOSE ALL MATERIAL FACTSCONCERNING 39 MUNICIPAL SECURITIES TRANSACTIONS AT OR PRIOR TOTHE TIME OF TRADE. SPECIFICALLY, THE FIRM FAILED TO INFORM ITSCUSTOMER THAT THE MUNICIPAL SECURITIES TRANSACTION WAS IN ANAMOUNT BELOW THE MINIMUM DENOMINATION OF THE ISSUE, OR THATTHE MUNICIPAL SECURITIES CONTAINED A RESALE RESTRICTION WHICHCOULD AFFECT THE LIQUIDITY OF THE CUSTOMER'S POSITION.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Docket/Case Number: 2015046578401

Principal Product Type: Debt - Municipal

Other Product Type(s):

Resolution Date: 10/20/2016

Resolution:

Other Sanctions Ordered: REQUIRED TO OFFER RESCISSION TO CUSTOMERS

Sanction Details: THE FIRM WAS CENSURED, FINED $42,500, AND REQUIRED TO OFFERRESCISSION TO THE CUSTOMERS WHO PURCHASED THE SECURITIES ATEITHER THE ORIGINAL PURCHASE PRICE OR THE CURRENT FAIR MARKETVALUE, WHICHEVER IS HIGHER. THE OFFER OF RESCISSION SHALLREMAIN OPEN WITH THE AFFECTED CUSTOMER FOR A PERIOD OF 60DAYS. FINES PAID IN FULL ON NOVEMBER 8, 2016.

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

No

Sanctions Ordered: CensureMonetary/Fine $42,500.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EFFECTED39 CUSTOMER TRANSACTIONS IN A MUNICIPAL SECURITY IN AN AMOUNTLOWER THAN THE MINIMUM DENOMINATION OF THE ISSUE WHICH WERENOT SUBJECT TO AN EXCEPTION UNDER THE RULE. THE FINDINGSSTATED THAT THE FIRM FAILED TO DISCLOSE ALL MATERIAL FACTSCONCERNING 39 MUNICIPAL SECURITIES TRANSACTIONS AT OR PRIOR TOTHE TIME OF TRADE. SPECIFICALLY, THE FIRM FAILED TO INFORM ITSCUSTOMER THAT THE MUNICIPAL SECURITIES TRANSACTION WAS IN ANAMOUNT BELOW THE MINIMUM DENOMINATION OF THE ISSUE, OR THATTHE MUNICIPAL SECURITIES CONTAINED A RESALE RESTRICTION WHICHCOULD AFFECT THE LIQUIDITY OF THE CUSTOMER'S POSITION.

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 10/20/2016

Docket/Case Number: 2015046578401

Principal Product Type: Debt - Municipal

Other Product Type(s):

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EFFECTED39 CUSTOMER TRANSACTIONS IN A MUNICIPAL SECURITY IN AN AMOUNTLOWER THAN THE MINIMUM DENOMINATION OF THE ISSUE WHICH WERENOT SUBJECT TO AN EXCEPTION UNDER THE RULE. THE FINDINGSSTATED THAT THE FIRM FAILED TO DISCLOSE ALL MATERIAL FACTSCONCERNING 39 MUNICIPAL SECURITIES TRANSACTIONS AT OR PRIOR TOTHE TIME OF TRADE. SPECIFICALLY, THE FIRM FAILED TO INFORM ITSCUSTOMER THAT THE MUNICIPAL SECURITIES TRANSACTION WAS IN ANAMOUNT BELOW THE MINIMUM DENOMINATION OF THE ISSUE, OR THATTHE MUNICIPAL SECURITIES CONTAINED A RESALE RESTRICTION WHICHCOULD AFFECT THE LIQUIDITY OF THE CUSTOMER'S POSITION.

Resolution Date: 10/20/2016

Resolution:

Other Sanctions Ordered: REQUIRED TO OFFER RESCISSION TO CUSTOMERS

Sanction Details: THE FIRM WAS CENSURED, FINED $42,500, AND REQUIRED TO OFFERRESCISSION TO THECUSTOMERS WHO PURCHASED THE SECURITIES AT EITHER THEORIGINAL PURCHASE PRICE ORTHE CURRENT FAIR MARKET VALUE, WHICHEVER IS HIGHER. THE OFFEROF RESCISSION SHALLREMAIN OPEN WITH THE AFFECTED CUSTOMER FOR A PERIOD OF 60DAYS. FINES PAID IN FULLON NOVEMBER 8, 2016.

Firm Statement N/A

Sanctions Ordered: CensureMonetary/Fine $42,500.00

Acceptance, Waiver & Consent(AWC)

Disclosure 13 of 158

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Reporting Source: Firm

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK,N.A. ("WFBNA") CONSENTED TO THE ENTRY OF AN ORDER THAT ITSCOMMUNITY BANK GROUP HAD UNSAFE OR UNSOUND PRACTICES INRISK MANAGEMENT AND OVERSIGHT OF SALES PRACTICES, AND UNSAFEOR UNSOUND SALES PRACTICES BY SELLING UNWANTED DEPOSIT ORCREDIT CARD ACCOUNTS, THE UNAUTHORIZED OPENING OF SUCHACCOUNTS, THE TRANSFER OF FUNDS TO UNAUTHORIZED ACCOUNTS,AND UNAUTHORIZED CREDIT INQUIRIES TO OPEN THE ACCOUNTS.

Current Status: Final

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Initiated By: COMPTROLLER OF THE CURRENCY (OCC)

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

COMPLIANCE AND RISK MANAGEMENT PLAN; PAY REIMBURSEMENT TOAFFECTED CONSUMERS; CIVIL MONEY PENALTY.

Date Initiated: 09/06/2016

Docket/Case Number: AA-EC-2016-66 AND AA-EC-2016-67

Principal Product Type: Banking Products (Other than CD(s))

Other Product Type(s):

WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK,N.A. ("WFBNA") CONSENTED TO THE ENTRY OF AN ORDER THAT ITSCOMMUNITY BANK GROUP HAD UNSAFE OR UNSOUND PRACTICES INRISK MANAGEMENT AND OVERSIGHT OF SALES PRACTICES, AND UNSAFEOR UNSOUND SALES PRACTICES BY SELLING UNWANTED DEPOSIT ORCREDIT CARD ACCOUNTS, THE UNAUTHORIZED OPENING OF SUCHACCOUNTS, THE TRANSFER OF FUNDS TO UNAUTHORIZED ACCOUNTS,AND UNAUTHORIZED CREDIT INQUIRIES TO OPEN THE ACCOUNTS.

Resolution Date: 09/06/2016

Resolution:

Other Sanctions Ordered: ESTABLISH A COMPLIANCE PLAN; CREATE RISK MANAGEMENT AND AUDITOVERSIGHT, PROVIDE REIMBURSEMENT PLAN AND ASSESSMENT.

Sanction Details: FINE PAID OF $35,000,000.00

Sanctions Ordered: Monetary/Fine $35,000,000.00Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 14 of 158

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Reporting Source: Firm

Initiated By: CONSUMER FINANCIAL PROTECTION BUREAU (CFPB)

Date Initiated: 09/04/2016

Docket/Case Number: 2016-CFPB-0015

Principal Product Type: Banking Products (Other than CD(s))

Other Product Type(s):

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK,N.A. ("WFBNA") CONSENTED TO THE ENTRY OF AN ORDER THAT ITSCOMMUNITY BANK GROUP ENGAGED IN UNFAIR AND ABUSIVE PRACTICESBY OPENING DEPOSIT ACCOUNTS, TRANSFERRING FUNDS BETWEENACCOUNTS, APPLYING FOR CREDIT CARDS, ISSUING DEBIT CARDS ANDENROLLING CUSTOMERS IN ON-LINE BANKING SERVICES WITHOUT THECUSTOMERS' CONSENT.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

CIVIL MONEY PENALTIES OF $100,000,000.00; COMPLIANCE AND REDRESSPLANS; INDEPENDENT CONSULTANT REVIEW, PAY REDRESS TO AFFECTEDCONSUMERS.

Other Product Type(s):

Resolution Date: 09/04/2016

Resolution:

Other Sanctions Ordered: DEVELOP COMPLIANCE PLAN AND MONITORING

Sanction Details: $100,000,000.00 FINE PAID

Sanctions Ordered: Monetary/Fine $100,000,000.00Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 15 of 158

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Reporting Source: Firm

Initiated By: CONSUMER FINANCIAL PROTECTION BUREAU (CFPB)

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

COMPLIANCE PLAN, REMEDIATION TO BORROWERS, PAY CIVIL MONEYPENALTIES OF $3,600,000 AND PROVIDE A QUARTERLY/ANNUAL TRACKINGREPORT TO CFPB.

Date Initiated: 08/20/2016

Docket/Case Number: 2016-CFPB-0013

Principal Product Type: Other

Other Product Type(s): STUDENT LOAN SERVICING

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, WELLS FARGO BANK,N.A. ("WFBNA") CONSENTED TO THE ENTRY OF AN ORDER THAT UNDERCERTAIN SCENARIOS AND IN CERTAIN TIMEFRAMES ITS EDUCATIONFINANCIAL SERVICES BUSINESS (EFS)ALLOCATED PARTIAL PAYMENTS,AGGREGATED PARTIAL PAYMENTS, AND CHARGED LATE FEES IN WAYSTHAT WERE ALLEGED TO BE UNLAWFUL.

Current Status: Final

Resolution Date: 08/20/2016

Resolution: Consent

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Resolution Date: 08/20/2016

Other Sanctions Ordered: DEVELOP COMPLIANCE PLAN AND MONITORING.

Sanction Details: $3,600,000.00 FINE PAID

Sanctions Ordered: Monetary/Fine $3,600,000.00Disgorgement/RestitutionCease and Desist/Injunction

Disclosure 16 of 158

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Reporting Source: Firm

Initiated By: VERMONT DEPARTMENT OF FINANCIAL REGULATION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

CENSURE

Date Initiated: 06/28/2016

Docket/Case Number: 16-25-S

Principal Product Type: Other

Other Product Type(s): NON-TRADITIONAL ETFS

Allegations: THE STATE OF VERMONT DEPARTMENT OF FINANCIAL REGULATIONALLEGED THAT WELLS FARGO ADVISORS, LLC FAILED TO REASONABLYSUPERVISE A REGISTERED REPRESENTATIVE WITH REGARD TO THE USEOF INVESTMENTS IN NON-TRADITIONAL ETFS; FAILED TO ESTABLISH ANDMAINTAIN AN ADEQUATE SUPERVISORY SYSTEM IN CONNECTION WITHTHE SALE OF AND INVESTMENT IN NON-TRADITIONAL ETFS; FAILED TOFOLLOW WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO THEUSE OF AND INVESTMENT IN NON-TRADITIONAL ETFS; AND ALLOWED AREGISTERED REPRESENTATIVE TO RECOMMEND UNSUITABLE PRODUCTSTO A CUSTOMER, ALL IN VIOLATION OF 9 VSA SECTION 5412(D)(9).

Current Status: Final

Resolution Date: 06/28/2016

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS.THEREFORE, THE FIRM IS CENSURED AND FINED $300,000.

Sanctions Ordered: CensureMonetary/Fine $300,000.00

Consent

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Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS.THEREFORE, THE FIRM IS CENSURED AND FINED $300,000.

Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS.THEREFORE, THE FIRM IS CENSURED AND FINED $300,000.

Disclosure 17 of 158

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Reporting Source: Regulator

Initiated By: VIRGINIA STATE CORPORATION COMMISION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

RESTITUTION

Date Initiated: 09/11/2015

Docket/Case Number: SEC-2014-00035

URL for Regulatory Action: HTTP://WWW.SCC.VIRGINIA.GOV/DOCKETSEARCH#/CASEDETAILS/133609

Principal Product Type: Investment Contract(s)

Other Product Type(s):

Allegations: WELLS FARGO ADVISORS FAILED TO SUPERVISE AN AGENT THAT SOLDOVER $400,000 IN UNREGISTERED SECURITIES TO WELLS FARGOADVISORS' CLIENTS.

Current Status: Final

Resolution Date: 09/11/2015

Resolution:

Other Sanctions Ordered: WELLS FARGO ADVISORS AGREED TO PAY $55,000 TO DEFRAY THE COSTOF INVESTIGATION.

Sanction Details: MONETARY FINE OF $150,000. WELLS FARGO ADVISORS AGREED TO PAY$55,000 TO DEFRAY THE COST OF INVESTIGATION.

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

No

Sanctions Ordered: Monetary/Fine $150,000.00Disgorgement/Restitution

Settled

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Sanction Details: MONETARY FINE OF $150,000. WELLS FARGO ADVISORS AGREED TO PAY$55,000 TO DEFRAY THE COST OF INVESTIGATION.

Regulator Statement WELLS FARGO ADVISORS EMPLOYED CHRISTOPHER CUNNINGHAM (CRD#2390800) AS AN AGENT FROM 2005 TO 2009. WHILE AT WELLS FARGOADVISORS, CUNNINGHAM SOLD OVER $400,000 IN UNREGISTEREDSECURITIES TO HIS CLIENTS. CUNNINGHAM IS CURRENTLY SERVING 57MONTHS IN FEDERAL PRISON FOR WIRE FRAUD RELATED TO HISSCHEME.

iReporting Source: Firm

Initiated By: COMMONWEALTH OF VIRGINIA

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 09/11/2015

Docket/Case Number: SEC-2014-00035

Principal Product Type: No Product

Other Product Type(s):

Allegations: THE DIVISION ALLEGES THAT WFA COMMITTED MULTIPLE VIOLATIONS OF(I) RULE 21 VAC 5-20-260 B BY FAILING TO EXERCISE DILIGENTSUPERVISION OVER SECURITIES ACTIVITIES OF ITS AGENT; (II) RULE 21VAC 5-20-260 D (2) BY FAILING TO MONITOR AND CONDUCT FREQUENTEXAMINATIONS OF ALL CUSTOMER ACCOUNTS TO DETECT AND PREVENTIRREGULARITIES OR ABUSES; AND (III)RULE 21 VAC 5-20-260 D BY FAILINGTO ENFORCE ITS WRITTEN POLICIES AND PROCEDURES.

Current Status: Final

Resolution Date: 09/11/2015

Resolution:

Other Sanctions Ordered: WELLS FARGO ADVISORS AGREED TO PAY $55,000 TO DEFRAY THE COSTOF INVESTIGATION.

Sanction Details: MONETARY FINE OF $150,000. WELLS FARGO ADVISORS AGREED TO PAY$55,000 TO DEFRAY THE COST OF INVESTIGATION.

Sanctions Ordered: Monetary/Fine $150,000.00Disgorgement/Restitution

Order

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Disclosure 18 of 158

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Reporting Source: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT MADEUNSUITABLE RECOMMENDATIONS TO RETAIL CUSTOMERS TO PURCHASESTRUCTURED REPACKAGED ASSET-BACKED TRUST SECURITIES(STRATS), A COMPLEX STRUCTURED PRODUCT THAT PAID A FLOATINGRATE OF PERIODIC INCOME UP TO A MINIMUM OR MAXIMUM RATE, BASEDON THE STRATS TRUST'S INTEREST IN A CAPITAL SECURITY ISSUED BY AFINANCIAL INSTITUTION AND THE STRATS TRUST'S INTEREST IN ANINTEREST RATE SWAP CONTRACT. THE FIRM SOLD APPROXIMATELY $12MILLION WORTH OF THE STRATS TO ITS RETAIL CUSTOMERS, IN BOTHPRIMARY AND SECONDARY MARKETS. ALTHOUGH THE FIRM PROVIDEDITS SALES-FORCE TRAINING ON STRUCTURED PRODUCTS, NONE OF THISTRAINING RELATED SPECIFICALLY TO THE UNIQUE FEATURES AND RISKSOF THE STRATS. ADDITIONALLY, ALTHOUGH THE FIRM'S INTRANET PAGEDEDICATED TO FIXED INCOME PRODUCTS PROVIDED BASICINFORMATION CONCERNING THE STRATS, IT DID NOT PROVIDE ANYINFORMATION CONCERNING THE RISKS OF INVESTING IN THESEPRODUCTS, AND SPECIFICALLY DID NOT ADDRESS THE RISKS TOCUSTOMER PRINCIPAL IN THE EVENT OF A REDEMPTION OF THEUNDERLYING CAPITAL SECURITY. UNDER THE TERMS OF THEPROSPECTUS FOR THE STRATS, THE AMOUNT PAID TO A CUSTOMER INTHE EVENT OF A TERMINATION WAS THE PROCEEDS OF THEREDEMPTION OF UNDERLYING CAPITAL SECURITY PLUS ACCRUEDINTEREST AND LESS THE SWAP TERMINATION FEE. IN CERTAINCIRCUMSTANCES, THE CUSTOMER WOULD FACE A SUBSTANTIAL RISK OFLOSS OF PRINCIPAL UPON TERMINATION OF THE STRATS DUE TO THEAMOUNT OF THE SWAP TERMINATION FEE. THE FIRM'S REGISTEREDREPRESENTATIVES GENERALLY WERE NOT FAMILIAR WITH SUCH RISKSOF INVESTING IN THE STRATS AND WERE CONSEQUENTLY UNABLE TOEXPLAIN SUCH RISKS WHEN RECOMMENDING THE PRODUCT TO THEFIRM'S RETAIL CUSTOMERS. EVENTUALLY, THE FINANCIAL INSTITUTIONREDEEMED THE UNDERLYING CAPITAL SECURITY, CAUSING THE STRATSTO BE TERMINATED. THE FINANCIAL INSTITUTION REDEEMED THEUNDERLYING CAPITAL SECURITY AT PAR VALUE PLUS ACCRUEDINTEREST. BASED ON THE TERMS OF THE UNDERLYING SWAPAGREEMENT, CUSTOMERS RECEIVED THE PROCEEDS OF THEREDEMPTION AFTER THE SWAP TERMINATION FEE WAS PAID. AS ARESULT, AT THE TIME OF THE STRATS' TERMINATION, MANY CUSTOMERSHOLDING THE STRATS RECEIVED LESS, AND IN SOME CASESSIGNIFICANTLY LESS, THAN THE AMOUNT THEY PAID FOR THE STRATS.THE FIRM FAILED TO EDUCATE ITS REGISTERED REPRESENTATIVESREGARDING THE UNIQUE FEATURES AND RISKS OF THE STRATS. AS ARESULT, THE FIRM'S REGISTERED REPRESENTATIVES DID NOTCOMPREHEND THE RISKS TO CUSTOMERS OF INVESTING IN THE STRATSAND THUS LACKED A REASONABLE BASIS FOR RECOMMENDING THESEPRODUCTS TO THE FIRM'S RETAIL CUSTOMERS. THE FINDINGS STATEDTHAT THE FIRM MADE AVAILABLE TO ITS SALES-FORCE CERTAININTERNAL-USE ONLY DOCUMENTS REGARDING THE STRATS. THESEDOCUMENTS DID NOT CONTAIN ADEQUATE DESCRIPTIONS OF THEPRODUCT, NOR DID THEY DISCLOSE THE DEGREE TO WHICH STRATSCUSTOMERS COULD LOSE PRINCIPAL IF THE UNDERLYING CAPITALSECURITY WAS REDEEMED. ACCORDINGLY, THE FIRM'S INTERNAL-USEONLY COMMUNICATIONS WERE NOT FAIR AND BALANCED AND DID NOTPROVIDE A SOUND BASIS FOR EVALUATING THE FACTS SURROUNDINGTHE STRATS OR ITS RISKS. THE FINDINGS ALSO STATED THAT THE FIRMFAILED TO ESTABLISH AND MAINTAIN SUPERVISORY PROCEDURES,INCLUDING TRAINING OF ITS REGISTERED REPRESENTATIVES,REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRASUITABILITY STANDARDS. THE FIRM'S SUPERVISORY SYSTEM FOR THESALE OF STRATS WAS NOT REASONABLY DESIGNED BECAUSE IT FAILEDTO INCLUDE ADEQUATE TRAINING FOR THE FIRM'S SALES-FORCEREGARDING THE RISKS OF INVESTING IN THE PRODUCT. THE FIRM DIDNOT PROVIDE PRODUCT SPECIFIC TRAINING TO ITS REGISTEREDREPRESENTATIVES, AND THE INTERNAL-USE ONLY MATERIALS MADEAVAILABLE TO ITS REGISTERED REPRESENTATIVES DID NOT ADEQUATELYINFORM ITS REPRESENTATIVES ABOUT THE RISKS OF INVESTING IN THESTRATS.

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 08/03/2015

Docket/Case Number: 2012033568901

Principal Product Type: Other

Other Product Type(s): STRUCTURED REPACKAGED ASSET-BACKED TRUST SECURITIES /INTEREST RATE SWAP CONTRACT

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT MADEUNSUITABLE RECOMMENDATIONS TO RETAIL CUSTOMERS TO PURCHASESTRUCTURED REPACKAGED ASSET-BACKED TRUST SECURITIES(STRATS), A COMPLEX STRUCTURED PRODUCT THAT PAID A FLOATINGRATE OF PERIODIC INCOME UP TO A MINIMUM OR MAXIMUM RATE, BASEDON THE STRATS TRUST'S INTEREST IN A CAPITAL SECURITY ISSUED BY AFINANCIAL INSTITUTION AND THE STRATS TRUST'S INTEREST IN ANINTEREST RATE SWAP CONTRACT. THE FIRM SOLD APPROXIMATELY $12MILLION WORTH OF THE STRATS TO ITS RETAIL CUSTOMERS, IN BOTHPRIMARY AND SECONDARY MARKETS. ALTHOUGH THE FIRM PROVIDEDITS SALES-FORCE TRAINING ON STRUCTURED PRODUCTS, NONE OF THISTRAINING RELATED SPECIFICALLY TO THE UNIQUE FEATURES AND RISKSOF THE STRATS. ADDITIONALLY, ALTHOUGH THE FIRM'S INTRANET PAGEDEDICATED TO FIXED INCOME PRODUCTS PROVIDED BASICINFORMATION CONCERNING THE STRATS, IT DID NOT PROVIDE ANYINFORMATION CONCERNING THE RISKS OF INVESTING IN THESEPRODUCTS, AND SPECIFICALLY DID NOT ADDRESS THE RISKS TOCUSTOMER PRINCIPAL IN THE EVENT OF A REDEMPTION OF THEUNDERLYING CAPITAL SECURITY. UNDER THE TERMS OF THEPROSPECTUS FOR THE STRATS, THE AMOUNT PAID TO A CUSTOMER INTHE EVENT OF A TERMINATION WAS THE PROCEEDS OF THEREDEMPTION OF UNDERLYING CAPITAL SECURITY PLUS ACCRUEDINTEREST AND LESS THE SWAP TERMINATION FEE. IN CERTAINCIRCUMSTANCES, THE CUSTOMER WOULD FACE A SUBSTANTIAL RISK OFLOSS OF PRINCIPAL UPON TERMINATION OF THE STRATS DUE TO THEAMOUNT OF THE SWAP TERMINATION FEE. THE FIRM'S REGISTEREDREPRESENTATIVES GENERALLY WERE NOT FAMILIAR WITH SUCH RISKSOF INVESTING IN THE STRATS AND WERE CONSEQUENTLY UNABLE TOEXPLAIN SUCH RISKS WHEN RECOMMENDING THE PRODUCT TO THEFIRM'S RETAIL CUSTOMERS. EVENTUALLY, THE FINANCIAL INSTITUTIONREDEEMED THE UNDERLYING CAPITAL SECURITY, CAUSING THE STRATSTO BE TERMINATED. THE FINANCIAL INSTITUTION REDEEMED THEUNDERLYING CAPITAL SECURITY AT PAR VALUE PLUS ACCRUEDINTEREST. BASED ON THE TERMS OF THE UNDERLYING SWAPAGREEMENT, CUSTOMERS RECEIVED THE PROCEEDS OF THEREDEMPTION AFTER THE SWAP TERMINATION FEE WAS PAID. AS ARESULT, AT THE TIME OF THE STRATS' TERMINATION, MANY CUSTOMERSHOLDING THE STRATS RECEIVED LESS, AND IN SOME CASESSIGNIFICANTLY LESS, THAN THE AMOUNT THEY PAID FOR THE STRATS.THE FIRM FAILED TO EDUCATE ITS REGISTERED REPRESENTATIVESREGARDING THE UNIQUE FEATURES AND RISKS OF THE STRATS. AS ARESULT, THE FIRM'S REGISTERED REPRESENTATIVES DID NOTCOMPREHEND THE RISKS TO CUSTOMERS OF INVESTING IN THE STRATSAND THUS LACKED A REASONABLE BASIS FOR RECOMMENDING THESEPRODUCTS TO THE FIRM'S RETAIL CUSTOMERS. THE FINDINGS STATEDTHAT THE FIRM MADE AVAILABLE TO ITS SALES-FORCE CERTAININTERNAL-USE ONLY DOCUMENTS REGARDING THE STRATS. THESEDOCUMENTS DID NOT CONTAIN ADEQUATE DESCRIPTIONS OF THEPRODUCT, NOR DID THEY DISCLOSE THE DEGREE TO WHICH STRATSCUSTOMERS COULD LOSE PRINCIPAL IF THE UNDERLYING CAPITALSECURITY WAS REDEEMED. ACCORDINGLY, THE FIRM'S INTERNAL-USEONLY COMMUNICATIONS WERE NOT FAIR AND BALANCED AND DID NOTPROVIDE A SOUND BASIS FOR EVALUATING THE FACTS SURROUNDINGTHE STRATS OR ITS RISKS. THE FINDINGS ALSO STATED THAT THE FIRMFAILED TO ESTABLISH AND MAINTAIN SUPERVISORY PROCEDURES,INCLUDING TRAINING OF ITS REGISTERED REPRESENTATIVES,REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRASUITABILITY STANDARDS. THE FIRM'S SUPERVISORY SYSTEM FOR THESALE OF STRATS WAS NOT REASONABLY DESIGNED BECAUSE IT FAILEDTO INCLUDE ADEQUATE TRAINING FOR THE FIRM'S SALES-FORCEREGARDING THE RISKS OF INVESTING IN THE PRODUCT. THE FIRM DIDNOT PROVIDE PRODUCT SPECIFIC TRAINING TO ITS REGISTEREDREPRESENTATIVES, AND THE INTERNAL-USE ONLY MATERIALS MADEAVAILABLE TO ITS REGISTERED REPRESENTATIVES DID NOT ADEQUATELYINFORM ITS REPRESENTATIVES ABOUT THE RISKS OF INVESTING IN THESTRATS.

Resolution Date: 08/03/2015

Resolution:

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

No

Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered: PLUS INTEREST ON THE RESTITUTION

Sanction Details: THE FIRM WAS CENSURED, FINED $500,000, AND ORDERED TO PAY$241,974.34, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS.

THE $500,000 FINE PAID IN FULL ON AUGUST 18, 2015.

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

No

Sanctions Ordered: CensureMonetary/Fine $500,000.00Disgorgement/Restitution

iReporting Source: Firm

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT MADEUNSUITABLE RECOMMENDATIONS TO RETAIL CUSTOMERS TO PURCHASESTRUCTURED REPACKAGED ASSET-BACKED TRUST SECURITIES(STRATS), A COMPLEX STRUCTURED PRODUCT THATPAID A FLOATING RATE OF PERIODIC INCOME UP TO A MINIMUM ORMAXIMUM RATE, BASED ON THE STRATS TRUST'S INTEREST IN A CAPITALSECURITY ISSUED BY A FINANCIAL INSTITUTION AND THE STRATS TRUST'SINTEREST IN AN INTEREST RATE SWAP CONTRACT. THE FIRM SOLDAPPROXIMATELY $12 MILLION WORTH OF THE STRATS TO ITS RETAILCUSTOMERS, IN BOTH PRIMARY AND SECONDARY MARKETS. ALTHOUGHTHE FIRM PROVIDED ITS SALES-FORCE TRAINING ON STRUCTUREDPRODUCTS, NONE OF THIS TRAINING RELATED SPECIFICALLY TO THEUNIQUE FEATURES AND RISKS OF THE STRATS. ADDITIONALLY, ALTHOUGHTHE FIRM'S INTRANET PAGE DEDICATED TO FIXED INCOME PRODUCTSPROVIDED BASIC INFORMATION CONCERNING THE STRATS, IT DID NOTPROVIDE ANY INFORMATION CONCERNING THE RISKS OF INVESTING INTHESE PRODUCTS, AND SPECIFICALLY DID NOT ADDRESS THE RISKS TOCUSTOMER PRINCIPAL IN THE EVENT OF A REDEMPTION OF THEUNDERLYING CAPITAL SECURITY. UNDER THE TERMS OF THEPROSPECTUS FOR THE STRATS, THE AMOUNT PAID TO A CUSTOMER INTHE EVENT OF A TERMINATION WAS THE PROCEEDS OF THEREDEMPTION OF UNDERLYING CAPITAL SECURITY PLUS ACCRUEDINTEREST AND LESS THE SWAP TERMINATION FEE. IN CERTAINCIRCUMSTANCES, THE CUSTOMER WOULD FACE A SUBSTANTIAL RISK OFLOSS OF PRINCIPAL UPON TERMINATION OF THE STRATS DUE TO THEAMOUNT OF THE SWAP TERMINATION FEE. THE FIRM'S REGISTEREDREPRESENTATIVES GENERALLY WERE NOT FAMILIAR WITH SUCH RISKSOF INVESTING IN THE STRATS AND WERE CONSEQUENTLY UNABLE TOEXPLAIN SUCH RISKS WHEN RECOMMENDING THE PRODUCT TO THEFIRM'S RETAIL CUSTOMERS. EVENTUALLY, THE FINANCIAL INSTITUTIONREDEEMED THE UNDERLYING CAPITAL SECURITY, CAUSING THE STRATSTO BE TERMINATED. THE FINANCIAL INSTITUTION REDEEMED THEUNDERLYING CAPITAL SECURITY AT PAR VALUE PLUS ACCRUEDINTEREST. BASED ON THE TERMS OF THE[NTC] STRATS, CUSTOMERSRECEIVED THE PROCEEDS OF THE REDEMPTION [NTC] OF THEUNDERLYING CAPITAL SECURITY LESS THE SWAP TERMINATION FEE PAID.AS A RESULT, AT THE TIME OF THE STRATS' TERMINATION, MANYCUSTOMERS HOLDING THE STRATS RECEIVED LESS, AND IN SOME CASESSIGNIFICANTLY LESS, THAN THE AMOUNT THEY PAID FOR THE STRATS.NEVERTHELESS, THE FIRM'S REGISTERED REPRESENTATIVES DID NOTCOMPREHEND THE RISKS TO CUSTOMERS OF INVESTING IN THE STRATSAND THUS LACKED A REASONABLE BASIS FOR RECOMMENDING THESEPRODUCTS TO THE FIRM'S RETAIL CUSTOMERS. THE FINDINGS STATEDTHAT THE FIRM MADE AVAILABLE TO ITS SALES-FORCE CERTAININTERNAL-USE ONLY DOCUMENTS REGARDINGTHE STRATS. THESE DOCUMENTS DID NOT CONTAIN ADEQUATEDESCRIPTIONS OF THE PRODUCT, NOR DID THEY DISCLOSE THE DEGREETO WHICH STRATS CUSTOMERS COULD LOSE PRINCIPAL IF THEUNDERLYING CAPITAL SECURITY WAS REDEEMED. ACCORDINGLY, THEFIRM'S INTERNAL-USE ONLY COMMUNICATIONS WERE NOT FAIR ANDBALANCED AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATING THEFACTS SURROUNDING THE STRATS OR ITS RISKS. THE FINDINGS ALSOSTATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAINSUPERVISORY PROCEDURES, INCLUDING TRAINING OF ITS REGISTEREDREPRESENTATIVES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITH FINRA SUITABILITY STANDARDS. THE FIRM'S SUPERVISORY SYSTEMFOR THE SALE OF STRATS WAS NOT REASONABLY DESIGNED BECAUSE ITFAILED TO INCLUDE ADEQUATE TRAINING FOR THE FIRM'S SALES-FORCEREGARDING THE RISKS OF INVESTING IN THE PRODUCT. THE FIRM DIDNOT PROVIDE PRODUCT SPECIFIC TRAINING TO ITS REGISTEREDREPRESENTATIVES, AND THE INTERNAL-USE ONLY MATERIALS MADEAVAILABLE TO ITS REGISTERED REPRESENTATIVES DID NOT ADEQUATEINFORM ITS REPRESENTATIVES ABOUT THE RISKS OF INVESTING IN THESTRATS.

Current Status: Final

69©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Initiated By: FINRA

Date Initiated: 08/03/2015

Docket/Case Number: 2012033568901

Principal Product Type: Other

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT MADEUNSUITABLE RECOMMENDATIONS TO RETAIL CUSTOMERS TO PURCHASESTRUCTURED REPACKAGED ASSET-BACKED TRUST SECURITIES(STRATS), A COMPLEX STRUCTURED PRODUCT THATPAID A FLOATING RATE OF PERIODIC INCOME UP TO A MINIMUM ORMAXIMUM RATE, BASED ON THE STRATS TRUST'S INTEREST IN A CAPITALSECURITY ISSUED BY A FINANCIAL INSTITUTION AND THE STRATS TRUST'SINTEREST IN AN INTEREST RATE SWAP CONTRACT. THE FIRM SOLDAPPROXIMATELY $12 MILLION WORTH OF THE STRATS TO ITS RETAILCUSTOMERS, IN BOTH PRIMARY AND SECONDARY MARKETS. ALTHOUGHTHE FIRM PROVIDED ITS SALES-FORCE TRAINING ON STRUCTUREDPRODUCTS, NONE OF THIS TRAINING RELATED SPECIFICALLY TO THEUNIQUE FEATURES AND RISKS OF THE STRATS. ADDITIONALLY, ALTHOUGHTHE FIRM'S INTRANET PAGE DEDICATED TO FIXED INCOME PRODUCTSPROVIDED BASIC INFORMATION CONCERNING THE STRATS, IT DID NOTPROVIDE ANY INFORMATION CONCERNING THE RISKS OF INVESTING INTHESE PRODUCTS, AND SPECIFICALLY DID NOT ADDRESS THE RISKS TOCUSTOMER PRINCIPAL IN THE EVENT OF A REDEMPTION OF THEUNDERLYING CAPITAL SECURITY. UNDER THE TERMS OF THEPROSPECTUS FOR THE STRATS, THE AMOUNT PAID TO A CUSTOMER INTHE EVENT OF A TERMINATION WAS THE PROCEEDS OF THEREDEMPTION OF UNDERLYING CAPITAL SECURITY PLUS ACCRUEDINTEREST AND LESS THE SWAP TERMINATION FEE. IN CERTAINCIRCUMSTANCES, THE CUSTOMER WOULD FACE A SUBSTANTIAL RISK OFLOSS OF PRINCIPAL UPON TERMINATION OF THE STRATS DUE TO THEAMOUNT OF THE SWAP TERMINATION FEE. THE FIRM'S REGISTEREDREPRESENTATIVES GENERALLY WERE NOT FAMILIAR WITH SUCH RISKSOF INVESTING IN THE STRATS AND WERE CONSEQUENTLY UNABLE TOEXPLAIN SUCH RISKS WHEN RECOMMENDING THE PRODUCT TO THEFIRM'S RETAIL CUSTOMERS. EVENTUALLY, THE FINANCIAL INSTITUTIONREDEEMED THE UNDERLYING CAPITAL SECURITY, CAUSING THE STRATSTO BE TERMINATED. THE FINANCIAL INSTITUTION REDEEMED THEUNDERLYING CAPITAL SECURITY AT PAR VALUE PLUS ACCRUEDINTEREST. BASED ON THE TERMS OF THE[NTC] STRATS, CUSTOMERSRECEIVED THE PROCEEDS OF THE REDEMPTION [NTC] OF THEUNDERLYING CAPITAL SECURITY LESS THE SWAP TERMINATION FEE PAID.AS A RESULT, AT THE TIME OF THE STRATS' TERMINATION, MANYCUSTOMERS HOLDING THE STRATS RECEIVED LESS, AND IN SOME CASESSIGNIFICANTLY LESS, THAN THE AMOUNT THEY PAID FOR THE STRATS.NEVERTHELESS, THE FIRM'S REGISTERED REPRESENTATIVES DID NOTCOMPREHEND THE RISKS TO CUSTOMERS OF INVESTING IN THE STRATSAND THUS LACKED A REASONABLE BASIS FOR RECOMMENDING THESEPRODUCTS TO THE FIRM'S RETAIL CUSTOMERS. THE FINDINGS STATEDTHAT THE FIRM MADE AVAILABLE TO ITS SALES-FORCE CERTAININTERNAL-USE ONLY DOCUMENTS REGARDINGTHE STRATS. THESE DOCUMENTS DID NOT CONTAIN ADEQUATEDESCRIPTIONS OF THE PRODUCT, NOR DID THEY DISCLOSE THE DEGREETO WHICH STRATS CUSTOMERS COULD LOSE PRINCIPAL IF THEUNDERLYING CAPITAL SECURITY WAS REDEEMED. ACCORDINGLY, THEFIRM'S INTERNAL-USE ONLY COMMUNICATIONS WERE NOT FAIR ANDBALANCED AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATING THEFACTS SURROUNDING THE STRATS OR ITS RISKS. THE FINDINGS ALSOSTATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAINSUPERVISORY PROCEDURES, INCLUDING TRAINING OF ITS REGISTEREDREPRESENTATIVES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITH FINRA SUITABILITY STANDARDS. THE FIRM'S SUPERVISORY SYSTEMFOR THE SALE OF STRATS WAS NOT REASONABLY DESIGNED BECAUSE ITFAILED TO INCLUDE ADEQUATE TRAINING FOR THE FIRM'S SALES-FORCEREGARDING THE RISKS OF INVESTING IN THE PRODUCT. THE FIRM DIDNOT PROVIDE PRODUCT SPECIFIC TRAINING TO ITS REGISTEREDREPRESENTATIVES, AND THE INTERNAL-USE ONLY MATERIALS MADEAVAILABLE TO ITS REGISTERED REPRESENTATIVES DID NOT ADEQUATEINFORM ITS REPRESENTATIVES ABOUT THE RISKS OF INVESTING IN THESTRATS.

70©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 73: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

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Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

FINE

Principal Product Type: Other

Other Product Type(s): STRUCTURED REPACKAGED ASSET-BACKED TRUST SECURITIES

Resolution Date: 08/03/2015

Resolution:

Other Sanctions Ordered: PLUS INTEREST ON THE RESTITUTION

Sanction Details: THE FIRM WAS CENSURED, FINED $500,000, AND ORDERED TO PAY$241,974.34, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS.

Sanctions Ordered: CensureMonetary/Fine $500,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

Disclosure 19 of 158

i

Reporting Source: Regulator

Initiated By: FINRA

Date Initiated: 07/06/2015

Docket/Case Number: 2014042689901

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITDISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLEORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASSA SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALESCHARGE. THE FINDINGS STATED THAT THESE CUSTOMERS WEREINSTEAD SOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE ORCLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHERONGOING FEES AND EXPENSES. THE FINDINGS ALSO STATED THAT THEFIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM ANDPROCEDURES REASONABLY DESIGNED TO ENSURE THAT ELIGIBLECUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THEBENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TOADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY DIDNOT PROVIDE SALES CHARGE WAIVERS TO CUSTOMERS IN CONNECTIONWITH THEIR MUTUAL FUND PURCHASES.

Current Status: Final

71©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 74: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

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Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Resolution Date: 07/06/2015

Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: THE FIRM IS CENSURED, ORDERED TO PROVIDE RESTITUTION TOCUSTOMERS, WHICH INCLUDES THE SALES CHARGE PAID, PLUSINTEREST, AND WITH RESPECT TO ANY ELIGIBLE CUSTOMER THATPURCHASED CLASS B OR C SHARES AND STILL HOLDS SUCH SHARES INAN ACCOUNT AT THE FIRM, IT SHALL OFFER SUCH CUSTOMER THEOPTION OF CONVERTING SUCH CLASS B OR C SHARES TO CLASS ASHARES. IF AN ELIGIBLE FUND DOES NOT PERMIT CONVERSION OF CLASSB OR C SHARES TO CLASS A SHARES, THE ELIGIBLE CUSTOMER SHALL BEPROVIDED THE OPTION OF REPLACING CLASS B OR C SHARES WITH ANEQUIVALENT VALUE OF CLASS A SHARES OFFERED BY ANOTHER ELIGIBLEFUND. THE FIRM SHALL CAUSE SUCH CONVERSION TO OCCUR AT NOEXPENSE TO THE CUSTOMER.

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

No

Sanctions Ordered: CensureDisgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITDISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLEORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASSA SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALESCHARGE. THE FINDINGS STATED THAT THESE CUSTOMERS WEREINSTEAD SOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE ORCLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHERONGOING FEES AND EXPENSES. THE FINDINGS ALSO STATED THAT THEFIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM ANDPROCEDURES REASONABLY DESIGNED TO ENSURE THAT ELIGIBLECUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THEBENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TOADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY DIDNOT PROVIDE SALES CHARGE WAIVERS TO CUSTOMERS IN CONNECTIONWITH THEIR MUTUAL FUND PURCHASES.

Current Status: Final

72©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 07/06/2015

Docket/Case Number: 2014042689901

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITDISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLEORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASSA SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALESCHARGE. THE FINDINGS STATED THAT THESE CUSTOMERS WEREINSTEAD SOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE ORCLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHERONGOING FEES AND EXPENSES. THE FINDINGS ALSO STATED THAT THEFIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM ANDPROCEDURES REASONABLY DESIGNED TO ENSURE THAT ELIGIBLECUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THEBENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TOADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY DIDNOT PROVIDE SALES CHARGE WAIVERS TO CUSTOMERS IN CONNECTIONWITH THEIR MUTUAL FUND PURCHASES.

Resolution Date: 07/06/2015

Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: THE FIRM IS CENSURED, ORDERED TO PROVIDE RESTITUTION TOCUSTOMERS, WHICH INCLUDES THE SALES CHARGE PAID, PLUSINTEREST, AND WITH RESPECT TO ANY ELIGIBLE CUSTOMER THATPURCHASED CLASS B OR C SHARES AND STILL HOLDS SUCH SHARES INAN ACCOUNT AT THE FIRM, IT SHALL OFFER SUCH CUSTOMER THEOPTION OF CONVERTING SUCH CLASS B OR C SHARES TO CLASS ASHARES. IF AN ELIGIBLE FUND DOES NOT PERMIT CONVERSION OF CLASSB OR C SHARES TO CLASS A SHARES, THE ELIGIBLE CUSTOMER SHALL BEPROVIDED THE OPTION OF REPLACING CLASS B OR C SHARES WITH ANEQUIVALENT VALUE OF CLASS A SHARES OFFERED BY ANOTHER ELIGIBLEFUND. THE FIRM SHALL CAUSE SUCH CONVERSION TO OCCUR AT NOEXPENSE TO THE CUSTOMER.

Sanctions Ordered: CensureDisgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

Disclosure 20 of 158

i

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Disclosure 20 of 158

Reporting Source: Regulator

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 05/06/2015

Docket/Case Number: 2012035222801

Principal Product Type: Other

Other Product Type(s): UNSPECIFIED SECURITIES

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT ACCEPTEDAND HELD CUSTOMER MARKET ORDERS, TRADED FOR ITS OWNACCOUNT AT PRICES THAT WOULD HAVE SATISFIED THE CUSTOMERMARKET ORDERS, AND FAILED TO IMMEDIATELY THEREAFTER EXECUTETHE CUSTOMER MARKET ORDERS. THE FINDINGS STATED THAT THE FIRMFAILED TO SHOW THE CORRECT TIME OF EXECUTION ON THEMEMORANDUM OF BROKERAGE ORDERS AND FAILED TO SHOW THECORRECT TIME OF ENTRY ON THE MEMORANDUM OF BROKERAGEORDERS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REPORTTHE CORRECT TIME OF EXECUTION TO THE OTC REPORTING FACILITY(OTCRF) LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATEDSECURITIES. THE FINDINGS ALSO INCLUDED THAT THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOTHE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND FINRARULES, CONCERNING OTC ORDER PROTECTION. THE FIRM'S WRITTENSUPERVISORY PROCEDURES (WSPS) FAILED TO PROVIDE FOR THEMINIMUM REQUIREMENTS FOR ADEQUATE WSPS CONCERNING OTCORDER PROTECTION.

Current Status: Final

Resolution Date: 05/06/2015

Resolution:

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

No

Acceptance, Waiver & Consent(AWC)

74©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Other Sanctions Ordered: UNDERTAKING

Sanction Details: THE FIRM WAS CENSURED, FINED $35,000, AND UNDERTAKES TO REVISEITS WSPS TO ADDRESS THE DEFICIENCIES DESCRIBED IN THE AWC. FINEPAID IN FULL ON 5/28/2015.

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

No

Sanctions Ordered: CensureMonetary/Fine $35,000.00

iReporting Source: Firm

Initiated By: FINRA

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT ACCEPTEDAND HELD CUSTOMER MARKET ORDERS, TRADED FOR ITS OWNACCOUNT AT PRICES THAT WOULD HAVE SATISFIED THE CUSTOMERMARKETORDERS, AND FAILED TO IMMEDIATELY THEREAFTER EXECUTE THECUSTOMER MARKET ORDERS. THE FINDINGS STATED THAT THE FIRMFAILED TOSHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDUM OFBROKERAGE ORDERS AND FAILED TO SHOW THE CORRECT TIME OFENTRY ONTHE MEMORANDUM OF BROKERAGE ORDERS. THE FINDINGS ALSOSTATED THAT THE FIRM FAILED TO REPORT THE CORRECT TIME OFEXECUTIONTO THE OTC REPORTING FACILITY (OTCRF) LAST SALE REPORTS OFTRANSACTIONS IN DESIGNATED SECURITIES. THE FINDINGS ALSOINCLUDEDTHAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHRESPECT TOTHE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND FINRARULES, CONCERNING OTC ORDER PROTECTION. THE FIRM'S WRITTENSUPERVISORY PROCEDURES (WSPS) FAILED TO PROVIDE FOR THEMINIMUM REQUIREMENTS FOR ADEQUATE WSPS CONCERNING OTCORDERPROTECTION.

Current Status: Final

75©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 05/06/2015

Docket/Case Number: 2012035222801

Principal Product Type: Other

Other Product Type(s): UNSPECIFIED SECURITIES

Resolution Date: 05/06/2015

Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED, FINED $35,000, AND UNDERTAKES TO REVISEITS WSPS TO ADDRESS THE DEFICIENCIES DESCRIBED IN THE AWC.

Firm Statement THE FIRM WAS CENSURED, FINED $35,000, AND UNDERTAKES TO REVISEITS WSPS TO ADDRESS THE DEFICIENCIES DESCRIBED IN THE AWC.

Sanctions Ordered: CensureMonetary/Fine $35,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 21 of 158

i

Reporting Source: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT FOR SEVERALYEARS THE FIRM FAILED TO COMPLY FULLY WITH A KEY ASPECT OF THEANTI-MONEY LAUNDERING ("AML") COMPLIANCE PROGRAMREQUIREMENTS FOR BROKER-DEALERS. TO SATISFY THOSEREQUIREMENTS, EVERY BROKER-DEALER MUST ESTABLISH ANDMAINTAIN A CUSTOMER IDENTIFICATION PROGRAM ("CIP") UNDER WHICHIT VERIFIES THE IDENTITY OF EACH CUSTOMER OPENING A NEWACCOUNT, AND, DURING THE RELEVANT PERIOD, THE FIRM'S CIP WASDEFICIENT, IN THAT IT DID NOT SUBJECT CERTAIN NEW CUSTOMERS TOIDENTITY VERIFICATION. THE FINDINGS STATED THAT DURING THERELEVANT PERIOD, WHEN THE FIRM'S TRANSACTION-PROCESSINGSYSTEM, THE BETA SYSTEM, ASSIGNED CUSTOMER IDENTIFIERS TO NEWSECURITIES ACCOUNTS, IT SOMETIMES RECYCLED IDENTIFIERSPREVIOUSLY ASSIGNED TO ACCOUNTS THAT HAD BEEN CLOSED. WHENTHIS HAPPENED, THE CIP SYSTEM RECOGNIZED THE IDENTIFIERS ANDTREATED THE NEW ACCOUNTS AS IF THEY HAD ALREADY GONETHROUGH THE CIP SYSTEM. THUS, EVEN THOUGH THE APPURTENANTCUSTOMER INFORMATION - SUCH AS CUSTOMER NAME, ADDRESS, TAX-IDENTIFICATION NUMBER, AND DATE OF BIRTH - WAS DIFFERENT FROMTHE PREVIOUS INSTANCE OF IDENTITY VERIFICATION, THE CIP SYSTEMDID NOT SUBJECT THE CUSTOMERS ASSOCIATED WITH THESE NEWACCOUNTS TO IDENTITY VERIFICATION. FOR THAT REASON, THE FIRM'SCIP SYSTEM DID NOT VERIFY THE IDENTITIES OF NEW CUSTOMERS WITHRECYCLED IDENTIFIERS. THIS RESULTED IN THE FIRMS' FAILURE TOCONDUCT CUSTOMER-IDENTITY VERIFICATION FOR NEARLY 220,000ACCOUNTS DURING THE RELEVANT PERIOD. THE FINDINGS ALSO STATEDTHAT OF THE ACCOUNTS THAT WERE NOT SUBJECTED TO IDENTITYVERIFICATION, APPROXIMATELY 120,000 WERE ALREADY CLOSED WHENTHE PROBLEM CAME TO LIGHT. THESE ACCOUNTS WERE NEVERSUBJECTED TO IDENTITY VERIFICATION. THE ACCOUNTS THAT WERESTILL OPEN WHEN THE FIRM DISCOVERED THE DESIGN FLAW WERESUBSEQUENTLY SENT THROUGH THE CIP PROCESS, WITH THE FIRMEVENTUALLY PROHIBITING FURTHER ACTIVITY IN 345 ACCOUNTS FORWHICH IDENTITY VERIFICATION COULD NOT BE COMPLETED.

Current Status: Final

76©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 12/18/2014

Docket/Case Number: 2012034123501

Principal Product Type: No Product

Other Product Type(s):

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT FOR SEVERALYEARS THE FIRM FAILED TO COMPLY FULLY WITH A KEY ASPECT OF THEANTI-MONEY LAUNDERING ("AML") COMPLIANCE PROGRAMREQUIREMENTS FOR BROKER-DEALERS. TO SATISFY THOSEREQUIREMENTS, EVERY BROKER-DEALER MUST ESTABLISH ANDMAINTAIN A CUSTOMER IDENTIFICATION PROGRAM ("CIP") UNDER WHICHIT VERIFIES THE IDENTITY OF EACH CUSTOMER OPENING A NEWACCOUNT, AND, DURING THE RELEVANT PERIOD, THE FIRM'S CIP WASDEFICIENT, IN THAT IT DID NOT SUBJECT CERTAIN NEW CUSTOMERS TOIDENTITY VERIFICATION. THE FINDINGS STATED THAT DURING THERELEVANT PERIOD, WHEN THE FIRM'S TRANSACTION-PROCESSINGSYSTEM, THE BETA SYSTEM, ASSIGNED CUSTOMER IDENTIFIERS TO NEWSECURITIES ACCOUNTS, IT SOMETIMES RECYCLED IDENTIFIERSPREVIOUSLY ASSIGNED TO ACCOUNTS THAT HAD BEEN CLOSED. WHENTHIS HAPPENED, THE CIP SYSTEM RECOGNIZED THE IDENTIFIERS ANDTREATED THE NEW ACCOUNTS AS IF THEY HAD ALREADY GONETHROUGH THE CIP SYSTEM. THUS, EVEN THOUGH THE APPURTENANTCUSTOMER INFORMATION - SUCH AS CUSTOMER NAME, ADDRESS, TAX-IDENTIFICATION NUMBER, AND DATE OF BIRTH - WAS DIFFERENT FROMTHE PREVIOUS INSTANCE OF IDENTITY VERIFICATION, THE CIP SYSTEMDID NOT SUBJECT THE CUSTOMERS ASSOCIATED WITH THESE NEWACCOUNTS TO IDENTITY VERIFICATION. FOR THAT REASON, THE FIRM'SCIP SYSTEM DID NOT VERIFY THE IDENTITIES OF NEW CUSTOMERS WITHRECYCLED IDENTIFIERS. THIS RESULTED IN THE FIRMS' FAILURE TOCONDUCT CUSTOMER-IDENTITY VERIFICATION FOR NEARLY 220,000ACCOUNTS DURING THE RELEVANT PERIOD. THE FINDINGS ALSO STATEDTHAT OF THE ACCOUNTS THAT WERE NOT SUBJECTED TO IDENTITYVERIFICATION, APPROXIMATELY 120,000 WERE ALREADY CLOSED WHENTHE PROBLEM CAME TO LIGHT. THESE ACCOUNTS WERE NEVERSUBJECTED TO IDENTITY VERIFICATION. THE ACCOUNTS THAT WERESTILL OPEN WHEN THE FIRM DISCOVERED THE DESIGN FLAW WERESUBSEQUENTLY SENT THROUGH THE CIP PROCESS, WITH THE FIRMEVENTUALLY PROHIBITING FURTHER ACTIVITY IN 345 ACCOUNTS FORWHICH IDENTITY VERIFICATION COULD NOT BE COMPLETED.

Resolution Date: 12/18/2014

Resolution:

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

No

Sanctions Ordered: CensureMonetary/Fine $1,500,000.00

Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND FINED, JOINTLY AND SEVERALLY,$1,500,000.

FINE PAID IN FULL ON JANUARY 12, 2015.

Regulator Statement IN DETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDEREDTHAT THE FIRM DISCOVERED THE CIP-RELATED VIOLATIONS THROUGHTHE FIRM'S COMPLIANCE RISK ANALYSIS SYSTEM (CRAS) TEST,INVESTIGATED THEIR CAUSES AND SCOPE, PERFORMED REMEDIATIONCIP ON THE APPROXIMATELY 100,000 AFFECTED ACCOUNTS THATREMAINED OPEN, MADE PROGRAMMING CHANGES TO THE CIP SYSTEMAND TO THE FIRM'S BETA IN AN EFFORT TO PREVENT RECURRENCES, ANDREPORTED THE VIOLATIONS TO FINRA IN ACCORDANCE WITH RULE4530(B).

Sanctions Ordered: CensureMonetary/Fine $1,500,000.00

iReporting Source: Firm

Allegations: FINRA HAS ALLEGED POTENTIAL VIOLATIONS OF FINRA RULES 3310 AND2010 AND NASD RULE 2110. WITHOUT ADMITTING OR DENYING THEFINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRYOF FINDINGS THAT FORSEVERAL YEARS THE FIRM FAILED TO COMPLY FULLY WITH A KEY ASPECTOF THE ANTI-MONEY LAUNDERING ("AML") COMPLIANCE PROGRAMREQUIREMENTS FOR BROKER-DEALERS. TO SATISFY THOSEREQUIREMENTS, EVERY BROKER-DEALER MUST ESTABLISH ANDMAINTAIN ACUSTOMER IDENTIFICATION PROGRAM ("CIP") UNDER WHICH IT VERIFIESTHE IDENTITY OF EACH CUSTOMER OPENING A NEW ACCOUNT, AND,DURING THE RELEVANT PERIOD, THE FIRM'S CIP WAS DEFICIENT, IN THATIT DID NOT SUBJECT CERTAIN NEW CUSTOMERS TO IDENTITYVERIFICATION. THE FINDINGS STATED THAT DURING THE RELEVANTPERIOD, WHEN THE FIRM'S TRANSACTION-PROCESSING SYSTEM, THEBETASYSTEM, ASSIGNED CUSTOMER IDENTIFIERS TO NEW SECURITIESACCOUNTS, IT SOMETIMES RECYCLED IDENTIFIERS PREVIOUSLYASSIGNED TOACCOUNTS THAT HAD BEEN CLOSED. WHEN THIS HAPPENED, THE CIPSYSTEM RECOGNIZED THE IDENTIFIERS AND TREATED THE NEWACCOUNTSAS IF THEY HAD ALREADY GONE THROUGH THE CIP SYSTEM. THUS, EVENTHOUGH THE APPURTENANT CUSTOMER INFORMATION - SUCH ASCUSTOMER NAME, ADDRESS, TAX-IDENTIFICATION NUMBER, AND DATE OFBIRTH - WAS DIFFERENT FROM THE PREVIOUS INSTANCE OF IDENTITYVERIFICATION, THE CIP SYSTEM DID NOT SUBJECT THE CUSTOMERSASSOCIATED WITH THESE NEW ACCOUNTS TO IDENTITY VERIFICATION.FORTHAT REASON, THE FIRM'S CIP SYSTEM DID NOT VERIFY THE IDENTITIESOF NEW CUSTOMERS WITH RECYCLED IDENTIFIERS. THIS RESULTED INTHE FIRMS' FAILURE TO CONDUCT CUSTOMER-IDENTITY VERIFICATIONFOR NEARLY 220,000 ACCOUNTS DURING THE RELEVANT PERIOD. THEFINDINGS ALSO STATED THAT OF THE ACCOUNTS THAT WERE NOTSUBJECTED TO IDENTITY VERIFICATION, APPROXIMATELY 120,000 WEREALREADY CLOSED WHEN THE PROBLEM CAME TO LIGHT. THESEACCOUNTS WERE NEVER SUBJECTED TO IDENTITY VERIFICATION. THEACCOUNTSTHAT WERE STILL OPEN WHEN THE FIRM DISCOVERED THE DESIGN FLAWWERE SUBSEQUENTLY SENT THROUGH THE CIP PROCESS, WITH THEFIRM EVENTUALLY PROHIBITING FURTHER ACTIVITY IN 345 ACCOUNTSFOR WHICH IDENTITY VERIFICATION COULD NOT BE COMPLETED. INDETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDERED THATTHE FIRM DISCOVERED THE CIP-RELATED VIOLATIONS THROUGH THEFIRM'S COMPLIANCE RISK ANALYSIS SYSTEM (CRAS) TEST, INVESTIGATEDTHEIR CAUSES AND SCOPE, PERFORMED REMEDIATION CIP ON THEAPPROXIMATELY 100,000 AFFECTED ACCOUNTS THAT REMAINED OPEN,MADE PROGRAMMING CHANGES TO THE CIP SYSTEM AND TO THE FIRM'SBETA IN AN EFFORT TO PREVENT RECURRENCES, AND REPORTED THEVIOLATIONS TO FINRA IN ACCORDANCE WITH RULE 4530(B).

Current Status: Final

78©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 81: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 12/18/2014

Docket/Case Number: 2012034123501

Principal Product Type: No Product

Other Product Type(s):

FINRA HAS ALLEGED POTENTIAL VIOLATIONS OF FINRA RULES 3310 AND2010 AND NASD RULE 2110. WITHOUT ADMITTING OR DENYING THEFINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRYOF FINDINGS THAT FORSEVERAL YEARS THE FIRM FAILED TO COMPLY FULLY WITH A KEY ASPECTOF THE ANTI-MONEY LAUNDERING ("AML") COMPLIANCE PROGRAMREQUIREMENTS FOR BROKER-DEALERS. TO SATISFY THOSEREQUIREMENTS, EVERY BROKER-DEALER MUST ESTABLISH ANDMAINTAIN ACUSTOMER IDENTIFICATION PROGRAM ("CIP") UNDER WHICH IT VERIFIESTHE IDENTITY OF EACH CUSTOMER OPENING A NEW ACCOUNT, AND,DURING THE RELEVANT PERIOD, THE FIRM'S CIP WAS DEFICIENT, IN THATIT DID NOT SUBJECT CERTAIN NEW CUSTOMERS TO IDENTITYVERIFICATION. THE FINDINGS STATED THAT DURING THE RELEVANTPERIOD, WHEN THE FIRM'S TRANSACTION-PROCESSING SYSTEM, THEBETASYSTEM, ASSIGNED CUSTOMER IDENTIFIERS TO NEW SECURITIESACCOUNTS, IT SOMETIMES RECYCLED IDENTIFIERS PREVIOUSLYASSIGNED TOACCOUNTS THAT HAD BEEN CLOSED. WHEN THIS HAPPENED, THE CIPSYSTEM RECOGNIZED THE IDENTIFIERS AND TREATED THE NEWACCOUNTSAS IF THEY HAD ALREADY GONE THROUGH THE CIP SYSTEM. THUS, EVENTHOUGH THE APPURTENANT CUSTOMER INFORMATION - SUCH ASCUSTOMER NAME, ADDRESS, TAX-IDENTIFICATION NUMBER, AND DATE OFBIRTH - WAS DIFFERENT FROM THE PREVIOUS INSTANCE OF IDENTITYVERIFICATION, THE CIP SYSTEM DID NOT SUBJECT THE CUSTOMERSASSOCIATED WITH THESE NEW ACCOUNTS TO IDENTITY VERIFICATION.FORTHAT REASON, THE FIRM'S CIP SYSTEM DID NOT VERIFY THE IDENTITIESOF NEW CUSTOMERS WITH RECYCLED IDENTIFIERS. THIS RESULTED INTHE FIRMS' FAILURE TO CONDUCT CUSTOMER-IDENTITY VERIFICATIONFOR NEARLY 220,000 ACCOUNTS DURING THE RELEVANT PERIOD. THEFINDINGS ALSO STATED THAT OF THE ACCOUNTS THAT WERE NOTSUBJECTED TO IDENTITY VERIFICATION, APPROXIMATELY 120,000 WEREALREADY CLOSED WHEN THE PROBLEM CAME TO LIGHT. THESEACCOUNTS WERE NEVER SUBJECTED TO IDENTITY VERIFICATION. THEACCOUNTSTHAT WERE STILL OPEN WHEN THE FIRM DISCOVERED THE DESIGN FLAWWERE SUBSEQUENTLY SENT THROUGH THE CIP PROCESS, WITH THEFIRM EVENTUALLY PROHIBITING FURTHER ACTIVITY IN 345 ACCOUNTSFOR WHICH IDENTITY VERIFICATION COULD NOT BE COMPLETED. INDETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDERED THATTHE FIRM DISCOVERED THE CIP-RELATED VIOLATIONS THROUGH THEFIRM'S COMPLIANCE RISK ANALYSIS SYSTEM (CRAS) TEST, INVESTIGATEDTHEIR CAUSES AND SCOPE, PERFORMED REMEDIATION CIP ON THEAPPROXIMATELY 100,000 AFFECTED ACCOUNTS THAT REMAINED OPEN,MADE PROGRAMMING CHANGES TO THE CIP SYSTEM AND TO THE FIRM'SBETA IN AN EFFORT TO PREVENT RECURRENCES, AND REPORTED THEVIOLATIONS TO FINRA IN ACCORDANCE WITH RULE 4530(B).

Resolution Date: 12/18/2014

Resolution:

Sanctions Ordered: CensureMonetary/Fine $1,500,000.00

Acceptance, Waiver & Consent(AWC)

79©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 82: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

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Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND FINED, JOINTLY AND SEVERALLY,$1,500,000.

Firm Statement IN DETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDEREDTHAT THE FIRM DISCOVERED THE CIP-RELATED VIOLATIONS THROUGHTHEFIRM'S COMPLIANCE RISK ANALYSIS SYSTEM (CRAS) TEST, INVESTIGATEDTHEIR CAUSES AND SCOPE, PERFORMED REMEDIATION CIP ON THEAPPROXIMATELY 100,000 AFFECTED ACCOUNTS THAT REMAINED OPEN,MADE PROGRAMMING CHANGES TO THE CIP SYSTEM AND TO THE FIRM'SBETA IN AN EFFORT TO PREVENT RECURRENCES, AND REPORTED THEVIOLATIONS TO FINRA IN ACCORDANCE WITH RULE 4530(B).

CensureMonetary/Fine $1,500,000.00

Disclosure 22 of 158

i

Reporting Source: Regulator

Allegations: SEC ADMIN RELEASE 34-73175, IA RELEASE 40-3928 / SEPTEMBER 22, 2014:THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATEAND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTEDPURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGEACT OF 1934 AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENTADVISERS ACT OF 1940 AGAINST WELLS FARGO ADVISORS, LLC ("WELLSFARGO ADVISORS" OR "RESPONDENT"). IN ANTICIPATION OF THEINSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED ANOFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TOACCEPT. WELLS FARGO ADVISORS ADMITS THE FINDINGS,ACKNOWLEDGES THAT ITS CONDUCT VIOLATED THE FEDERALSECURITIES LAWS, ADMITS THE COMMISSION'S JURISDICTION OVER ITAND THE SUBJECT MATTER OF THESE PROCEEDINGS, AND CONSENTS TOTHE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS. THIS CASE INVOLVES THE FAILURE OFWELLS FARGO ADVISORS TO ADEQUATELY ESTABLISH, MAINTAIN, ANDENFORCE POLICIES AND PROCEDURES REASONABLY DESIGNED TOPREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION,SPECIFICALLY, THE MATERIAL NONPUBLIC INFORMATION OBTAINED FROMITS CUSTOMERS AND ITS ADVISORY CLIENTS. WELLS FARGO ADVISORS'POLICIES AND PROCEDURES TO PREVENT THE MISUSE OF MATERIALNONPUBLIC INFORMATION WERE NOT REASONABLY DESIGNED TOADDRESS THE RISK THAT ITS ASSOCIATED PERSONS COULD OBTAINMATERIAL NONPUBLIC INFORMATION FROM ITS CUSTOMERS ANDADVISORY CLIENTS EVEN THOUGH THE FIRM EXPRESSLY IDENTIFIEDTHAT RISK IN MULTIPLE INTERNAL DOCUMENTS. THIS RISK MANIFESTEDITSELF IN 2010 WHEN ONE OF THE REGISTERED REPRESENTATIVES OFWELLS FARGO ADVISORS MISAPPROPRIATED INFORMATION FROM ONEOF HIS CUSTOMERS ABOUT A COMPANY'S SECURITIES, TRADED ON THEBASIS OF THAT INFORMATION, AND TIPPED OTHERS INCLUDING SEVERALOF HIS WELLS FARGO ADVISORS CUSTOMERS. THE MANNER IN WHICHTHE POLICIES AND PROCEDURES WERE DESIGNED AFFECTED THECOMPANY SECURITIES REVIEW. MULTIPLE UNITS WITHIN THE FIRMRECEIVED INDICATIONS SUGGESTING THAT THE REGISTEREDREPRESENTATIVE WAS MISUSING MATERIAL NONPUBLIC INFORMATIONOBTAINED FROM A CUSTOMER TO TRADE IN THE COMPANY'S SECURITIES.BECAUSE OF A LACK OF ASSIGNED RESPONSIBILITY OR COORDINATION,EACH OF THESE UNITS FAILED TO TAKE NEEDED ACTIONS. THE POLICIESAND PROCEDURES DESIGNED CAUSED RESPONDENT NOT TORECOGNIZE SEVERAL RED FLAGS THAT ITS REPRESENTATIVE WASENGAGING IN INSIDER TRADING IN THE COMPANY'S SECURITIES. INADDITION THE RESPONDENT DID NOT EFFECTIVELY MAINTAIN ANDENFORCE THE POLICIES AND PROCEDURES. ADDITIONALLY, ALTHOUGHTHE POLICIES AND PROCEDURES REQUIRED "DAILY REVIEW TO IDENTIFYSITUATIONS WHEN PROFIT OR AVOIDANCE OF LOSS COULD MOST LIKELYRESULT FROM TRADING PRIOR TO THE PUBLIC RELEASE OFINFORMATION," FOR A TEN MONTH PERIOD THE RETAIL CONTROL GROUP(RCG), A UNIT IN THE FIRM'S COMPLIANCE DEPARTMENT, FAILED TOPERFORM REVIEWS IN A TIMELY MANNER OF AT LEAST 40 INSTANCES OFPOSSIBLE INSIDER TRADING FLAGGED FOR REVIEW. WHEN THERESPONDENT PRODUCED DOCUMENTS, AS REQUESTED BY THECOMMISSION, RELATING TO REVIEWS OF TRADING BY THE REGISTEREDREPRESENTATIVE WHO TRADED IN THE COMPANY'S SECURITIES, INRESPONSE TO THE COMMISSION'S REQUEST, DOCUMENTS RELATING TOTHE RCG REVIEW OF THE SECURITIES TRADING WERE NOT PRODUCED.RESPONDENT UNREASONABLY DELAYED, WITHOUT ANY EXPLANATION,FOR SIX MONTHS PRODUCING DOCUMENTS RELATING TO THE RCGREVIEW OF THE REPRESENTATIVE WHO TRADED IN THE COMPANY'SSECURITIES. WHEN THE DOCUMENTS WERE PRODUCED, THE FIRMFAILED TO PRODUCE AN ACCURATE RECORD OF THE REVIEW AS ITEXISTED AT THE TIME OF THE REQUEST. INSTEAD, IT PRODUCED ADOCUMENT THAT HAD BEEN ALTERED BY AN EMPLOYEE. WHENQUESTIONS AROSE SURROUNDING THE ALTERED DOCUMENT, THEEMPLOYEE WAS PLACED ON ADMINISTRATIVE LEAVE AND EVENTUALLYTERMINATED. AS A RESULT, RESPONDENT WILLFULLY VIOLATEDSECTIONS 15(G), 17(A), AND 17(B) OF THE EXCHANGE ACT AND RULE 17A-4(J) THEREUNDER AND SECTIONS 204(A) AND 204A OF THE ADVISERS ACT.

Current Status: Final

80©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Date Initiated: 09/22/2014

SEC ADMIN RELEASE 34-73175, IA RELEASE 40-3928 / SEPTEMBER 22, 2014:THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATEAND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTEDPURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGEACT OF 1934 AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENTADVISERS ACT OF 1940 AGAINST WELLS FARGO ADVISORS, LLC ("WELLSFARGO ADVISORS" OR "RESPONDENT"). IN ANTICIPATION OF THEINSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED ANOFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TOACCEPT. WELLS FARGO ADVISORS ADMITS THE FINDINGS,ACKNOWLEDGES THAT ITS CONDUCT VIOLATED THE FEDERALSECURITIES LAWS, ADMITS THE COMMISSION'S JURISDICTION OVER ITAND THE SUBJECT MATTER OF THESE PROCEEDINGS, AND CONSENTS TOTHE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS. THIS CASE INVOLVES THE FAILURE OFWELLS FARGO ADVISORS TO ADEQUATELY ESTABLISH, MAINTAIN, ANDENFORCE POLICIES AND PROCEDURES REASONABLY DESIGNED TOPREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION,SPECIFICALLY, THE MATERIAL NONPUBLIC INFORMATION OBTAINED FROMITS CUSTOMERS AND ITS ADVISORY CLIENTS. WELLS FARGO ADVISORS'POLICIES AND PROCEDURES TO PREVENT THE MISUSE OF MATERIALNONPUBLIC INFORMATION WERE NOT REASONABLY DESIGNED TOADDRESS THE RISK THAT ITS ASSOCIATED PERSONS COULD OBTAINMATERIAL NONPUBLIC INFORMATION FROM ITS CUSTOMERS ANDADVISORY CLIENTS EVEN THOUGH THE FIRM EXPRESSLY IDENTIFIEDTHAT RISK IN MULTIPLE INTERNAL DOCUMENTS. THIS RISK MANIFESTEDITSELF IN 2010 WHEN ONE OF THE REGISTERED REPRESENTATIVES OFWELLS FARGO ADVISORS MISAPPROPRIATED INFORMATION FROM ONEOF HIS CUSTOMERS ABOUT A COMPANY'S SECURITIES, TRADED ON THEBASIS OF THAT INFORMATION, AND TIPPED OTHERS INCLUDING SEVERALOF HIS WELLS FARGO ADVISORS CUSTOMERS. THE MANNER IN WHICHTHE POLICIES AND PROCEDURES WERE DESIGNED AFFECTED THECOMPANY SECURITIES REVIEW. MULTIPLE UNITS WITHIN THE FIRMRECEIVED INDICATIONS SUGGESTING THAT THE REGISTEREDREPRESENTATIVE WAS MISUSING MATERIAL NONPUBLIC INFORMATIONOBTAINED FROM A CUSTOMER TO TRADE IN THE COMPANY'S SECURITIES.BECAUSE OF A LACK OF ASSIGNED RESPONSIBILITY OR COORDINATION,EACH OF THESE UNITS FAILED TO TAKE NEEDED ACTIONS. THE POLICIESAND PROCEDURES DESIGNED CAUSED RESPONDENT NOT TORECOGNIZE SEVERAL RED FLAGS THAT ITS REPRESENTATIVE WASENGAGING IN INSIDER TRADING IN THE COMPANY'S SECURITIES. INADDITION THE RESPONDENT DID NOT EFFECTIVELY MAINTAIN ANDENFORCE THE POLICIES AND PROCEDURES. ADDITIONALLY, ALTHOUGHTHE POLICIES AND PROCEDURES REQUIRED "DAILY REVIEW TO IDENTIFYSITUATIONS WHEN PROFIT OR AVOIDANCE OF LOSS COULD MOST LIKELYRESULT FROM TRADING PRIOR TO THE PUBLIC RELEASE OFINFORMATION," FOR A TEN MONTH PERIOD THE RETAIL CONTROL GROUP(RCG), A UNIT IN THE FIRM'S COMPLIANCE DEPARTMENT, FAILED TOPERFORM REVIEWS IN A TIMELY MANNER OF AT LEAST 40 INSTANCES OFPOSSIBLE INSIDER TRADING FLAGGED FOR REVIEW. WHEN THERESPONDENT PRODUCED DOCUMENTS, AS REQUESTED BY THECOMMISSION, RELATING TO REVIEWS OF TRADING BY THE REGISTEREDREPRESENTATIVE WHO TRADED IN THE COMPANY'S SECURITIES, INRESPONSE TO THE COMMISSION'S REQUEST, DOCUMENTS RELATING TOTHE RCG REVIEW OF THE SECURITIES TRADING WERE NOT PRODUCED.RESPONDENT UNREASONABLY DELAYED, WITHOUT ANY EXPLANATION,FOR SIX MONTHS PRODUCING DOCUMENTS RELATING TO THE RCGREVIEW OF THE REPRESENTATIVE WHO TRADED IN THE COMPANY'SSECURITIES. WHEN THE DOCUMENTS WERE PRODUCED, THE FIRMFAILED TO PRODUCE AN ACCURATE RECORD OF THE REVIEW AS ITEXISTED AT THE TIME OF THE REQUEST. INSTEAD, IT PRODUCED ADOCUMENT THAT HAD BEEN ALTERED BY AN EMPLOYEE. WHENQUESTIONS AROSE SURROUNDING THE ALTERED DOCUMENT, THEEMPLOYEE WAS PLACED ON ADMINISTRATIVE LEAVE AND EVENTUALLYTERMINATED. AS A RESULT, RESPONDENT WILLFULLY VIOLATEDSECTIONS 15(G), 17(A), AND 17(B) OF THE EXCHANGE ACT AND RULE 17A-4(J) THEREUNDER AND SECTIONS 204(A) AND 204A OF THE ADVISERS ACT.

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Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

Date Initiated: 09/22/2014

Docket/Case Number: 3-16153

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

Other Product Type(s):

Resolution Date: 09/22/2014

Resolution:

Other Sanctions Ordered: UNDERTAKINGS

Sanction Details: RESPONDENT CEASE AND DESIST FROM COMMITTING OR CAUSING ANYVIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 15(G), 17(A), AND17(B) OF THE EXCHANGE ACT AND RULE 17A-4(J) PROMULGATEDTHEREUNDER AND SECTIONS 204A AND 204(A) OF THE ADVISERS ACT.RESPONDENT IS CENSURED. RESPONDENT SHALL, WITHIN 10 DAYS OFTHE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNTOF $5,000,000. RESPONDENT SHALL COMPLY WITH THE UNDERTAKINGSENUMERATED IN THIS ORDER.

WILLFULLY VIOLATED SECTIONS 15(G), 17(A), AND 17(B) OF THEEXCHANGE ACT AND RULE 17A-4(J) THEREUNDER AND SECTIONS 204(A)AND 204A OF THE ADVISERS ACT.

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

No

Sanctions Ordered: CensureMonetary/Fine $5,000,000.00Cease and Desist/Injunction

Order

iReporting Source: Firm

Allegations: SEC ADMIN RELEASE 34-73175, IA RELEASE 40-3928/SEPTEMBER 22, 2014:THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATEAND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTEDPURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGEACT OF 1934 AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENTADVISERS ACT OF 1940 AGAINST WELLS FARGO ADVISORS, LLC ("WELLSFARGO ADVISORS" OR "RESPONDENT"). IN ANTICIPATION OF THEINSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED ANOFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TOACCEPT. WELLS FARGO ADVISORS ADMITS THE FINDINGS,ACKNOWLEDGES THAT ITS CONDUCT VIOLATED THE FEDERALSECURITIES LAWS, ADMITS THE COMMISSION'S JURISDICTION OVER ITAND THE SUBJECT MATTER OF THESE PROCEEDINGS, AND CONSENTS TOTHE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS. THIS CASE INVOLVES THE FAILURE OFWELLS FARGO ADVISORS TO ADEQUATELY ESTABLISH, MAINTAIN, ANDENFORCE POLICIES AND PROCEDURES REASONABLY DESIGNED TOPREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION,SPECIFICALLY, THE MATERIAL NONPUBLIC INFORMATION OBTAINED FROMITS CUSTOMERS AND ITS ADVISORY CLIENTS. WELLS FARGO ADVISORS'POLICIES AND PROCEDURES TO PREVENT THE MISUSE OF MATERIALNONPUBLIC INFORMATION WERE NOT REASONABLY DESIGNED TOADDRESS THERISK THAT ITS ASSOCIATED PERSONS COULD OBTAIN MATERIALNONPUBLIC INFORMATION FROM ITS CUSTOMERS AND ADVISORYCLIENTS EVEN THOUGH THE FIRM EXPRESSLY IDENTIFIED THAT RISK INMULTIPLE INTERNAL DOCUMENTS. THIS RISK MANIFESTED ITSELF IN 2010WHEN ONE OF THE REGISTERED REPRESENTATIVES OF WELLS FARGOADVISORS MISAPPROPRIATED INFORMATION FROM ONE OF HISCUSTOMERS ABOUT A COMPANY'S SECURITIES, TRADED ON THE BASISOF THAT INFORMATION,AND TIPPED OTHERS INCLUDING SEVERAL OF HISWELLS FARGO ADVISORS CUSTOMERS. THE MANNER IN WHICH THEPOLICIES AND PROCEDURES WERE DESIGNED AFFECTED THE COMPANYSECURITIES REVIEW. MULTIPLE UNITS WITHIN THE FIRM RECEIVEDINDICATIONS SUGGESTING THAT THE REGISTERED REPRESENTATIVEWAS MISUSING MATERIAL NONPUBLIC INFORMATION OBTAINED FROM ACUSTOMER TO TRADE IN THE COMPANY'S SECURITIES. BECAUSE OF ALACK OF ASSIGNED RESPONSIBILITY OR COORDINATION, EACH OF THESEUNITS FAILED TO TAKE NEEDED ACTIONS. THE POLICIES ANDPROCEDURES DESIGNED CAUSED RESPONDENT NOT TO RECOGNIZESEVERAL RED FLAGS THAT ITS REPRESENTATIVE WAS ENGAGING ININSIDER TRADING IN THE COMPANY'S SECURITIES. IN ADDITION THERESPONDENT DID NOT EFFECTIVELY MAINTAIN AND ENFORCE THEPOLICIES AND PROCEDURES. ADDITIONALLY, ALTHOUGH THE POLICIESAND PROCEDURES REQUIRED "DAILY REVIEW TO IDENTIFY SITUATIONSWHEN PROFIT OR AVOIDANCE OF LOSS COULD MOST LIKELY RESULTFROM TRADING PRIOR TO THE PUBLIC RELEASE OF INFORMATION," FOR ATEN MONTH PERIOD THE RETAIL CONTROL GROUP (RCG), A UNIT IN THEFIRM'S COMPLIANCE DEPARTMENT, FAILED TO PERFORM REVIEWS IN ATIMELY MANNER OF AT LEAST 40 INSTANCES OF POSSIBLE INSIDERTRADING FLAGGED FOR REVIEW.WHEN THE RESPONDENT PRODUCED DOCUMENTS, AS REQUESTED BYTHE COMMISSION,RELATING TO REVIEWS OF TRADING BY THEREGISTEREDREPRESENTATIVE WHO TRADED IN THE COMPANY'S SECURITIES, INRESPONSE TO THE COMMISSION'S REQUEST,DOCUMENTS RELATING TOTHE RCG REVIEW OF THE SECURITIES TRADING WERE NOT PRODUCED.RESPONDENT UNREASONABLY DELAYED,WITHOUT ANYEXPLANATION,FOR SIX MONTHS PRODUCING DOCUMENTS RELATING TOTHE RCG REVIEW OF THE REPRESENTATIVE WHO TRADED IN THECOMPANY'S SECURITIES. WHEN THE DOCUMENTS WERE PRODUCED, THEFIRM FAILED TO PRODUCE AN ACCURATE RECORD OF THE REVIEW AS ITEXISTED AT THE TIME OF THE REQUEST. INSTEAD, IT PRODUCED ADOCUMENT THAT HAD BEEN ALTERED BY AN EMPLOYEE. WHENQUESTIONS AROSE SURROUNDING THE ALTERED DOCUMENT, THEEMPLOYEE WAS PLACED ON ADMINISTRATIVE LEAVE AND EVENTUALLYTERMINATED. AS A RESULT, RESPONDENT WILLFULLY VIOLATEDSECTIONS 15(G), 17(A), AND 17(B) OF THE EXCHANGE ACT AND RULE 17A-4(J) THEREUNDER AND SECTIONS 204(A) AND 204A OF THE ADVISERS ACT.

Current Status: Final

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SEC ADMIN RELEASE 34-73175, IA RELEASE 40-3928/SEPTEMBER 22, 2014:THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATEAND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTEDPURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGEACT OF 1934 AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENTADVISERS ACT OF 1940 AGAINST WELLS FARGO ADVISORS, LLC ("WELLSFARGO ADVISORS" OR "RESPONDENT"). IN ANTICIPATION OF THEINSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED ANOFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TOACCEPT. WELLS FARGO ADVISORS ADMITS THE FINDINGS,ACKNOWLEDGES THAT ITS CONDUCT VIOLATED THE FEDERALSECURITIES LAWS, ADMITS THE COMMISSION'S JURISDICTION OVER ITAND THE SUBJECT MATTER OF THESE PROCEEDINGS, AND CONSENTS TOTHE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS. THIS CASE INVOLVES THE FAILURE OFWELLS FARGO ADVISORS TO ADEQUATELY ESTABLISH, MAINTAIN, ANDENFORCE POLICIES AND PROCEDURES REASONABLY DESIGNED TOPREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION,SPECIFICALLY, THE MATERIAL NONPUBLIC INFORMATION OBTAINED FROMITS CUSTOMERS AND ITS ADVISORY CLIENTS. WELLS FARGO ADVISORS'POLICIES AND PROCEDURES TO PREVENT THE MISUSE OF MATERIALNONPUBLIC INFORMATION WERE NOT REASONABLY DESIGNED TOADDRESS THERISK THAT ITS ASSOCIATED PERSONS COULD OBTAIN MATERIALNONPUBLIC INFORMATION FROM ITS CUSTOMERS AND ADVISORYCLIENTS EVEN THOUGH THE FIRM EXPRESSLY IDENTIFIED THAT RISK INMULTIPLE INTERNAL DOCUMENTS. THIS RISK MANIFESTED ITSELF IN 2010WHEN ONE OF THE REGISTERED REPRESENTATIVES OF WELLS FARGOADVISORS MISAPPROPRIATED INFORMATION FROM ONE OF HISCUSTOMERS ABOUT A COMPANY'S SECURITIES, TRADED ON THE BASISOF THAT INFORMATION,AND TIPPED OTHERS INCLUDING SEVERAL OF HISWELLS FARGO ADVISORS CUSTOMERS. THE MANNER IN WHICH THEPOLICIES AND PROCEDURES WERE DESIGNED AFFECTED THE COMPANYSECURITIES REVIEW. MULTIPLE UNITS WITHIN THE FIRM RECEIVEDINDICATIONS SUGGESTING THAT THE REGISTERED REPRESENTATIVEWAS MISUSING MATERIAL NONPUBLIC INFORMATION OBTAINED FROM ACUSTOMER TO TRADE IN THE COMPANY'S SECURITIES. BECAUSE OF ALACK OF ASSIGNED RESPONSIBILITY OR COORDINATION, EACH OF THESEUNITS FAILED TO TAKE NEEDED ACTIONS. THE POLICIES ANDPROCEDURES DESIGNED CAUSED RESPONDENT NOT TO RECOGNIZESEVERAL RED FLAGS THAT ITS REPRESENTATIVE WAS ENGAGING ININSIDER TRADING IN THE COMPANY'S SECURITIES. IN ADDITION THERESPONDENT DID NOT EFFECTIVELY MAINTAIN AND ENFORCE THEPOLICIES AND PROCEDURES. ADDITIONALLY, ALTHOUGH THE POLICIESAND PROCEDURES REQUIRED "DAILY REVIEW TO IDENTIFY SITUATIONSWHEN PROFIT OR AVOIDANCE OF LOSS COULD MOST LIKELY RESULTFROM TRADING PRIOR TO THE PUBLIC RELEASE OF INFORMATION," FOR ATEN MONTH PERIOD THE RETAIL CONTROL GROUP (RCG), A UNIT IN THEFIRM'S COMPLIANCE DEPARTMENT, FAILED TO PERFORM REVIEWS IN ATIMELY MANNER OF AT LEAST 40 INSTANCES OF POSSIBLE INSIDERTRADING FLAGGED FOR REVIEW.WHEN THE RESPONDENT PRODUCED DOCUMENTS, AS REQUESTED BYTHE COMMISSION,RELATING TO REVIEWS OF TRADING BY THEREGISTEREDREPRESENTATIVE WHO TRADED IN THE COMPANY'S SECURITIES, INRESPONSE TO THE COMMISSION'S REQUEST,DOCUMENTS RELATING TOTHE RCG REVIEW OF THE SECURITIES TRADING WERE NOT PRODUCED.RESPONDENT UNREASONABLY DELAYED,WITHOUT ANYEXPLANATION,FOR SIX MONTHS PRODUCING DOCUMENTS RELATING TOTHE RCG REVIEW OF THE REPRESENTATIVE WHO TRADED IN THECOMPANY'S SECURITIES. WHEN THE DOCUMENTS WERE PRODUCED, THEFIRM FAILED TO PRODUCE AN ACCURATE RECORD OF THE REVIEW AS ITEXISTED AT THE TIME OF THE REQUEST. INSTEAD, IT PRODUCED ADOCUMENT THAT HAD BEEN ALTERED BY AN EMPLOYEE. WHENQUESTIONS AROSE SURROUNDING THE ALTERED DOCUMENT, THEEMPLOYEE WAS PLACED ON ADMINISTRATIVE LEAVE AND EVENTUALLYTERMINATED. AS A RESULT, RESPONDENT WILLFULLY VIOLATEDSECTIONS 15(G), 17(A), AND 17(B) OF THE EXCHANGE ACT AND RULE 17A-4(J) THEREUNDER AND SECTIONS 204(A) AND 204A OF THE ADVISERS ACT.

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Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

Date Initiated: 09/22/2014

Docket/Case Number: 3-16153

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

Other Product Type(s):

SEC ADMIN RELEASE 34-73175, IA RELEASE 40-3928/SEPTEMBER 22, 2014:THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATEAND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTEDPURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGEACT OF 1934 AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENTADVISERS ACT OF 1940 AGAINST WELLS FARGO ADVISORS, LLC ("WELLSFARGO ADVISORS" OR "RESPONDENT"). IN ANTICIPATION OF THEINSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED ANOFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TOACCEPT. WELLS FARGO ADVISORS ADMITS THE FINDINGS,ACKNOWLEDGES THAT ITS CONDUCT VIOLATED THE FEDERALSECURITIES LAWS, ADMITS THE COMMISSION'S JURISDICTION OVER ITAND THE SUBJECT MATTER OF THESE PROCEEDINGS, AND CONSENTS TOTHE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS. THIS CASE INVOLVES THE FAILURE OFWELLS FARGO ADVISORS TO ADEQUATELY ESTABLISH, MAINTAIN, ANDENFORCE POLICIES AND PROCEDURES REASONABLY DESIGNED TOPREVENT THE MISUSE OF MATERIAL NONPUBLIC INFORMATION,SPECIFICALLY, THE MATERIAL NONPUBLIC INFORMATION OBTAINED FROMITS CUSTOMERS AND ITS ADVISORY CLIENTS. WELLS FARGO ADVISORS'POLICIES AND PROCEDURES TO PREVENT THE MISUSE OF MATERIALNONPUBLIC INFORMATION WERE NOT REASONABLY DESIGNED TOADDRESS THERISK THAT ITS ASSOCIATED PERSONS COULD OBTAIN MATERIALNONPUBLIC INFORMATION FROM ITS CUSTOMERS AND ADVISORYCLIENTS EVEN THOUGH THE FIRM EXPRESSLY IDENTIFIED THAT RISK INMULTIPLE INTERNAL DOCUMENTS. THIS RISK MANIFESTED ITSELF IN 2010WHEN ONE OF THE REGISTERED REPRESENTATIVES OF WELLS FARGOADVISORS MISAPPROPRIATED INFORMATION FROM ONE OF HISCUSTOMERS ABOUT A COMPANY'S SECURITIES, TRADED ON THE BASISOF THAT INFORMATION,AND TIPPED OTHERS INCLUDING SEVERAL OF HISWELLS FARGO ADVISORS CUSTOMERS. THE MANNER IN WHICH THEPOLICIES AND PROCEDURES WERE DESIGNED AFFECTED THE COMPANYSECURITIES REVIEW. MULTIPLE UNITS WITHIN THE FIRM RECEIVEDINDICATIONS SUGGESTING THAT THE REGISTERED REPRESENTATIVEWAS MISUSING MATERIAL NONPUBLIC INFORMATION OBTAINED FROM ACUSTOMER TO TRADE IN THE COMPANY'S SECURITIES. BECAUSE OF ALACK OF ASSIGNED RESPONSIBILITY OR COORDINATION, EACH OF THESEUNITS FAILED TO TAKE NEEDED ACTIONS. THE POLICIES ANDPROCEDURES DESIGNED CAUSED RESPONDENT NOT TO RECOGNIZESEVERAL RED FLAGS THAT ITS REPRESENTATIVE WAS ENGAGING ININSIDER TRADING IN THE COMPANY'S SECURITIES. IN ADDITION THERESPONDENT DID NOT EFFECTIVELY MAINTAIN AND ENFORCE THEPOLICIES AND PROCEDURES. ADDITIONALLY, ALTHOUGH THE POLICIESAND PROCEDURES REQUIRED "DAILY REVIEW TO IDENTIFY SITUATIONSWHEN PROFIT OR AVOIDANCE OF LOSS COULD MOST LIKELY RESULTFROM TRADING PRIOR TO THE PUBLIC RELEASE OF INFORMATION," FOR ATEN MONTH PERIOD THE RETAIL CONTROL GROUP (RCG), A UNIT IN THEFIRM'S COMPLIANCE DEPARTMENT, FAILED TO PERFORM REVIEWS IN ATIMELY MANNER OF AT LEAST 40 INSTANCES OF POSSIBLE INSIDERTRADING FLAGGED FOR REVIEW.WHEN THE RESPONDENT PRODUCED DOCUMENTS, AS REQUESTED BYTHE COMMISSION,RELATING TO REVIEWS OF TRADING BY THEREGISTEREDREPRESENTATIVE WHO TRADED IN THE COMPANY'S SECURITIES, INRESPONSE TO THE COMMISSION'S REQUEST,DOCUMENTS RELATING TOTHE RCG REVIEW OF THE SECURITIES TRADING WERE NOT PRODUCED.RESPONDENT UNREASONABLY DELAYED,WITHOUT ANYEXPLANATION,FOR SIX MONTHS PRODUCING DOCUMENTS RELATING TOTHE RCG REVIEW OF THE REPRESENTATIVE WHO TRADED IN THECOMPANY'S SECURITIES. WHEN THE DOCUMENTS WERE PRODUCED, THEFIRM FAILED TO PRODUCE AN ACCURATE RECORD OF THE REVIEW AS ITEXISTED AT THE TIME OF THE REQUEST. INSTEAD, IT PRODUCED ADOCUMENT THAT HAD BEEN ALTERED BY AN EMPLOYEE. WHENQUESTIONS AROSE SURROUNDING THE ALTERED DOCUMENT, THEEMPLOYEE WAS PLACED ON ADMINISTRATIVE LEAVE AND EVENTUALLYTERMINATED. AS A RESULT, RESPONDENT WILLFULLY VIOLATEDSECTIONS 15(G), 17(A), AND 17(B) OF THE EXCHANGE ACT AND RULE 17A-4(J) THEREUNDER AND SECTIONS 204(A) AND 204A OF THE ADVISERS ACT.

Resolution Date: 09/22/2014

Resolution:

Other Sanctions Ordered:

Sanction Details: RESPONDENT CEASE AND DESIST FROM COMMITTING OR CAUSING ANYVIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 15(G), 17(A), AND17(B) OF THE EXCHANGE ACT AND RULE 17A-4(J) PROMULGATEDTHEREUNDER AND SECTIONS 204A AND 204(A) OF THE ADVISERS ACT.RESPONDENT IS CENSURED. RESPONDENT SHALL, WITHIN 10 DAYS OFTHE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNTOF $5,000,000. WILLFULLY VIOLATED SECTIONS 15(G), 17(A), AND 17(B) OFTHE EXCHANGE ACT AND RULE 17A-4(J) THEREUNDER AND SECTIONS204(A) AND 204A OF THE ADVISERS ACT.

Sanctions Ordered: CensureMonetary/Fine $5,000,000.00Cease and Desist/Injunction

Order

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Sanction Details: RESPONDENT CEASE AND DESIST FROM COMMITTING OR CAUSING ANYVIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 15(G), 17(A), AND17(B) OF THE EXCHANGE ACT AND RULE 17A-4(J) PROMULGATEDTHEREUNDER AND SECTIONS 204A AND 204(A) OF THE ADVISERS ACT.RESPONDENT IS CENSURED. RESPONDENT SHALL, WITHIN 10 DAYS OFTHE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNTOF $5,000,000. WILLFULLY VIOLATED SECTIONS 15(G), 17(A), AND 17(B) OFTHE EXCHANGE ACT AND RULE 17A-4(J) THEREUNDER AND SECTIONS204(A) AND 204A OF THE ADVISERS ACT.

Firm Statement SEE SANCTION DETAILS IN 12.B.

Disclosure 23 of 158

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Reporting Source: Regulator

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Date Initiated: 06/02/2014

Docket/Case Number: 2010023976502

Principal Product Type: Other

Other Product Type(s): UNSPECIFIED SECURITIES

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT, THROUGH AREGISTERED REPRESENTATIVE, DISSEMINATED SALES LITERATURE TOFIRM CUSTOMERS AND POTENTIAL CUSTOMERS THAT FAILED TO COMPLYWITH THE CONTENT STANDARDS OF NASD RULE 2210(D)(1). THE FINDINGSSTATED THAT THE FIRM APPROVED THREE ITERATIONS OF THE SALESLITERATURE, WHICH MARKETED THE REGISTERED REPRESENTATIVE'SSTOP-LOSS TRADING STRATEGY. THERE WERE NO SIGNIFICANTDIFFERENCES BETWEEN THE THREE VERSIONS OF THE ADVERTISEMENT.THE SALES LITERATURE CONTAINED UNWARRANTED STATEMENTS ANDCLAIMS AND FAILED TO PROVIDE A SOUND BASIS FOR EVALUATING ALL OFTHE FACTS ABOUT THE TRADING STRATEGY. IT FAILED TO PROVIDE ACOMPREHENSIVE DESCRIPTION OF THE STOP-LOSS TRADING STRATEGYBECAUSE IT FAILED TO DESCRIBE THE MECHANICS OF THE STRATEGYAND PROVIDE A BALANCED DISCUSSION OF THE BENEFITS ANDSHORTCOMINGS OF THE STRATEGY, AND THE ILLUSTRATION OF THEHYPOTHETICAL INVESTMENT INCLUDED IN THE SALES LITERATUREFAILED TO PROVIDE A COMPREHENSIVE DESCRIPTION OF THEINVESTMENT RETURNS.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Resolution Date: 06/02/2014

Resolution:

Other Sanctions Ordered:

Sanction Details: SEE ABOVE

Regulator Statement FINE PAID JUNE 12, 2014

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

No

Sanctions Ordered: CensureMonetary/Fine $25,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 06/02/2014

Docket/Case Number: 2010023976502

Principal Product Type: Other

Other Product Type(s): ETF

Allegations: WELLS FARGO ADVISORS, LLC ("WFA") IS THE SUCCESSOR TO WELLSFARGO INVESTMENTS, LLC ("WFI") (CRD-10582). THE ALLEGATIONSSOLELY INVOLVE WFI'S DISSEMINATION OF SALES LITERATURE THATFAILED TO CONFORM TO THE CONTENT STANDARDS OF NASD RULE2210 AND FINRA RULE 2010.

Current Status: Final

Resolution: Acceptance, Waiver & Consent(AWC) 86©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Resolution Date: 06/02/2014

Resolution:

Other Sanctions Ordered:

Sanction Details: WELLS FARGO ADVISORS, LLC ("WFA") IS THE SUCCESSOR TO WELLSFARGO INVESTMENTS, LLC ("WFI") (CRD-10582). THE ALLEGATIONS SOLEYINVOLVE WFI'S DISSEMINATION OF SALES LITERATURE THAT FAILED TOCONFORM TO THE CONTENT STANDARDS OF NASD RULE 2210 AND FINRA2010. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRMTHROUGH ITS SUCCESSOR CONSENTED TO A CENSURE AND $25,000MONETARY FINE. THE FIRM SENT PAYMENT TO FINRA ON OR ABOUT JUNE11, 2014. FINE PAID JUNE 12, 2014

Sanctions Ordered: CensureMonetary/Fine $25,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 24 of 158

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Reporting Source: Regulator

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 07/15/2014

Docket/Case Number: 2012033330501

Principal Product Type: Other

Other Product Type(s): AGENCY BONDS

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT SOLDAGENCY BONDS TO ITS CUSTOMERS AND FAILED TO BUY OR SELL SUCHBONDS AT A PRICE THAT WAS FAIR, TAKING INTO CONSIDERATION ALLRELEVANT CIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITHRESPECT TO EACH AT THE TIME OF THE TRANSACTION, THE EXPENSEINVOLVED AND THAT THE FIRM WAS ENTITLED TO A PROFIT.

Current Status: Final

Resolution Date: 07/15/2014

Resolution:

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

No

Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered: ORDERED TO PAY RESTITUTION TO FIRM CUSTOMERS IN THE AMOUNT OF$5,032.12, PLUS INTEREST

Sanction Details: SEE ABOVE

Regulator Statement FINE PAID IN FULL ON JULY 31, 2014.

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

No

Sanctions Ordered: CensureMonetary/Fine $10,000.00Disgorgement/Restitution

iReporting Source: Firm

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 07/15/2014

Docket/Case Number: 2012033330501

Principal Product Type: Other

Other Product Type(s): AGENCY BONDS

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OFFINDINGS THAT IT SOLD AGENCY BONDS TO ITS CUSTOMERS AND FAILEDTO BUY OR SELL SUCH BONDS AT A PRICETHAT WAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANTCIRCUMSTANCES, INCLUDING MARKET CONDITIONSWITH RESPECT TO EACH AT THE TIME OF THE TRANSACTION, THEEXPENSE INVOLVED AND THAT THE FIRM WASENTITLED TO A PROFIT.

Current Status: Final

Resolution Date: 07/15/2014

Resolution: Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered: ORDERED TO PAY RESTITUTION TO FIRM CUSTOMERS IN THE AMOUNT OF$5,032.12, PLUS INTEREST

Sanction Details: SEE ABOVE

Sanctions Ordered: CensureMonetary/Fine $10,000.00Disgorgement/Restitution

Disclosure 25 of 158

i

Reporting Source: Regulator

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 12/23/2013

Docket/Case Number: 2009020171701

Principal Product Type: Debt - Municipal

Other Product Type(s): AGENCY BONDS

Allegations: FINRA RULE 2010, MSRB RULES G-17, G-30(A) - WELLS FARGO ADVISORS,LLC BOUGHT OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNTFROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES TOCUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANY MARKUP ORMARKDOWN) THAT WAS NOT FAIR AND REASONABLE, TAKING INTOCONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BESTJUDGMENT OF THE BROKER, DEALER, OR MUNICIPAL SECURITIESDEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIMEOF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADEDIN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED INEFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER,OR MUNICIPAL SECURITIES IS ENTITLED TO A PROFIT, AND THE TOTALDOLLAR AMOUNT OF THE TRANSACTION. THE FIRM SOLD AGENCY BONDSTO ITS CUSTOMERS AND FAILED TO SELL SUCH BONDS AT A PRICE THATWAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANTCIRCUMSTANCES, INCLUDINGMARKET CONDITIONS WITH RESPECT TO EACH AT THE TIME OF THETRANSACTION, THE EXPENSE INVOLVED, AND THAT THE FIRM WASENTITLED TO A PROFIT.

Current Status: Final

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Resolution Date: 12/23/2013

Resolution:

Other Sanctions Ordered:

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 $20,000, OF WHICH $10,000IS FOR MSRB RULE VIOLATIONS, AND ORDERED TO PAY $8,660.93, PLUSINTEREST, IN RESTITUTION TO CUSTOMERS. THE FIRM HAS ALREADY PAIDFULL OR PARTIAL RESTITUTION FOR SEVERAL OF THE TRANSACTIONS. AREGISTERED FIRM PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OFPAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTEDEFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATERTHAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. THE FIRM SHALLFORWARD ANY UNDISTRIBUTED RESTITUTION AND INTEREST TO THEAPPROPRIATE ESCHEAT, UNCLAIMED-PROPERTY OR ABANDONED-PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS KNOWN TOHAVE LAST RESIDED. FINE PAID IN FULL ON JANUARY 8, 2014.

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

No

Sanctions Ordered: CensureMonetary/Fine $20,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Allegations: FINRA RULE 2010, MSRB RULES G-17, G-30(A) - WELLS FARGO ADVISORS,LLC BOUGHT OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNTFROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES TOCUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANY MARKUP ORMARKDOWN) THAT WAS NOT FAIR AND REASONABLE, TAKING INTOCONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BESTJUDGMENT OF THE BROKER, DEALER, OR MUNICIPAL SECURITIESDEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIMEOF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADEDIN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED INEFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER,OR MUNICIPAL SECURITIES IS ENTITLED TO A PROFIT, AND THE TOTALDOLLAR AMOUNT OF THE TRANSACTION. THE FIRM SOLD AGENCY BONDSTO ITS CUSTOMERS AND FAILED TO SELL SUCH BONDS AT A PRICE THATWAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANTCIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TOEACH AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVED, ANDTHAT THE FIRM WAS ENTITLED TO A PROFIT.

Current Status: Final

90©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 12/23/2013

Docket/Case Number: 2009020171701

Principal Product Type: Debt - Municipal

Other Product Type(s): AGENCY BONDS

FINRA RULE 2010, MSRB RULES G-17, G-30(A) - WELLS FARGO ADVISORS,LLC BOUGHT OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNTFROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES TOCUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANY MARKUP ORMARKDOWN) THAT WAS NOT FAIR AND REASONABLE, TAKING INTOCONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BESTJUDGMENT OF THE BROKER, DEALER, OR MUNICIPAL SECURITIESDEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIMEOF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADEDIN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED INEFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER,OR MUNICIPAL SECURITIES IS ENTITLED TO A PROFIT, AND THE TOTALDOLLAR AMOUNT OF THE TRANSACTION. THE FIRM SOLD AGENCY BONDSTO ITS CUSTOMERS AND FAILED TO SELL SUCH BONDS AT A PRICE THATWAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANTCIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TOEACH AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVED, ANDTHAT THE FIRM WAS ENTITLED TO A PROFIT.

Resolution Date: 12/23/2013

Resolution:

Other Sanctions Ordered:

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 $20,000, OF WHICH $10,000IS FOR MSRB RULE VIOLATIONS, AND ORDERED TO PAY $8,660.93, PLUSINTEREST, IN RESTITUTION TO CUSTOMERS. THE FIRM HAS ALREADY PAIDFULL OR PARTIAL RESTITUTION FOR SEVERAL OF THE TRANSACTIONS. AREGISTERED FIRM PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OFPAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTEDEFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATERTHAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. THE FIRM SHALLFORWARD ANY UNDISTRIBUTED RESTITUTION AND INTEREST TO THEAPPROPRIATE ESCHEAT, UNCLAIMED-PROPERTY OR ABANDONED-PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS KNOWN TOHAVE LAST RESIDED. FINE PAID IN FULL ON JANUARY 8, 2014.

Sanctions Ordered: CensureMonetary/Fine $20,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

Disclosure 26 of 158

i

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Disclosure 26 of 158

Reporting Source: Regulator

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 11/18/2013

Docket/Case Number: 2011028036801

Principal Product Type: Equity - OTC

Other Product Type(s):

Allegations: FINRA RULE 2010, NASD INTERPRETATIVE MATERIAL 2110-2 - WELLSFARGO ADVISORS,LLC FAILED TO CONTEMPORANEOUSLY EXECUTECUSTOMER LIMIT ORDERS IN OVER-THE-COUNTER (OTC) SECURITIESAFTER IT TRADED EACH SUBJECT SECURITY FOR ITS OWN MARKET-MAKING ACCOUNT AT A PRICE THAT WOULD HAVE SATISFIED EACHCUSTOMER'S LIMIT ORDER.

Current Status: Final

Resolution Date: 11/18/2013

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS FINED $5,000. THE FIRM HAS ALREADY MADERESTITUTION TO THE CUSTOMERS WHO RECEIVED INFERIOR PRICES ASA RESULT OF THESE VIOLATIONS.

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

No

Sanctions Ordered: Monetary/Fine $5,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

92©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 95: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 11/18/2013

Docket/Case Number: 2011028036801

Principal Product Type: Equity - OTC

Other Product Type(s):

Allegations: FINRA RULE 2010, NASD INTERPRETATIVE MATERIAL 2110-2 - WELLSFARGO ADVISORS,LLC FAILED TO CONTEMPORANEOUSLY EXECUTECUSTOMER LIMIT ORDERS IN OVER-THE-COUNTER (OTC) SECURITIESAFTER IT TRADED EACH SUBJECT SECURITY FOR ITS OWN MARKET-MAKING ACCOUNT AT A PRICE THAT WOULD HAVE SATISFIED EACHCUSTOMER'S LIMIT ORDER.

Current Status: Final

Resolution Date: 11/18/2013

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS FINED $5,000.

Sanctions Ordered: Monetary/Fine $5,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 27 of 158

i

Reporting Source: Regulator

Allegations: FINRA RULE 2010, NASD RULES 3010 AND 3012(A)(2)(B)(I):WELLS FARGO'S SUPERVISORY CONTROL SYSTEM FAILED TO INCLUDE APOLICY OR PROCEDURE REQUIRING A REVIEW TO DETECT OR PREVENTMULTIPLE TRANSMITTALS OF FUNDS FROM MULTIPLE CUSTOMERS GOINGTO THE SAME THIRD PARTY ACCOUNTS. THE FIRM'S SYSTEM ALSO FAILEDTO INCLUDE EXCEPTION REPORTS THAT WOULD HAVE IDENTIFIEDMULTIPLE CUSTOMER WIRES GOING TO THE SAME THIRD PARTYACCOUNT. CONSEQUENTLY, WELLS FARGO FAILED TO DETECT THAT AREGISTERED REPRESENTATIVE HAD INITIATED FUND TRANSFERS,TOTALING APPROXIMATELY $258,000, OUT OF TWO CUSTOMERACCOUNTS, TO BANK ACCOUNTS THAT SHE OR HER FAMILY MEMBERAPPARENTLY CONTROLLED.WELLS FARGO FAILED TO ESTABLISH, MAINTAIN AND ENFORCE ASUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TOADEQUATELY REVIEW AND MONITOR THE TRANSMITTALS OF FUNDSFROM THE ACCOUNTS OF CUSTOMERS TO THIRD PARTY ACCOUNTS ANDOUTSIDE ENTITIES.

Current Status: Final

93©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 09/12/2013

Docket/Case Number: 2012031047501

Principal Product Type: No Product

Other Product Type(s):

FINRA RULE 2010, NASD RULES 3010 AND 3012(A)(2)(B)(I):WELLS FARGO'S SUPERVISORY CONTROL SYSTEM FAILED TO INCLUDE APOLICY OR PROCEDURE REQUIRING A REVIEW TO DETECT OR PREVENTMULTIPLE TRANSMITTALS OF FUNDS FROM MULTIPLE CUSTOMERS GOINGTO THE SAME THIRD PARTY ACCOUNTS. THE FIRM'S SYSTEM ALSO FAILEDTO INCLUDE EXCEPTION REPORTS THAT WOULD HAVE IDENTIFIEDMULTIPLE CUSTOMER WIRES GOING TO THE SAME THIRD PARTYACCOUNT. CONSEQUENTLY, WELLS FARGO FAILED TO DETECT THAT AREGISTERED REPRESENTATIVE HAD INITIATED FUND TRANSFERS,TOTALING APPROXIMATELY $258,000, OUT OF TWO CUSTOMERACCOUNTS, TO BANK ACCOUNTS THAT SHE OR HER FAMILY MEMBERAPPARENTLY CONTROLLED.WELLS FARGO FAILED TO ESTABLISH, MAINTAIN AND ENFORCE ASUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TOADEQUATELY REVIEW AND MONITOR THE TRANSMITTALS OF FUNDSFROM THE ACCOUNTS OF CUSTOMERS TO THIRD PARTY ACCOUNTS ANDOUTSIDE ENTITIES.

Resolution Date: 09/12/2013

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE IT IS CENSURED AND FINED $150,000. FINE PAID IN FULL ONSEPTEMBER 27, 2013.

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

No

Sanctions Ordered: CensureMonetary/Fine $150,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Allegations: FINRA RULE 2010, NASD RULES 3010 AND 3012(A)(2)(B)(I): WELLS FARGO'SSUPERVISORY CONTROL SYSTEM FAILED TO INCLUDE A POLICY ORPROCEDURE REQUIRING A REVIEW TO DETECT OR PREVENT MULTIPLETRANSMITTALS OF FUNDS FROM MULTIPLE CUSTOMERS GOING TO THESAME THIRD PARTY ACCOUNTS. THE FIRM'S SYSTEM ALSO FAILED TOINCLUDE EXCEPTION REPORTS THAT WOULD HAVE IDENTIFIED MULTIPLECUSTOMER WIRES GOING TO THE SAME THIRD PARTY ACCOUNT.CONSEQUENTLY, WELLS FARGO FAILED TO DETECT THAT A REGISTEREDREPRESENTATIVE HAD INITIATED FUND TRANSFERS, TOTALINGAPPROXIMATELY $258,000, OUT OF TWO CUSTOMER ACCOUNTS, TO BANKACCOUNTS THAT SHE OR HER FAMILY MEMBER APPARENTLYCONTROLLED. WELLS FARGO FAILED TO ESTABLISH, MAINTAIN ANDENFORCE A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNEDTO ADEQUATELY REVIEW AND MONITOR THE TRANSMITTALS OF FUNDSFROM THE ACCOUNTS OF CUSTOMERS TO THIRD PARTY ACCOUNTS ANDOUTSIDE ENTITIES.

Current Status: Final

94©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 09/12/2013

Docket/Case Number: 2012031047501

Principal Product Type: No Product

Other Product Type(s):

Allegations: FINRA RULE 2010, NASD RULES 3010 AND 3012(A)(2)(B)(I): WELLS FARGO'SSUPERVISORY CONTROL SYSTEM FAILED TO INCLUDE A POLICY ORPROCEDURE REQUIRING A REVIEW TO DETECT OR PREVENT MULTIPLETRANSMITTALS OF FUNDS FROM MULTIPLE CUSTOMERS GOING TO THESAME THIRD PARTY ACCOUNTS. THE FIRM'S SYSTEM ALSO FAILED TOINCLUDE EXCEPTION REPORTS THAT WOULD HAVE IDENTIFIED MULTIPLECUSTOMER WIRES GOING TO THE SAME THIRD PARTY ACCOUNT.CONSEQUENTLY, WELLS FARGO FAILED TO DETECT THAT A REGISTEREDREPRESENTATIVE HAD INITIATED FUND TRANSFERS, TOTALINGAPPROXIMATELY $258,000, OUT OF TWO CUSTOMER ACCOUNTS, TO BANKACCOUNTS THAT SHE OR HER FAMILY MEMBER APPARENTLYCONTROLLED. WELLS FARGO FAILED TO ESTABLISH, MAINTAIN ANDENFORCE A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNEDTO ADEQUATELY REVIEW AND MONITOR THE TRANSMITTALS OF FUNDSFROM THE ACCOUNTS OF CUSTOMERS TO THIRD PARTY ACCOUNTS ANDOUTSIDE ENTITIES.

Resolution Date: 09/12/2013

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE IT IS CENSURED AND FINED $150,000. WELLS FARGOADVISORS, LLC FULLY COMPENSATED THE AFFECTED CLIENTS, ANDREPORTED THIS MATTER TO REGULATORS. THE FIRM ALSO REPORTEDTHE MATTER TO LAW ENFORCEMENT AND HAS COOPERATED WITH THEIREFFORTS TO RESOLVE THIS MATTER."

Sanctions Ordered: CensureMonetary/Fine $150,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 28 of 158

i95©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Disclosure 28 of 158

Reporting Source: Regulator

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 07/02/2013

Docket/Case Number: 2011026083001

Principal Product Type: Other

Other Product Type(s): AGENCY SECURITIES

Allegations: FINRA RULE 2010: IN 25 TRANSACTIONS, THE FIRM PURCHASED AGENCYSECURITIES FOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLDAGENCY SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER IN THECOURSE OF ITS BUSINESS AT AN AGGREGATE PRICE THAT WAS NOT FAIRAND REASONABLE, AND IN SO DOING FAILED TO OBSERVE HIGHSTANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLEPRINCIPLES OF TRADE.

Current Status: Final

Resolution Date: 07/02/2013

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, IT IS CENSURED, FINED $35,000 AND ORDERED TO PAY$17,384.81, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. AREGISTERED FIRM PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OFPAYMENT OF THE RESTITUTION, OR OF REASONABLE AND DOCUMENTEDEFFORTS UNDERTAKEN TO EFFECT RESTITUTION, TO FINRA NO LATERTHAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. ANY UNDISTRIBUTEDRESTITUTION AND INTEREST SHALL BE FORWARDED TO THEAPPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED.

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

No

Sanctions Ordered: CensureMonetary/Fine $35,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

96©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, IT IS CENSURED, FINED $35,000 AND ORDERED TO PAY$17,384.81, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. AREGISTERED FIRM PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OFPAYMENT OF THE RESTITUTION, OR OF REASONABLE AND DOCUMENTEDEFFORTS UNDERTAKEN TO EFFECT RESTITUTION, TO FINRA NO LATERTHAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. ANY UNDISTRIBUTEDRESTITUTION AND INTEREST SHALL BE FORWARDED TO THEAPPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED.

iReporting Source: Firm

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 07/02/2013

Docket/Case Number: 2011026083001

Principal Product Type: Other

Other Product Type(s): AGENCY SECURITIES

Allegations: WELLS FARGO ADVISORS, LLC IS THE SUCCESSOR OF WELLS FARGOINVESTMENTS. THE ALLEGATIONS RELATE SOLEY TO WELLS FARGOINVESTMENTS, LLC (CRD-10582)AND TRANSACTIONS AFFECTED BY IT,PRIOR TO JANUARY 2011, WHEN IT CEASED DOING BUSINESS. FINRA RULE2010: IN 25 TRANSACTIONS, THE FIRM PURCHASED AGENCY SECURITIESFOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD AGENCYSECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER IN THE COURSE OFITS BUSINESS AT AN AGGREGATE PRICE THAT WAS NOT FAIR ANDREASONABLE, AND IN SO DOING FAILED TO OBSERVE HIGH STANDARDSOF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OFTRADE.

Current Status: Final

Resolution Date: 07/02/2013

Resolution:

Other Sanctions Ordered:

Sanction Details: WELLS FARGO ADVISORS, LLC IS THE SUCCESSOR OF WELLS FARGOINVESTMENTS. THE ALLEGATIONS RELATE SOLEY TO WELLS FARGOINVESTMENTS, LLC (CRD-10582)AND TRANSACTIONS AFFECTED BY IT,PRIOR TO JANUARY 2011, WHEN IT CEASED DOING BUSINESS. WITHOUTADMITTING OR DENYING THE FINDINGS, THE FIRM THROUGH ITSSUCCESSOR CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS; THEREFORE, IT IS CENSURED, FINED $35,000 ANDORDERED TO PAY $17,384.81, PLUS INTEREST, IN RESTITUTION TOCUSTOMERS. A REGISTERED FIRM PRINCIPAL SHALL SUBMITSATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OFREASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECTRESTITUTION, TO FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCEOF THIS AWC. ANY UNDISTRIBUTED RESTITUTION AND INTEREST SHALLBE FORWARDED TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTYOR ABANDONED PROPERTY FUND FOR THE STATE IN WHICH THECUSTOMER LAST RESIDED.

Sanctions Ordered: CensureMonetary/Fine $35,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

97©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Sanction Details: WELLS FARGO ADVISORS, LLC IS THE SUCCESSOR OF WELLS FARGOINVESTMENTS. THE ALLEGATIONS RELATE SOLEY TO WELLS FARGOINVESTMENTS, LLC (CRD-10582)AND TRANSACTIONS AFFECTED BY IT,PRIOR TO JANUARY 2011, WHEN IT CEASED DOING BUSINESS. WITHOUTADMITTING OR DENYING THE FINDINGS, THE FIRM THROUGH ITSSUCCESSOR CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS; THEREFORE, IT IS CENSURED, FINED $35,000 ANDORDERED TO PAY $17,384.81, PLUS INTEREST, IN RESTITUTION TOCUSTOMERS. A REGISTERED FIRM PRINCIPAL SHALL SUBMITSATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OFREASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECTRESTITUTION, TO FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCEOF THIS AWC. ANY UNDISTRIBUTED RESTITUTION AND INTEREST SHALLBE FORWARDED TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTYOR ABANDONED PROPERTY FUND FOR THE STATE IN WHICH THECUSTOMER LAST RESIDED.

Disclosure 29 of 158

i

Reporting Source: Regulator

Allegations: THIS ACTION RELATES TO CONDUCT THAT OCCURRED AT WELLS FARGOINVESTMENTS, LLC (CRD #10582). WELLS FARGO ADVISORS, LLC ISNAMED AS A RESPONDENT SOLELY AS SUCCESSOR IN LIABILITY FORWELLS FARGO INVESTMENTS, LLC. FINRA RULE 2010, NASD RULES 2110,2310, 3010: WELLS FARGO INVESTMENTS REGISTERED REPRESENTATIVESMADE RECOMMENDATIONS TO CUSTOMERS TO PURCHASE FLOATINGRATE LOAN FUNDS THAT WERE UNSUITABLE FOR THOSE CUSTOMERS INLIGHT OF THEIR FINANCIAL SITUATIONS AND NEEDS. IN PARTICULAR,WELLS FARGO INVESTMENTS MADE NUMEROUS RECOMMENDATIONS TOCUSTOMERS WHOSE RISK TOLERANCES AND INVESTMENT OBJECTIVESWERE INCONSISTENT WITH THE RISKS AND FEATURES OF FLOATING RATELOAN FUNDS. THE FLOATING RATE LOAN FUNDS SOLD BY WELLS FARGOINVESTMENTS WERE SUBJECT TO SIGNIFICANT CREDIT AND LIQUIDITYRISKS. ACCORDINGLY, THE FUNDS WERE NOT TYPICALLY SUITABLE FORINVESTORS WITH AN INVESTMENT OBJECTIVE OF INCOME AND ACONSERVATIVE RISK TOLERANCE OR THOSE CUSTOMERS WHO WERESEEKING TO PRESERVE PRINCIPAL, PARTICULARLY WHEN THOSECUSTOMERS' PURCHASES CONSTITUTED A LARGE PERCENTAGE OFTHEIR INVESTIBLE ASSETS OR LIQUID NET WORTH. MOREOVER,FLOATING RATE LOAN FUNDS, PARTICULARLY THOSE WITH RESTRICTIVEREDEMPTION POLICIES, WERE NOT TYPICALLY SUITABLE FOR INVESTORSWITH SHORT INVESTMENT TIME HORIZONS. IN SPITE OF THESEFEATURES OF FLOATING RATE FUNDS, WELLS FARGO INVESTMENTSRECOMMENDED FLOATING RATE FUND INVESTMENTS TO HUNDREDS OFCUSTOMERS FOR WHOM THE INVESTMENT WAS UNSUITABLE IN LIGHT OFTHE CUSTOMERS' FINANCIAL SITUATIONS, RISK TOLERANCES, ANDINVESTMENT OBJECTIVES. BETWEEN 2007 AND EARLY 2009, THE NETASSET VALUE OF THE TYPICAL FLOATING RATE LOAN FUNDS DECLINEDSUBSTANTIALLY. SINCE THAT TIME, THE NET ASSET VALUE OF THETYPICAL FLOATING RATE LOAN FUND HAS PARTIALLY RECOVERED.HOWEVER, MANY WELLS FARGO INVESTMENTS CUSTOMERS FOR WHOMA FLOATING RATE LOAN FUND WAS UNSUITABLE SOLD THEIR HOLDINGSIN FLOATING RATE LOAN FUNDS AND INCURRED NET LOSSES. WELLSFARGO INVESTMENTS CUSTOMERS SUFFERED LOSSES IN THE TOTALAMOUNT OF $1,962,000 AS A RESULT OF UNSUITABLE TRANSACTIONS INFLOATING RATE LOAN FUNDS RECOMMENDED BY THE FIRM. WELLSFARGO INVESTMENTS FAILED TO ESTABLISH AND MAINTAIN A SYSTEMFOR SUPERVISING ITS SALES OF FLOATING RATE LOAN FUNDS THAT WASREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE SUITABILITYREQUIREMENTS OF NASD AND FINRA RULES. WELLS FARGOINVESTMENTS SOLD BILLIONS OF DOLLARS OF FLOATING RATE LOANFUNDS TO ITS CUSTOMERS. THOSE SALES WERE A SIGNIFICANT PART OFWELLS FARGO INVESTMENTS' MUTUAL FUND BUSINESS. BY AUGUST 2007,FLOATING RATE LOAN FUNDS CONSTITUTED APPROXIMATELY 16PERCENT OF THE FIRM'S TOTAL MUTUAL FUNDS SALES. DESPITE THIS,WELLS FARGO INVESTMENTS FAILED TO PROVIDE SUFFICIENT GUIDANCETO REGISTERED REPRESENTATIVES OR SUPERVISORS TO DETERMINEWHETHER FLOATING RATE LOAN FUNDS WERE SUITABLE FOR ITSCLIENTS. WELLS FARGO INVESTMENTS ALSO FAILED TO ADEQUATELYTRAIN ITS REGISTERED PERSONS ABOUT THE CREDIT AND LIQUIDITYRISKS ASSOCIATED WITH FLOATING RATE FUNDS, OR THE CUSTOMERSFOR WHOM SUCH FUNDS WOULD BE SUITABLE. WELLS FARGOINVESTMENTS FAILED TO IMPLEMENT PROCEDURES REASONABLYDESIGNED TO ENSURE THAT ITS SALES OF FLOATING RATE LOAN FUNDSWERE SUITABLE FOR ITS CUSTOMERS EVEN AFTER POTENTIALCONCERNS WERE RAISED INTERNALLY ABOUT THOSE SALES. THE FIRM'SMUTUAL FUND PRODUCT TEAM CONDUCTED A REVIEW OF FLOATINGRATE LOAN FUNDS IN 2007 AND RECOMMENDED THAT WELLS FARGOINVESTMENTS REMIND SELLING REPRESENTATIVES THAT THE FUNDSSHOULD BE PART OF AN OVERALL ASSET ALLOCATION STRATEGY ANDNOT SOLD AS A HIGH YIELDING ALTERNATIVE TO MONEY MARKET FUNDS.THE TEAM ALSO PREPARED A PRESENTATION WHICH INCLUDEDGUIDANCE REGARDING CUSTOMERS FOR WHOM FLOATING RATE LOANFUNDS MIGHT BE SUITABLE. HOWEVER, WELLS FARGO INVESTMENTSFAILED TO ADEQUATELY DISTRIBUTE THIS INFORMATION TO REGISTEREDREPRESENTATIVES OR TAKE ACTION TO ENSURE THAT THE PRODUCTTEAM'S CONCERNS WERE TAKEN INTO ACCOUNT WHEN FLOATING RATELOAN FUND PURCHASES WERE RECOMMENDED TO CUSTOMERS.

Current Status: Final

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Initiated By: FINRA

THIS ACTION RELATES TO CONDUCT THAT OCCURRED AT WELLS FARGOINVESTMENTS, LLC (CRD #10582). WELLS FARGO ADVISORS, LLC ISNAMED AS A RESPONDENT SOLELY AS SUCCESSOR IN LIABILITY FORWELLS FARGO INVESTMENTS, LLC. FINRA RULE 2010, NASD RULES 2110,2310, 3010: WELLS FARGO INVESTMENTS REGISTERED REPRESENTATIVESMADE RECOMMENDATIONS TO CUSTOMERS TO PURCHASE FLOATINGRATE LOAN FUNDS THAT WERE UNSUITABLE FOR THOSE CUSTOMERS INLIGHT OF THEIR FINANCIAL SITUATIONS AND NEEDS. IN PARTICULAR,WELLS FARGO INVESTMENTS MADE NUMEROUS RECOMMENDATIONS TOCUSTOMERS WHOSE RISK TOLERANCES AND INVESTMENT OBJECTIVESWERE INCONSISTENT WITH THE RISKS AND FEATURES OF FLOATING RATELOAN FUNDS. THE FLOATING RATE LOAN FUNDS SOLD BY WELLS FARGOINVESTMENTS WERE SUBJECT TO SIGNIFICANT CREDIT AND LIQUIDITYRISKS. ACCORDINGLY, THE FUNDS WERE NOT TYPICALLY SUITABLE FORINVESTORS WITH AN INVESTMENT OBJECTIVE OF INCOME AND ACONSERVATIVE RISK TOLERANCE OR THOSE CUSTOMERS WHO WERESEEKING TO PRESERVE PRINCIPAL, PARTICULARLY WHEN THOSECUSTOMERS' PURCHASES CONSTITUTED A LARGE PERCENTAGE OFTHEIR INVESTIBLE ASSETS OR LIQUID NET WORTH. MOREOVER,FLOATING RATE LOAN FUNDS, PARTICULARLY THOSE WITH RESTRICTIVEREDEMPTION POLICIES, WERE NOT TYPICALLY SUITABLE FOR INVESTORSWITH SHORT INVESTMENT TIME HORIZONS. IN SPITE OF THESEFEATURES OF FLOATING RATE FUNDS, WELLS FARGO INVESTMENTSRECOMMENDED FLOATING RATE FUND INVESTMENTS TO HUNDREDS OFCUSTOMERS FOR WHOM THE INVESTMENT WAS UNSUITABLE IN LIGHT OFTHE CUSTOMERS' FINANCIAL SITUATIONS, RISK TOLERANCES, ANDINVESTMENT OBJECTIVES. BETWEEN 2007 AND EARLY 2009, THE NETASSET VALUE OF THE TYPICAL FLOATING RATE LOAN FUNDS DECLINEDSUBSTANTIALLY. SINCE THAT TIME, THE NET ASSET VALUE OF THETYPICAL FLOATING RATE LOAN FUND HAS PARTIALLY RECOVERED.HOWEVER, MANY WELLS FARGO INVESTMENTS CUSTOMERS FOR WHOMA FLOATING RATE LOAN FUND WAS UNSUITABLE SOLD THEIR HOLDINGSIN FLOATING RATE LOAN FUNDS AND INCURRED NET LOSSES. WELLSFARGO INVESTMENTS CUSTOMERS SUFFERED LOSSES IN THE TOTALAMOUNT OF $1,962,000 AS A RESULT OF UNSUITABLE TRANSACTIONS INFLOATING RATE LOAN FUNDS RECOMMENDED BY THE FIRM. WELLSFARGO INVESTMENTS FAILED TO ESTABLISH AND MAINTAIN A SYSTEMFOR SUPERVISING ITS SALES OF FLOATING RATE LOAN FUNDS THAT WASREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE SUITABILITYREQUIREMENTS OF NASD AND FINRA RULES. WELLS FARGOINVESTMENTS SOLD BILLIONS OF DOLLARS OF FLOATING RATE LOANFUNDS TO ITS CUSTOMERS. THOSE SALES WERE A SIGNIFICANT PART OFWELLS FARGO INVESTMENTS' MUTUAL FUND BUSINESS. BY AUGUST 2007,FLOATING RATE LOAN FUNDS CONSTITUTED APPROXIMATELY 16PERCENT OF THE FIRM'S TOTAL MUTUAL FUNDS SALES. DESPITE THIS,WELLS FARGO INVESTMENTS FAILED TO PROVIDE SUFFICIENT GUIDANCETO REGISTERED REPRESENTATIVES OR SUPERVISORS TO DETERMINEWHETHER FLOATING RATE LOAN FUNDS WERE SUITABLE FOR ITSCLIENTS. WELLS FARGO INVESTMENTS ALSO FAILED TO ADEQUATELYTRAIN ITS REGISTERED PERSONS ABOUT THE CREDIT AND LIQUIDITYRISKS ASSOCIATED WITH FLOATING RATE FUNDS, OR THE CUSTOMERSFOR WHOM SUCH FUNDS WOULD BE SUITABLE. WELLS FARGOINVESTMENTS FAILED TO IMPLEMENT PROCEDURES REASONABLYDESIGNED TO ENSURE THAT ITS SALES OF FLOATING RATE LOAN FUNDSWERE SUITABLE FOR ITS CUSTOMERS EVEN AFTER POTENTIALCONCERNS WERE RAISED INTERNALLY ABOUT THOSE SALES. THE FIRM'SMUTUAL FUND PRODUCT TEAM CONDUCTED A REVIEW OF FLOATINGRATE LOAN FUNDS IN 2007 AND RECOMMENDED THAT WELLS FARGOINVESTMENTS REMIND SELLING REPRESENTATIVES THAT THE FUNDSSHOULD BE PART OF AN OVERALL ASSET ALLOCATION STRATEGY ANDNOT SOLD AS A HIGH YIELDING ALTERNATIVE TO MONEY MARKET FUNDS.THE TEAM ALSO PREPARED A PRESENTATION WHICH INCLUDEDGUIDANCE REGARDING CUSTOMERS FOR WHOM FLOATING RATE LOANFUNDS MIGHT BE SUITABLE. HOWEVER, WELLS FARGO INVESTMENTSFAILED TO ADEQUATELY DISTRIBUTE THIS INFORMATION TO REGISTEREDREPRESENTATIVES OR TAKE ACTION TO ENSURE THAT THE PRODUCTTEAM'S CONCERNS WERE TAKEN INTO ACCOUNT WHEN FLOATING RATELOAN FUND PURCHASES WERE RECOMMENDED TO CUSTOMERS.

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Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 06/04/2013

Docket/Case Number: 2008014350501

Principal Product Type: Other

Other Product Type(s): FLOATING RATE LOAN FUNDS

Resolution Date: 06/04/2013

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED, FINED $1,250,000 AND MUST PAYRESTITUTION TO CUSTOMERS IN THE AMOUNT OF $1,981,561.70. AREGISTERED PRINCIPAL ON BEHALF OF THE FIRM SHALL SUBMITSATISFACTORY PROOF OF PAYMENT OF RESTITUTION OR OFREASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECTRESTITUTION TO FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCEOF THE AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE ANY OF THECUSTOMERS RECEIVING RESTITUTION AFTER REASONABLE ANDDOCUMENTED EFFORTS WITHIN 120 DAYS FROM THE DATE THE AWC ISACCEPTED, OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA, THEFIRM SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION AND INTERESTTO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS LASTKNOWN TO HAVE RESIDED. THE FIRM SHALL PROVIDE SATISFACTORYPROOF OF SUCH ACTION TO FINRA WITHIN 14 DAYS OF FORWARDING THEUNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATESTATE AUTHORITY.

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

No

Sanctions Ordered: CensureMonetary/Fine $1,250,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

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iReporting Source: Firm

Initiated By: FINRA

Allegations: THIS ACTION RELATES TO CONDUCT THAT OCCURRED AT WELLS FARGOINVESTMENTS, LLC (CRD #10582). WELLS FARGO ADVISORS, LLC WAS NOTAFFILIATED WITH WELLS FARGO INVESTMENTS DURING THE RELEVANTPERIOD AND IS NAMED AS A RESPONDENT SOLELY AS SUCCESSOR INLIABILITY FOR WELLS FARGO INVESTMENTS, LLC. FINRA RULE 2010, NASDRULES 2110, 2310, 3010: BETWEEN JANUARY 1, 2007 AND DECEMBER 31,2008 WELLS FARGO INVESTMENTS REGISTERED REPRESENTATIVESMADE RECOMMENDATIONS TO CUSTOMERS TO PURCHASE FLOATINGRATE LOAN FUNDS THAT WERE UNSUITABLE FOR THOSE CUSTOMERS INLIGHT OF THEIR FINANCIAL SITUATIONS AND NEEDS. IN PARTICULAR,WELLS FARGO INVESTMENTS MADE NUMEROUS RECOMMENDATIONS TOCUSTOMERS WHOSE RISK TOLERANCES AND INVESTMENT OBJECTIVESWERE INCONSISTENT WITH THE RISKS AND FEATURES OF FLOATING RATELOAN FUNDS. THE FLOATING RATE LOAN FUNDS SOLD BY WELLS FARGOINVESTMENTS WERE SUBJECT TO SIGNIFICANT CREDIT AND LIQUIDITYRISKS. ACCORDINGLY, THE FUNDS WERE NOT TYPICALLY SUITABLE FORINVESTORS WITH AN INVESTMENT OBJECTIVE OF INCOME AND ACONSERVATIVE RISK TOLERANCE OR THOSE CUSTOMERS WHO WERESEEKING TO PRESERVE PRINCIPAL, PARTICULARLY WHEN THOSECUSTOMERS' PURCHASES CONSTITUTED A LARGE PERCENTAGE OFTHEIR INVESTIBLE ASSETS OR LIQUID NET WORTH. MOREOVER,FLOATING RATE LOAN FUNDS, PARTICULARLY THOSE WITH RESTRICTIVEREDEMPTION POLICIES, WERE NOT TYPICALLY SUITABLE FOR INVESTORSWITH SHORT INVESTMENT TIME HORIZONS. BETWEEN 2007 AND EARLY2009, THE NET ASSET VALUE OF THE TYPICAL FLOATING RATE LOANFUNDS DECLINED SUBSTANTIALLY AND SINCE THAT TIME HAS PARTIALLYRECOVERED. HOWEVER, MANY WELLS FARGO INVESTMENTSCUSTOMERS FOR WHOM A FLOATING RATE LOAN FUND WAS UNSUITABLESOLD THEIR HOLDINGS IN FLOATING RATE LOAN FUNDS AND INCURREDNET LOSSES. WELLS FARGO INVESTMENTS ALSO FAILED TO ESTABLISHAND MAINTAIN A SYSTEM FOR SUPERVISING ITS SALES OF FLOATINGRATE LOAN FUNDS THAT WAS REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH THE SUITABILITY REQUIREMENTS OF NASD AND FINRARULES. EVEN AFTER POTENTIAL CONCERNS WERE RAISED INTERNALLY,WELLS FARGO INVESTMENTS FAILED TO PROVIDE SUFFICIENT GUIDANCEOR TRAINING TO REGISTERED REPRESENTATIVES OR SUPERVISORS TODETERMINE WHETHER FLOATING RATE LOAN FUNDS WERE SUITABLEFOR ITS CLIENTS AND THE CREDIT AND LIQUIDITY RISKS ASSOCIATEDWITH FLOATING RATE FUNDS.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

NA

Date Initiated: 06/04/2013

Docket/Case Number: 2008014350501

Principal Product Type: Other

Other Product Type(s): FLOATING RATE FUNDS

Resolution Date: 06/04/2013

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED, FINED $1,250,000 AND MUST PAYRESTITUTION TO CUSTOMERS IN THE AMOUNT OF $1,981,561.70. AREGISTERED PRINCIPAL ON BEHALF OF THE FIRM SHALL SUBMITSATISFACTORY PROOF OF PAYMENT OF RESTITUTION OR OFREASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECTRESTITUTION TO FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCEOF THE AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE ANY OF THECUSTOMERS RECEIVING RESTITUTION AFTER REASONABLE ANDDOCUMENTED EFFORTS WITHIN 120 DAYS FROM THE DATE THE AWC ISACCEPTED, OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA, THEFIRM SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION AND INTERESTTO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS LASTKNOWN TO HAVE RESIDED. THE FIRM SHALL PROVIDE SATISFACTORYPROOF OF SUCH ACTION TO FINRA WITHIN 14 DAYS OF FORWARDING THEUNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATESTATE AUTHORITY.

Sanctions Ordered: CensureMonetary/Fine $1,250,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

Disclosure 30 of 158

i

Reporting Source: Regulator

Allegations: FINRA BY-LAWS ARTICLE V, SECTION 2; FINRA RULES 1122, 2010; NASDRULES 2110, 3010, 3070, CAUSED VIOLATIONS OF FINRA RULE 3240(A),NASD RULE 2370(A): WELLS FARGO PERMITTED CERTAIN CUSTOMERS TOBORROW MONEY FROM THE MEMBER FIRM BY WITHDRAWING MOREFUNDS THAN WERE AVAILABLE IN THE CUSTOMERS' ACCOUNTS,THROUGH THE USE OF AMONG OTHER THINGS, ONLINE PAYMENTS,CHECKS, AND DEBIT CARDS. THE REGISTERED REPRESENTATIVESASSIGNED TO THE ACCOUNTS, WITH THE CONCURRENCE OF THEBRANCH MANAGERS AND THE FIRM'S CREDIT AND MARGIN DEPARTMENT,DETERMINED WHETHER TO ALLOW THESE TYPES OF WITHDRAWALS TOGO THROUGH. IF THE OVERDRAFTS WERE ALLOWED TO OCCUR, THECUSTOMERS WERE RESPONSIBLE FOR SATISFYING THE OVERDRAFTTHROUGH A SAME DAY DEPOSIT OF FUNDS, WIRE TRANSFER, ORCOLLATERAL OR SALE OF SECURITIES. ACCORDING TO THE FIRM'SPOLICY, IF A CUSTOMER DID NOT SATISFY AN OVERDRAFT ON THE SAMEDAY, THE DEBIT WOULD NOT BE HONORED. HOWEVER, DURING THE TIMEPERIOD AT ISSUE, THE FIRM ALLOWED EXCEPTIONS TO THIS POLICY ONAN OCCASIONAL, THOUGH NOT FREQUENT, BASIS AND PERMITTEDOVERDRAFTS IN SITUATIONS WHERE CUSTOMERS DID NOT COVER THEDEBIT ON THE SAME DAY, THEREBY LOANING MONEY TO THOSECUSTOMERS. IN THOSE INSTANCES, IN ACCORDANCE WITH THE FIRM'SPOLICIES AND PROCEDURES, IF THE OVERDRAFT WAS NOT REPAIDAFTER A PERIOD OF TIME, THE UNSECURED DEBIT WAS CHARGEDAGAINST THE REGISTERED REPRESENTATIVE'S PRODUCTION.ONCE AN OVERDRAFT WAS CHARGED AGAINST A REGISTEREDREPRESENTATIVE'S PRODUCTION, THE REGISTEREDREPRESENTATIVE COULD REQUEST THAT THE DEBT BE SENT TOCOLLECTIONS, THROUGH THE FIRM, FOR RECOVERY FROM THECUSTOMER. AMOUNTS RECOVERED FROM THE CUSTOMER WERE PAIDTO THE REGISTERED REPRESENTATIVE, MINUS ANY COLLECTIONSEXPENSES. BY TRANSFERRING RESPONSIBILITY FOR THE LOAN TOREGISTERED REPRESENTATIVES AND ALLOWING REGISTEREDREPRESENTATIVES TO OBTAIN REPAYMENT FROM THE CUSTOMERS, THEFIRM CAUSED REGISTERED REPRESENTATIVES TO LOAN MONEY TOCUSTOMERS.THE FIRM ALSO ALLOWED THE LOANS TO OCCUR WITHOUT ANY SYSTEMOR PROCEDURE IN PLACE TO DETERMINE WHETHER THE LOANS MET THECONDITIONS OF FINRA RULE 3240(A) AND NASD RULE 2370(A).THEREFORE IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORYSYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRAAND NASD RULES.TWO CUSTOMERS ALLEGED IN WRITING THAT A REGISTEREDREPRESENTATIVE HAD MADE JOURNAL TRANSFERS OF FUNDS TO OTHERCUSTOMERS WITHOUT THEIR AUTHORIZATION. THE FIRM SETTLED ONECOMPLAINT FOR $16,500 WHILE THE OTHER WAS RESOLVED WITHOUT AMONETARY SETTLEMENT. THE FIRM NEVER REPORTED EITHER OF THESECOMPLAINTS ON THE REGISTERED REPRESENTATIVE'S FORM U4, ANDNEVER DISCLOSED THE SETTLEMENT OF THE SECOND COMPLAINT FORMORE THAN $15,000.THE CUSTOMER COMPLAINTS ALLEGED MISAPPROPRIATION OF FUNDSWHICH REQUIRES DISCLOSURE UNDER NASD RULE 3070 WITHIN TENDAYS. ONE COMPLAINT WAS NOT REPORTED UNTIL THREE AND ONE-HALFMONTHS AFTER IT WAS RECEIVED WHILE TO OTHER WAS NEVERREPORTED.

Current Status: Final

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Allegations: FINRA BY-LAWS ARTICLE V, SECTION 2; FINRA RULES 1122, 2010; NASDRULES 2110, 3010, 3070, CAUSED VIOLATIONS OF FINRA RULE 3240(A),NASD RULE 2370(A): WELLS FARGO PERMITTED CERTAIN CUSTOMERS TOBORROW MONEY FROM THE MEMBER FIRM BY WITHDRAWING MOREFUNDS THAN WERE AVAILABLE IN THE CUSTOMERS' ACCOUNTS,THROUGH THE USE OF AMONG OTHER THINGS, ONLINE PAYMENTS,CHECKS, AND DEBIT CARDS. THE REGISTERED REPRESENTATIVESASSIGNED TO THE ACCOUNTS, WITH THE CONCURRENCE OF THEBRANCH MANAGERS AND THE FIRM'S CREDIT AND MARGIN DEPARTMENT,DETERMINED WHETHER TO ALLOW THESE TYPES OF WITHDRAWALS TOGO THROUGH. IF THE OVERDRAFTS WERE ALLOWED TO OCCUR, THECUSTOMERS WERE RESPONSIBLE FOR SATISFYING THE OVERDRAFTTHROUGH A SAME DAY DEPOSIT OF FUNDS, WIRE TRANSFER, ORCOLLATERAL OR SALE OF SECURITIES. ACCORDING TO THE FIRM'SPOLICY, IF A CUSTOMER DID NOT SATISFY AN OVERDRAFT ON THE SAMEDAY, THE DEBIT WOULD NOT BE HONORED. HOWEVER, DURING THE TIMEPERIOD AT ISSUE, THE FIRM ALLOWED EXCEPTIONS TO THIS POLICY ONAN OCCASIONAL, THOUGH NOT FREQUENT, BASIS AND PERMITTEDOVERDRAFTS IN SITUATIONS WHERE CUSTOMERS DID NOT COVER THEDEBIT ON THE SAME DAY, THEREBY LOANING MONEY TO THOSECUSTOMERS. IN THOSE INSTANCES, IN ACCORDANCE WITH THE FIRM'SPOLICIES AND PROCEDURES, IF THE OVERDRAFT WAS NOT REPAIDAFTER A PERIOD OF TIME, THE UNSECURED DEBIT WAS CHARGEDAGAINST THE REGISTERED REPRESENTATIVE'S PRODUCTION.ONCE AN OVERDRAFT WAS CHARGED AGAINST A REGISTEREDREPRESENTATIVE'S PRODUCTION, THE REGISTEREDREPRESENTATIVE COULD REQUEST THAT THE DEBT BE SENT TOCOLLECTIONS, THROUGH THE FIRM, FOR RECOVERY FROM THECUSTOMER. AMOUNTS RECOVERED FROM THE CUSTOMER WERE PAIDTO THE REGISTERED REPRESENTATIVE, MINUS ANY COLLECTIONSEXPENSES. BY TRANSFERRING RESPONSIBILITY FOR THE LOAN TOREGISTERED REPRESENTATIVES AND ALLOWING REGISTEREDREPRESENTATIVES TO OBTAIN REPAYMENT FROM THE CUSTOMERS, THEFIRM CAUSED REGISTERED REPRESENTATIVES TO LOAN MONEY TOCUSTOMERS.THE FIRM ALSO ALLOWED THE LOANS TO OCCUR WITHOUT ANY SYSTEMOR PROCEDURE IN PLACE TO DETERMINE WHETHER THE LOANS MET THECONDITIONS OF FINRA RULE 3240(A) AND NASD RULE 2370(A).THEREFORE IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORYSYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRAAND NASD RULES.TWO CUSTOMERS ALLEGED IN WRITING THAT A REGISTEREDREPRESENTATIVE HAD MADE JOURNAL TRANSFERS OF FUNDS TO OTHERCUSTOMERS WITHOUT THEIR AUTHORIZATION. THE FIRM SETTLED ONECOMPLAINT FOR $16,500 WHILE THE OTHER WAS RESOLVED WITHOUT AMONETARY SETTLEMENT. THE FIRM NEVER REPORTED EITHER OF THESECOMPLAINTS ON THE REGISTERED REPRESENTATIVE'S FORM U4, ANDNEVER DISCLOSED THE SETTLEMENT OF THE SECOND COMPLAINT FORMORE THAN $15,000.THE CUSTOMER COMPLAINTS ALLEGED MISAPPROPRIATION OF FUNDSWHICH REQUIRES DISCLOSURE UNDER NASD RULE 3070 WITHIN TENDAYS. ONE COMPLAINT WAS NOT REPORTED UNTIL THREE AND ONE-HALFMONTHS AFTER IT WAS RECEIVED WHILE TO OTHER WAS NEVERREPORTED.

103©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 04/09/2013

Docket/Case Number: 2010022380001

Principal Product Type: Other

Other Product Type(s): N/A

FINRA BY-LAWS ARTICLE V, SECTION 2; FINRA RULES 1122, 2010; NASDRULES 2110, 3010, 3070, CAUSED VIOLATIONS OF FINRA RULE 3240(A),NASD RULE 2370(A): WELLS FARGO PERMITTED CERTAIN CUSTOMERS TOBORROW MONEY FROM THE MEMBER FIRM BY WITHDRAWING MOREFUNDS THAN WERE AVAILABLE IN THE CUSTOMERS' ACCOUNTS,THROUGH THE USE OF AMONG OTHER THINGS, ONLINE PAYMENTS,CHECKS, AND DEBIT CARDS. THE REGISTERED REPRESENTATIVESASSIGNED TO THE ACCOUNTS, WITH THE CONCURRENCE OF THEBRANCH MANAGERS AND THE FIRM'S CREDIT AND MARGIN DEPARTMENT,DETERMINED WHETHER TO ALLOW THESE TYPES OF WITHDRAWALS TOGO THROUGH. IF THE OVERDRAFTS WERE ALLOWED TO OCCUR, THECUSTOMERS WERE RESPONSIBLE FOR SATISFYING THE OVERDRAFTTHROUGH A SAME DAY DEPOSIT OF FUNDS, WIRE TRANSFER, ORCOLLATERAL OR SALE OF SECURITIES. ACCORDING TO THE FIRM'SPOLICY, IF A CUSTOMER DID NOT SATISFY AN OVERDRAFT ON THE SAMEDAY, THE DEBIT WOULD NOT BE HONORED. HOWEVER, DURING THE TIMEPERIOD AT ISSUE, THE FIRM ALLOWED EXCEPTIONS TO THIS POLICY ONAN OCCASIONAL, THOUGH NOT FREQUENT, BASIS AND PERMITTEDOVERDRAFTS IN SITUATIONS WHERE CUSTOMERS DID NOT COVER THEDEBIT ON THE SAME DAY, THEREBY LOANING MONEY TO THOSECUSTOMERS. IN THOSE INSTANCES, IN ACCORDANCE WITH THE FIRM'SPOLICIES AND PROCEDURES, IF THE OVERDRAFT WAS NOT REPAIDAFTER A PERIOD OF TIME, THE UNSECURED DEBIT WAS CHARGEDAGAINST THE REGISTERED REPRESENTATIVE'S PRODUCTION.ONCE AN OVERDRAFT WAS CHARGED AGAINST A REGISTEREDREPRESENTATIVE'S PRODUCTION, THE REGISTEREDREPRESENTATIVE COULD REQUEST THAT THE DEBT BE SENT TOCOLLECTIONS, THROUGH THE FIRM, FOR RECOVERY FROM THECUSTOMER. AMOUNTS RECOVERED FROM THE CUSTOMER WERE PAIDTO THE REGISTERED REPRESENTATIVE, MINUS ANY COLLECTIONSEXPENSES. BY TRANSFERRING RESPONSIBILITY FOR THE LOAN TOREGISTERED REPRESENTATIVES AND ALLOWING REGISTEREDREPRESENTATIVES TO OBTAIN REPAYMENT FROM THE CUSTOMERS, THEFIRM CAUSED REGISTERED REPRESENTATIVES TO LOAN MONEY TOCUSTOMERS.THE FIRM ALSO ALLOWED THE LOANS TO OCCUR WITHOUT ANY SYSTEMOR PROCEDURE IN PLACE TO DETERMINE WHETHER THE LOANS MET THECONDITIONS OF FINRA RULE 3240(A) AND NASD RULE 2370(A).THEREFORE IT FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORYSYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRAAND NASD RULES.TWO CUSTOMERS ALLEGED IN WRITING THAT A REGISTEREDREPRESENTATIVE HAD MADE JOURNAL TRANSFERS OF FUNDS TO OTHERCUSTOMERS WITHOUT THEIR AUTHORIZATION. THE FIRM SETTLED ONECOMPLAINT FOR $16,500 WHILE THE OTHER WAS RESOLVED WITHOUT AMONETARY SETTLEMENT. THE FIRM NEVER REPORTED EITHER OF THESECOMPLAINTS ON THE REGISTERED REPRESENTATIVE'S FORM U4, ANDNEVER DISCLOSED THE SETTLEMENT OF THE SECOND COMPLAINT FORMORE THAN $15,000.THE CUSTOMER COMPLAINTS ALLEGED MISAPPROPRIATION OF FUNDSWHICH REQUIRES DISCLOSURE UNDER NASD RULE 3070 WITHIN TENDAYS. ONE COMPLAINT WAS NOT REPORTED UNTIL THREE AND ONE-HALFMONTHS AFTER IT WAS RECEIVED WHILE TO OTHER WAS NEVERREPORTED.

Resolution Date: 04/09/2013

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 IT IS CENSURED AND FINED $50,000. THE FIRM FURTHERUNDERTOOK AND AGREED TO CONDUCT A COMPREHENSIVE REVIEW OFITS SYSTEMS, POLICIES AND PROCEDURES TO ENSURE THAT THOSEPOLICIES AND PROCEDURES ARE REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH FINRA RULES AND THE FEDERAL SECURITIES LAWSREGARDING BORROWING MONEY FROM, OR LENDING MONEY TO,CUSTOMERS BY REGISTERED REPRESENTATIVES. WITHIN 120 DAYS OFTHE ISSUANCE OF A NOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICEROF THE FIRM SHALL CERTIFY IN WRITING TO FINRA THAT (I) THE FIRM HASENGAGED IN THE COMPREHENSIVE REVIEW; AND (II) AS OF THE DATE OFTHE CERTIFICATION, THE FIRM HAS IN PLACE POLICIES ANDPROCEDURES TO REASONABLY DESIGNED TO ADDRESS AND CORRECTTHE VIOLATIONS RELATING TO SUPERVISION DESCRIBED IN THIS AWC.FINE PAID MAY 29, 2013.

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

No

Sanctions Ordered: CensureMonetary/Fine $50,000.00

Acceptance, Waiver & Consent(AWC)

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WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE IT IS CENSURED AND FINED $50,000. THE FIRM FURTHERUNDERTOOK AND AGREED TO CONDUCT A COMPREHENSIVE REVIEW OFITS SYSTEMS, POLICIES AND PROCEDURES TO ENSURE THAT THOSEPOLICIES AND PROCEDURES ARE REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH FINRA RULES AND THE FEDERAL SECURITIES LAWSREGARDING BORROWING MONEY FROM, OR LENDING MONEY TO,CUSTOMERS BY REGISTERED REPRESENTATIVES. WITHIN 120 DAYS OFTHE ISSUANCE OF A NOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICEROF THE FIRM SHALL CERTIFY IN WRITING TO FINRA THAT (I) THE FIRM HASENGAGED IN THE COMPREHENSIVE REVIEW; AND (II) AS OF THE DATE OFTHE CERTIFICATION, THE FIRM HAS IN PLACE POLICIES ANDPROCEDURES TO REASONABLY DESIGNED TO ADDRESS AND CORRECTTHE VIOLATIONS RELATING TO SUPERVISION DESCRIBED IN THIS AWC.FINE PAID MAY 29, 2013.

iReporting Source: Firm

Allegations: FINRA BY-LAWS ARTICLE V, SECTION 2; FINRA RULES 1122, 2010; NASDRULES 2110, 3010, 3070, CAUSED VIOLATIONS OF FINRA RULE 3240(A),NASD RULE 2370(A): WELLS FARGO PERMITTED CERTAIN CUSTOMERS TOBORROW MONEY FROM THE MEMBER FIRM BY WITHDRAWING MOREFUNDS THAN WERE AVAILABLE IN THE CUSTOMERS' ACCOUNTS,THROUGH THE USE OF AMONG OTHER THINGS, ONLINE PAYMENTS,CHECKS, AND DEBIT CARDS. THE REGISTERED REPRESENTATIVESASSIGNED TO THE ACCOUNTS, WITH THE CONCURRENCE OF THEBRANCH MANAGERS AND THE FIRM'S CREDIT AND MARGIN DEPARTMENT,DETERMINED WHETHER TO ALLOW THESE TYPES OF WITHDRAWALS TOGO THROUGH. IF THE OVERDRAFTS WERE ALLOWED TO OCCUR, THECUSTOMERS WERE RESPONSIBLE FOR SATISFYING THE OVERDRAFTTHROUGH A SAME DAY DEPOSIT OF FUNDS, WIRE TRANSFER, ORCOLLATERAL OR SALE OF SECURITIES. ACCORDING TO THE FIRM'SPOLICY, IF A CUSTOMER DID NOT SATISFY AN OVERDRAFT ON THE SAMEDAY, THE DEBIT WOULD NOT BE HONORED. HOWEVER, DURING THE TIMEPERIOD AT ISSUE, THE FIRM ALLOWED EXCEPTIONS TO THIS POLICY ONAN OCCASIONAL, THOUGH NOT FREQUENT, BASIS AND PERMITTEDOVERDRAFTS IN SITUATIONS WHERE CUSTOMERS DID NOT COVER THEDEBIT ON THE SAME DAY, THEREBY LOANING MONEY TO THOSECUSTOMERS. IN THOSE INSTANCES, IN ACCORDANCE WITH THE FIRM'SPOLICIES AND PROCEDURES, IF THE OVERDRAFT WAS NOT REPAIDAFTER A PERIOD OF TIME, THE UNSECURED DEBIT WAS CHARGEDAGAINST THE REGISTERED REPRESENTATIVE'S PRODUCTION. ONCE ANOVERDRAFT WAS CHARGED AGAINST A REGISTERED REPRESENTATIVE'SPRODUCTION, THE REGISTERED REPRESENTATIVE COULD REQUESTTHAT THE DEBT BE SENT TO COLLECTIONS, THROUGH THE FIRM, FORRECOVERY FROM THE CUSTOMER. AMOUNTS RECOVERED FROM THECUSTOMER WERE PAID TO THE REGISTERED REPRESENTATIVE, MINUSANY COLLECTIONS EXPENSES. BY TRANSFERRING RESPONSIBILITY FORTHE LOAN TO REGISTERED REPRESENTATIVES AND ALLOWINGREGISTERED REPRESENTATIVES TO OBTAIN REPAYMENT FROM THECUSTOMERS, THE FIRM CAUSED REGISTERED REPRESENTATIVES TOLOAN MONEY TO CUSTOMERS. THE FIRM ALSO ALLOWED THE LOANS TOOCCUR WITHOUT ANY SYSTEM OR PROCEDURE IN PLACE TO DETERMINEWHETHER THE LOANS MET THE CONDITIONS OF FINRA RULE 3240(A) ANDNASD RULE 2370(A). THEREFORE IT FAILED TO ESTABLISH AND MAINTAIN ASUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH FINRA AND NASD RULES. TWO CUSTOMERS ALLEGEDIN WRITING THAT A REGISTERED REPRESENTATIVE HAD MADE JOURNALTRANSFERS OF FUNDS TO OTHER CUSTOMERS WITHOUT THEIRAUTHORIZATION. THE FIRM SETTLED ONE COMPLAINT FOR $16,500 WHILETHE OTHER WAS RESOLVED WITHOUT A MONETARY SETTLEMENT. THEFIRM NEVER REPORTED EITHER OF THESE COMPLAINTS ON THEREGISTERED REPRESENTATIVE'S FORM U4, AND NEVER DISCLOSED THESETTLEMENT OF THE SECOND COMPLAINT FOR MORE THAN $15,000. THECUSTOMER COMPLAINTS ALLEGED MISAPPROPRIATION OF FUNDS WHICHREQUIRES DISCLOSURE UNDER NASD RULE 3070 WITHIN TEN DAYS. ONECOMPLAINT WAS NOT REPORTED UNTIL THREE AND ONE-HALF MONTHSAFTER IT WAS RECEIVED WHILE TO OTHER WAS NEVER REPORTED.

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

CENSURE AND UNDERTAKING

Date Initiated: 04/09/2013

Docket/Case Number: 2010022380001

Principal Product Type: Other

Other Product Type(s): NA

FINRA BY-LAWS ARTICLE V, SECTION 2; FINRA RULES 1122, 2010; NASDRULES 2110, 3010, 3070, CAUSED VIOLATIONS OF FINRA RULE 3240(A),NASD RULE 2370(A): WELLS FARGO PERMITTED CERTAIN CUSTOMERS TOBORROW MONEY FROM THE MEMBER FIRM BY WITHDRAWING MOREFUNDS THAN WERE AVAILABLE IN THE CUSTOMERS' ACCOUNTS,THROUGH THE USE OF AMONG OTHER THINGS, ONLINE PAYMENTS,CHECKS, AND DEBIT CARDS. THE REGISTERED REPRESENTATIVESASSIGNED TO THE ACCOUNTS, WITH THE CONCURRENCE OF THEBRANCH MANAGERS AND THE FIRM'S CREDIT AND MARGIN DEPARTMENT,DETERMINED WHETHER TO ALLOW THESE TYPES OF WITHDRAWALS TOGO THROUGH. IF THE OVERDRAFTS WERE ALLOWED TO OCCUR, THECUSTOMERS WERE RESPONSIBLE FOR SATISFYING THE OVERDRAFTTHROUGH A SAME DAY DEPOSIT OF FUNDS, WIRE TRANSFER, ORCOLLATERAL OR SALE OF SECURITIES. ACCORDING TO THE FIRM'SPOLICY, IF A CUSTOMER DID NOT SATISFY AN OVERDRAFT ON THE SAMEDAY, THE DEBIT WOULD NOT BE HONORED. HOWEVER, DURING THE TIMEPERIOD AT ISSUE, THE FIRM ALLOWED EXCEPTIONS TO THIS POLICY ONAN OCCASIONAL, THOUGH NOT FREQUENT, BASIS AND PERMITTEDOVERDRAFTS IN SITUATIONS WHERE CUSTOMERS DID NOT COVER THEDEBIT ON THE SAME DAY, THEREBY LOANING MONEY TO THOSECUSTOMERS. IN THOSE INSTANCES, IN ACCORDANCE WITH THE FIRM'SPOLICIES AND PROCEDURES, IF THE OVERDRAFT WAS NOT REPAIDAFTER A PERIOD OF TIME, THE UNSECURED DEBIT WAS CHARGEDAGAINST THE REGISTERED REPRESENTATIVE'S PRODUCTION. ONCE ANOVERDRAFT WAS CHARGED AGAINST A REGISTERED REPRESENTATIVE'SPRODUCTION, THE REGISTERED REPRESENTATIVE COULD REQUESTTHAT THE DEBT BE SENT TO COLLECTIONS, THROUGH THE FIRM, FORRECOVERY FROM THE CUSTOMER. AMOUNTS RECOVERED FROM THECUSTOMER WERE PAID TO THE REGISTERED REPRESENTATIVE, MINUSANY COLLECTIONS EXPENSES. BY TRANSFERRING RESPONSIBILITY FORTHE LOAN TO REGISTERED REPRESENTATIVES AND ALLOWINGREGISTERED REPRESENTATIVES TO OBTAIN REPAYMENT FROM THECUSTOMERS, THE FIRM CAUSED REGISTERED REPRESENTATIVES TOLOAN MONEY TO CUSTOMERS. THE FIRM ALSO ALLOWED THE LOANS TOOCCUR WITHOUT ANY SYSTEM OR PROCEDURE IN PLACE TO DETERMINEWHETHER THE LOANS MET THE CONDITIONS OF FINRA RULE 3240(A) ANDNASD RULE 2370(A). THEREFORE IT FAILED TO ESTABLISH AND MAINTAIN ASUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH FINRA AND NASD RULES. TWO CUSTOMERS ALLEGEDIN WRITING THAT A REGISTERED REPRESENTATIVE HAD MADE JOURNALTRANSFERS OF FUNDS TO OTHER CUSTOMERS WITHOUT THEIRAUTHORIZATION. THE FIRM SETTLED ONE COMPLAINT FOR $16,500 WHILETHE OTHER WAS RESOLVED WITHOUT A MONETARY SETTLEMENT. THEFIRM NEVER REPORTED EITHER OF THESE COMPLAINTS ON THEREGISTERED REPRESENTATIVE'S FORM U4, AND NEVER DISCLOSED THESETTLEMENT OF THE SECOND COMPLAINT FOR MORE THAN $15,000. THECUSTOMER COMPLAINTS ALLEGED MISAPPROPRIATION OF FUNDS WHICHREQUIRES DISCLOSURE UNDER NASD RULE 3070 WITHIN TEN DAYS. ONECOMPLAINT WAS NOT REPORTED UNTIL THREE AND ONE-HALF MONTHSAFTER IT WAS RECEIVED WHILE TO OTHER WAS NEVER REPORTED.

Resolution Date: 04/09/2013

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 IT IS CENSURED AND FINED $50,000. THE FIRM FURTHERUNDERTOOK AND AGREED TO CONDUCT A COMPREHENSIVE REVIEW OFITS SYSTEMS, POLICIES AND PROCEDURES TO ENSURE THAT THOSEPOLICIES AND PROCEDURES ARE REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH FINRA RULES AND THE FEDERAL SECURITIES LAWSREGARDING BORROWING MONEY FROM, OR LENDING MONEY TO,CUSTOMERS BY REGISTERED REPRESENTATIVES. WITHIN 120 DAYS OFTHE ISSUANCE OF A NOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICEROF THE FIRM SHALL CERTIFY IN WRITING TO FINRA THAT (I) THE FIRM HASENGAGED IN THE COMPREHENSIVE REVIEW; AND (II) AS OF THE DATE OFTHE CERTIFICATION, THE FIRM HAS IN PLACE POLICIES ANDPROCEDURES TO REASONABLY DESIGNED TO ADDRESS AND CORRECTTHE VIOLATIONS RELATING TO SUPERVISION DESCRIBED IN THIS AWC.

Sanctions Ordered: CensureMonetary/Fine $50,000.00

Acceptance, Waiver & Consent(AWC)

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WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE IT IS CENSURED AND FINED $50,000. THE FIRM FURTHERUNDERTOOK AND AGREED TO CONDUCT A COMPREHENSIVE REVIEW OFITS SYSTEMS, POLICIES AND PROCEDURES TO ENSURE THAT THOSEPOLICIES AND PROCEDURES ARE REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH FINRA RULES AND THE FEDERAL SECURITIES LAWSREGARDING BORROWING MONEY FROM, OR LENDING MONEY TO,CUSTOMERS BY REGISTERED REPRESENTATIVES. WITHIN 120 DAYS OFTHE ISSUANCE OF A NOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICEROF THE FIRM SHALL CERTIFY IN WRITING TO FINRA THAT (I) THE FIRM HASENGAGED IN THE COMPREHENSIVE REVIEW; AND (II) AS OF THE DATE OFTHE CERTIFICATION, THE FIRM HAS IN PLACE POLICIES ANDPROCEDURES TO REASONABLY DESIGNED TO ADDRESS AND CORRECTTHE VIOLATIONS RELATING TO SUPERVISION DESCRIBED IN THIS AWC.

Disclosure 31 of 158

i

Reporting Source: Firm

Initiated By: NEW YORK DEPARTMENT OF FINANCIAL SERVICES

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

STIPULATION

Date Initiated: 02/27/2013

Docket/Case Number: 2012-0184-S

Principal Product Type: Insurance

Other Product Type(s):

Allegations: THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES ALLEGEDTHAT DURING THE APPROXIMATE PERIOD OF JANUARY 2007 THROUGHDECEMBER 2010 WELLS FARGO ADVISORS, LLC, AN UNLICENSED ENTITY,ACCEPTED INSURANCE COMMISSIONS FROM WELLS FARGO ADVISORSINSURANCE AGENCY LLC, IN VIOLATION OF NEW YORK INSURANCE LAW.THE DEPARTMENT FURTHER ALLEGED THAT BOTH WELLS FARGOADVISORS LLC AND WELLS FARGO ADVISORS FINANCIAL NETWORK LLCPROVIDED MATERIALLY INCOMPLETE INFORMATION IN THEIR RESPECTIVEINSURANCE LICENSE APPLICATIONS SUBMITTED TO THE STATE ON ORABOUT JANUARY 27, 2012.

Current Status: Final

Resolution Date: 02/27/2013

Resolution:

Other Sanctions Ordered:

Sanction Details: WELLS FARGO ADVISORS AND AFFILIATES PAID A $50,000 FINE ANDAGREED TO TAKE ALL NECESSARY STEPS TO PREVENT THEREOCCURRENCE OF SIMILAR VIOLATIONS.

Sanctions Ordered: Monetary/Fine $50,000.00

Stipulation and Consent

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Sanction Details: WELLS FARGO ADVISORS AND AFFILIATES PAID A $50,000 FINE ANDAGREED TO TAKE ALL NECESSARY STEPS TO PREVENT THEREOCCURRENCE OF SIMILAR VIOLATIONS.

Disclosure 32 of 158

i

Reporting Source: Regulator

Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION ("OFR")

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 03/16/2012

Docket/Case Number: 0672-S-9/12

URL for Regulatory Action:

Principal Product Type: Other

Other Product Type(s):

Allegations: ON DECEMBER 15, 2010, WELLS FARGO, A FEDERALLY COVEREDINVESTMENT ADVISER, INFORMED THE OFFICE BY LETTER THAT ANANOMALY IN ITS AUTOMATED SYSTEMS HAD CAUSED A NUMBER OFINDIVIDUALS TO ENGAGE IN INVESTMENT ADVISORY BUSINESS INFLORIDA WITHOUT BENEFIT OF INVESTMENT ADVISER REPRESENTATIVEREGISTRATION. IN EARLY 2012, WELLS FARGO ADVISORS, LLC NOTIFIEDTHE OFFICE THAT IT HAD ADDITIONAL FINANCIAL ADVISORS, INCLUDINGSHAPIRO AND BEACH, THAT POTENTIALLY NEEDED INVESTMENT ADVISERREPRESENTATIVE REGISTRATION IN FLORIDA. SHAPIRO AND BEACH AREPROPERLY REGISTERED WITH THE OFFICE TO SELL SECURITIES. ONMARCH 16,2012, THE OFFICE ISSUED A LETTER TO DETERMINE IFSHAPIRO AND BEACH HAD ENGAGED IN INVESTMENT ADVISORYBUSINESS FROM OFFICES IN FLORIDA. IN RESPONSE TO THE OFFICE'SINQUIRY, SHAPIRO INDICATED THAT HE HAD ENGAGED IN BUSINESS FORTHREE MONTHS OUT OF THE YEAR SINCE 2008, AND BEACH INDICATEDTHAT HE HAD ENGAGED IN BUSINESS FOR TWO TO FOUR MONTHS PERYEAR SINCE 2009, PRIOR TO THEM EACH OBTAINING PROPERREGISTRATION IN FLORIDA.

Current Status: Final

Resolution Date: 02/12/2013

Resolution:

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

No

Order

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Other Sanctions Ordered:

Sanction Details: ON 2/12/2013, THE OFFICE OF FINANCIAL REGULATION ("OFFICE")ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENTAGREEMENT IN THE MATTER OF WELLS FARGO ADVISORS, LLC, MARTINSHAPIRO, AND SAMUEL BEACH JR ("RESPONDENTS"). RESPONDENTSNEITHER ADMITTED NOR DENIED THE FINDINGS BUT CONSENTED TO THEENTRY OF FINDINGS BY THE OFFICE. WELLS FARGO ADVISORS, LLCAGREES TO CEASE AND DESIST FROM ANY AND ALL FUTURE VIOLATIONSOF CHAPTER 517, F.S. AND THE ADMINISTRATIVE RULES THEREUNDERAND AGREES TO PAY AN ADMINISTRATIVE FINE OF $30,000.00.

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

No

Sanctions Ordered: Monetary/Fine $30,000.00

iReporting Source: Firm

Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION ("OFR")

Date Initiated: 02/12/2013

Allegations: ON DECEMBER 15, 2010, WELLS FARGO, A FEDERALLY COVEREDINVESTMENT ADVISER, INFORMED THE OFFICE BY LETTER THAT ANANOMALY IN ITS AUTOMATED SYSTEMS HAD CAUSED A NUMBER OFINDIVIDUALS TO ENGAGE IN INVESTMENT ADVISORY BUSINESS INFLORIDA WITHOUT BENEFIT OF INVESTMENT ADVISER REPRESENTATIVEREGISTRATION. IN EARLY 2012, WELLS FARGO ADVISORS, LLC NOTIFIEDTHE OFFICE THAT IT HAD ADDITIONAL FINANCIAL ADVISORS, INCLUDINGTWO OTHER REGISTERED ASSOCIATES, THAT POTENTIALLY NEEDEDINVESTMENT ADVISER REPRESENTATIVE REGISTRATION IN FLORIDA. THEREGISTERED ASSOCIATAED ARE PROPERLY REGISTERED WITH THEOFFICE TO SELL SECURITIES. ON MARCH 16,2012, THE OFFICE ISSUED ALETTER TO DETERMINE IF THEY HAD ENGAGED IN INVESTMENTADVISORY BUSINESS FROM OFFICES IN FLORIDA. IN RESPONSE TO THEOFFICE'S INQUIRY, A REGISTERED ASSOCIATE INDICATED THAT HE HADENGAGED IN BUSINESS FOR THREE MONTHS OUT OF THE YEAR SINCE2008, AND ANOTHER REGISTERED ASSOCIATE INDICATED THAT HE HADENGAGED IN BUSINESS FOR TWO TO FOUR MONTHS PER YEAR SINCE2009, PRIOR TO THEM EACH OBTAINING PROPER REGISTRATION INFLORIDA.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 02/12/2013

Docket/Case Number: 0672-S-9/12

Principal Product Type: No Product

Other Product Type(s):

Resolution Date: 02/12/2013

Resolution:

Other Sanctions Ordered:

Sanction Details: ON 2/12/2013, THE OFFICE OF FINANCIAL REGULATION ("OFFICE")ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENTAGREEMENT IN THE MATTER OF WELLS FARGO ADVISORS, LLC, AND TWOOTHER REGISTERED ASSOCIATES ("RESPONDENTS"). RESPONDENTSNEITHER ADMITTED NOR DENIED THE FINDINGS BUT CONSENTED TO THEENTRY OF FINDINGS BY THE OFFICE. WELLS FARGO ADVISORS, LLCAGREES TO CEASE AND DESIST FROM ANY AND ALL FUTURE VIOLATIONSOF CHAPTER 517, F.S. AND THE ADMINISTRATIVE RULES THEREUNDERAND AGREES TO PAY AN ADMINISTRATIVE FINE OF $30,000.00.

Sanctions Ordered: Monetary/Fine $30,000.00

Order

Disclosure 33 of 158

i

Reporting Source: Regulator

Allegations: FINRA RULE 2010, NASD RULES 2110, 2310, 3010 - WELLS FARGOADVISORS, LLC FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORYSYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH NASD AND FINRA RULES IN CONNECTIONWITH THE SALE OF NON-TRADITIONAL EXCHANGE-TRADED FUNDS (ETFS)IN ACCOUNTS WHERE THE FIRM PROVIDED BROKERAGE SERVICES TOCERTAIN RETAIL CUSTOMERS AND THE FIRM FAILED TO PROVIDEADEQUATE FORMAL TRAINING AND GUIDANCE TO ITS REGISTEREDREPRESENTATIVES AND SUPERVISORS REGARDING NON-TRADITIONALETFS. THE FIRM ALLOWED ITS REGISTERED REPRESENTATIVES TORECOMMEND A NON-TRADITIONAL ETF TO CUSTOMERS WITHOUTPERFORMING REASONABLE DILIGENCE TO UNDERSTAND THE RISKS ANDFEATURES ASSOCIATED WITH IT. CERTAIN FIRM REGISTEREDREPRESENTATIVES MADE UNSUITABLE RECOMMENDATION OF NON-TRADITIONAL ETFS TO CERTAIN CUSTOMERS WITH CONSERVATIVEINCOME OR CONSERVATIVE GROWTH & INCOME INVESTMENTOBJECTIVES AND/OR RISK TOLERANCES.

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 05/01/2012

Docket/Case Number: 2009019113901

Principal Product Type: Other

Other Product Type(s): NON-TRADITIONAL EXCHANGE TRADED FUNDS

FINRA RULE 2010, NASD RULES 2110, 2310, 3010 - WELLS FARGOADVISORS, LLC FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORYSYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH NASD AND FINRA RULES IN CONNECTIONWITH THE SALE OF NON-TRADITIONAL EXCHANGE-TRADED FUNDS (ETFS)IN ACCOUNTS WHERE THE FIRM PROVIDED BROKERAGE SERVICES TOCERTAIN RETAIL CUSTOMERS AND THE FIRM FAILED TO PROVIDEADEQUATE FORMAL TRAINING AND GUIDANCE TO ITS REGISTEREDREPRESENTATIVES AND SUPERVISORS REGARDING NON-TRADITIONALETFS. THE FIRM ALLOWED ITS REGISTERED REPRESENTATIVES TORECOMMEND A NON-TRADITIONAL ETF TO CUSTOMERS WITHOUTPERFORMING REASONABLE DILIGENCE TO UNDERSTAND THE RISKS ANDFEATURES ASSOCIATED WITH IT. CERTAIN FIRM REGISTEREDREPRESENTATIVES MADE UNSUITABLE RECOMMENDATION OF NON-TRADITIONAL ETFS TO CERTAIN CUSTOMERS WITH CONSERVATIVEINCOME OR CONSERVATIVE GROWTH & INCOME INVESTMENTOBJECTIVES AND/OR RISK TOLERANCES.

Resolution Date: 05/01/2012

Resolution:

Other Sanctions Ordered:

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 $2.1 MILLION AND ORDEREDTO PAY $641,489 IN RESTITUTION, JOINTLY AND SEVERALLY. AREGISTERED FIRM PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OFPAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTEDEFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATERTHAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. ANY UNDISTRIBUTEDRESTITUTION SHALL BE FORWARDED TO THE APPROPRIATE ESCHEAT,UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THESTATE IN WHICH THE CUSTOMER LAST RESIDED. THE FIRM SHALLPROVIDE SATISFACTORY PROOF OF SUCH ACTION TO FINRA WITHIN 14DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION TO THEAPPROPRIATE STATE AUTHORITY. FINE PAID IN FULL ON MAY 16, 2012.

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

No

Sanctions Ordered: CensureMonetary/Fine $2,100,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

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WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $2.1 MILLION AND ORDEREDTO PAY $641,489 IN RESTITUTION, JOINTLY AND SEVERALLY. AREGISTERED FIRM PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OFPAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTEDEFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATERTHAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. ANY UNDISTRIBUTEDRESTITUTION SHALL BE FORWARDED TO THE APPROPRIATE ESCHEAT,UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THESTATE IN WHICH THE CUSTOMER LAST RESIDED. THE FIRM SHALLPROVIDE SATISFACTORY PROOF OF SUCH ACTION TO FINRA WITHIN 14DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION TO THEAPPROPRIATE STATE AUTHORITY. FINE PAID IN FULL ON MAY 16, 2012.

iReporting Source: Firm

Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

CENSURERESTITUTION

Date Initiated: 05/01/2012

Docket/Case Number: 20090191139

Principal Product Type: Other

Other Product Type(s): NON-TRADITIONAL EXCHANGE TRADED FUNDS

Allegations: FINRA RULE 2010, NASD RULES 2110, 2310, 3010 - WELLS FARGOADVISORS, LLC FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORYSYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH NASD AND FINRA RULES IN CONNECTIONWITH THE SALE OF NON-TRADITIONAL EXCHANGE-TRADED FUNDS (ETFS)IN ACCOUNTS WHERE THE FIRM PROVIDED BROKERAGE SERVICES TOCERTAIN RETAIL CUSTOMERS AND THE FIRM FAILED TO PROVIDEADEQUATE FORMAL TRAINING AND GUIDANCE TO ITS REGISTEREDREPRESENTATIVES AND SUPERVISORS REGARDING NON-TRADITIONALETFS. THE FIRM ALLOWED ITS REGISTERED REPRESENTATIVES TORECOMMEND A NON-TRADITIONAL ETF TO CUSTOMERS WITHOUTPERFORMING REASONABLE DILIGENCE TO UNDERSTAND THE RISKS ANDFEATURES ASSOCIATED WITH IT. CERTAIN FIRM REGISTEREDREPRESENTATIVES MADE UNSUITABLE RECOMMENDATION OF NON-TRADITIONAL ETFS TO CERTAIN CUSTOMERS WITH CONSERVATIVEINCOME OR CONSERVATIVE GROWTH & INCOME INVESTMENTOBJECTIVES AND/OR RISK TOLERANCES.

Current Status: Final

Resolution Date: 05/01/2012

Resolution:

Other Sanctions Ordered:

Sanctions Ordered: CensureMonetary/Fine $2,100,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, AND WITH ITS AFFILIATE WELLSFARGO ADVISORS FINANCIAL NETWORK, LLC IS FINED $2.1 MILLION ANDORDERED TO PAY $641,489 IN RESTITUTION, JOINTLY AND SEVERALLY. AREGISTERED FIRM PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OFPAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTEDEFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATERTHAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. ANY UNDISTRIBUTEDRESTITUTION SHALL BE FORWARDED TO THE APPROPRIATE ESCHEAT,UNCLAIMED PROPERTY OR ABANDONED PROPERTY FUND FOR THESTATE IN WHICH THE CUSTOMER LAST RESIDED. THE FIRM SHALLPROVIDE SATISFACTORY PROOF OF SUCH ACTION TO FINRA WITHIN 14DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION TO THEAPPROPRIATE STATE AUTHORITY.

Disclosure 34 of 158

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Reporting Source: Regulator

Allegations: NASD RULES 2110, 3010(B)(1): THE FIRM FAILED TO ESTABLISH, MAINTAINAND ENFORCE ADEQUATE WRITTEN PROCEDURES RELATED TO THERESTORATION OR RELEASE OF ACCOUNTS FROM ABANDONED STATUS.THE FIRM'S WRITTEN PROCEDURES REQUIRED THAT EMPLOYEESWISHING TO RESTORE CUSTOMER ACCOUNTS FROM AN ABANDONEDSTATUS SEND A WRITTEN REQUEST TO ITS ESCHEATMENT GROUP TORESTORE THE ACCOUNT. THE FIRM'S WRITTEN PROCEDURES FAILED TOIDENTIFY THE FIRM PERSONNEL WHO WERE AUTHORIZED TO SUBMITREQUESTS TO HAVE ABANDONED ACCOUNTS RESTORED OR RELEASEDFROM ABANDONED STATUS. ESCHEATMENT ACCEPTED REQUESTS TORESTORE ABANDONED ACCOUNTS FROM BRANCH OFFICE PERSONNELWORKING IN THE BRANCH OFFICE WHERE THE ABANDONED ACCOUNTWAS LAST SERVICED. THE FIRM'S WRITTEN PROCEDURES DID NOTREQUIRE THAT THE REQUESTOR OBTAIN SUPERVISORY APPROVALBEFORE SUBMITTING REQUESTS TO HAVE ABANDONED ACCOUNTSRESTORED OR RELEASED FROM ABANDONED STATUS, DID NOT REQUIRETHE REQUESTOR TO SUBMIT PROOF TO ESCHEATMENT THAT ACUSTOMER HAD BEEN LOCATED AND DID NOT REQUIRE THE REQUESTORTO SUBMIT PROOF TO ESCHEATMENT OF THE CUSTOMER'S NEWADDRESS. THE FIRM'S PROCEDURES ALSO DID NOT REQUIRE THATESCHEATMENT NOTIFY BRANCH OFFICE MANAGERS WHEN ACCOUNTSWERE RESTORED TO ACTIVE STATUS. AFTER THE RESTORATION OF ANABANDONED ACCOUNT, THE REQUESTOR WAS REQUIRED TO SUBMIT ACHANGE OF ADDRESS REQUEST WITH THE CUSTOMER'S NEW ADDRESSTO THE FIRM'S NEW ACCOUNTS GROUP. UPON RECEIPT OF THE ADDRESSCHANGE REQUESTS, THE FIRM CHANGED THE ADDRESS OF RECORD OFTHE RESTORED ACCOUNT AND SENT LETTERS CONFIRMING THE CHANGEOF ADDRESS TO BOTH THE CUSTOMER'S NEW AND OLD ADDRESS,ALTHOUGH THE OLD ADDRESS WAS INVARIABLY AN INVALID ADDRESS.THE FIRM'S DEFICIENT PROCEDURES FACILITATED A FIRM OPERATIONSMANAGER'S CONVERSION OF APPROXIMATELY $850,000 IN CUSTOMERS'FUNDS FOR HER PERSONAL USE AND ENABLED THE OPERATIONSMANAGER'S CONDUCT TO ESCAPE DETECTION BY THE FIRM.

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 10/24/2011

Docket/Case Number: 2009020630701

Principal Product Type: No Product

Other Product Type(s):

NASD RULES 2110, 3010(B)(1): THE FIRM FAILED TO ESTABLISH, MAINTAINAND ENFORCE ADEQUATE WRITTEN PROCEDURES RELATED TO THERESTORATION OR RELEASE OF ACCOUNTS FROM ABANDONED STATUS.THE FIRM'S WRITTEN PROCEDURES REQUIRED THAT EMPLOYEESWISHING TO RESTORE CUSTOMER ACCOUNTS FROM AN ABANDONEDSTATUS SEND A WRITTEN REQUEST TO ITS ESCHEATMENT GROUP TORESTORE THE ACCOUNT. THE FIRM'S WRITTEN PROCEDURES FAILED TOIDENTIFY THE FIRM PERSONNEL WHO WERE AUTHORIZED TO SUBMITREQUESTS TO HAVE ABANDONED ACCOUNTS RESTORED OR RELEASEDFROM ABANDONED STATUS. ESCHEATMENT ACCEPTED REQUESTS TORESTORE ABANDONED ACCOUNTS FROM BRANCH OFFICE PERSONNELWORKING IN THE BRANCH OFFICE WHERE THE ABANDONED ACCOUNTWAS LAST SERVICED. THE FIRM'S WRITTEN PROCEDURES DID NOTREQUIRE THAT THE REQUESTOR OBTAIN SUPERVISORY APPROVALBEFORE SUBMITTING REQUESTS TO HAVE ABANDONED ACCOUNTSRESTORED OR RELEASED FROM ABANDONED STATUS, DID NOT REQUIRETHE REQUESTOR TO SUBMIT PROOF TO ESCHEATMENT THAT ACUSTOMER HAD BEEN LOCATED AND DID NOT REQUIRE THE REQUESTORTO SUBMIT PROOF TO ESCHEATMENT OF THE CUSTOMER'S NEWADDRESS. THE FIRM'S PROCEDURES ALSO DID NOT REQUIRE THATESCHEATMENT NOTIFY BRANCH OFFICE MANAGERS WHEN ACCOUNTSWERE RESTORED TO ACTIVE STATUS. AFTER THE RESTORATION OF ANABANDONED ACCOUNT, THE REQUESTOR WAS REQUIRED TO SUBMIT ACHANGE OF ADDRESS REQUEST WITH THE CUSTOMER'S NEW ADDRESSTO THE FIRM'S NEW ACCOUNTS GROUP. UPON RECEIPT OF THE ADDRESSCHANGE REQUESTS, THE FIRM CHANGED THE ADDRESS OF RECORD OFTHE RESTORED ACCOUNT AND SENT LETTERS CONFIRMING THE CHANGEOF ADDRESS TO BOTH THE CUSTOMER'S NEW AND OLD ADDRESS,ALTHOUGH THE OLD ADDRESS WAS INVARIABLY AN INVALID ADDRESS.THE FIRM'S DEFICIENT PROCEDURES FACILITATED A FIRM OPERATIONSMANAGER'S CONVERSION OF APPROXIMATELY $850,000 IN CUSTOMERS'FUNDS FOR HER PERSONAL USE AND ENABLED THE OPERATIONSMANAGER'S CONDUCT TO ESCAPE DETECTION BY THE FIRM.

Resolution Date: 10/24/2011

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED AND FINED $350,000.

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

No

Sanctions Ordered: CensureMonetary/Fine $350,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

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Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

MONETARY FINE OF $350,000.00

Date Initiated: 10/24/2011

Docket/Case Number: 20090206307

Principal Product Type: No Product

Other Product Type(s):

Allegations: NASD RULES 2110, 3010(B)(1): THE FIRM FAILED TO ESTABLISH, MAINTAINAND ENFORCE ADEQUATE WRITTEN PROCEDURES RELATED TO THERESTORATION OR RELEASE OF ACCOUNTS FROM ABANDONED STATUS.THE FIRM'S WRITTEN PROCEDURES REQUIRED THAT EMPLOYEESWISHING TO RESTORE CUSTOMER ACCOUNTS FROM AN ABANDONEDSTATUS SEND A WRITTEN REQUEST TO ITS ESCHEATMENT GROUP TORESTORE THE ACCOUNT. THE FIRM'S WRITTEN PROCEDURES FAILED TOIDENTIFY THE FIRM PERSONNEL WHO WERE AUTHORIZED TO SUBMITREQUESTS TO HAVE ABANDONED ACCOUNTS RESTORED OR RELEASEDFROM ABANDONED STATUS. ESCHEATMENT ACCEPTED REQUESTS TORESTORE ABANDONED ACCOUNTS FROM BRANCH OFFICE PERSONNELWORKING IN THE BRANCH OFFICE WHERE THE ABANDONED ACCOUNTWAS LAST SERVICED. THE FIRM'S WRITTEN PROCEDURES DID NOTREQUIRE THAT THE REQUESTOR OBTAIN SUPERVISORY APPROVALBEFORE SUBMITTING REQUESTS TO HAVE ABANDONED ACCOUNTSRESTORED OR RELEASED FROM ABANDONED STATUS, DID NOT REQUIRETHE REQUESTOR TO SUBMIT PROOF TO ESCHEATMENT THAT ACUSTOMER HAD BEEN LOCATED AND DID NOT REQUIRE THE REQUESTORTO SUBMIT PROOF TO ESCHEATMENT OF THE CUSTOMER'S NEWADDRESS. THE FIRM'S PROCEDURES ALSO DID NOT REQUIRE THATESCHEATMENT NOTIFY BRANCH OFFICE MANAGERS WHEN ACCOUNTSWERE RESTORED TO ACTIVE STATUS. AFTER THE RESTORATION OF ANABANDONED ACCOUNT, THE REQUESTOR WAS REQUIRED TO SUBMIT ACHANGE OF ADDRESS REQUEST WITH THE CUSTOMER'S NEW ADDRESSTO THE FIRM'S NEW ACCOUNTS GROUP. UPON RECEIPT OF THE ADDRESSCHANGE REQUESTS, THE FIRM CHANGED THE ADDRESS OF RECORD OFTHE RESTORED ACCOUNT AND SENT LETTERS CONFIRMING THE CHANGEOF ADDRESS TO BOTH THE CUSTOMER'S NEW AND OLD ADDRESS,ALTHOUGH THE OLD ADDRESS WAS INVARIABLY AN INVALID ADDRESS.THE FIRM'S DEFICIENT PROCEDURES FACILITATED A FIRM OPERATIONSMANAGER'S CONVERSION OF APPROXIMATELY $850,000 IN CUSTOMERS'FUNDS FOR HER PERSONAL USE AND ENABLED THE OPERATIONSMANAGER'S CONDUCT TO ESCAPE DETECTION BY THE FIRM.

Current Status: Final

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Other Sanction(s)/ReliefSought:

MONETARY FINE OF $350,000.00

Resolution Date: 10/24/2011

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED AND FINED $350,000.

Firm Statement IN APRIL 2011, THE FINANCIAL INDUSTRY REGULATORY AUTHORITY("FINRA") NOTIFIED WELLS FARGO ADVISORS, L.L.C. ("WELLS FARGO") OFITS INTENT TO RECOMMEND THAT WELLS FARGO BE SUBJECT TODISCIPLINARY ACTION FOR VIOLATIONS OF NASD RULE 3010(B)(1) ANDFINRA RULE 2010 FOR ITS FAILURE, FROM OCTOBER 2005 - MARCH 2007,TO ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES FOR THERESTORATION OF ACCOUNTS FROM "ABANDONED" TO "ACTIVE" STATUS.DURING THAT TIME, A REGISTERED PRINCIPAL OF WACHOVIA SECURITIES,LLC ("WACHOVIA"), N/K/A WELLS FARGO ADVISORS,LLCMISAPPROPRIATED APPROXIMATELY $847,188.87 OF ASSETS FROMABANDONED CLIENT ACCOUNTS BY FRAUDULENTLY RESTORING "ABANDONED" ACCOUNTS TO "ACTIVE" STATUS AND THEREAFTERFORGING CHECK AND WIRE TRANSFER DOCUMENTATION TO CONVERT "ABANDONED" ASSETS TO HER OWN USE AND BENEFIT. WACHOVIA WASA REGISTERED BROKER-DEALER AND WHOLLY-OWNED SUBSIDIARY OFWACHOVIA CORPORATION. WACHOVIA SECURITIES, LLC WAS RENAMEDWELLS FARGO ADVISORS, L.L.C. AFTER WACHOVIA CORPORATIONMERGED WITH WELLS FARGO & COMPANY ON DECEMBER 31, 2008.

AFTER DISCOVERING THE FRAUDULENT ACTIVITY, WACHOVIA RESTOREDALL FUNDS TO EACH AFFECTED ACCOUNT AND IMPLEMENTEDADDITIONAL POLICIES AND PROCEDURES TO STRENGTHEN OVERSIGHTOF THE PROCESS THROUGH WHICH ACCOUNTS ARE RESTORED FROM "ABANDONED" TO "ACTIVE" STATUS. WELLS FARGO HAS FULLYCOOPERATED WITH THE FINRA INVESTIGATION.

Sanctions Ordered: CensureMonetary/Fine $350,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 35 of 158

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Reporting Source: Regulator

Allegations: BY THE TERMS, WACHOVIA SECURITIES, LLC (RESPONDENT) DOES NOTADMIT OR DENY THE ALLEGATIONS OF THE PENNSYLVANIA SECURITIESCOMMISSION THAT THE RESPONDENT FAILED TO PROPERLY SUPERVISEITS REGISTERED REPRESENTATIVE IN VIOLATION OF THE PROVISIONS OFTHE PA SECURITIES ACT OF 1972.

Current Status: Final

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Initiated By: PENNSYLVANIA CONTACT: COUNSEL DANIEL J. GALLAGHER (717)-783-4226

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

WACHOVIA SECURITIES, LLC IS ORDERED TO PAY $150,000.00 TO THECOMMONWEALTH OF PENNSYLVANIA WITHIN 30 DAYS OF THE DATE OFTHIS ORDER, WHICH AMOUNT REPRESENTS AN ADMINISTRATIVEASSESSMENT.

Date Initiated: 09/20/2011

Docket/Case Number: 2010-03-23

URL for Regulatory Action:

Principal Product Type: No Product

Other Product Type(s):

Allegations: BY THE TERMS, WACHOVIA SECURITIES, LLC (RESPONDENT) DOES NOTADMIT OR DENY THE ALLEGATIONS OF THE PENNSYLVANIA SECURITIESCOMMISSION THAT THE RESPONDENT FAILED TO PROPERLY SUPERVISEITS REGISTERED REPRESENTATIVE IN VIOLATION OF THE PROVISIONS OFTHE PA SECURITIES ACT OF 1972.

Resolution Date: 09/20/2011

Resolution:

Other Sanctions Ordered:

Sanction Details: WACHOVIA SECURITIES, LLC IS ORDERED TO PAY $150,000.00 TO THECOMMONWEALTH OF PENNSYLVANIA WITHIN 30 DAYS OF THE DATE OFTHIS ORDER, WHICH AMOUNT REPRESENTS AN ADMINISTRATIVEASSESSMENT. WACHOVIA SECURITIES, LLC IS ORDERED TO PAY $8,557.85TO THE COMMONWEALTH OF PENNSYLVANIA WITHIN 30 DAYS OF THEDATE OF THIS ORDER, WHICH AMOUNT REPRESENTS LEGAL ANDINVESTIGATIVE COSTS.

Regulator Statement FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER ISSUED TOWACHOVICA SECURITIES, LLC.

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

No

Sanctions Ordered: Monetary/Fine $150,000.00

Settled

117©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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iReporting Source: Firm

Initiated By: PENNSYLVANIA SECURITIES COMMISSION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

WACHOVIA SECURITIES, LLC IS ORDERED TO PAY $150,000.00 TO THECOMMONWEALTH OF PENNSYLVANIA WITHIN 30DAYS OF THE DATE OF THIS ORDER, WHICH AMOUNT REPRESENTS ANADMINISTRATIVE ASSESSMENT.

Date Initiated: 09/20/2011

Docket/Case Number: 2010-03-23

Principal Product Type: Options

Other Product Type(s):

Allegations: THE COMMONWEALTH OF PENNSYLVANIA ALLEGED THAT THE FIRMFAILED TO SUPERVISE AN AGENT LOCATED IN MORGANTOWN, WV FROMJUNE 2007 TO OCTOBER 2008. WITHOUT ADMITTING ANY LIABILITY ORWRONGDOING, THE FIRM SETTLED THIS MATTER ON SEPTEMBER 20, 2011WITH THE CLIENT FOR THE AMOUNT OF $158,557.85. FINRA MATTER #WAS 20100226488.

Current Status: Final

Resolution Date: 09/20/2011

Resolution:

Other Sanctions Ordered: WITHIN 30 DAYS OF THE DATE OF THIS ORDER, WACHOVIA SECURITIES,LLC IS ORDERED TO PAY $8,557.85 TO THE COMMONWEALTH OFPENNSYLVANIA FOR LEGAL AND INVESTIGATIVE COSTS.

Sanction Details: WACHOVIA SECURITIES, LLC IS ORDERED TO PAY AN ADMINISTRATIVEASSESSMENT OF $150,000.00 AND LEGAL AND INVESTIGATIVE COSTS OF$8,557.85 TO THE COMMONWEALTH OF PENNSYLVANIA WITHIN 30 DAYS OFTHE DATE OF THIS ORDER. .

Firm Statement THE COMMONWEALTH OF PENNSYLVANIA ALLEGED THAT THE FIRMFAILED TO SUPERVISE AN AGENT LOCATED IN MORGANTOWN, WVDURING THE TIME PERIOD OF JUNE 2007 TO OCTOBER 2008. WITHOUTADMITTING ANY LIABILITY OR WRONGDOING, THE FIRM SETTLED THISMATTER WITH THE CLIENT ON SEPTEMBER 20, 2011 FOR THE AMOUNT OF$158,557.85. FINRA MATTER # 20100226488.

Sanctions Ordered: Monetary/Fine $150,000.00

Settled

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Disclosure 36 of 158

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Reporting Source: Firm

Initiated By: STATE OF NEW JERSEYOFFICE OF THE ATTORNEY GENERALBUREAU OF SECURITIES

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 09/27/2011

Docket/Case Number: CONSENT ORDER

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Allegations: THE STATE OF NEW JERSEY HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

Resolution Date: 09/27/2011

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TOCURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE IS DUE TO THE STATE OF NEW JERSEY ON OCTOBER 7, 2011.

Sanctions Ordered: CensureMonetary/Fine $3,234,065.06Disgorgement/Restitution

Consent

Disclosure 37 of 158

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Reporting Source: Firm

Allegations: IN AMENDED CONSENT ORDER, DOCKET NO. 2011-0312, IN THE MATTEROF WELLS FARGO ADVISORS, LLC, THE MARYLAND DIVISION OFSECURITIES ALLEGED THAT WELLS FARGO ADVISORS, LLC EMPLOYEDEIGHT INVESTMENT ADVISER REPRESENTATIVES WHO PROVIDEDINVESTMENT ADVISORY SERVICES TO CLIENTS PRIOR TO BEINGREGISTERED WITH THE SECURITIES DIVISION AS INVESTMENT ADVISERREPRESENTATIVES PURSUANT TO SECTION 11-402 OF THE MARYLANDSECURITIES ACT. THE DIVISION ALSO ALLEGED THAT THE FIRM FAILED TOTIMELY AMEND THE FORMS U4 OF TWO OF ITS AGENTS TO REFLECT THECHANGE IN THEIR EMPLOYMENT ADDRESS PURSUANT TO SECTION 11-411(D) OF THE MARYLAND SECURITIES ACT AND REGULATION 02.02.02.07OF THE CODE OF MARYLAND REGULATIONS. THE FIRM WAS ORDERED TOPAY A FINE OF $50,000 TO THE MARYLAND SECURITIES DIVISION, LESSTHE $5,000 FINE THE FIRM PAID TO THE DIVISION IN AUGUST 2011PURSUANT TO THE ORIGINAL CONSENT ORDER ISSUED IN THIS MATTER.THE FIRM WAS ALSO ORDERED TO FOLLOW THE COMPLIANCE POLICIESAND PROCEDURES PROVIDED TO THE DIVISION IN CONNECTION WITHTHE MATTER, AND COMPLY FULLY WITH THE MARYLAND SECURITIES ACTAND RULES AND REGULATIONS PROMULGATED THEREUNDER.

Current Status: Final

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Initiated By: STATE OF MARYLAND ATTORNEY GENERAL - SECURITIES DIVISION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 03/12/2012

Docket/Case Number: 2011-0312 (AMENDED)

Principal Product Type: No Product

Other Product Type(s): INVESTMENT ADVISORY SERVICES

IN AMENDED CONSENT ORDER, DOCKET NO. 2011-0312, IN THE MATTEROF WELLS FARGO ADVISORS, LLC, THE MARYLAND DIVISION OFSECURITIES ALLEGED THAT WELLS FARGO ADVISORS, LLC EMPLOYEDEIGHT INVESTMENT ADVISER REPRESENTATIVES WHO PROVIDEDINVESTMENT ADVISORY SERVICES TO CLIENTS PRIOR TO BEINGREGISTERED WITH THE SECURITIES DIVISION AS INVESTMENT ADVISERREPRESENTATIVES PURSUANT TO SECTION 11-402 OF THE MARYLANDSECURITIES ACT. THE DIVISION ALSO ALLEGED THAT THE FIRM FAILED TOTIMELY AMEND THE FORMS U4 OF TWO OF ITS AGENTS TO REFLECT THECHANGE IN THEIR EMPLOYMENT ADDRESS PURSUANT TO SECTION 11-411(D) OF THE MARYLAND SECURITIES ACT AND REGULATION 02.02.02.07OF THE CODE OF MARYLAND REGULATIONS. THE FIRM WAS ORDERED TOPAY A FINE OF $50,000 TO THE MARYLAND SECURITIES DIVISION, LESSTHE $5,000 FINE THE FIRM PAID TO THE DIVISION IN AUGUST 2011PURSUANT TO THE ORIGINAL CONSENT ORDER ISSUED IN THIS MATTER.THE FIRM WAS ALSO ORDERED TO FOLLOW THE COMPLIANCE POLICIESAND PROCEDURES PROVIDED TO THE DIVISION IN CONNECTION WITHTHE MATTER, AND COMPLY FULLY WITH THE MARYLAND SECURITIES ACTAND RULES AND REGULATIONS PROMULGATED THEREUNDER.

Resolution Date: 03/12/2012

Resolution:

Other Sanctions Ordered: FOLLOW THE COMPLIANCE POLICIES AND PROCEDURES THAT THE FIRMDESIGNED TO PREVENT ANY FURTHER UNREGISTERED INVESTMENTADVISOR REPRESENTATIVE ACTIVITIES AND LATE AMENDMENT FILINGSAND COMPLY FULLY WITH THE MARYLAND SECURITIES ACT AND THERULES AND REGULATIONS PROMULGATED THEREUNDER.

Sanction Details: THE FIRM WAS ORDERED TO PAY A FINE OF $50,000 TO THE MARYLANDSECURITIES DIVISION, LESS THE $5,000 FINE THE FIRM PAID TO THEDIVISION IN AUGUST 2011 PURSUANT TO THE ORIGINAL CONSENT ORDERISSUED IN THIS MATTER.

Firm Statement IN AMENDED CONSENT ORDER, DOCKET NO. 2011-0312, IN THE MATTEROF WELLS FARGO ADVISORS, LLC, THE MARYLAND DIVISION OFSECURITIES ALLEGED THAT WELLS FARGO ADVISORS, LLC EMPLOYEDEIGHT INVESTMENT ADVISER REPRESENTATIVES WHO PROVIDEDINVESTMENT ADVISORY SERVICES TO CLIENTS PRIOR TO BEINGREGISTERED WITH THE SECURITIES DIVISION AS INVESTMENT ADVISERREPRESENTATIVES PURSUANT TO SECTION 11-402 OF THE MARYLANDSECURITIES ACT. THE DIVISION ALSO ALLEGED THAT THE FIRM FAILED TOTIMELY AMEND THE FORMS U4 OF TWO OF ITS AGENTS TO REFLECT THECHANGE IN THEIR EMPLOYMENT ADDRESS PURSUANT TO SECTION 11-411(D) OF THE MARYLAND SECURITIES ACT AND REGULATION 02.02.02.07OF THE CODE OF MARYLAND REGULATIONS. THE FIRM WAS ORDERED TOPAY A FINE OF $50,000 TO THE MARYLAND SECURITIES DIVISION, LESSTHE $5,000 FINE THE FIRM PAID TO THE DIVISION IN AUGUST 2011PURSUANT TO THE ORIGINAL CONSENT ORDER ISSUED IN THIS MATTER.THE FIRM WAS ALSO ORDERED TO FOLLOW THE COMPLIANCE POLICIESAND PROCEDURES PROVIDED TO THE DIVISION IN CONNECTION WITHTHE MATTER, AND COMPLY FULLY WITH THE MARYLAND SECURITIES ACTAND RULES AND REGULATIONS PROMULGATED THEREUNDER.

Sanctions Ordered: Monetary/Fine $50,000.00

Consent

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Firm Statement IN AMENDED CONSENT ORDER, DOCKET NO. 2011-0312, IN THE MATTEROF WELLS FARGO ADVISORS, LLC, THE MARYLAND DIVISION OFSECURITIES ALLEGED THAT WELLS FARGO ADVISORS, LLC EMPLOYEDEIGHT INVESTMENT ADVISER REPRESENTATIVES WHO PROVIDEDINVESTMENT ADVISORY SERVICES TO CLIENTS PRIOR TO BEINGREGISTERED WITH THE SECURITIES DIVISION AS INVESTMENT ADVISERREPRESENTATIVES PURSUANT TO SECTION 11-402 OF THE MARYLANDSECURITIES ACT. THE DIVISION ALSO ALLEGED THAT THE FIRM FAILED TOTIMELY AMEND THE FORMS U4 OF TWO OF ITS AGENTS TO REFLECT THECHANGE IN THEIR EMPLOYMENT ADDRESS PURSUANT TO SECTION 11-411(D) OF THE MARYLAND SECURITIES ACT AND REGULATION 02.02.02.07OF THE CODE OF MARYLAND REGULATIONS. THE FIRM WAS ORDERED TOPAY A FINE OF $50,000 TO THE MARYLAND SECURITIES DIVISION, LESSTHE $5,000 FINE THE FIRM PAID TO THE DIVISION IN AUGUST 2011PURSUANT TO THE ORIGINAL CONSENT ORDER ISSUED IN THIS MATTER.THE FIRM WAS ALSO ORDERED TO FOLLOW THE COMPLIANCE POLICIESAND PROCEDURES PROVIDED TO THE DIVISION IN CONNECTION WITHTHE MATTER, AND COMPLY FULLY WITH THE MARYLAND SECURITIES ACTAND RULES AND REGULATIONS PROMULGATED THEREUNDER.

Disclosure 38 of 158

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Reporting Source: Regulator

Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

ADMINISTRATIVE FINE

Date Initiated: 06/21/2011

Docket/Case Number: 0154-SR-5/11

URL for Regulatory Action:

Principal Product Type: No Product

Other Product Type(s):

Allegations: N/A

Current Status: Final

Resolution Date: 06/21/2011

Resolution:

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

No

Stipulation and Consent

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Other Sanctions Ordered:

Sanction Details: $65,000 ADMINISTRATIVE FINE WAS LEVIED AGAINST WELLS FARGOADVISORS LLC. THE FINE WAS PAID IN FULL ON 6/21/2011.

Regulator Statement ON 6/21/2011 THE OFFICE OF FINANCIAL REGULATION ENTERED A FINALORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THEMATTER OF WELLS FARGO ADVISORS, LLC. WELLS FARGO ADVISORS LLCNEITHER ADMITTED NOR DENIED THE FINDINGS BUT CONSENT TO THEENTRY OF FINDINGS BY THE OFFICE.THE OFFICE FOUND THAT BEGINNING IN OCTOBER 2004, WELLS FARGOADVISORS LLC, ACTING THROUGH 13 INDIVIDUALS, ENGAGED ININVESTMENT ADVISORY BUSINESS FROM OFFICES WITHIN THIS STATEWITHOUT THE 13 INDIVIDUALS BEING LAWFULLY REGISTRATION IN THESTATE OF FLORIDA IN VIOLATION OF SECTION 517.12(4), F. S. WELLSFARGO ADVISORS LLC AGREED TO CEASE AND DESIST FROM ALLPRESENT AND FUTURE VIOLATIONS OF CHAPTER 517, F.S. AND THEADMINISTRATIVE RULES THEREUNDER; AND TO PAY AN ADMINISTRATIVEFINE IN THE AMOUNT OF $65,000.

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

No

Sanctions Ordered: Monetary/Fine $65,000.00Cease and Desist/Injunction

iReporting Source: Firm

Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION

Date Initiated: 06/21/2011

Docket/Case Number: 0154-SR-5/11

Principal Product Type: No Product

Other Product Type(s):

Allegations: THE OFFICE FOUND THAT BEGINNING IN OCTOBER 2004, WELLS FARGOADVISORS LLC, ACTING THROUGH 13 INDIVIDUALS, ENGAGED ININVESTMENT ADVISORY BUSINESS FROM OFFICES WITHIN THIS STATEWITHOUT THE 13 INDIVIDUALS BEING LAWFULLY REGISTERED IN THESTATE OF FLORIDA AS INVESTMENT ADVISOR REPRESENTATIVES FORTHE FIRM IN VIOLATION OF SECTION 517.12(4), F. S.

Current Status: Final

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www.finra.org/brokercheck User Guidance

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

ADMINISTRATIVE FINE

Other Product Type(s):

Resolution Date: 06/21/2011

Resolution:

Other Sanctions Ordered:

Sanction Details: $65,000 ADMINISTRATIVE FINE WAS LEVIED AGAINST WELLS FARGOADVISORS LLC. THE FINE WAS PAID IN FULL ON6/21/2011.

Firm Statement ON 6/21/2011 THE OFFICE OF FINANCIAL REGULATION ENTERED A FINALORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THEMATTER OF WELLS FARGO ADVISORS, LLC.WELLS FARGO ADVISORS LLC NEITHER ADMITTED NOR DENIED THEFINDINGS BUT CONSENTED TO THE ENTRY OF FINDINGS BY THE OFFICE.THE OFFICE FOUND THAT BEGINNING IN OCTOBER 2004, WELLS FARGOADVISORS LLC, ACTING THROUGH 13 INDIVIDUALS, ENGAGED ININVESTMENT ADVISORY BUSINESS FROM OFFICES WITHIN THIS STATEWITHOUT THE 13 INDIVIDUALS BEING LAWFULLYREGISTERED IN THE STATE OF FLORIDA IN VIOLATION OF SECTION 517.12(4), F. S. WELLS FARGO ADVISORS LLC AGREED TO CEASE AND DESISTFROM ALL PRESENT AND FUTURE VIOLATIONS OF CHAPTER 517, F.S. ANDTHE ADMINISTRATIVE RULES THEREUNDER; AND TO PAY ANADMINISTRATIVE FINE IN THE AMOUNT OF $65,000.

Sanctions Ordered: Monetary/Fine $65,000.00Cease and Desist/Injunction

Stipulation and Consent

Disclosure 39 of 158

i

Reporting Source: Regulator

Initiated By: FINRA

Allegations: MSRB RULES G-14(B)(II), G-15(A)(I) - WELLS FARGO ADVISORS, LLC FAILEDTO REPORT THE CORRECT YIELD TO THE REAL-TIME TRANSACTIONREPORTING SYSTEM (RTRS) IN REPORTS OF TRANSACTIONS INMUNICIPAL SECURITIES. THE FIRM FAILED TO PROVIDE WRITTENNOTIFICATION DISCLOSING TO ITS CUSTOMER THE CORRECT LOWESTEFFECTED YIELD IN MOST OF THESE TRANSACTIONS IN MUNICIPALSECURITIES.

Current Status: Final

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www.finra.org/brokercheck User Guidance

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 06/17/2011

Docket/Case Number: 2009020728001

Principal Product Type: Debt - Municipal

Other Product Type(s):

Resolution Date: 06/17/2011

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $20,000 FOR VIOLATIONSOF MSRB RULES G-14(B)(II) AND G-15(A)(I).

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

No

Sanctions Ordered: CensureMonetary/Fine $20,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)

Date Initiated: 06/17/2011

Allegations: MSRB RULES G-14(B)(II), G-15(A)(I) - WELLS FARGO ADVISORS, LLC FAILEDTO REPORT THE CORRECT YIELD TO THE REAL-TIME TRANSACTIONREPORTING SYSTEM (RTRS) IN REPORTS OF TRANSACTIONS INMUNICIPAL SECURITIES. THE FIRM FAILED TO PROVIDE WRITTENNOTIFICATION DISCLOSING TO ITS CUSTOMER THE CORRECT LOWESTEFFECTED YIELD IN MOST OF THESE TRANSACTIONS IN MUNICIPALSECURITIES.

Current Status: Final

124©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

CENSURE

Date Initiated: 06/17/2011

Docket/Case Number: 2009020728001

Principal Product Type: Debt - Municipal

Other Product Type(s):

Resolution Date: 06/17/2011

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TOTHE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED ANDFINED $20,000 FOR VIOLATIONS OF MSRB RULESG-14(B)(II) AND G-15(A)(I).

Sanctions Ordered: CensureMonetary/Fine $20,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 40 of 158

i

Reporting Source: Firm

Initiated By: STATE OF NEW HAMPSHIREDEPARTMENT OF STATEBUREAU OF SECURITIES REGULATIONS

Principal Sanction(s)/ReliefSought:

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

Date Initiated: 05/02/2011

Docket/Case Number: ADMINISTRATIVE CONSENT ORDER: INV- 2009000015

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Allegations: THE STATE OF NEW HAMPSHIRE-DEPARTMENT OF STATE-BUREAU OFSECURITIES REGULATIONS HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

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www.finra.org/brokercheck User Guidance

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Resolution Date: 05/02/2011

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TOCURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS.

Sanction Details: THE FINE WAS SENT TO THE STATE OF NEW HAMPSHIRE-DEPARTMENT OFSTATE-BUREAU OF SECURITIES REGULATIONS ON MAY 9, 2011.

Sanctions Ordered: Monetary/Fine $289,021.88Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 41 of 158

i

Reporting Source: Regulator

Allegations: FINRA BY-LAWS ARTICLE V, SECTIONS 2(C) AND 3(B), FINRA RULE 2010,NASD RULE 2110: THE FIRM WAS REQUIRED TO PROVIDE EACH OF ITSCUSTOMERS WHO PURCHASED A MUTUAL FUND A PHYSICAL COPY OF APROSPECTUS FOR THAT FUND NO LATER THAN THREE BUSINESS DAYSAFTER THE TRANSACTION, BUT IT FAILED TO DELIVER PROSPECTUS TOITS CUSTOMERS WITHIN THREE DAYS OF THEIR PURCHASES IN 934,074MUTUAL FUND TRANSACTIONS ACTING IN CONTRAVENTION OF SECTION5(B)(2) OF THE SECURITIES ACT OF 1933 AND THEREBY VIOLATED FINRARULE 2010. SECTION 5(B)(2) OF THE SECURITIES ACT PROHIBITS THEDELIVERY OF CERTAIN SECURITIES UNLESS SUCH DELIVERY ISACCOMPANIED BY OR PRECEDED BY A PHYSICAL COPY OF APROSPECTUS THAT MEETS THE REQUIREMENTS OF THE SECURITIES ACT.THE FEDERAL SECURITIES LAWS REQUIRE THE DELIVERY OF APROSPECTUS TO INVESTORS BECAUSE IT PROVIDES THEM WITHIMPORTANT DISCLOSURE INFORMATION REGARDING THE PRODUCTBEING PURCHASED. THE FIRM SATISFIED ITS PROSPECTUS DELIVERYOBLIGATION BY CONTRACTING WITH A THIRD PARTY SERVICE PROVIDERFOR THE DELIVERY OF PROSPECTUSES. THE FIRM'S PERSONNEL HADDAILY CONTACT WITH THE SERVICE PROVIDER'S PERSONNEL TORESOLVE EXCEPTIONS ON THE REPORTS, ALONG WITH OTHER ISSUESRELATING TO DELIVERY OF PROSPECTUSES. THE FIRM DID NOT TIMELYDELIVER, OR DID NOT ENSURE THAT THE SERVICE PROVIDER TIMELYDELIVERED, PROSPECTUSES TO CERTAIN CUSTOMERS WHO PURCHASEDMUTUAL FUNDS. IN 934,074 SEPARATE INSTANCES THE FIRM'SCUSTOMERS WHO PURCHASED MUTUAL FUNDS DID NOT RECEIVE APROSPECTUS WITHIN THREE BUSINESS DAYS OF THE TRANSACTION.THOSE CUSTOMERS RECEIVED THE PROSPECTUSES BETWEEN ONE AND153 DAYS LATE. OUT OF THE 934,074 SEPARATE INSTANCES IN WHICHDELIVERY WAS UNTIMELY, 47% WERE DELIVERED WITHIN THREE DAYS OFSETTLEMENT DATE, 69% WERE DELIVERED WITHIN SEVEN DAYS OFSETTLEMENT, AND 94% WERE DELIVERED WITHIN 14 DAYS OFSETTLEMENT DATE. THE PRIMARY CAUSE OF THE LATE DELIVERIES WASTHE FAILURE OF CERTAIN MUTUAL FUND COMPANIES TO MAINTAINADEQUATE SUPPLIES OF PAPER COPIES OF PROSPECTUSES. AS ARESULT, FOR MANY PURCHASES FROM THESE FUND COMPANIES,NEITHER THE SERVICE PROVIDER NOR THE FIRM COULD OBTAIN APROSPECTUS TO TIMELY PROVIDE TO THE CUSTOMER. THE FIRM DIDNOT TAKE STEPS TO CHANGE THE PRACTICES OF THOSE FUNDCOMPANIES THAT DID NOT KEEP ADEQUATE STOCKS OF PROSPECTUSES.THE FIRM ALSO DID NOT TAKE REMEDIAL STEPS AVAILABLE TO IT TOENSURE THAT ITS CUSTOMERS WERE RECEIVING PROSPECTUSES IN ATIMELY FASHION. FOR INSTANCE, THE SERVICE PROVIDER OFFERED A "PRINT ON DEMAND" ("POD") SERVICE AND POD SERVICE ALLOWED THESERVICE PROVIDER TO OBTAIN ELECTRONIC COPIES OF MUTUAL FUNDPROSPECTUSES FROM THOSE MUTUAL FUND COMPANIES THAT OFFEREDTHEM, AND TO THEN PRINT COPIES OF THE PROSPECTUSES AND SENDTHEM TO THE FIRM'S CUSTOMERS. WITH POD, EVEN IF THE MUTUAL FUNDCOMPANY DID NOT HAVE ADEQUATE SUPPLIES OF PAPER COPIES OFPROSPECTUSES IN STOCK, THE SERVICE PROVIDER COULD PRINT THEELECTRONICALLY-AVAILABLE PROSPECTUS, AND SEND IT TO THECUSTOMER. THE FIRM DID NOT USE THIS SERVICE EXTENSIVELY DURINGTHE RELEVANT PERIOD. THE FIRM HAD NOTICE THAT ITS CUSTOMERSWERE NOT RECEIVING PROSPECTUSES ON A TIMELY BASIS BOTHBEFORE AND DURING THE RELEVANT PERIOD. THE REPORTS PROVIDEDBY THE SERVICE PROVIDER IDENTIFIED THE EXTENT OF THE UN-TIMELINESS OF EACH PROSPECTUS THAT HAD NOT YET BEENDELIVERED. IN ALMOST ALL INSTANCES IN WHICH A FIRM CUSTOMERRECEIVED A PROSPECTUS LATE, THE DAILY REPORTS PROVIDED BY THESERVICE PROVIDER WOULD HAVE IDENTIFIED THE TRANSACTION ON ADAILY BASIS UNTIL THE PROSPECTUS WAS DELIVERED TO THECUSTOMER. FURTHER, THE FIRM OPERATIONS PERSONNEL WHOREVIEWED THESE DAILY REPORTS AND UPDATED INFORMATION FOR THESERVICE PROVIDER WOULD HAVE HAD REGULAR CONTACT WITH THESERVICE PROVIDER TO RESOLVE ISSUES RELATING TO PROSPECTUSESTHAT HAD NOT YET BEEN DELIVERED TO THE FIRM'S CUSTOMERS.(CONTINUE IN THE COMMENT SECTION)

Current Status: Final

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www.finra.org/brokercheck User Guidance

Initiated By: FINRA

FINRA BY-LAWS ARTICLE V, SECTIONS 2(C) AND 3(B), FINRA RULE 2010,NASD RULE 2110: THE FIRM WAS REQUIRED TO PROVIDE EACH OF ITSCUSTOMERS WHO PURCHASED A MUTUAL FUND A PHYSICAL COPY OF APROSPECTUS FOR THAT FUND NO LATER THAN THREE BUSINESS DAYSAFTER THE TRANSACTION, BUT IT FAILED TO DELIVER PROSPECTUS TOITS CUSTOMERS WITHIN THREE DAYS OF THEIR PURCHASES IN 934,074MUTUAL FUND TRANSACTIONS ACTING IN CONTRAVENTION OF SECTION5(B)(2) OF THE SECURITIES ACT OF 1933 AND THEREBY VIOLATED FINRARULE 2010. SECTION 5(B)(2) OF THE SECURITIES ACT PROHIBITS THEDELIVERY OF CERTAIN SECURITIES UNLESS SUCH DELIVERY ISACCOMPANIED BY OR PRECEDED BY A PHYSICAL COPY OF APROSPECTUS THAT MEETS THE REQUIREMENTS OF THE SECURITIES ACT.THE FEDERAL SECURITIES LAWS REQUIRE THE DELIVERY OF APROSPECTUS TO INVESTORS BECAUSE IT PROVIDES THEM WITHIMPORTANT DISCLOSURE INFORMATION REGARDING THE PRODUCTBEING PURCHASED. THE FIRM SATISFIED ITS PROSPECTUS DELIVERYOBLIGATION BY CONTRACTING WITH A THIRD PARTY SERVICE PROVIDERFOR THE DELIVERY OF PROSPECTUSES. THE FIRM'S PERSONNEL HADDAILY CONTACT WITH THE SERVICE PROVIDER'S PERSONNEL TORESOLVE EXCEPTIONS ON THE REPORTS, ALONG WITH OTHER ISSUESRELATING TO DELIVERY OF PROSPECTUSES. THE FIRM DID NOT TIMELYDELIVER, OR DID NOT ENSURE THAT THE SERVICE PROVIDER TIMELYDELIVERED, PROSPECTUSES TO CERTAIN CUSTOMERS WHO PURCHASEDMUTUAL FUNDS. IN 934,074 SEPARATE INSTANCES THE FIRM'SCUSTOMERS WHO PURCHASED MUTUAL FUNDS DID NOT RECEIVE APROSPECTUS WITHIN THREE BUSINESS DAYS OF THE TRANSACTION.THOSE CUSTOMERS RECEIVED THE PROSPECTUSES BETWEEN ONE AND153 DAYS LATE. OUT OF THE 934,074 SEPARATE INSTANCES IN WHICHDELIVERY WAS UNTIMELY, 47% WERE DELIVERED WITHIN THREE DAYS OFSETTLEMENT DATE, 69% WERE DELIVERED WITHIN SEVEN DAYS OFSETTLEMENT, AND 94% WERE DELIVERED WITHIN 14 DAYS OFSETTLEMENT DATE. THE PRIMARY CAUSE OF THE LATE DELIVERIES WASTHE FAILURE OF CERTAIN MUTUAL FUND COMPANIES TO MAINTAINADEQUATE SUPPLIES OF PAPER COPIES OF PROSPECTUSES. AS ARESULT, FOR MANY PURCHASES FROM THESE FUND COMPANIES,NEITHER THE SERVICE PROVIDER NOR THE FIRM COULD OBTAIN APROSPECTUS TO TIMELY PROVIDE TO THE CUSTOMER. THE FIRM DIDNOT TAKE STEPS TO CHANGE THE PRACTICES OF THOSE FUNDCOMPANIES THAT DID NOT KEEP ADEQUATE STOCKS OF PROSPECTUSES.THE FIRM ALSO DID NOT TAKE REMEDIAL STEPS AVAILABLE TO IT TOENSURE THAT ITS CUSTOMERS WERE RECEIVING PROSPECTUSES IN ATIMELY FASHION. FOR INSTANCE, THE SERVICE PROVIDER OFFERED A "PRINT ON DEMAND" ("POD") SERVICE AND POD SERVICE ALLOWED THESERVICE PROVIDER TO OBTAIN ELECTRONIC COPIES OF MUTUAL FUNDPROSPECTUSES FROM THOSE MUTUAL FUND COMPANIES THAT OFFEREDTHEM, AND TO THEN PRINT COPIES OF THE PROSPECTUSES AND SENDTHEM TO THE FIRM'S CUSTOMERS. WITH POD, EVEN IF THE MUTUAL FUNDCOMPANY DID NOT HAVE ADEQUATE SUPPLIES OF PAPER COPIES OFPROSPECTUSES IN STOCK, THE SERVICE PROVIDER COULD PRINT THEELECTRONICALLY-AVAILABLE PROSPECTUS, AND SEND IT TO THECUSTOMER. THE FIRM DID NOT USE THIS SERVICE EXTENSIVELY DURINGTHE RELEVANT PERIOD. THE FIRM HAD NOTICE THAT ITS CUSTOMERSWERE NOT RECEIVING PROSPECTUSES ON A TIMELY BASIS BOTHBEFORE AND DURING THE RELEVANT PERIOD. THE REPORTS PROVIDEDBY THE SERVICE PROVIDER IDENTIFIED THE EXTENT OF THE UN-TIMELINESS OF EACH PROSPECTUS THAT HAD NOT YET BEENDELIVERED. IN ALMOST ALL INSTANCES IN WHICH A FIRM CUSTOMERRECEIVED A PROSPECTUS LATE, THE DAILY REPORTS PROVIDED BY THESERVICE PROVIDER WOULD HAVE IDENTIFIED THE TRANSACTION ON ADAILY BASIS UNTIL THE PROSPECTUS WAS DELIVERED TO THECUSTOMER. FURTHER, THE FIRM OPERATIONS PERSONNEL WHOREVIEWED THESE DAILY REPORTS AND UPDATED INFORMATION FOR THESERVICE PROVIDER WOULD HAVE HAD REGULAR CONTACT WITH THESERVICE PROVIDER TO RESOLVE ISSUES RELATING TO PROSPECTUSESTHAT HAD NOT YET BEEN DELIVERED TO THE FIRM'S CUSTOMERS.(CONTINUE IN THE COMMENT SECTION)

127©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 05/04/2011

Docket/Case Number: 2010022921801

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Resolution Date: 05/04/2011

Resolution:

Other Sanctions Ordered: UNDERTAKINGS

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED AND FINED $1,000,000. THE FIRMFURTHER UNDERTAKES TO COMPLETE THE FOLLOWING WITHIN 120 DAYSOF NOTICES OF ACCEPTANCE OF THIS AWC: (I) ADOPT AND IMPLEMENTSYSTEMS AND PROCEDURES REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND FINRA RULESAPPLICABLE TO FILING, AND TIMELY FILING, OF FORMS U4 AND U5, AND (II)PROVIDE A WRITTEN CERTIFICATION BY A DULY AUTHORIZED SENIOROFFICER OF THE FIRM THAT THE FIRM HAS ADOPTED AND IMPLEMENTEDSUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND FINRARULES APPLICABLE TO FILING, AND TIMELY FILING, OF FORMS U4 AND U5.

Regulator Statement ALSO, THE SERVICE PROVIDER MET WITH THE FIRM OFFICIALS ON AQUARTERLY BASIS THROUGHOUT THE RELEVANT PERIOD TO PROVIDESTATISTICAL DATA REGARDING AMONG OTHER THINGS, MUTUAL FUNDPROSPECTUS DELIVERY. DURING THESE MEETING, THE FIRM RECEIVEDSTATISTICAL DATA INDICATING THAT THE FIRM'S CUSTOMERS WERE NOTTIMELY RECEIVING PROSPECTUSES IN 4% TO 9% OF THE MUTUAL FUNDTRANSACTIONS CONDUCTED BY THE FIRM DURING THIS TIME. THE FIRMALSO ITSELF CREATED AND ANALYZED DATA INDICATING THAT ITSCUSTOMERS WERE NOT RECEIVING PROSPECTUSES ON A TIMELY BASIS.BOTH PRIOR TO AND THROUGHOUT THE RELEVANT PERIOD THE FIRM'SMANAGEMENT SUPERVISORY GROUP RESPONSIBLE FOR PROSPECTUSDELIVERY CONDUCTED A MONTHLY REVIEW IDENTIFYING STATISTICALINFORMATION REGARDING PROSPECTUS DELIVERY FOR, AMONG OTHERTHINGS, MUTUAL FUNDS. THIS DATA FURTHER SHOWED THAT THE FIRM'SCUSTOMERS WERE NOT TIMELY RECEIVING MUTUAL FUNDPROSPECTUSES. BECAUSE OF THE FIRM'S FAILURE TO TIMELY DELIVERPROSPECTUSES TO ITS CUSTOMERS WHO PURCHASED MUTUAL FUNDS,THESE CUSTOMERS WERE NOT PROVIDED WITH IMPORTANTDISCLOSURE INFORMATION AMOUNT THESE PRODUCTS. THE FIRM FILED147 LATE AMENDMENTS TO FORMS U4, RELATING TO CUSTOMERCOMPLAINTS, ARBITRATIONS, CIVIL LITIGATION, REGULATORY MATTERSAND BANKRUPTCIES. THIS REPRESENTED 8.1% OF THE 1,808 FORM U4AMENDMENTS THE FIRM WAS REQUIRED TO FILE. THE FIRM FILED 40 LATEAMENDMENTS TO FORMS U5, RELATING TO CUSTOMER COMPLAINTS,ARBITRATIONS, AND CIVIL LITIGATION. THIS REPRESENTED 7.6% OF THE522 FORM U5 AMENDMENTS THE FIRM WAS REQUIRED TO FILE DURINGTHIS PERIOD.

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

No

Sanctions Ordered: CensureMonetary/Fine $1,000,000.00

Acceptance, Waiver & Consent(AWC)

128©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User GuidanceALSO, THE SERVICE PROVIDER MET WITH THE FIRM OFFICIALS ON AQUARTERLY BASIS THROUGHOUT THE RELEVANT PERIOD TO PROVIDESTATISTICAL DATA REGARDING AMONG OTHER THINGS, MUTUAL FUNDPROSPECTUS DELIVERY. DURING THESE MEETING, THE FIRM RECEIVEDSTATISTICAL DATA INDICATING THAT THE FIRM'S CUSTOMERS WERE NOTTIMELY RECEIVING PROSPECTUSES IN 4% TO 9% OF THE MUTUAL FUNDTRANSACTIONS CONDUCTED BY THE FIRM DURING THIS TIME. THE FIRMALSO ITSELF CREATED AND ANALYZED DATA INDICATING THAT ITSCUSTOMERS WERE NOT RECEIVING PROSPECTUSES ON A TIMELY BASIS.BOTH PRIOR TO AND THROUGHOUT THE RELEVANT PERIOD THE FIRM'SMANAGEMENT SUPERVISORY GROUP RESPONSIBLE FOR PROSPECTUSDELIVERY CONDUCTED A MONTHLY REVIEW IDENTIFYING STATISTICALINFORMATION REGARDING PROSPECTUS DELIVERY FOR, AMONG OTHERTHINGS, MUTUAL FUNDS. THIS DATA FURTHER SHOWED THAT THE FIRM'SCUSTOMERS WERE NOT TIMELY RECEIVING MUTUAL FUNDPROSPECTUSES. BECAUSE OF THE FIRM'S FAILURE TO TIMELY DELIVERPROSPECTUSES TO ITS CUSTOMERS WHO PURCHASED MUTUAL FUNDS,THESE CUSTOMERS WERE NOT PROVIDED WITH IMPORTANTDISCLOSURE INFORMATION AMOUNT THESE PRODUCTS. THE FIRM FILED147 LATE AMENDMENTS TO FORMS U4, RELATING TO CUSTOMERCOMPLAINTS, ARBITRATIONS, CIVIL LITIGATION, REGULATORY MATTERSAND BANKRUPTCIES. THIS REPRESENTED 8.1% OF THE 1,808 FORM U4AMENDMENTS THE FIRM WAS REQUIRED TO FILE. THE FIRM FILED 40 LATEAMENDMENTS TO FORMS U5, RELATING TO CUSTOMER COMPLAINTS,ARBITRATIONS, AND CIVIL LITIGATION. THIS REPRESENTED 7.6% OF THE522 FORM U5 AMENDMENTS THE FIRM WAS REQUIRED TO FILE DURINGTHIS PERIOD.

iReporting Source: Firm

Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)

Principal Sanction(s)/ReliefSought:

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

Date Initiated: 05/04/2011

Docket/Case Number: 2010022921801

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations: FINRA ALLEGED THAT WFA FAILED TO DELIVER PROSPECTUSES TO ITSCUSTOMERS WITHIN THREE BUSINESS DAYS OF THEIR PURCHASESIN 934,047 MUTUAL FUND TRANSACTIONS BETWEEN JANUARY 1, 2009 ANDDECEMBER 31, 2009 (THE "RELEVANT PERIOD").

FINRA ALLEGED THAT WFA FAILED TO TIMELY FILE CERTAIN AMENDMENTSTO UNIFORM APPLICATIONS FOR SECURITIES INDUSTRY OR TRANSFER("FORMS U4") AND UNIFORM TERMINATION NOTICES FOR SECURITIESINDUSTRY REGISTRATION ("FORMS U5") FROMJULY 1, 2008 TO JUNE 30, 2009.

Current Status: Final

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www.finra.org/brokercheck User Guidance

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

CENSUREUNDERTAKINGS

Resolution Date: 05/04/2011

Resolution:

Other Sanctions Ordered: WFA FURTHER UNDERTAKES WITHIN 120 DAYS TO:(1) ADOPT AND IMPLEMENT SYSTEMS AND PROCEDURES REASONABLYDESIGNED TO ACHEIVE TIMELY FILING OF FORMS U4 AND FORMS U5.(2) PROVIDE WRITTEN CERTIFICATION BY A DULY AUTHORIZED SENIOROFFICER OF WFA THAT THE FIRM HAS ADOPTED AND IMPLEMENTEDSUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TOACHEIVE TIMELY FILING OF FORMS U4 AND FORMS U5.

Sanction Details: $1,000,000 FINE TO WFA

Firm Statement AWC ACCEPTED ON MAY 4, 2011

Sanctions Ordered: CensureMonetary/Fine $1,000,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 42 of 158

i

Reporting Source: Regulator

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 05/02/2011

Docket/Case Number: 2006005324201

Principal Product Type: Debt - Corporate

Other Product Type(s):

Allegations: NASD RULES 2110, 2320: IN EIGHT TRANSACTIONS FOR OR WITH ACUSTOMER, THE FIRM FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY ORSELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS.

Current Status: Final

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Other Sanction(s)/ReliefSought:

N/A

Resolution Date: 05/02/2011

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED, FINED $23,000 AND ORDERED TO PAYRESTITUTION TO CUSTOMERS IN THE TOTAL AMOUNT OF $15,708.25, PLUSINTEREST AT THE RATE SET FORTH IN SECTION 6621(A) OF THE INTERNALREVENUE CODE, FROM THE DATE OF THE VIOLATIVE CONDUCT UNTIL THEDATE THIS AWC IS ACCEPTED BY THE NATIONAL ADJUDICATORY COUNCIL(NAC). A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMITSATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OFREASONABLE DOCUMENTED EFFORTS UNDERTAKEN TO EFFECTRESTITUTION TO FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCEOF THIS AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE ANYCUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHINSUCH PERIOD, OR SUCH ADDITIONAL PERIOD AGREED TO BY THE STAFF,THE FIRM SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION ANDINTEREST TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY, ORABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMERIS LAST KNOWN TO HAVE RESIDED.

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

No

Sanctions Ordered: CensureMonetary/Fine $23,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Allegations: NASD RULES 2110, 2320: IN EIGHT TRANSACTIONS FOR OR WITH ACUSTOMER, THE FIRM FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY ORSELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS.

Current Status: Final

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Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 05/02/2011

Docket/Case Number: 2006005324201

Principal Product Type: Debt - Corporate

Other Product Type(s): MUNICIPAL SECURITIES

NASD RULES 2110, 2320: IN EIGHT TRANSACTIONS FOR OR WITH ACUSTOMER, THE FIRM FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY ORSELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS.

Resolution Date: 05/02/2011

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED, FINED $23,000.00 AND ORDERED TO PAYRESTITUTION TO CUSTOMERS IN THE TOTAL AMOUNT OF $15,708.25, PLUSINTEREST AT THE RATE SET FORTH IN SECTION 6621(A) OF THE INTERNALREVENUE CODE, FROM THE DATE OF THE VIOLATIVE CONDUCT UNTIL THEDATE THIS AWC IS ACCEPTED BY THE NATIONAL ADJUDICATORY COUNCIL(NAC). A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMITSATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OFREASONABLE DOCUMENTED EFFORTS UNDERTAKEN TO EFFECTRESTITUTION TO FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCEOF THIS AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE ANYCUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHINSUCH PERIOD, OR SUCH ADDITIONAL PERIOD AGREED TO BY THE STAFF,THE FIRM SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION ANDINTEREST TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY, ORABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMERIS LAST KNOWN TO HAVE RESIDED.

Firm Statement THE FIRM SENT THE $23,000.00 FINE TO FINRA ON 05/13/2011.

Sanctions Ordered: CensureMonetary/Fine $23,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

Disclosure 43 of 158

i

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Reporting Source: Regulator

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 04/28/2011

Docket/Case Number: 2007008011601

Principal Product Type: Debt - Corporate

Other Product Type(s): MUNICIPAL SECURITIES

Allegations: NASD RULES 2110, 2440, INTERPRETATIVE MATERIAL-2440, MSRB RULESG-17, G-30(A): IN NINE TRANSACTIONS, THE FIRM SOLD (OR BOUGHT)CORPORATE BONDS TO (OR FROM) CUSTOMERS AND FAILED TO SELL (ORBUY) SUCH BONDS AT A PRICE THAT WAS FAIR, TAKING INTOCONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKETCONDITIONS WITH RESPECT TO EACH BOND AT THE TIME OF THETRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WASENTITLED TO A PROFIT. IN TEN TRANSACTIONS, THE FIRM SOLDMUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT ANAGGREGATE PRICE (INCLUDING ANY MARK-UP) THAT WAS NOT FAIR ANDREASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS,INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER ORMUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THESECURITIES AT THE TIME OF THE TRANSACTIONS AND OF ANYSECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THETRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THETRANSACTION, THE FACT THAT THE BROKER, DEALER, OR MUNICIPALSECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLARAMOUNT OF THE TRANSACTION.

Current Status: Final

Resolution Date: 04/28/2011

Resolution:

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

No

Sanctions Ordered: CensureMonetary/Fine $58,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED, FINED $58,000 AND ORDERED TO PAYRESTITUTION TO CUSTOMERS IN THE TOTAL AMOUNT OF $38,462.01, PLUSINTEREST, AT THE RATE SET FORTH IN SECTION 6221(A) OF THE INTERNALREVENUE CODE, FROM THE DATE OF THE VIOLATIVE CONDUCT UNTIL THEDATE THIS AWC IS ACCEPTED BY THE NATIONAL ADJUDICATORY COUNCIL(NAC). A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMITSATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OFREASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECTRESTITUTION, TO FINRA, NO LATER THAN 120 DAYS AFTER ACCEPTANCEOF THIS AWC. IF FOR ANY REASON, THE FIRM CANNOT LOCATE ANYCUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHINSUCH PERIOD, OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA, THEFIRM SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION AND INTERESTTO THE APPROPRIATE ESCHEAT, UNCLAIMED-PROPERTY OR ABANDONED-PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS KNOWN TOHAVE LAST RESIDED.

Sanctions Ordered: CensureMonetary/Fine $58,000.00Disgorgement/Restitution

iReporting Source: Firm

Allegations: NASD RULES 2110, 2440, INTERPRETATIVE MATERIAL-2440, MSRB RULESG-17, G-30(A): IN NINE TRANSACTIONS, THE FIRM SOLD (OR BOUGHT)CORPORATE BONDS TO (OR FROM)CUSTOMERS AND FAILED TO SELL (ORBUY) SUCH BONDS AT A PRICE THAT WAS FAIR,TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES,INCLUDING MARKET CONDITIONS WITH RESPECT TO EACH BOND AT THETIME OF THE TRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRMWAS ENTITLED TO A PROFIT. IN TEN TRANSACTIONS, THE FIRM SOLDMUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO ACUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY MARK-UP) THATWAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALLRELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER,DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIRMARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTIONSAND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITHTHE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THETRANSACTION, THE FACT THAT THE BROKER,DEALER, OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT,AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION.

Current Status: Final

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Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 04/28/2011

Docket/Case Number: 2007008011601

Principal Product Type: Debt - Corporate

Other Product Type(s): MUNICIPAL SECURITIES

NASD RULES 2110, 2440, INTERPRETATIVE MATERIAL-2440, MSRB RULESG-17, G-30(A): IN NINE TRANSACTIONS, THE FIRM SOLD (OR BOUGHT)CORPORATE BONDS TO (OR FROM)CUSTOMERS AND FAILED TO SELL (ORBUY) SUCH BONDS AT A PRICE THAT WAS FAIR,TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES,INCLUDING MARKET CONDITIONS WITH RESPECT TO EACH BOND AT THETIME OF THE TRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRMWAS ENTITLED TO A PROFIT. IN TEN TRANSACTIONS, THE FIRM SOLDMUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO ACUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY MARK-UP) THATWAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALLRELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER,DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIRMARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTIONSAND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITHTHE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THETRANSACTION, THE FACT THAT THE BROKER,DEALER, OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT,AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION.

Resolution Date: 04/28/2011

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED, FINED $58,000 AND ORDERED TO PAYRESTITUTION TO CUSTOMERS IN THE TOTALAMOUNT OF $38,462.01, PLUS INTEREST, AT THE RATE SET FORTH INSECTION 6221(A) OF THE INTERNAL REVENUE CODE, FROM THE DATE OFTHE VIOLATIVE CONDUCT UNTIL THE DATE THIS AWC IS ACCEPTED BY THENATIONAL ADJUDICATORY COUNCIL (NAC). AREGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORYPROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE ANDDOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION, TOFINRA, NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THISAWC. IF FOR ANY REASON, THE FIRM CANNOT LOCATE ANY CUSTOMERAFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN SUCH PERIOD,OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA, THE FIRM SHALLFORWARD ANY UNDISTRIBUTED RESTITUTION AND INTEREST TO THEAPPROPRIATE ESCHEAT, UNCLAIMED-PROPERTY OR ABANDONED-PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS KNOWN TOHAVE LAST RESIDED.

Firm Statement THE FIRM SENT THE $58,000.00 FINE TO FINRA ON 05/11/2011.

Sanctions Ordered: CensureMonetary/Fine $58,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

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Disclosure 44 of 158

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Reporting Source: Firm

Initiated By: STATE OF OHIO DIVISION OF SECURITIES

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 03/23/2011

Docket/Case Number: ADMINISTRATIVE CONSENT ORDER - DIVISION ORDER NO. 11-015

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Allegations: THE STATE OF OHIO HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

Resolution Date: 03/23/2011

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TOCURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS.

Sanction Details: THE FINE IS DUE TO THE STATE OF OHIO DIVISION OF SECURITIES -SECURITIES INVESTOR EDUCATION AND ENFORCEMENT EXPENSE FUNDON APRIL 2, 2011.

Sanctions Ordered: Monetary/Fine $814,454.59Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 45 of 158

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Reporting Source: Firm

Allegations: THE DIVISION ALLEGED THAT A WFA EMPLOYEE HAD ACTED AS ANINVESTMENNT ADVISOR REPRESENTATIVE IN MISSSISSIPPI, WITHOUTBEING PROPERLY REGISTERED AS SUCH IN VIOLATION OFSECTION 75-71-303 (B)(2) MISSSISSIPPI SECURITIES ACT 2000 &SECTION 75-71-403 (2)(D) MISSSISSIPPI SECURITIES ACT 2009.

Current Status: Final

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Initiated By: STATE OF MISSISSIPPI, OFFICE OF THE SECRETARY OFSTATE, SECURITTIES AND CHARITIES DIVISION (DIVISION)

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 03/01/2011

Docket/Case Number: MOU 03/01/2011

Principal Product Type: Other

Other Product Type(s): FEE FOR SERVICE - INVESTMENT ADVISING

THE DIVISION ALLEGED THAT A WFA EMPLOYEE HAD ACTED AS ANINVESTMENNT ADVISOR REPRESENTATIVE IN MISSSISSIPPI, WITHOUTBEING PROPERLY REGISTERED AS SUCH IN VIOLATION OFSECTION 75-71-303 (B)(2) MISSSISSIPPI SECURITIES ACT 2000 &SECTION 75-71-403 (2)(D) MISSSISSIPPI SECURITIES ACT 2009.

Resolution Date: 03/01/2011

Resolution:

Other Sanctions Ordered: OTHER - MEMORANDUM OF AGREEMENT BETWEENWFA AND THE DIVISION.

Sanction Details: WFA PAID THE $25000 FINE TO THE DIVISION ON 02/25/2011.

Firm Statement THE DIVISION ALLEGED THAT A WFA EMPLOYEE ACTED AS ANINVESTMENNT ADVISOR REPRESENTATIVE IN MISSSISSIPPI, WITHOUTBEING PROPERLY REGISTERED AS SUCH, VIOLATINGSECTION 75-71-303 (B)(2) MISSSISSIPPI SECURITIES ACT 2000 & SECTION75-71-403 (2)(D) MISSSISSIPPI SECURITIES ACT 2009. WFA PAID THE $25000FINE TO THE DIVISION ON 02/25/2011.

Sanctions Ordered: Monetary/Fine $25,000.00

Other

Disclosure 46 of 158

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Reporting Source: Firm

Initiated By: STATE OF DELAWRE DEPARTMENT OF JUSTICE DIVISION OF SECURITIES

Date Initiated: 01/21/2011

Allegations: STATE OF DELAWRE DEPARTMENT OF JUSTICE DIVISION OF SECURITIESALLEGED THAT WACHOVIA SECURITIES, LLC VIOLATED 6 DEL.C. § 7316(A)(7) OF THE DELAWARE SECURIYTIES ACT BY EXECUTING ATRANSACTION ON BEHALF OF A CUSTOMER WITHOUT PRIORAUTHORIZATION

Current Status: Final

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Principal Sanction(s)/ReliefSought:

Undertaking

Other Sanction(s)/ReliefSought:

Date Initiated: 01/21/2011

Docket/Case Number: CASE NO. 09-03-03

Principal Product Type: Unit Investment Trust(s)

Other Product Type(s):

Resolution Date: 01/21/2011

Resolution:

Other Sanctions Ordered: WACHOVIA AGREES TO PROVIDE UIT TRAINING TO THE NAPLES, FLBRANCH OFFICE (SPECIFICALLY THE OPTIONS AVAILABLE TO A UITINVESTOR AT TIME OF MATURITY) AND TO REVIEW POLICIES REGARDINGRECORDKEEPING AND CLIENT CONTACT. WACHOVIA WILL PROVIDE TOTHE DIVISION A WRITTEN TRAINING AGENDA AND AN ATTENDANCE LISTSIGNED BY EACH ATTENDEE. WACHOVIA AGREES TO REIMBURSE$1746.00 TO THE DIVISION TO COVER COST OF THEIR INVESTIGATION.

Sanction Details: BOTH PARTIES WISH TO AMICABLY RESOLVE THIS MATTER WITHOUT THETIME AND EXPENSE ASSOCIATED WITH CONTINUED LITIGATION.WACHOVIA AGREES TO PERMANENTLY WAIVE ALL RIGHTS TO A HEARINGOR APPEAL. WACHOVIA NEITHER ADMITS NOR DENIES THE DIVISIONDETERMINATIONS. THE DIVISION AGREES TO CONCLUDE ITSINVESTIGATION AND TAKE NO FURTHER ACTION.

Sanctions Ordered: Monetary/Fine $1,746.00

Settled

Disclosure 47 of 158

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Reporting Source: Regulator

Allegations: ON DECEMBER 29, 2010, THE CONNECTICUT BANKING COMMISSIONERENTERED A CONSENT ORDER WITH RESPECT TO WACHOVIA SECURITIES,LLC, NOW KNOWN AS WELLS FARGO ADVISORS, LLC, A CONNECTICUT-REGISTERED BROKER-DEALER. THE CONSENT ORDER ALLEGED THATTHE FIRM FAILED TO ESTABLISH, ENFORCE AND MAINTAIN AN ADEQUATESUPERVISORY SYSTEM IN OVERSEEING THE ACTIVITIES OF DANIELCHARLES ALLEGRINI (CRD NO. 2962754), AN EX-BROKER-DEALER AGENTOF THE FIRM. ACCORDING TO THE CONSENT ORDER, ALLEGRINI ISSUED,AND RECOMMENDED TO A CERTAIN WACHOVIA SECURITIES, LLC CLIENT,UNREGISTERED PROMISSORY NOTES THAT WERE NOT SUITABLE FORTHE CLIENT BASED ON THE CLIENT'S FINANCIAL SITUATION AND NEEDS.THE CONSENT ORDER ADDED THAT ALLEGRINI ACTED OUTSIDE THEREGULAR COURSE OR SCOPE OF HIS EMPLOYMENT WITH THE FIRM INSELLING THE NOTES AND IN RECEIVING COMPENSATION FOR REFERRINGBROKERAGE AND BANK CLIENTS TO AN ASSOCIATE FOR THE PURPOSEOF INVESTING IN OTHER INTEREST-PAYING PROMISSORY NOTES.ALLEGRINI ALLEGEDLY DID NOT PROVIDE THE FIRM WITH PRIOR WRITTENNOTICE OF SUCH ACTIVITIES, NOR WERE THE TRANSACTIONS RECORDEDON THE FIRM'S BOOKS AND RECORDS.

Current Status: Final

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Initiated By: CONNECTICUT

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 12/29/2010

Docket/Case Number: CO-10-7710-S

URL for Regulatory Action:

Principal Product Type: Other

Other Product Type(s): PROMISSORY NOTES SOLD BY ONE DANIEL CHARLES ALLEGRINI (CRD NO.2962754)

ON DECEMBER 29, 2010, THE CONNECTICUT BANKING COMMISSIONERENTERED A CONSENT ORDER WITH RESPECT TO WACHOVIA SECURITIES,LLC, NOW KNOWN AS WELLS FARGO ADVISORS, LLC, A CONNECTICUT-REGISTERED BROKER-DEALER. THE CONSENT ORDER ALLEGED THATTHE FIRM FAILED TO ESTABLISH, ENFORCE AND MAINTAIN AN ADEQUATESUPERVISORY SYSTEM IN OVERSEEING THE ACTIVITIES OF DANIELCHARLES ALLEGRINI (CRD NO. 2962754), AN EX-BROKER-DEALER AGENTOF THE FIRM. ACCORDING TO THE CONSENT ORDER, ALLEGRINI ISSUED,AND RECOMMENDED TO A CERTAIN WACHOVIA SECURITIES, LLC CLIENT,UNREGISTERED PROMISSORY NOTES THAT WERE NOT SUITABLE FORTHE CLIENT BASED ON THE CLIENT'S FINANCIAL SITUATION AND NEEDS.THE CONSENT ORDER ADDED THAT ALLEGRINI ACTED OUTSIDE THEREGULAR COURSE OR SCOPE OF HIS EMPLOYMENT WITH THE FIRM INSELLING THE NOTES AND IN RECEIVING COMPENSATION FOR REFERRINGBROKERAGE AND BANK CLIENTS TO AN ASSOCIATE FOR THE PURPOSEOF INVESTING IN OTHER INTEREST-PAYING PROMISSORY NOTES.ALLEGRINI ALLEGEDLY DID NOT PROVIDE THE FIRM WITH PRIOR WRITTENNOTICE OF SUCH ACTIVITIES, NOR WERE THE TRANSACTIONS RECORDEDON THE FIRM'S BOOKS AND RECORDS.

Resolution Date: 12/29/2010

Resolution:

Other Sanctions Ordered:

Sanction Details: THE CONSENT ORDER FINED THE FIRM $75,000 AND DIRECTED IT TOCEASE AND DESIST FROM REGULATORY VIOLATIONS.

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

No

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

Consent

iReporting Source: Firm

Allegations: ON DECEMBER 29, 2010, THE CONNECTICUT BANKING COMMISSIONERENTERED A CONSENT ORDER WITH RESPECT TO WACHOVIA SECURITIES,LLC, NOW KNOWN AS WELLS FARGO ADVISORS, LLC, A CONNECTICUT-REGISTERED BROKER-DEALER. THE CONSENT ORDER ALLEGED THATTHE FIRM FAILED TO ESTABLISH, ENFORCE AND MAINTAIN AN ADEQUATESUPERVISORY SYSTEM IN OVERSEEING THE ACTIVITIES OF AN EX-BROKER-DEALER AGENT OF THE FIRM. ACCORDING TO THE CONSENTORDER, THE AGENT ISSUED, AND RECOMMENDED TO A CERTAINWACHOVIA SECURITIES, LLC CLIENT, UNREGISTERED PROMISSORYNOTES THAT WERE NOT SUITABLE FOR THE CLIENT BASED ON THECLIENT'S FINANCIAL SITUATION AND NEEDS. THE CONSENT ORDERADDED THAT THE AGENT ACTED OUTSIDE THE REGULAR COURSE ORSCOPE OF HIS EMPLOYMENT WITH THE FIRM IN SELLING THE NOTES ANDIN RECEIVING COMPENSATION FOR REFERRING BROKERAGE AND BANKCLIENTS TO AN ASSOCIATE FOR THE PURPOSE OF INVESTING IN OTHERINTEREST-PAYING PROMISSORY NOTES. THE AGENT ALLEGEDLY DID NOTPROVIDE THE FIRM WITH PRIOR WRITTEN NOTICE OF SUCH ACTIVITIES,NOR WERE THE TRANSACTIONS RECORDED ON THE FIRM'S BOOKS ANDRECORDS

Current Status: Final

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Initiated By: CONNECTICUT

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 12/29/2010

Docket/Case Number: CO-10-7710-S

Principal Product Type: Other

Other Product Type(s): PROMISSORY NOTES

Allegations: ON DECEMBER 29, 2010, THE CONNECTICUT BANKING COMMISSIONERENTERED A CONSENT ORDER WITH RESPECT TO WACHOVIA SECURITIES,LLC, NOW KNOWN AS WELLS FARGO ADVISORS, LLC, A CONNECTICUT-REGISTERED BROKER-DEALER. THE CONSENT ORDER ALLEGED THATTHE FIRM FAILED TO ESTABLISH, ENFORCE AND MAINTAIN AN ADEQUATESUPERVISORY SYSTEM IN OVERSEEING THE ACTIVITIES OF AN EX-BROKER-DEALER AGENT OF THE FIRM. ACCORDING TO THE CONSENTORDER, THE AGENT ISSUED, AND RECOMMENDED TO A CERTAINWACHOVIA SECURITIES, LLC CLIENT, UNREGISTERED PROMISSORYNOTES THAT WERE NOT SUITABLE FOR THE CLIENT BASED ON THECLIENT'S FINANCIAL SITUATION AND NEEDS. THE CONSENT ORDERADDED THAT THE AGENT ACTED OUTSIDE THE REGULAR COURSE ORSCOPE OF HIS EMPLOYMENT WITH THE FIRM IN SELLING THE NOTES ANDIN RECEIVING COMPENSATION FOR REFERRING BROKERAGE AND BANKCLIENTS TO AN ASSOCIATE FOR THE PURPOSE OF INVESTING IN OTHERINTEREST-PAYING PROMISSORY NOTES. THE AGENT ALLEGEDLY DID NOTPROVIDE THE FIRM WITH PRIOR WRITTEN NOTICE OF SUCH ACTIVITIES,NOR WERE THE TRANSACTIONS RECORDED ON THE FIRM'S BOOKS ANDRECORDS

Resolution Date: 12/29/2010

Resolution:

Other Sanctions Ordered: THE CONSENT ORDER FINED THE FIRM $75,000 AND DIRECTED IT TOCEASE AND DESIST FROM REGULATORY VIOLATIONS.

Sanction Details: WITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONS ORFINDINGS, WACHOVIA SECURITIES, LLC CONSENTED TO THE TERMS OFTHIS CONSENT ORDER, PAID APPROXIMATELY $800,000.00 IN RESTITUTIONTO THE CLIENT, AND AGREED TO PAY THE $75,000.00 FINE TO THE STATEOF CONNECTICUT.

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

Consent

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www.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONS ORFINDINGS, WACHOVIA SECURITIES, LLC CONSENTED TO THE TERMS OFTHIS CONSENT ORDER, PAID APPROXIMATELY $800,000.00 IN RESTITUTIONTO THE CLIENT, AND AGREED TO PAY THE $75,000.00 FINE TO THE STATEOF CONNECTICUT.

Disclosure 48 of 158

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Reporting Source: Regulator

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 12/20/2010

Docket/Case Number: 2008015589701

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations: MSRB RULES G-14(B)(II), G-15(A)(I) - WELLS FARGO ADVISORS, LLC FAILEDTO REPORT THE CORRECT YIELD TO THE REAL-TIME TRANSACTIONREPORTING SYSTEM (RTRS) IN REPORTS OF TRANSACTIONS INMUNICIPAL SECURITIES AND FAILED TO PROVIDE WRITTEN NOTIFICATIONDISCLOSING TO ITS CUSTOMERS THE CORRECT LOWEST EFFECTEDYIELD IN THESE MUNICIPAL SECURITIES TRANSACTIONS.

Current Status: Final

Resolution Date: 12/20/2010

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $12,500.

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

No

Sanctions Ordered: CensureMonetary/Fine $12,500.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: 141©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Reporting Source: Firm

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

Date Initiated: 12/20/2010

Docket/Case Number: 20080155897-01

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations: MSRB RULES G-14(B)(II), G-15(A)(I) - WELLS FARGO ADVISORS, LLC FAILEDTO REPORT THE CORRECT YIELD TO THE REAL-TIME TRANSACTIONREPORTING SYSTEM (RTRS) IN REPORTS OF TRANSACTIONS INMUNICIPAL SECURITIES AND FAILED TO PROVIDE WRITTEN NOTIFICATIONDISCLOSING TO ITS CUSTOMERS THE CORRECT LOWEST EFFECTEDYIELD IN THESE MUNICIPAL SECURITIES TRANSACTIONS.

Current Status: Final

Resolution Date: 12/20/2010

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $12,500.A COMPANY CHECK FOR THE FULL AMOUNT, $12,500.00 WAS SENT TOFINRA VIA OVERNIGHT CARRIER ON JANUARY 4, 2011.

Sanctions Ordered: CensureMonetary/Fine $12,500.00

Acceptance, Waiver & Consent(AWC)

Disclosure 49 of 158

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Reporting Source: Regulator

Allegations: THE DIVISION ALLEGES THAT ON OR ABOUT JUNE 9, 2009, WFA ENGAGEDIN DISHONEST AND UNETHICAL PRACTICES BY FAILING TO PROMPTLY ANDREASONABLY FOLLOW INSTRUCTIONS FROM A CLIENT TO TRANSFER THEASSETS IN HER ACCOUNTS TO ANOTHER FINANCIAL INSTITUTION IN-KIND,IN VIOLATION OF IND. CODE § 23-19-4-12(D)(13) AND 710 IAC 1-17-1(Y)(2001).

THE DIVISION ALLEGES THAT FROM APPROXIMATELY MAY 5, 2009, TOJUNE 11, 2009, WELLS FARGO ADVISORS, LLC ("WFA") ENGAGED INDISHONEST AND UNETHICAL PRACTICES BY FAILING TO SUPERVISE ITSAGENTS AND EMPLOYEES IN VIOLATION OF IND. CODE § 23-19-4-12(D)(13)AND 710 IAC 1-17-1(V) (2001).

Current Status: Final

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www.finra.org/brokercheck User Guidance

Initiated By: INDIANA

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

RESTITUTION TO NANCY MOORE IN THE AMOUNT OF $495.84.

Date Initiated: 11/18/2010

Docket/Case Number: 10-0271 CA

URL for Regulatory Action:

Principal Product Type: Other

Other Product Type(s):

THE DIVISION ALLEGES THAT ON OR ABOUT JUNE 9, 2009, WFA ENGAGEDIN DISHONEST AND UNETHICAL PRACTICES BY FAILING TO PROMPTLY ANDREASONABLY FOLLOW INSTRUCTIONS FROM A CLIENT TO TRANSFER THEASSETS IN HER ACCOUNTS TO ANOTHER FINANCIAL INSTITUTION IN-KIND,IN VIOLATION OF IND. CODE § 23-19-4-12(D)(13) AND 710 IAC 1-17-1(Y)(2001).

THE DIVISION ALLEGES THAT FROM APPROXIMATELY MAY 5, 2009, TOJUNE 11, 2009, WELLS FARGO ADVISORS, LLC ("WFA") ENGAGED INDISHONEST AND UNETHICAL PRACTICES BY FAILING TO SUPERVISE ITSAGENTS AND EMPLOYEES IN VIOLATION OF IND. CODE § 23-19-4-12(D)(13)AND 710 IAC 1-17-1(V) (2001).

Resolution Date: 11/18/2010

Resolution:

Other Sanctions Ordered:

Sanction Details: WFA PAID A CIVIL PENALTY TO THE INDIANA SECURITIES DIVISION IN THEAMOUNT OF EIGHT THOUSAND DOLLARS ($8,000) AND ALSO RESTITUTIONTO NANCY MOORE FOR FOUR HUNDRED NINETY-FIVE DOLLARS ANDEIGHTY-FOUR CENTS ($495.84).

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

No

Sanctions Ordered: Monetary/Fine $8,000.00Disgorgement/Restitution

Consent

iReporting Source: Firm

Allegations: THE DIVISION ALLEGED THAT O/A JUNE 9,2009, WELLS FARGO ADVISORS,LLC (WFA) ENGAGED IN DISHONEST AND UNETHICAL PRACTICES BYFAILING TO PROMPTLY AND REASONABLY FOLLOW INSTRUCTIONS FROMA CLIENT TO TRANSFER THE ASSETS IN HER ACCOUNTS TO ANOTHERFINANCIAL INSTITUTION IN-KIND, IN VIOLATION OF IND. CODE § 23-19-4-12(D)(13) AND 710 IAC 1-17-1(Y)(2001). THE DIVISION ALLEGED THATFROM APPROXIMATELY MAY 5. 2009, TO JUNE 11,2009, WFA ENGAGED INDISHONEST AND UNETHICAL PRACTICES BY FAILING TO SUPERVISE ITSAGENTS AND EMPLOYEES IN VIOLATION OF IND. CODE § 23-19-4-12(D)(13) & 710 IAC 1-17-1(V)(2001).

Current Status: Final

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www.finra.org/brokercheck User Guidance

Initiated By: INDIANA SECURITIES DIVISION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

RESTITUTION TO NANCY MOORE IN THE AMOUNT OF $495.84

Date Initiated: 11/18/2010

Docket/Case Number: 10-0271 CA

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations: THE DIVISION ALLEGED THAT O/A JUNE 9,2009, WELLS FARGO ADVISORS,LLC (WFA) ENGAGED IN DISHONEST AND UNETHICAL PRACTICES BYFAILING TO PROMPTLY AND REASONABLY FOLLOW INSTRUCTIONS FROMA CLIENT TO TRANSFER THE ASSETS IN HER ACCOUNTS TO ANOTHERFINANCIAL INSTITUTION IN-KIND, IN VIOLATION OF IND. CODE § 23-19-4-12(D)(13) AND 710 IAC 1-17-1(Y)(2001). THE DIVISION ALLEGED THATFROM APPROXIMATELY MAY 5. 2009, TO JUNE 11,2009, WFA ENGAGED INDISHONEST AND UNETHICAL PRACTICES BY FAILING TO SUPERVISE ITSAGENTS AND EMPLOYEES IN VIOLATION OF IND. CODE § 23-19-4-12(D)(13) & 710 IAC 1-17-1(V)(2001).

Resolution Date: 11/18/2010

Resolution:

Other Sanctions Ordered:

Sanction Details: WELLS FARGO ADVISORS, LLC PAID A CIVIL PENALTY TO THE INDIANASECURITIES DIVISION IN THE AMOUNT OF $8,000.00 AND ALSO PAIDRESTITUTION TO NANCY MOORE IN THE AMOUNT OF $495.84.

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO THE DESCRIBED SANCTIONS. THE FIRM WAS FINED$8,000.00 AND PAID RESTITUTION TO THE CLIENT IN THE AMOUNT OF$495.84.

Sanctions Ordered: Monetary/Fine $8,000.00Disgorgement/Restitution

Consent

Disclosure 50 of 158

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Reporting Source: Firm

Allegations: THE STATE OF ALASKA HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS

Current Status: Final

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Initiated By: STATE OF ALASKA; DEPARTMENT COMMERCE, COMMUNITY, ANDECONOMIC DEVELOPMENT; DIVISION OF BANKING AND SECURITIES

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 10/19/2010

Docket/Case Number: ADMINISTRATIVE CONSENT ORDER NO. 10-07-S

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Allegations: THE STATE OF ALASKA HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS

Resolution Date: 10/19/2010

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS.

Sanction Details: THE FINE IS DUE TO THE STATE OF ALASKA ON OCTOBER 29, 2009.

Sanctions Ordered: Monetary/Fine $129,131.10Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 51 of 158

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Reporting Source: Regulator

Allegations: ON JULY 15, 2010, THE CONNECTICUT BANKING COMMISSIONER ENTEREDA CONSENT ORDER WITH RESPECT TO WACHOVIA SECURITIES, LLC (N/K/AWELLS FARGO ADVISORS, LLC), A CONNECTICUT-REGISTERED BROKER-DEALER LOCATED AT ONE NORTH JEFFERSON AVENUE, ST. LOUIS,MISSOURI, AND WACHOVIA CAPITAL MARKETS, LLC (N/K/A WELLS FARGOSECURITIES, LLC), A CONNECTICUT-REGISTERED BROKER-DEALERLOCATED AT 301 SOUTH COLLEGE STREET, CHARLOTTE, NORTHCAROLINA. THE CONSENT ORDER FOLLOWED AN INVESTIGATION BY AMULTISTATE TASK FORCE INTO THE MARKETING AND SALE OF AUCTIONRATE SECURITIES (ARS) BY THE FIRMS FROM JANUARY 1, 2006 THROUGHFEBRUARY 14, 2008. THE CONSENT ORDER ALLEGED THAT, INCONJUNCTION WITH THE MARKETING OF ARS, THE FIRMS FAILED TOSUPERVISE THEIR EMPLOYEES, AND THAT THE FIRM ENGAGED INDISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS BYMISCHARACTERIZING OR FAILING TO ADEQUATELY EXPLAIN ARS TOCUSTOMERS.

Current Status: Final

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www.finra.org/brokercheck User Guidance

Initiated By: CONNECTICUT

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 07/15/2010

Docket/Case Number: CO-10-7568-S

URL for Regulatory Action:

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

ON JULY 15, 2010, THE CONNECTICUT BANKING COMMISSIONER ENTEREDA CONSENT ORDER WITH RESPECT TO WACHOVIA SECURITIES, LLC (N/K/AWELLS FARGO ADVISORS, LLC), A CONNECTICUT-REGISTERED BROKER-DEALER LOCATED AT ONE NORTH JEFFERSON AVENUE, ST. LOUIS,MISSOURI, AND WACHOVIA CAPITAL MARKETS, LLC (N/K/A WELLS FARGOSECURITIES, LLC), A CONNECTICUT-REGISTERED BROKER-DEALERLOCATED AT 301 SOUTH COLLEGE STREET, CHARLOTTE, NORTHCAROLINA. THE CONSENT ORDER FOLLOWED AN INVESTIGATION BY AMULTISTATE TASK FORCE INTO THE MARKETING AND SALE OF AUCTIONRATE SECURITIES (ARS) BY THE FIRMS FROM JANUARY 1, 2006 THROUGHFEBRUARY 14, 2008. THE CONSENT ORDER ALLEGED THAT, INCONJUNCTION WITH THE MARKETING OF ARS, THE FIRMS FAILED TOSUPERVISE THEIR EMPLOYEES, AND THAT THE FIRM ENGAGED INDISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS BYMISCHARACTERIZING OR FAILING TO ADEQUATELY EXPLAIN ARS TOCUSTOMERS.

Resolution Date: 07/15/2010

Resolution:

Other Sanctions Ordered: THE CONSENT ORDER FINED WACHOVIA SECURITIES, LLC (N/K/A WELLSFARGO ADVISORS, LLC) AND WACHOVIA CAPITAL MARKETS, LLC (N/K/AWELLS FARGO SECURITIES, LLC) $863,341.30, AND DIRECTED THEM TOCEASE AND DESIST FROM REGULATORY VIOLATIONS.

Sanction Details: SEE RESPONSE TO ITEM 13.B.

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

Yes

Sanctions Ordered: Monetary/Fine $863,341.30Cease and Desist/Injunction

Consent

iReporting Source: Firm

Allegations: ON JULY 15, 2010, THE CONNECTICUT BANKING COMMISSIONER ENTEREDA CONSENT ORDER WITH RESPECT TO WACHOVIA SECURITIES, LLC (N/K/AWELLS FARGO ADVISORS, LLC), A CONNECTICUT-REGISTERED BROKERDEALER LOCATED AT ONE NORTH JEFFERSON AVENUE, ST. LOUIS,MISSOURI. THE CONSENT ORDER FOLLOWED AN INVESTIGATION BY AMULTISTATE TASK FORCE INTO THE MARKETING AND SALE OF AUCTIONRATE SECURITIES (ARS) BY THE FIRM FROM JANUARY 1, 2006 THROUGHFEBRUARY 14, 2008. THE CONSENT ORDER ALLEGED THAT, INCONJUNCTION WITH THE MARKETING OF ARS, THE FIRM FAILED TOSUPERVISE THEIR EMPLOYEES, AND THAT THE FIRM ENGAGED INDISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS BYMISCHARACTERIZING OR FAILING TO ADEQUATELY EXPLAIN ARS TOCUSTOMERS.

Current Status: Final

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www.finra.org/brokercheck User Guidance

Initiated By: STATE OF CONECTICUT DEPARTMENT OF BANKING

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 07/15/2010

Docket/Case Number: CO-10-7568-S

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

ON JULY 15, 2010, THE CONNECTICUT BANKING COMMISSIONER ENTEREDA CONSENT ORDER WITH RESPECT TO WACHOVIA SECURITIES, LLC (N/K/AWELLS FARGO ADVISORS, LLC), A CONNECTICUT-REGISTERED BROKERDEALER LOCATED AT ONE NORTH JEFFERSON AVENUE, ST. LOUIS,MISSOURI. THE CONSENT ORDER FOLLOWED AN INVESTIGATION BY AMULTISTATE TASK FORCE INTO THE MARKETING AND SALE OF AUCTIONRATE SECURITIES (ARS) BY THE FIRM FROM JANUARY 1, 2006 THROUGHFEBRUARY 14, 2008. THE CONSENT ORDER ALLEGED THAT, INCONJUNCTION WITH THE MARKETING OF ARS, THE FIRM FAILED TOSUPERVISE THEIR EMPLOYEES, AND THAT THE FIRM ENGAGED INDISHONEST OR UNETHICAL PRACTICES IN THE SECURITIES BUSINESS BYMISCHARACTERIZING OR FAILING TO ADEQUATELY EXPLAIN ARS TOCUSTOMERS.

Resolution Date: 07/15/2010

Resolution:

Other Sanctions Ordered: THE CONSENT ORDER FINED WACHOVIA SECURITIES, LLC (N/K/A WELLSFARGO ADVISORS, LLC)4863,341.30 AND DIRECTED THEM TO CEASE ANDDESIST FROM REGULATORY VIOLATIONS.

Sanction Details: SEE RESPONSE TO ITEM 12.B. PAYMENT OF THE $863,341.30 FINE WASSENT TO THE STATE OF CONNECTICUT DEPARTMENT OF BANKING ON07/20/2010.

Sanctions Ordered: Monetary/Fine $863,341.30Cease and Desist/Injunction

Consent

Disclosure 52 of 158

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Reporting Source: Firm

Allegations: STATE OF HAWAII ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

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Initiated By: STATE OF HAWAII DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 07/14/2010

Docket/Case Number: SEU-2008-069

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

STATE OF HAWAII ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Resolution Date: 07/14/2010

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THERELEVANT CLASS.

Sanction Details: PAYMENT OF THE FINE TO THE STATE OF HAWAII DEPARTMENT OFCOMMERCE AND CONSUMER AFFAIRS IS DUE BY 07/24/2010.

Sanctions Ordered: Monetary/Fine $211,619.92Disgorgement/Restitution

Consent

Disclosure 53 of 158

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Reporting Source: Regulator

Initiated By: SOUTH DAKOTA

Date Initiated: 08/08/2009

Docket/Case Number:

Allegations: THE DIVISION CONDUCTED AN INVESTIGATION INTO THE ACTIVITIES OF ATEAM OF AGENTS WHO WORKED TOGETHER FOR A.G. EDWARDS (WHICHWAS LATER ACQUIRED BY WACHOVIA SECURITIES, LLC AND LATER BYWELLS FARGO ADVISORS). A LARGE PERCENTAGE OF THE TEAM'SPRODUCTION WAS FROM ANNUITY AND INSURANCE SALES AND THEDIVISION WAS CONCERNED ABOUT THE SUPERVISION OF THE TEAM ANDTHE SUITABILITY OF THEIR SALES. THE FIRM PLACED THE TEAM ONHEIGHTENED SUPERVISION AND PAID A FINE AND COSTS OFINVESTIGATION TO THE DIVISION.

Current Status: Final

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www.finra.org/brokercheck User Guidance

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Docket/Case Number:

URL for Regulatory Action:

Principal Product Type: No Product

Other Product Type(s):

Resolution Date: 08/08/2009

Resolution:

Other Sanctions Ordered:

Sanction Details: CONSENT ORDER

Sanctions Ordered: Monetary/Fine $21,000.00

Consent

iReporting Source: Firm

Initiated By: STATE OF SOUTH DAKOTA DEPARTMENT OF REVENUE & REGULATIONDIVISION OF SECURITIES

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

PAYMENT OF COST OF INVESTIGATION

Date Initiated: 08/08/2009

Docket/Case Number: CONSENT ORDER

Principal Product Type: No Product

Other Product Type(s): ANNUITY AND INSURANCE SALES

Allegations: THE STATE OF SOUTH DAKOTA DEPARTMENT OF REVENUE & REGULATIONDIVISION OF SECURITIES CONDUCTED AN INVESTIGATION INTO THEACTIVITIES OF A TEAM OF AGENTS WHO WORKED TOGETHER FOR A.G.EDWARDS (WHICH WAS LATER ACQUIRED BY WACHOVIA SECURITIES, LLCAND LATER BY WELLS FARGO ADVISORS, LLC.) A LARGE PERCENTAGE OFTHE TEAM'S PRODUCTION WAS FROM ANNUITY AND INSURANCE SALESAND THE DIVISION WAS CONCERNED ABOUT THE SUPERVISION OF THETEAM AND THE SUITABILITY OF THEIR SALES. THE FIRM PLACED THETEAM ON HEIGHTENED SUPERVISION AND PAID THE DIVISION A $21,000.00FINE AND $20,000.00 TO COVER THE COSTS OF INVESTIGATION.

Current Status: Final

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Other Sanction(s)/ReliefSought:

PAYMENT OF COST OF INVESTIGATION

Resolution Date: 08/08/2009

Resolution:

Other Sanctions Ordered: $20000.00 COST OF INVESTIGATION AND HEIGHTENED SUPERVISION OFTHE SALES TEAM FOR A PERIOD OF ONE YEAR FROM THE DATE OF THECONSENT ORDER OR AUGUST 8, 2010.

Sanction Details: CONSENT ORDER

Firm Statement THE STATE OF SOUTH DAKOTA DEPARTMENT OF REVENUE & REGULATIONDIVISION OF SECURITIES CONDUCTED AN INVESTIGATION INTO THESALES ACTIVITIES OF A TEAM OF AGENTS WHO WORKED TOGETHER FORA.G. EDWARDS (WHICH WAS LATER ACQUIRED BY WACHOVIA SECURITIES,LLC AND LATER BY WELLS FARGO ADVISORS, LLC). APPROXIMATELY 44%OF THE GROUP'S PRODUCTION (ABOVE THE FIRM'S AVERAGE FOR THEPERIOD OF JANUARY 1, 2008 TO SEPTEMBER 30, 2008) WAS FROMANNUITY AND INSURANCE SALES AND THE DIVISION WAS CONCERNEDABOUT THE SUPERVISION OF THE TEAM AND THE SUITABILITY OF THEIRSALES. WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT ANDCONCLUSIONS OF LAW CONTAINED IN THE CONSENT ORDER, THE FIRMVOLUNTARILY PLACED THE TEAM ON HEIGHTENED SUPERVISION FOR APERIOD OF ONE YEAR FROM THE DATE OF THE CONSENT ORDER (ORUNTIL AUGUST 8, 2010); PAID THE DIVISION A $21,000.00 FINE; AND PAID$20,000.00 TO COVER THE COSTS OF INVESTIGATION. ALSO THE FIRMNOW USES AN AUTOMATED TOOL (ANNUITYNET) WITH A BUILT IN SCORINGSYSTEM THAT ROUTES VARIABLE ANNUITY TRANSACTIONS TO THEAPPROPRIATE SUPERVISOR FOR REVIEW.

Sanctions Ordered: Monetary/Fine $21,000.00

Consent

Disclosure 54 of 158

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Reporting Source: Firm

Initiated By: STATE OF LOUISIANA - OFFICE OF FINANCIAL INSTITUTIONS -COMMISSIONER OF SECURITIES

Date Initiated: 06/18/2010

Docket/Case Number: OIF-2010-001

Allegations: STATEOF LOUISIANA HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATESECURITIES TO CUSTOMERS.

Current Status: Final

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www.finra.org/brokercheck User Guidance

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Resolution Date: 06/18/2010

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOTSUBJECT TO CURRENT CALLS OR REDEMPTION ("ELIGIBLE ARS") FROMALL INVESTORS IN THE RELEVANT CLASS.

Sanction Details: PAYMENT OF THE FINE TO THE STATE OF LOUISIANA - OFFICE OFFINANCIAL INSTITUTIONS - COMMISSIONER OF SECURITIES IS DUE WITHINTEN DAYS - ON JUNE 28, 2010.

Sanctions Ordered: Monetary/Fine $596,362.56Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 55 of 158

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Reporting Source: Regulator

Initiated By: FINRA

Allegations: NASD RULES 2110, 2210(C)(1), 2210(C)(2)(A), 2210(D)(1)(A), 2210(D)(1)(B),2210(D)(2)(B), 2211(D): RESPONDENT WELLS FARGO ADVISORS LLC FAILEDTO FILE PIECES OF UNIT INVESTMENT TRUST ("UIT") MARKETINGMATERIAL WITH THE NASD DEPARTMENT OF ADVERTISING REGULATIONWITHIN 10 DAYS OF FIRST USE OR PUBLICATION. THE FIRM INTERNALLYUSED PIECES OF UIT MARKETING MATERIAL THAT FAILED TO COMPLYWITH NASD CONTENT STANDARDS IN THAT THEY FAILED TO PROVIDE ASOUND BASIS FOR EVALUATION AND A COMPLETE PRESENTATIONREGARDING THE UITS. THE FIRM ALSO USED A PIECE OF MARKETINGMATERIAL THAT COMPARED UITS TO OTHER INVESTMENTS WITHOUTINCLUDING ALL MATERIAL DIFFERENCES BETWEEN THE INVESTMENTOPTIONS. THE FIRM ALSO FAILED TO DISCLOSE RISKS ASSOCIATED WITHUITS AND USED MARKETING MATERIALS THAT INCLUDED PERFORMANCEOF PRIOR, UNAVAILABLE UIT PORTFOLIOS TO PROMOTE UIT PORTFOLIOSTHAT WERE CURRENTLY AVAILABLE AND UIT PERFORMANCE DATA THATWAS MISLEADING.

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 05/11/2010

Docket/Case Number: 2007009356502

Principal Product Type: Unit Investment Trust(s)

Other Product Type(s):

Resolution Date: 05/11/2010

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $25,000.

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

No

Sanctions Ordered: CensureMonetary/Fine $25,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Allegations: VIOLATION OF NASD RULES 2110, 2210(C)(1), 2210(C)(2)(A),2210(D)(1)(A), 2210(D)(1)(B), 2210(D)(2)(B), & 2211 (D): RESPONDENT WELLSFARGO ADVISORS, LLC FAILED TO FILE PIECES OF UNIT INVESTMENTTRUST "UIT" MARKETING MATERIAL WITH THE NASD DEPARTMENT OFADVERTISING REGULATION. THE FIRM INTERNALLY USED PIECES OF UITMARKETING MATERIAL THAT FAILED TO COMPLY WITH NASD CONTENTSTANDARDS IN THAT THEY FAILED TP PROVIDE A SOUND BASIS FOREVALUATION AND A COMPLETE PRESENTATION REGARDING THE UITS.THE FIRM ALSO USED A PIECE OF MARKETING MATERIAL THAT COMPAREDUITS TO OTHER INVESTMENTS WITHOUT INCLUDING ALL MATERIALDIFFERENCES BETWEEN THE INVESTMENT OPTIONS.

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

MONETARY FINE

Date Initiated: 05/11/2010

Docket/Case Number: 2007009356502

Principal Product Type: Unit Investment Trust(s)

Other Product Type(s):

VIOLATION OF NASD RULES 2110, 2210(C)(1), 2210(C)(2)(A),2210(D)(1)(A), 2210(D)(1)(B), 2210(D)(2)(B), & 2211 (D): RESPONDENT WELLSFARGO ADVISORS, LLC FAILED TO FILE PIECES OF UNIT INVESTMENTTRUST "UIT" MARKETING MATERIAL WITH THE NASD DEPARTMENT OFADVERTISING REGULATION. THE FIRM INTERNALLY USED PIECES OF UITMARKETING MATERIAL THAT FAILED TO COMPLY WITH NASD CONTENTSTANDARDS IN THAT THEY FAILED TP PROVIDE A SOUND BASIS FOREVALUATION AND A COMPLETE PRESENTATION REGARDING THE UITS.THE FIRM ALSO USED A PIECE OF MARKETING MATERIAL THAT COMPAREDUITS TO OTHER INVESTMENTS WITHOUT INCLUDING ALL MATERIALDIFFERENCES BETWEEN THE INVESTMENT OPTIONS.

Resolution Date: 05/11/2010

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF THE FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $25,000.00.

Firm Statement FINRA ALLEGED VIOLATION OF NASD RULES 2110, 2210(C)(1),2210(C)(2)(A), 2210(D)(1)(A), 2210(D)(1)(B), 2210(D)(2)(B), & 2211(D)IN THATTHE RESPONDENT WELLS FARGO ADVISORS, LLC FAILED TO FILE PIECESOF UNIT INVESTMENT TRUST "UIT" MARKETING MATERIAL WITH THE NASDDEPARTMENT OF ADVERTISING REGULATION. THE FIRM INTERNALLYUSED PIECES OF UIT MARKETING MATERIAL THAT FAILED TO COMPLYWITH NASD CONTENT STANDARDS IN THAT THEY FAILED TP PROVIDE ASOUND BASIS FOR EVALUATION AND A COMPLETE PRESENTATIONREGARDING THE UITS. THE FIRM ALSO USED A PIECE OF MARKETINGMATERIAL THAT COMPARED UITS TO OTHER INVESTMENTS WITHOUTINCLUDING ALL MATERIAL DIFFERENCES BETWEEN THE INVESTMENTOPTIONS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF THEFINDINGS; THEREFORE, THE FIRM WAS CENSURED AND FINED $25,000.00

Sanctions Ordered: CensureMonetary/Fine $25,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 56 of 158

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Reporting Source: Firm

Allegations: THE STATE OF ILLINOIS HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES (ARS)TO CUSTOMERS.

Current Status: Final

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Initiated By: OFFICE OF THE SECRETARY OF STATE ILLINOIS SECURITIES DEPARTMENT

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 03/29/2010

Docket/Case Number: 08-00202

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Allegations: THE STATE OF ILLINOIS HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES (ARS)TO CUSTOMERS.

Resolution Date: 03/29/2010

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENTCALLS OR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THERELEVANT CLASS.

Sanction Details: THE FINE WAS SENT TO THE STATE OF ILLINOIS ON 04/06/2010.

Sanctions Ordered: Monetary/Fine $1,691,207.30Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 57 of 158

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Reporting Source: Firm

Initiated By: STATE OF ARKANSAS SECURITIES COMMISSIONER

Date Initiated: 03/11/2010

Docket/Case Number: S-09-024-09-CO01

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Allegations: STATEOF ARKANSAS HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATESECURITIES TO CUSTOMERS.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Resolution Date: 03/11/2010

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THERELEVANT CLASS.

Sanction Details: PAYMENT OF THE FINE TO THE STATE OF ARKANSAS IS DUE BY 03/21/2010.

Sanctions Ordered: Monetary/Fine $238,385.75Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 58 of 158

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Reporting Source: Firm

Initiated By: STATE OF MARYLAND - OFFICE OF THE ATTORNEY GENERAL - SECURITIESDIVISION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 03/11/2010

Docket/Case Number: 2009-0164

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Allegations: THE STATE OF MARYLAND HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

Resolution Date: 03/11/2009

Resolution: Consent

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Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THERELEVANT CLASS.

Sanction Details: THE FINE IS DUE TO STATE OF MARYLAND - OFFICE OF THE ATTORNEYGENERAL - SECURITIES DIVISION UPON RECEIPT OF THE CONSENTORDER.

Sanctions Ordered: Monetary/Fine $810,624.05Disgorgement/RestitutionCease and Desist/Injunction

Disclosure 59 of 158

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Reporting Source: Firm

Initiated By: STATE OF WISCONSIN DEPARTMENT OF FINANCIAL INSTITUTIONSDIVISION OF SECURITIES

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 01/15/2010

Docket/Case Number: S-09137(EX)

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Allegations: STATE OF WISCONSIN HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES (ARS) TOCUSTOMERS.

Current Status: Final

Resolution Date: 01/15/2010

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THERELEVANT CLASS.

Sanctions Ordered: Monetary/Fine $457,903.77Disgorgement/RestitutionCease and Desist/Injunction

Decision

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OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THERELEVANT CLASS.

Sanction Details: THE PAYMENT WAS SENT TO THE STATE OF WISCONSIN ON 01/25/2010.

Disclosure 60 of 158

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Reporting Source: Firm

Initiated By: U.S. VIRGIN ISLANDS - OFFICE OF THE LIEUTENANT GOVERNOR - DIVISIONOF BANKING AND INSURANCE

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 01/04/2010

Docket/Case Number: 01-09

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Allegations: U.S. VIRGIN ISLANDS HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

Resolution Date: 01/04/2010

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THERELEVANT CLASS.

Sanction Details: THE PAYMENT WAS SENT TO THE U.S. VIRGIN ISLANDS ON 01/13/2010.

Sanctions Ordered: Monetary/Fine $116,748.21Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 61 of 158

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Reporting Source: Firm

Allegations: THE STATE OF INDIANA HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

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

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 05/06/2009

Docket/Case Number: 09-0082 CO

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Allegations: THE STATE OF INDIANA HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Resolution Date: 05/06/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THERELEVANT CLASS.

Sanction Details: THE PAYMENT WAS SENT TO THE STATE OF INDIANA ON 05/12/2009.

Sanctions Ordered: Monetary/Fine $509,628.73Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 62 of 158

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Reporting Source: Firm

Initiated By: STATE OF WEST VIRGINIA SECURITIES COMMISSION

Date Initiated: 11/03/2009

Docket/Case Number: 98-44964

Principal Product Type: Other

Allegations: THE STATE OF WEST VIRGINIA HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Resolution Date: 11/03/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS.

Sanction Details: THE FINE IS DUE TO THE STATE OF WEST VIRGINIA - WITHIN TEN DAYS -ON NOVEMBER 13, 2009.

Sanctions Ordered: Monetary/Fine $170,766.82Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 63 of 158

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Reporting Source: Firm

Initiated By: THE SECURITIES COMMISIONER OF THE STATE OF DELAWARE

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 03/31/2009

Docket/Case Number: 09-2-2

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Allegations: THE STATE OF DELAWARE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

Resolution Date: 03/31/2009

Resolution:

Sanctions Ordered: Monetary/Fine $309,117.79Disgorgement/RestitutionCease and Desist/Injunction

Consent

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Other Sanctions Ordered: OFFER TO REPURCHASE AT ARS THAT ARE SUBJECT TO AUCTIONS THATARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS.

Sanction Details: THE PAYMENT WAS SENT TO THE STATE OF DELAWARE ON 04/09/2009.

Sanctions Ordered: Monetary/Fine $309,117.79Disgorgement/RestitutionCease and Desist/Injunction

Disclosure 64 of 158

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Reporting Source: Firm

Initiated By: STATE OF MAINE DEPARTMENT OF PROFESSIONAL AND FINANCIALREGULATION OFFICE OF SECURITIES

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 04/14/2009

Docket/Case Number: ADMINISTRATIVE CONSENT ORDER

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Allegations: THE STATE OF MAINE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

Resolution Date: 04/14/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE AT ARS THAT ARE SUBJECT TO AUCTIONS THATARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS.

Sanction Details: THE PAYMENT WAS SENT TO THE STATE OF MAINE ON 04/22/2009.

Sanctions Ordered: Monetary/Fine $237,916.17Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 65 of 158

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Disclosure 65 of 158

Reporting Source: Regulator

Initiated By: DISTRICT OF COLUMBIA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

CONSENT ORDER

Date Initiated: 08/21/2009

Docket/Case Number: SB-09-02

URL for Regulatory Action:

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE COMMISSIONER OF THE DEPARTMENT OF INSURANCE, SECURITIESAND BANKING FINDS WACHOVIA SECURITIES FAILED TO SUPERVISE ITSEMPLOYEES AND ENGAGED IN DISHONEST OR UNETHICAL PRACTICES INTHE SECURITIES BUSINESS, AND IN THE SALE OF AUCTION RATESECURITIES IN THE DISTRICT OF COLUMBIA, IN VIOLATION OF D.C.OFFICIAL CODE §31-5602.07(A)(9)AND(12).

Current Status: Final

Resolution Date: 08/21/2009

Resolution:

Other Sanctions Ordered: WACHOVIA WILL CEASE AND DESIST FROM VIOLATING D.C. OFFICIALCODE §§ 31-5602.07(A)(9) AND 31-5602.07(A)(12) AND WILL COMPLY WITHALL OF THE LAWS OF THE SECURITIES ACT OF 2000, AND ALL OF THELAWS OF THE DISTRICT OF COLUMBIA. WITHIN TEN DAYS AFTER THEENTRY OF THIS ORDER, WACHOVIA SHALL PAY THE SUM OF THREEHUNDRED ELEVEN THOUSAND, SEVEN HUNDRED AND SISTY FIVEDOLLARS AND ELEVEN CENTS ($311,765.11) TO THE DEPARTMENT AS ACIVIL MONETARY PENALTY PURSUANT TO D.C. OFFICIAL CODE §1-204.50

Sanction Details: N/A

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

Yes

Sanctions Ordered: Monetary/Fine $311,765.11Cease and Desist/Injunction

Consent

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Sanction Details: N/A

iReporting Source: Firm

Initiated By: DISTRICT OF COLUMBIA DEPARTMENT OF INSURANCE AND BANKING

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 09/16/2009

Docket/Case Number: SB-09-02

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES (ARS)

Allegations: THE DISTRICT OF COLUMBIA HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

Resolution Date: 09/16/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS.

Sanction Details: THE FINE IS DUE IN FULL BY SEPTEMBER 26, 2009.

Sanctions Ordered: Monetary/Fine $311,765.11Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 66 of 158

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Reporting Source: Regulator

Allegations: THE UTAH DIVISION OF SECURITIES, AS PART OF A MULTI-STATE TASKFORCE CONSISTING OF MEMBER STATES OF THE NORTH AMERICANSECURITIES ADMINISTRATORS ASSOCIATION ("NASAA") INVESTIGATINGTHE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS") TOINVESTORS, ALLEGED THAT WACHOVIA SECURITIES, LLC ("WACHOVIA"):(1) ENGAGED IN DISHONEST AND UNETHICAL PRACTICES IN THEMARKETING AND SALE OF ARS BY MISREPRESENTING TO INVESTORSTHAT ARS WERE CASH EQUIVALENTS, COMPLETELY SAFE, AND/OR LIQUIDAT ANY TIME; (2) ENGAGED IN DISHONEST AND UNETHICAL PRACTICES BYNOT ADEQUATELY EXPLAINING ISSUES INVOLVING TEMPORARY MAXIMUMWAIVERS ON CERTAIN ARS; AND (3) FAILED TO REASONABLY SUPERVISEITS EMPLOYEES WHO SOLD ARS.

Current Status: Final

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Initiated By: UTAH DIVISION OF SECURITIES

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

ADMINISTRATIVE FINE AND BUY BACK OF AUCTION RATE SECURITIESTHAT IT SOLD TO ELIGIBLE UTAH INVESTORS.

Date Initiated: 09/17/2009

Docket/Case Number: SD-09-0043

URL for Regulatory Action:

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

THE UTAH DIVISION OF SECURITIES, AS PART OF A MULTI-STATE TASKFORCE CONSISTING OF MEMBER STATES OF THE NORTH AMERICANSECURITIES ADMINISTRATORS ASSOCIATION ("NASAA") INVESTIGATINGTHE MARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS") TOINVESTORS, ALLEGED THAT WACHOVIA SECURITIES, LLC ("WACHOVIA"):(1) ENGAGED IN DISHONEST AND UNETHICAL PRACTICES IN THEMARKETING AND SALE OF ARS BY MISREPRESENTING TO INVESTORSTHAT ARS WERE CASH EQUIVALENTS, COMPLETELY SAFE, AND/OR LIQUIDAT ANY TIME; (2) ENGAGED IN DISHONEST AND UNETHICAL PRACTICES BYNOT ADEQUATELY EXPLAINING ISSUES INVOLVING TEMPORARY MAXIMUMWAIVERS ON CERTAIN ARS; AND (3) FAILED TO REASONABLY SUPERVISEITS EMPLOYEES WHO SOLD ARS.

Resolution Date: 09/17/2009

Resolution:

Other Sanctions Ordered: OFFER TO PURCHASE, AT PAR PLUS ACCRUED AND UNPAIDDIVIDENDS/INTEREST, ELIGIBLE ARS FROM ALL INVESTORS IN THERELEVANT CLASS AS OUTLINED IN THE DIVISION'S STIPULATION ANDCONSENT ORDER.

Sanction Details: PURSUANT TO A STIPULATION AND CONSENT ORDER WITH THE UTAHDIVISION OF SECURITIES, WACHOVIA SECURITIES, LLC ("WACHOVIA")WILL: (1) CEASE AND DESIST FROM VIOLATING THE UTAH UNIFORMSECURITIES ACT ("ACT") AND WILL HEREAFTER COMPLY WITH THE ACTWITH REGARD TO THE MARKETING AND SALE OF ARS TO UTAHINVESTORS; (2) PAY THE SUM OF $247,272.91 AS AN ADMINISTRATIVE FINETO THE DIVISION; AND (3) OFFER TO PURCHASE, AT PAR PLUS ACCRUEDAND UNPAID DIVIDENDS/INTEREST, ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTIONS FROM ALL INVESTORS WHO PURCHASED ARS FROMWACHOVIA ON OR BEFORE 13 FEBRUARY 2008 INTO ACCOUNTSMAINTAINED AT WACHOVIA.

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

Yes

Sanctions Ordered: Monetary/Fine $449,851.41Cease and Desist/Injunction

Stipulation and Consent

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PURSUANT TO A STIPULATION AND CONSENT ORDER WITH THE UTAHDIVISION OF SECURITIES, WACHOVIA SECURITIES, LLC ("WACHOVIA")WILL: (1) CEASE AND DESIST FROM VIOLATING THE UTAH UNIFORMSECURITIES ACT ("ACT") AND WILL HEREAFTER COMPLY WITH THE ACTWITH REGARD TO THE MARKETING AND SALE OF ARS TO UTAHINVESTORS; (2) PAY THE SUM OF $247,272.91 AS AN ADMINISTRATIVE FINETO THE DIVISION; AND (3) OFFER TO PURCHASE, AT PAR PLUS ACCRUEDAND UNPAID DIVIDENDS/INTEREST, ARS THAT ARE SUBJECT TO AUCTIONSTHAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLSOR REDEMPTIONS FROM ALL INVESTORS WHO PURCHASED ARS FROMWACHOVIA ON OR BEFORE 13 FEBRUARY 2008 INTO ACCOUNTSMAINTAINED AT WACHOVIA.

Regulator Statement A PDF COPY OF THE DIVISION'S STIPULATION AND CONSENT ORDER CANBE VIEWED ONLINE ATHTTP://SECURITIES.UTAH.GOV/DOCKETS/09004301.PDF

iReporting Source: Firm

Initiated By: DIVISION OF SECURITIES UTAH DEPARTMENT OF COMMERCE

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 09/17/2009

Docket/Case Number: SD-09-0043

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

Resolution Date: 09/17/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE IS DUE IN FULL BY 09/27/2009

Sanctions Ordered: Monetary/Fine $247,272.91Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 67 of 158

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Reporting Source: Firm

Initiated By: STATE OF NEW MEXICOREGULATION AND LICENSING DEPARTMENTSECURITIES DIVISION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 08/18/2009

Docket/Case Number: 09-09-007040

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER.

Current Status: Final

Resolution Date: 08/18/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS.

Sanction Details: THE FINE WAS SENT ON AUGUST 18, 2009.

Sanctions Ordered: Monetary/Fine $221,609.71Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 68 of 158

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Reporting Source: Firm

Initiated By: COMMONWEALTH OF VIRGINIASTATE CORPORATION COMMISSION

Date Initiated: 08/12/2009

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 08/12/2009

Docket/Case Number: SEC-20900044 ARS

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Resolution Date: 08/12/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS.

Sanction Details: PAYMENT WAS MADE ON AUGUST 25, 2009.

Sanctions Ordered: Monetary/Fine $1,220,592.50Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 69 of 158

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Reporting Source: Regulator

Initiated By: PENNSYLVANIA CONTACT: CAROLYN MENDELSON (412)-565-5083

Principal Sanction(s)/ReliefSought:

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

Date Initiated: 08/11/2009

Docket/Case Number: 2008-04-16

URL for Regulatory Action:

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: IF THE FACTS ARE AS FOUND IN THE FINDINGS OF FACT IN THE MISSOURIORDER, THEN THE ACTS AND CONDUCT SET FORTH IN THE MISSOURIORDER, IN PARTICULAR THE AUCTION RATE SECURITIES SALES IN PA,WOULD CONSTITUTE DISHONEST OR UNETHICAL PRACTICES IN THESECURITIES BUSINESS BY RESPONDENT, AND WOULD CONSTITUTEFAILURE TO REASONABLY SUPERVISE AGENTS OR EMPLOYEES.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

WACHOVIA SECURITIES, LLC D/B/A WELLS FARGO ADVISORS, LLC(RESPONDENT) IS REQUIRED TO OFFER AND TO COMPLETE A BUYBACKOF AUCTION RATE SECURITIES THAT IT SOLD TO ELIGIBLE PA INVESTORS.

Resolution Date: 08/11/2009

Resolution:

Other Sanctions Ordered:

Sanction Details: RESPONDENT SHALL PAY WITHIN TEN DAYS AFTER ENTRY OF THIS ORDER$2,527,771.09 TO THE COMMONWEALTH OF PA, WHICH AMOUNTREPRESENTS AN ADMINISTRATIVE ASSESSMENT.

Regulator Statement FINDINGS OF FACT, CONCLUSIONS OF LAW AND ORDER ISSUED TOWACHOVIA SECURITIES, LLC D/B/A WELLS FARGO ADVISORS, LLC ANDANOTHER NAMED RESPONDENT.

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

Yes

Sanctions Ordered: Monetary/Fine $2,527,771.09

Settled

iReporting Source: Firm

Initiated By: PENNSYLVANIA SECURITIES COMMISSION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 08/11/2009

Docket/Case Number: 2008-04-16

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER.

Current Status: Final

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Resolution Date: 08/11/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS.

Sanction Details: PAYMENT WAS MADE AUGUST 19, 2009.

Sanctions Ordered: Monetary/Fine $2,527,771.09Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 70 of 158

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Reporting Source: Firm

Initiated By: IOWA INSURANCE DIVISION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 07/30/2009

Docket/Case Number: 64477

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER.

Current Status: Final

Resolution Date: 07/30/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS.

Sanction Details: PAYMENT WAS MADE ON AUGUST 5, 2009.

Sanctions Ordered: Monetary/Fine $191,289.03Disgorgement/RestitutionCease and Desist/Injunction

Consent

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Sanction Details: PAYMENT WAS MADE ON AUGUST 5, 2009.

Disclosure 71 of 158

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Reporting Source: Regulator

Allegations: NASD RULES 2110, 3010(A), 3010(B): THE FIRM, FROM AUGUST 2001,THROUGH OCTOBER 2004, SUPERVISORY SYSTEM AND WRITTENSUPERVISORY PROCEDURES WERE INADEQUATE TO DETECT ABUSIVESALES PRACTICES REGARDING VARIABLE ANNUITIES THEREBY ALLOWINGTWO REPRESENTATIVES TO ENGAGE IN ABUSIVE SALES PRACTICESREGARDING VARIABLE ANNUITIES. THE FIRM'S WRITTEN SUPERVISORYPROCEDURES PLACED RESPONSIBILITY WITH THE BRANCH OFFICEMANAGER FOR THE REVIEW OF ANNUITY TRANSACTIONS, BOTH INITIALPURCHASES AND EXCHANGES, AND THE WRITTEN SUPERVISORYPROCEDURES DID NOT DESCRIBE ADEQUATELY THE REQUIREDDOCUMENTATION AND/OR INFORMATION THE BRANCH OFFICE MANAGER(OR HIS DESIGNEE) SHOULD REVIEW DURING A SUITABILITY ANALYSIS ORHOW TO EVIDENCE APPROVAL, AND AS A RESULT OF INADEQUATEPROCEDURES IN THIS AREA, THERE WERE INCONSISTENT ANDINADEQUATE SUITABILITY REVIEWS CONDUCTED AT THE FIRM OFTRANSACTIONS EXECUTED BY THE REPRESENTATIVES. THE WRITTENSUPERVISORY PROCEDURES RELIED SUBSTANTIALLY ON A DIALOGUEBETWEEN THE BRANCH OFFICE MANAGER AND THE FINANCIAL ADVISORREGARDING A SUITABILITY ANALYSIS AND THE PROCEDURES DID NOTREQUIRE THE BRANCH OFFICE MANAGER TO VERIFY REPRESENTATIONSMADE BY THE FINANCIAL ADVISOR, AS A RESULT NO STEPS WERE TAKENTO DETECT THE REPEATED FALSEHOODS BY THE REPRESENTATIVESTHAT THE ANNUITY TRANSACTIONS REPRESENTED AN INVESTMENT OFNEW FUNDS AND DID NOT REPRESENT EXCHANGES OR REPLACEMENTS,FURTHERMORE TO THE EXTENT THAT THE BRANCH OFFICE MANAGERREVIEWED INFORMATION ON THE FIRM'S COMPUTER REGARDING THESOURCE OF FUNDS, THE FIRM'S SYSTEM DID NOT REFLECT THATINSURANCE COMPANIES WERE THE SOURCE OF DEPOSITS THAT THEREPRESENTATIVES ASSERTED WERE NEW FUNDS. THE FIRM DID NOTHAVE ANY EXCEPTION REPORTS APPROPRIATE FOR MONITORINGVARIABLE ANNUITY SALES PRACTICES, THUS WHEN THEREPRESENTATIVES WERE ENGAGING IN UNAUTHORIZED ANNUITYSWITCHES, THE FIRM GENERATED MONTHLY ACTIVE ACCOUNT REPORTSBASED ON ESTABLISHED CRITERIA LARGELY RELATED TO EQUITIES,WHICH DID NOT SUCCESSFULLY IDENTIFY ANNUITY SALES PRACTICEVIOLATIONS. THE FIRM DID NOT HAVE EXCEPTION REPORTS TO IDENTIFYVARIABLE ANNUITY RELATED CONCERNS, FAILED TO VERIFY THAT THECUSTOMER'S INFORMATION ON THE ANNUITY APPLICATION MATCHEDTHAT ON THE BROKERAGE ACCOUNT, DID NOT HAVE ADEQUATECONTROLS TO MONITOR ANNUITY WITHDRAWALS, AND DID NOT HAVE ANADEQUATE PROCEDURE TO REMOVE ANNUITIES FROM CUSTOMERACCOUNTS WHEN THEY WERE SURRENDERED BUT INSTEAD RELIEDUPON A DISCLAIMER ON EACH CUSTOMER'S ACCOUNT STATEMENTS. THEFIRM'S PROCEDURE BY WHICH CUSTOMERS' ACCOUNT STATEMENTSWERE UPDATED RELIED UPON THE FINANCIAL ADVISOR ADVISING THEBRANCH'S OPERATIONS DEPARTMENT THAT AN ANNUITY HAD BEENCLOSED AND, AT THE TIME, THE OPERATIONS AREA WOULD THEN SENDTHE SURRENDER INFORMATION TO THE FIRM'S ANNUITY DEPARTMENT,WHICH WOULD REMOVE THE POSITION FROM THE CLIENT'S STATEMENT,THUS THE REPRESENTATIVES FAILED TO SO ADVISE THE BRANCH'SOPERATIONS DEPARTMENT, AND WERE ABLE TO USE THIS WEAKNESS INTHE FIRM'S PROCEDURE TO CONCEAL THEIR UNAUTHORIZED PARTIALWITHDRAWALS. THE FIRM DID NOT HAVE AN ADEQUATE PROCEDURE TOREJECT ANNUITY TRANSACTIONS IF THE ANNUITY BUY TICKET WAS NOTCOMPLETE AND THE ANNUITY BUY TICKETS FOR MANY OF THE SUBJECTTRANSACTIONS, HOWEVER, WERE PROCESSED WITHOUT FULL ANDCOMPLETE INFORMATION.

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 08/28/2009

Docket/Case Number: 2005002169202

Principal Product Type: Annuity(ies) - Variable

Other Product Type(s):

NASD RULES 2110, 3010(A), 3010(B): THE FIRM, FROM AUGUST 2001,THROUGH OCTOBER 2004, SUPERVISORY SYSTEM AND WRITTENSUPERVISORY PROCEDURES WERE INADEQUATE TO DETECT ABUSIVESALES PRACTICES REGARDING VARIABLE ANNUITIES THEREBY ALLOWINGTWO REPRESENTATIVES TO ENGAGE IN ABUSIVE SALES PRACTICESREGARDING VARIABLE ANNUITIES. THE FIRM'S WRITTEN SUPERVISORYPROCEDURES PLACED RESPONSIBILITY WITH THE BRANCH OFFICEMANAGER FOR THE REVIEW OF ANNUITY TRANSACTIONS, BOTH INITIALPURCHASES AND EXCHANGES, AND THE WRITTEN SUPERVISORYPROCEDURES DID NOT DESCRIBE ADEQUATELY THE REQUIREDDOCUMENTATION AND/OR INFORMATION THE BRANCH OFFICE MANAGER(OR HIS DESIGNEE) SHOULD REVIEW DURING A SUITABILITY ANALYSIS ORHOW TO EVIDENCE APPROVAL, AND AS A RESULT OF INADEQUATEPROCEDURES IN THIS AREA, THERE WERE INCONSISTENT ANDINADEQUATE SUITABILITY REVIEWS CONDUCTED AT THE FIRM OFTRANSACTIONS EXECUTED BY THE REPRESENTATIVES. THE WRITTENSUPERVISORY PROCEDURES RELIED SUBSTANTIALLY ON A DIALOGUEBETWEEN THE BRANCH OFFICE MANAGER AND THE FINANCIAL ADVISORREGARDING A SUITABILITY ANALYSIS AND THE PROCEDURES DID NOTREQUIRE THE BRANCH OFFICE MANAGER TO VERIFY REPRESENTATIONSMADE BY THE FINANCIAL ADVISOR, AS A RESULT NO STEPS WERE TAKENTO DETECT THE REPEATED FALSEHOODS BY THE REPRESENTATIVESTHAT THE ANNUITY TRANSACTIONS REPRESENTED AN INVESTMENT OFNEW FUNDS AND DID NOT REPRESENT EXCHANGES OR REPLACEMENTS,FURTHERMORE TO THE EXTENT THAT THE BRANCH OFFICE MANAGERREVIEWED INFORMATION ON THE FIRM'S COMPUTER REGARDING THESOURCE OF FUNDS, THE FIRM'S SYSTEM DID NOT REFLECT THATINSURANCE COMPANIES WERE THE SOURCE OF DEPOSITS THAT THEREPRESENTATIVES ASSERTED WERE NEW FUNDS. THE FIRM DID NOTHAVE ANY EXCEPTION REPORTS APPROPRIATE FOR MONITORINGVARIABLE ANNUITY SALES PRACTICES, THUS WHEN THEREPRESENTATIVES WERE ENGAGING IN UNAUTHORIZED ANNUITYSWITCHES, THE FIRM GENERATED MONTHLY ACTIVE ACCOUNT REPORTSBASED ON ESTABLISHED CRITERIA LARGELY RELATED TO EQUITIES,WHICH DID NOT SUCCESSFULLY IDENTIFY ANNUITY SALES PRACTICEVIOLATIONS. THE FIRM DID NOT HAVE EXCEPTION REPORTS TO IDENTIFYVARIABLE ANNUITY RELATED CONCERNS, FAILED TO VERIFY THAT THECUSTOMER'S INFORMATION ON THE ANNUITY APPLICATION MATCHEDTHAT ON THE BROKERAGE ACCOUNT, DID NOT HAVE ADEQUATECONTROLS TO MONITOR ANNUITY WITHDRAWALS, AND DID NOT HAVE ANADEQUATE PROCEDURE TO REMOVE ANNUITIES FROM CUSTOMERACCOUNTS WHEN THEY WERE SURRENDERED BUT INSTEAD RELIEDUPON A DISCLAIMER ON EACH CUSTOMER'S ACCOUNT STATEMENTS. THEFIRM'S PROCEDURE BY WHICH CUSTOMERS' ACCOUNT STATEMENTSWERE UPDATED RELIED UPON THE FINANCIAL ADVISOR ADVISING THEBRANCH'S OPERATIONS DEPARTMENT THAT AN ANNUITY HAD BEENCLOSED AND, AT THE TIME, THE OPERATIONS AREA WOULD THEN SENDTHE SURRENDER INFORMATION TO THE FIRM'S ANNUITY DEPARTMENT,WHICH WOULD REMOVE THE POSITION FROM THE CLIENT'S STATEMENT,THUS THE REPRESENTATIVES FAILED TO SO ADVISE THE BRANCH'SOPERATIONS DEPARTMENT, AND WERE ABLE TO USE THIS WEAKNESS INTHE FIRM'S PROCEDURE TO CONCEAL THEIR UNAUTHORIZED PARTIALWITHDRAWALS. THE FIRM DID NOT HAVE AN ADEQUATE PROCEDURE TOREJECT ANNUITY TRANSACTIONS IF THE ANNUITY BUY TICKET WAS NOTCOMPLETE AND THE ANNUITY BUY TICKETS FOR MANY OF THE SUBJECTTRANSACTIONS, HOWEVER, WERE PROCESSED WITHOUT FULL ANDCOMPLETE INFORMATION.

Resolution Date: 08/28/2009

Resolution:

Other Sanctions Ordered: UNDERTAKING

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

No

Sanctions Ordered: CensureMonetary/Fine $350,000.00

Acceptance, Waiver & Consent(AWC)

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Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED AND FINED $350,000.

AN UNDERTAKING TO CERTIFY TO FINRA WITHIN 90 DAYS THAT FIRM HASREVIEWED ITS PROCEDURES REGARDING VARIABLE ANNUITIES AND HASSYSTEMS AND PROCEDURES IN PLACE THAT ARE REASONABLYDESIGNED TO DETECT ABUSIVE SALES PRACTICES.

iReporting Source: Firm

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 08/28/2009

Docket/Case Number: 2005002169202

Principal Product Type: Annuity(ies) - Variable

Other Product Type(s):

Allegations: NASD RULES 2110, 3010(A), 3010(B): THE FIRM, FROM AUGUST 2001,THROUGH OCTOBER 2004, SUPERVISORY SYSTEM AND WRITTENSUPERVISORY PROCEDURES WERE INADEQUATE TO DETECT ABUSIVESALES PRACTICES REGARDING VARIABLE ANNUITIES THEREBY ALLOWINGTWO REPRESENTATIVES TO ENGAGE IN ABUSIVE SALES PRACTICESREGARDING VARIABLE ANNUITIES.

Current Status: Final

Resolution Date: 08/28/2009

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 AND FINED $350,000. ANUNDERTAKING TO CERTIFY TO FINRA WITHIN 90 DAYS THAT FIRM HASREVIEWED ITS PROCEDURES REGARDING VARIABLE ANNUITIES AND HASSYSTEMS AND PROCEDURES IN PLACE THAT ARE REASONABLYDESIGNED TO DETECT ABUSIVE SALES PRACTICES.

Sanctions Ordered: CensureMonetary/Fine $350,000.00

Acceptance, Waiver & Consent(AWC)

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www.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED AND FINED $350,000. ANUNDERTAKING TO CERTIFY TO FINRA WITHIN 90 DAYS THAT FIRM HASREVIEWED ITS PROCEDURES REGARDING VARIABLE ANNUITIES AND HASSYSTEMS AND PROCEDURES IN PLACE THAT ARE REASONABLYDESIGNED TO DETECT ABUSIVE SALES PRACTICES.

Disclosure 72 of 158

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Reporting Source: Firm

Initiated By: STATE OF WYOMINGSECRETARY OF STATESECURITIES DIVISION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 06/23/2009

Docket/Case Number: 09-05

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

Resolution Date: 06/23/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS.

Sanction Details: THE FINE WAS PAID ON JUNE 29, 2009.

Sanctions Ordered: Monetary/Fine $176,314.77Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 73 of 158

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Reporting Source: Firm

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

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Initiated By: STATE OF OREGONDIVISION OF FINANCE AND CORPORATE SECURITIES

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 06/29/2009

Docket/Case Number: S-09-0022

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Resolution Date: 06/29/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS.

Sanction Details: THE FINE IS PAYABLE WITHIN 10 DAYS IF THE ORDER.

Sanctions Ordered: Monetary/Fine $397,234.57Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 74 of 158

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Reporting Source: Firm

Initiated By: STATE OF IDAHO

Principal Sanction(s)/ReliefSought:

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

Date Initiated: 06/22/2009

Docket/Case Number: 2009-7-08

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Resolution Date: 06/22/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS.

Sanction Details: THE FINE WAS PAID ON JUNE 29, 2009.

Sanctions Ordered: Monetary/Fine $191,049.02Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 75 of 158

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Reporting Source: Firm

Initiated By: STATE OF KANSAS

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 06/09/2009

Docket/Case Number: 09 E 012

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

Resolution Date: 06/09/2009

Resolution:

Sanctions Ordered: Monetary/Fine $633,090.35Disgorgement/RestitutionCease and Desist/Injunction

Consent

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Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE WAS PAID ON JUNE 16, 2009.

Monetary/Fine $633,090.35Disgorgement/RestitutionCease and Desist/Injunction

Disclosure 76 of 158

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Reporting Source: Firm

Initiated By: STATE OF NEBRASKA

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 06/04/2009

Docket/Case Number: N/A

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

Resolution Date: 06/04/2009

Resolution:

Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THATARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANTCLASS.

Sanction Details: THE FINE WAS PAID ON JUNE 12TH, 2009

Sanctions Ordered: Monetary/Fine $298,818.42Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 77 of 158

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Reporting Source: Regulator

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Initiated By: TENNESSEE DEPARTMENT OF COMMERCE AND INSURANCE, SECURITIESDIVISION

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

RESTITUTION; CIVIL PENALTY

Date Initiated: 05/22/2009

Docket/Case Number: 09-003

URL for Regulatory Action:

Principal Product Type: Other

Other Product Type(s): AUTION RATE SECURITIES

Allegations: THE TN SECURITIES DIVISION, AS PART OF A MULTI-STATE TASK FORCECONSISTING OF MEMBER STATES OF THE NORTH AMERICAN SECURITIESADMINISTRATORS ASSOCIATION ("NASAA") INVESTIGATING THEMARKETING AND SALE OF AUCTION RATE SECURITIES ("ARS") TOINVESTORS, ALLEGED THAT DURING THE PERIOD OF JANUARY 2006THROUGH FEBRUARY 2008 WACHOVIA SECURITIES, LLC, ("WACHOVIA")MISREPRESENTED THE SALE OF ARS TO INVESTORS AS CONSERVATIVE,LIQUID, CASH-EQUIVALENT INVESTMENTS AND THAT WACHOVIA FAILEDTO REASONABLY SUPERVISE ITS EMPLOYEES WITH RESPECT TO THESALE OF ARS.

Current Status: Final

Resolution Date: 05/22/2009

Resolution:

Other Sanctions Ordered: UNDERTAKINGS

Sanction Details: PURSUANT TO A CONSENT ORDER IN WHICH WACHOVIA NEITHERADMITTED NOR DENIED THE FINDINGS OF FACT AND CONCLUSIONS OFLAW, THE COMMISSIONER OF THE TN DEPARTMENT OF COMMERCE ANDINSURANCE ORDERED WACHOVIA TO CEASE AND DESIST FROMVIOLATING THE TN SECURITIES ACT OF 1980; AND ORDERED WACHOVIATO MAKE CERTAIN UNDERTAKINGS, INCLUDING OFFERING TOREPURCHASE FROM CERTAIN INVESTORS ARS THAT ARE SUBJECT TOAUCTIONS THAT ARE NOT SUCCESSFUL AND THAT ARE NOT SUBJECT TOCURRENT CALLS OR REDEMPTIONS; AND ORDERED WACHOVIA TO MAKEA PAYMENT OF $449,851.41 TO THE TN DEPARTMENT OF COMMERCE ANDINSURANCE.

Sanctions Ordered: Monetary/Fine $449,851.41Disgorgement/RestitutionCease and Desist/Injunction

Settled

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PURSUANT TO A CONSENT ORDER IN WHICH WACHOVIA NEITHERADMITTED NOR DENIED THE FINDINGS OF FACT AND CONCLUSIONS OFLAW, THE COMMISSIONER OF THE TN DEPARTMENT OF COMMERCE ANDINSURANCE ORDERED WACHOVIA TO CEASE AND DESIST FROMVIOLATING THE TN SECURITIES ACT OF 1980; AND ORDERED WACHOVIATO MAKE CERTAIN UNDERTAKINGS, INCLUDING OFFERING TOREPURCHASE FROM CERTAIN INVESTORS ARS THAT ARE SUBJECT TOAUCTIONS THAT ARE NOT SUCCESSFUL AND THAT ARE NOT SUBJECT TOCURRENT CALLS OR REDEMPTIONS; AND ORDERED WACHOVIA TO MAKEA PAYMENT OF $449,851.41 TO THE TN DEPARTMENT OF COMMERCE ANDINSURANCE.

iReporting Source: Firm

Initiated By: TENNESSEE SECURITIES DIVISION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 05/22/2009

Docket/Case Number: 09-003 SI 2008-010

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER

Current Status: Final

Resolution Date: 05/22/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE IS DUE BY 06/01/2009

Sanctions Ordered: Monetary/Fine $449,851.41Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 78 of 158

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Reporting Source: Regulator

Allegations: THE COMMISSION ISSUED CONSENT ORDER NO. CO-2009-0011, CITEDWACHOVIA SECURITIES LLC AND WACHOVIA CAPITAL MARKETS LLC WITHENGAGING IN UNETHICAL AND DISHONEST PRACTICES AND FAILURE TOPROPERLY SUPERVISE ITS AGENTS. THIS ACTION STEMMED FROM THEFIRMS INAPPROPRIATE MARKETING OF AUCTION RATE SECURITIES (ARS)TO CUSTOMERS WITHOUT ADEQUATELY DISCLOSING RISKS OFILLIQUIDITY

Current Status: Final

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Initiated By: ALABAMA SECURITIES COMMISSION

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

CONSENT ORDER

Date Initiated: 05/26/2009

Docket/Case Number: CO-2009-0011

URL for Regulatory Action:

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

THE COMMISSION ISSUED CONSENT ORDER NO. CO-2009-0011, CITEDWACHOVIA SECURITIES LLC AND WACHOVIA CAPITAL MARKETS LLC WITHENGAGING IN UNETHICAL AND DISHONEST PRACTICES AND FAILURE TOPROPERLY SUPERVISE ITS AGENTS. THIS ACTION STEMMED FROM THEFIRMS INAPPROPRIATE MARKETING OF AUCTION RATE SECURITIES (ARS)TO CUSTOMERS WITHOUT ADEQUATELY DISCLOSING RISKS OFILLIQUIDITY

Resolution Date: 05/26/2009

Resolution:

Other Sanctions Ordered: $350,000 TO STATE OF ALABAMA; $250,000 TO ALABAMA SECURITIESCOMMISSION; $73,141.24 TO INVESTOR PROTECTION TRUST; $10,000 TOALABAMA DISTRICT ATTORNEY'S ASSOCIATION.RECEIVED 06/10/2009

Sanction Details: $350,000 TO STATE OF ALABAMA; $250,000 TO ALABAMA SECURITIESCOMMISSION; $73,141.24 TO INVESTOR PROTECTION TRUST; $10,000 TOALABAMA DISTRICT ATTORNEY'S ASSOCIATION.RECEIVED 06/10/2009

Regulator Statement THE COMMISSION ISSUED CONSENT ORDER NO. CO-2009-0011, CITEDWACHOVIA SECURITIES LLC AND WACHOVIA CAPITAL MARKETS LLC WITHENGAGING IN UNETHICAL AND DISHONEST PRACTICES AND FAILURE TOPROPERLY SUPERVISE ITS AGENTS. THIS ACTION STEMMED FROM THEFIRMS INAPPROPRIATE MARKETING OF AUCTION RATE SECURITIES (ARS)TO CUSTOMERS WITHOUT ADEQUATELY DISCLOSING RISKS OFILLIQUIDITY

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

No

Sanctions Ordered: Monetary/Fine $683,141.24

Consent

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Reporting Source: Firm

Initiated By: ALABAMA SECURITIES COMMISSION

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

CONSENT ORDER

Date Initiated: 05/26/2009

Docket/Case Number: CO-2009-0011

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE COMMISSION ISSUED CONSENT ORDER NO. CO-2009-0011, CITEDWACHOVIA SECURITIES, LLC WITH ENGAGING IN UNETHICAL ANDDISHONEST PRACTICES AND FAILURE TO PROPERLY SUPERVISE ITSAGENTS. THIS ACTION STEMMED FROM THE FIRMS INAPPROPIATEMARKETING OF AUCTION RATE SECURITIES (ARS) TO CUSTOMERSWITHOUT ADEQUATELY DISCLOSING RISKS OF ILLIQUIDITY

Current Status: Final

Resolution Date: 05/26/2009

Resolution:

Other Sanctions Ordered: $350.000 TO STATE OF ALABAMA; $250,000 TO ALABAMA SECURITIESCOMMISSION; $73,141.24 TO INVESTOR PROTECTION TRUST; $10,000 TOALABAMA DISTRICT ATTORNEY'S ASSOCIATION. RECEIVED 06/10/2009

Sanction Details: $350.000 TO STATE OF ALABAMA; $250,000 TO ALABAMA SECURITIESCOMMISSION; $73,141.24 TO INVESTOR PROTECTION TRUST; $10,000 TOALABAMA DISTRICT ATTORNEY'S ASSOCIATION. RECEIVED 06/10/2009THE FIRM SENT THE $683,141.24 TOTAL FINE, AS STIPULATED, TO THESTATE OF ALABAMA ON 06/04/2009.

Firm Statement THE COMMISSION ISSUED CONSENT ORDER NO. CO-2009-0011, CITEDWACHOVIA SECURITIES, LLC WITH ENGAGING IN UNETHICAL ANDDISHONEST PRACTICES AND FAILURE TO PROPERLY SUPERVISE ITSAGENTS. THIS ACTION STEMMED FROM THE FIRMS INAPPROPIATEMARKETING OF AUCTION RATE SECURITIES (ARS) TO CUSTOMERSWITHOUT ADEQUATELY DISCLOSING RISKS OF ILLIQUIDITY

Sanctions Ordered: Monetary/Fine $683,141.24

Consent

Disclosure 79 of 158

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Reporting Source: Firm

Initiated By: MINNESOTA DEPARTMENT OF COMMERCE

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 05/11/2009

Docket/Case Number: FILE 11200

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER

Current Status: Final

Resolution Date: 05/11/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE WAS PAID ON 05/18/2009

Sanctions Ordered: Monetary/Fine $387,790.88Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 80 of 158

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Reporting Source: Firm

Initiated By: COMMONWEALTH OF KENTUCKY

Date Initiated: 05/14/2009

Docket/Case Number: NO. 2009-AH-032

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Resolution Date: 05/14/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE WAS PAID ON 05/19/2009

Sanctions Ordered: Monetary/Fine $315,300.14Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 81 of 158

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Reporting Source: Firm

Initiated By: STATE OF RHODE ISLAND

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 04/22/2009

Docket/Case Number: 09-110

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER

Current Status: Final

Resolution Date: 04/22/2009

Resolution:

Sanctions Ordered: Monetary/Fine $131,565.93Disgorgement/RestitutionCease and Desist/Injunction

Consent

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Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE WAS PAID ON 05/01/2009

Sanctions Ordered: Monetary/Fine $131,565.93Disgorgement/RestitutionCease and Desist/Injunction

Disclosure 82 of 158

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Reporting Source: Regulator

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 05/01/2009

Docket/Case Number: 2007010181101

Principal Product Type: Debt - Corporate

Other Product Type(s): AFTERMARKET EQUITY NON-SYNDICATE IPOS, COLLATERAL MORTGAGEOBLIGATIONS (CMOS), AUCTION MARKET PREFERRED SECURITIES,PREFERRED STOCKS, MUTUAL FUNDS, ALTERNATIVE INVESTMENTSECURITIES, EQUITY IPO TRANSACTIONS AND EXCHANGE TRADED FUNDS(ETFS)

Allegations: NASD RULES 2110 AND 3010: RESPONDENT WACHOVIA SECURITIES, LLCFAILED TO DELIVER PROSPECTUSES AND PRODUCT DESCRIPTIONS TOCERTAIN CUSTOMERS WHO PURCHASED INVESTMENT PRODUCTS, ASREQUIRED UNDER FEDERAL SECURITIES LAWS AND NASD RULES.WACHOVIA SECURITIES FAILED TO HAVE ADEQUATE SUPERVISORYSYSTEMS AND APPROPRIATE WRITTEN SUPERVISORY PROCEDURES INPLACE TO ENSURE THAT OFFERING DOCUMENTS WERE BEING SENT TOCUSTOMERS IN CONNECTION WITH SECURITIES TRANSACTIONS.WACHOVIA SECURITIES ALSO FAILED TO ADEQUATELY SUPERVISE THESUBMISSION OF INFORMATION TO FINRA STAFF AND ENSURE THAT ITSSUBMISSIONS WERE ACCURATE, COMPLETE AND TIMELY SUBMITTED.

Current Status: Final

Resolution Date: 05/01/2009

Resolution: Acceptance, Waiver & Consent(AWC)

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Resolution Date: 05/01/2009

Other Sanctions Ordered: UNDERTAKING

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, WACHOVIASECURITIES, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TOTHE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED ANDFINED $1,400,000. IN ADDITION, WACHOVIA SECURITIES UNDERTAKES TOCOMPLETE THE FOLLOWING WITHIN 120 DAYS OF NOTICE OFACCEPTANCE OF THE AWC: 1) ADOPT AND IMPLEMENT SYSTEMS ANDPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHTHE FEDERAL SECURITIES LAWS AND NASD/FINRA RULES APPLICABLE TOTHE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS,INCLUDING SYSTEMS AND PROCEDURES TO PROVIDE ADEQUATEOVERSIGHT IF THIRD PARTY VENDORS ARE UTILIZED; AND 2) PROVIDE AWRITTEN CERTIFICATE BY A DULY AUTHORIZED SENIOR OFFICER OFWACHOVIA SECURITIES LLC THAT THE FIRM HAS ADOPTED ANDIMPLEMENTED SUPERVISORY SYSTEMS AND PROCEDURES REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH THE FEDERAL SECURITIESLAWS AND NASD/FINRA RULES APPLICABLE TO THE DELIVERY OFPROSPECTUSES AND PRODUCT DESCRIPTIONS.

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

No

Sanctions Ordered: CensureMonetary/Fine $1,400,000.00

iReporting Source: Firm

Initiated By: FINRA

Allegations: NASD RULES 2110 AND 3010: RESPONDENT WACHOVIA SECURITIES, LLCFAILED TO DELIVER PROSPECTUSES AND PRODUCT DESCRIPTIONS TOCERTAIN CUSTOMERS WHO PURCHASED INVESTMENT PRODUCTS, ASREQUIRED UNDER FEDERAL SECURITIES LAWS AND NASD RULES.WACHOVIA SECURITIES FAILED TO HAVE ADEQUATE SUPERVISORYSYSTEMS AND APPROPRIATE WRITTEN SUPERVISORY PROCEDURES INPLACE TO ENSURE THAT OFFERING DOCUMENTS WERE BEING SENT TOCUSTOMERS IN CONNECTION WITH SECURITIES TRANSACTIONS.WACHOVIA SECURITIES ALSO FAILED TO ADEQUATELY SUPERVISE THESUBMISSION OF INFORMATION TO FINRA STAFF AND ENSURE THAT ITSSUBMISSIONS WERE ACCURATE, COMPLETE AND TIMELY SUBMITTED.

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 05/01/2009

Docket/Case Number: 2007010181101

Principal Product Type: Debt - Corporate

Other Product Type(s): AFTERMARKET EQUITY NON-SYNDICATE IPOS, COLLATERAL MORTGAGEOBLIGATIONS (CMOS), AUCTION MARKET PREFERRED SECURITIES,PREFERRED STOCKS, MUTUAL FUNDS, ALTERNATIVE INVESTMENTSECURITIES, EQUITY IPO TRANSACTIONS AND EXCHANGE TRADED FUNDS(ETFS)

Resolution Date: 05/01/2009

Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, WACHOVIASECURITIES, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TOTHE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED ANDFINED $1,400,000. IN ADDITION, WACHOVIA SECURITIES UNDERTAKES TOCOMPLETE THE FOLLOWING WITHIN 120 DAYS OF NOTICE OFACCEPTANCE OF THE AWC: 1) ADOPT AND IMPLEMENT SYSTEMS ANDPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHTHE FEDERAL SECURITIES LAWS AND NASD/FINRA RULES APPLICABLE TOTHE DELIVERY OF PROSPECTUSES AND PRODUCT DESCRIPTIONS,INCLUDING SYSTEMS AND PROCEDURES TO PROVIDE ADEQUATEOVERSIGHT IF THIRD PARTY VENDORS ARE UTILIZED; AND 2) PROVIDE AWRITTEN CERTIFICATE BY A DULY AUTHORIZED SENIOR OFFICER OFWACHOVIA SECURITIES LLC THAT THE FIRM HAS ADOPTED ANDIMPLEMENTED SUPERVISORY SYSTEMS AND PROCEDURES REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH THE FEDERAL SECURITIESLAWS AND NASD/FINRA RULES APPLICABLE TO THE DELIVERY OFPROSPECTUSES AND PRODUCT DESCRIPTIONS.

Sanctions Ordered: CensureMonetary/Fine $1,400,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 83 of 158

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Reporting Source: Firm

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Initiated By: STATE OF COLORADO SECURITIES COMMISSIONER

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 04/20/2009

Docket/Case Number: 09-L-11

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER

Current Status: Final

Resolution Date: 04/20/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE IS DUE BY 04/30/2009

Sanctions Ordered: Monetary/Fine $664,614.09Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 84 of 158

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Reporting Source: Firm

Initiated By: STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION

Date Initiated: 04/17/2009

Docket/Case Number: 0420-S-2/09

Principal Product Type: Other

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Resolution Date: 04/17/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE IS DUE BY 04/27/2009

Sanctions Ordered: Monetary/Fine $5,673,320.82Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 85 of 158

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Reporting Source: Firm

Initiated By: STATE COMMISSIONER OF SOUTH CAROLINA

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 04/13/2009

Docket/Case Number: 08018

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER

Current Status: Final

Resolution Date: 04/13/2009

Resolution:

Sanctions Ordered: Monetary/Fine $772,958.03Disgorgement/RestitutionCease and Desist/Injunction

Consent

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Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE IS DUE IN FULL BY 12/31/2009

Sanctions Ordered: Monetary/Fine $772,958.03Disgorgement/RestitutionCease and Desist/Injunction

Disclosure 86 of 158

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Reporting Source: Regulator

Initiated By: OKLAHOMA DEPARTMENT OF SECURITIES

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

CIVIL PENALTY AND RESCISSION

Date Initiated: 04/03/2009

Docket/Case Number: 09-087

URL for Regulatory Action:

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THESALE OF AUCTION RATE SECURITIES TO CUSTOMERS AND FAILED TOSUPERVISE AGENTS WHO SOLD THE SECURITIES

Current Status: Final

Resolution Date: 04/03/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE AUCTION RATE SECURITIES THAT ARE SUBJECTTO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TOCURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS

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

No

Sanctions Ordered: Monetary/Fine $478,286.84Cease and Desist/Injunction

Consent

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OFFER TO REPURCHASE AUCTION RATE SECURITIES THAT ARE SUBJECTTO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOT SUBJECT TOCURRENT CALLS OR REDEMPTION IN THE RELEVANT CLASS

Sanction Details: WACHOVIA HAS PAID THE FINE

iReporting Source: Firm

Initiated By: STATE OF OKLAHOMA DEPARTMENT OF SECURITIES

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 04/03/2009

Docket/Case Number: 09-087

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER

Current Status: Final

Resolution Date: 04/03/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE WAS PAID ON 04/10/2009

Sanctions Ordered: Monetary/Fine $478,286.84Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 87 of 158

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Reporting Source: Firm

Initiated By: STATE OF NORTH DAKOTA SECURITIES DEPARTMENT

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER

Current Status: Final

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Initiated By: STATE OF NORTH DAKOTA SECURITIES DEPARTMENT

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 04/01/2009

Docket/Case Number:

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Resolution Date: 04/01/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE WAS PAID ON 04/03/2009

Sanctions Ordered: Monetary/Fine $121,409.18Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 88 of 158

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Reporting Source: Firm

Initiated By: STATE OF MICHIGAN OFFICE OF FINANCIAL AND INSURANCE REGULATION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 03/27/2009

Docket/Case Number:

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER

Current Status: Final

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Other Sanction(s)/ReliefSought:

Resolution Date: 03/27/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE WAS PAID ON 04/07/2009

Sanctions Ordered: Monetary/Fine $653,981.26Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 89 of 158

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Reporting Source: Firm

Initiated By: STATE OF ARIZONA - ARIZONA CORPORATION COMMISSION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 03/24/2009

Docket/Case Number: S-20655A-09-0071

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER

Current Status: Final

Resolution Date: 03/24/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanctions Ordered: Monetary/Fine $642,280.13Disgorgement/RestitutionCease and Desist/Injunction

Consent

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Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE WAS PAID ON 04/01/2009

Disclosure 90 of 158

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Reporting Source: Firm

Initiated By: STATE OF VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIESAND HEALTH CARE ADMINISTRATION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 03/18/2009

Docket/Case Number: 09-039-S

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER

Current Status: Final

Resolution Date: 03/18/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE WAS PAID ON 03/25/2009

Sanctions Ordered: Monetary/Fine $166,923.26Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 91 of 158

i

Reporting Source: Firm

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER

Current Status: Final

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Initiated By: TEXAS STATE SECURITIES BOARD

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 03/16/2009

Docket/Case Number: IC09-CDO-06

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER

Resolution Date: 03/16/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE WAS PAID ON 03/18/2009

Sanctions Ordered: Monetary/Fine $3,982,274.57Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 92 of 158

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Reporting Source: Regulator

Allegations: ON MARCH 24, 2009, THE SECURITIES DIVISION ENTERED INTO ACONSENT ORDER WITH WACHOVIA SECURITIES, LLC AND WACHOVIACAPITAL MARKETS, LLC (COLLECTIVELY "RESPONDENTS"), IN ORDER TOSETTLE THE ALLEGATIONS THAT RESPONDENTS HAD ENGAGED INDISHONEST AND UNETHICAL CONDUCT IN THE MARKETING AND SALE OFAUCTION RATE SECURITIES ("ARS"), AND FAILED TO REASONABLYSUPERVISE THEIR SALESPERSONS IN THE SALE OF ARS. RESPONDENTSNEITHER ADMITTED NOR DENIED THE ALLEGATIONS, BUT AGREED TOCEASE AND DESIST FROM VIOLATING THE SECURITIES ACT OFWASHINGTON. RESPONDENTS AGREED TO OFFER TO PURCHASE AT PARARS THAT ARE SUBJECT TO UNSUCCESSFUL AUCTIONS AND THAT ARENOT SUBJECT TO CURRENT CALLS OR REDEMPTIONS, FROM INVESTORSWHO PURCHASED ARS FROM RESPONDENTS ON OR BEFORE FEBRUARY13, 2008, INTO ACCOUNTS MAINTAINED WITH RESPONDENTS.RESPONDENTS AGREED TO PAY $491,556.71 AS A CIVIL MONETARYPENALTY. RESPONDENTS EACH WAIVED THEIR RIGHT TO A HEARING ANDTO JUDICIAL REVIEW OF THIS MATTER.

Current Status: Final

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Initiated By: WASHINGTON

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

Date Initiated: 03/24/2009

Docket/Case Number: S-08-229-09-CO01

URL for Regulatory Action:

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

ON MARCH 24, 2009, THE SECURITIES DIVISION ENTERED INTO ACONSENT ORDER WITH WACHOVIA SECURITIES, LLC AND WACHOVIACAPITAL MARKETS, LLC (COLLECTIVELY "RESPONDENTS"), IN ORDER TOSETTLE THE ALLEGATIONS THAT RESPONDENTS HAD ENGAGED INDISHONEST AND UNETHICAL CONDUCT IN THE MARKETING AND SALE OFAUCTION RATE SECURITIES ("ARS"), AND FAILED TO REASONABLYSUPERVISE THEIR SALESPERSONS IN THE SALE OF ARS. RESPONDENTSNEITHER ADMITTED NOR DENIED THE ALLEGATIONS, BUT AGREED TOCEASE AND DESIST FROM VIOLATING THE SECURITIES ACT OFWASHINGTON. RESPONDENTS AGREED TO OFFER TO PURCHASE AT PARARS THAT ARE SUBJECT TO UNSUCCESSFUL AUCTIONS AND THAT ARENOT SUBJECT TO CURRENT CALLS OR REDEMPTIONS, FROM INVESTORSWHO PURCHASED ARS FROM RESPONDENTS ON OR BEFORE FEBRUARY13, 2008, INTO ACCOUNTS MAINTAINED WITH RESPONDENTS.RESPONDENTS AGREED TO PAY $491,556.71 AS A CIVIL MONETARYPENALTY. RESPONDENTS EACH WAIVED THEIR RIGHT TO A HEARING ANDTO JUDICIAL REVIEW OF THIS MATTER.

Resolution Date: 03/24/2009

Resolution:

Other Sanctions Ordered:

Sanction Details: IT IS HEREBY ORDERED: 1. THIS ORDER CONCLUDES THE INVESTIGATIONBY THE SECURITIES DIVISION OF THE WASHINGTON STATE DEPARTMENTOF FINANCIAL INSTITUTIONS AND ANY OTHER ACTION THAT THESECURITIES DIVISION OF THE WASHINGTON STATE DEPARTMENT OFFINANCIAL INSTITUTIONS COULD COMMENCE UNDER APPLICABLEWASHINGTON STATE LAW ON BEHALF OF THE STATE OF WASHINGTON ASIT RELATES TO WACHOVIA, AND ITS MARKETING AND SALE OF AUCTIONRATE SECURITIES TO INVESTORS.2.THIS ORDER IS ENTERED INTO SOLELY FOR THE PURPOSE OFRESOLVING THE REFERENCED MULTI-STATE INVESTIGATION, AND IS NOTINTENDED TO BE USED FOR ANY OTHER PURPOSE. 3. WACHOVIA SHALLCEASE AND DESIST FROM VIOLATING THE SECURITIES ACT OFWASHINGTON AND SHALL COMPLY WITH THE SECURITIES ACT OFWASHINGTON.4. WITHIN TEN DAYS AFTER THE ENTRY OF THIS ORDER, WACHOVIA SHALLPAY THE SUM OF $491,556.71 TO THE STATE OF WASHINGTON AS A CIVILMONETARY PENALTY PURSUANT TO RCW 21.20.110, TO BE DEPOSITED INTHE SECURITIES PROSECUTION FUND, PURSUANT TO RCW 21.20.395,WHICH AMOUNT CONSTITUTES THE STATE OF WASHINGTON'SPROPORTIONATE SHARE OF THE STATE SETTLEMENT AMOUNT OF 50MILLION DOLLARS ($50,000,000.00).5. IN THE EVENT ANOTHER STATE SECURITIES REGULATOR DETERMINESNOT TO ACCEPT WACHOVIA'S STATE SETTLEMENT OFFER, THE TOTALAMOUNT OF THE STATE OF WASHINGTON'S PAYMENT SHALL NOT BEAFFECTED, AND SHALL REMAIN AT $491,556.71.6. WACHOVIA SECURITIES AND WACHOVIA CAPITAL MARKETS,RESPECTIVELY, AS AGENTS FOR ONE OR MORE AFFILIATED COMPANIESAND NOT AS PRINCIPAL, SHALL OFFER TO PURCHASE AT PAR ARS THATARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOTSUBJECT TO CURRENT CALLS OR REDEMPTIONS ("ELIGIBLE ARS") FROMALL INVESTORS IN THE RELEVANT CLASS. FOR PURPOSES OF THISORDER THE RELEVANT CLASS SHALL BE DEFINED AS ALL INVESTORSWHO PURCHASED ARS FROM EITHER WACHOVIA SECURITIES ORWACHOVIA CAPITAL MARKETS, RESPECTIVELY, ON OR BEFORE FEBRUARY13, 2008 INTO ACCOUNTS MAINTAINED AT WACHOVIA SECURITIES ORWACHOVIA CAPITAL MARKETS, RESPECTIVELY.

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

Yes

Sanctions Ordered: Monetary/Fine $491,556.71Cease and Desist/Injunction

Consent

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IT IS HEREBY ORDERED: 1. THIS ORDER CONCLUDES THE INVESTIGATIONBY THE SECURITIES DIVISION OF THE WASHINGTON STATE DEPARTMENTOF FINANCIAL INSTITUTIONS AND ANY OTHER ACTION THAT THESECURITIES DIVISION OF THE WASHINGTON STATE DEPARTMENT OFFINANCIAL INSTITUTIONS COULD COMMENCE UNDER APPLICABLEWASHINGTON STATE LAW ON BEHALF OF THE STATE OF WASHINGTON ASIT RELATES TO WACHOVIA, AND ITS MARKETING AND SALE OF AUCTIONRATE SECURITIES TO INVESTORS.2.THIS ORDER IS ENTERED INTO SOLELY FOR THE PURPOSE OFRESOLVING THE REFERENCED MULTI-STATE INVESTIGATION, AND IS NOTINTENDED TO BE USED FOR ANY OTHER PURPOSE. 3. WACHOVIA SHALLCEASE AND DESIST FROM VIOLATING THE SECURITIES ACT OFWASHINGTON AND SHALL COMPLY WITH THE SECURITIES ACT OFWASHINGTON.4. WITHIN TEN DAYS AFTER THE ENTRY OF THIS ORDER, WACHOVIA SHALLPAY THE SUM OF $491,556.71 TO THE STATE OF WASHINGTON AS A CIVILMONETARY PENALTY PURSUANT TO RCW 21.20.110, TO BE DEPOSITED INTHE SECURITIES PROSECUTION FUND, PURSUANT TO RCW 21.20.395,WHICH AMOUNT CONSTITUTES THE STATE OF WASHINGTON'SPROPORTIONATE SHARE OF THE STATE SETTLEMENT AMOUNT OF 50MILLION DOLLARS ($50,000,000.00).5. IN THE EVENT ANOTHER STATE SECURITIES REGULATOR DETERMINESNOT TO ACCEPT WACHOVIA'S STATE SETTLEMENT OFFER, THE TOTALAMOUNT OF THE STATE OF WASHINGTON'S PAYMENT SHALL NOT BEAFFECTED, AND SHALL REMAIN AT $491,556.71.6. WACHOVIA SECURITIES AND WACHOVIA CAPITAL MARKETS,RESPECTIVELY, AS AGENTS FOR ONE OR MORE AFFILIATED COMPANIESAND NOT AS PRINCIPAL, SHALL OFFER TO PURCHASE AT PAR ARS THATARE SUBJECT TO AUCTIONS THAT ARE NOT SUCCESSFUL AND ARE NOTSUBJECT TO CURRENT CALLS OR REDEMPTIONS ("ELIGIBLE ARS") FROMALL INVESTORS IN THE RELEVANT CLASS. FOR PURPOSES OF THISORDER THE RELEVANT CLASS SHALL BE DEFINED AS ALL INVESTORSWHO PURCHASED ARS FROM EITHER WACHOVIA SECURITIES ORWACHOVIA CAPITAL MARKETS, RESPECTIVELY, ON OR BEFORE FEBRUARY13, 2008 INTO ACCOUNTS MAINTAINED AT WACHOVIA SECURITIES ORWACHOVIA CAPITAL MARKETS, RESPECTIVELY.

Regulator Statement BRIDGETT FISHER 360-902-8783

iReporting Source: Firm

Initiated By: STATE OF WASHINGTON FINANCIAL INSTITUTIONS SECURITIES DIVISION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 03/24/2009

Docket/Case Number: S08-229-09-CO01

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMER

Current Status: Final

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Other Sanction(s)/ReliefSought:

Resolution Date: 03/24/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE WAS PAID ON 03/27/2009

Sanctions Ordered: Monetary/Fine $491,556.71Cease and Desist/Injunction

Consent

Disclosure 93 of 158

i

Reporting Source: Firm

Initiated By: STATE OF CALIFORNIA - DEPARTMENT OF CORPORATIONS

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 03/09/2009

Docket/Case Number:

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS

Current Status: Final

Resolution Date: 03/09/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO ACUTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanctions Ordered: Monetary/Fine $5,507,824.50Disgorgement/RestitutionCease and Desist/Injunction

Consent

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OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO ACUTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE WAS PAID ON 03/13/2009

Disclosure 94 of 158

i

Reporting Source: Firm

Initiated By: OFFICE OF THE COMMISSIONER OF FINANCIAL INSTITUTIONSCOMMONWEALTH OF PUERTO RICO

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 03/05/2009

Docket/Case Number: C09-V-001

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: ALLEGED THAT WACHOVIA SECURITIES MISREPRESENTED THE SALE OFAUCTION RATE SECURITIES TO CUSTOMERS.

Current Status: Final

Resolution Date: 03/05/2009

Resolution:

Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THATARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANTCLASS.

Sanction Details: FINE WAS PAID ON 3/11/2009.

Sanctions Ordered: Monetary/Fine $103,739.22Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 95 of 158

i

Reporting Source: Firm

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

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Initiated By: OFFICE OF THE MISSISSIPPI SECRETARY OF STATE

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 03/03/2009

Docket/Case Number: S-09-0086

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Resolution Date: 03/03/2009

Resolution:

Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THATARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANTCLASS.

Sanction Details: FINE WAS PAID ON 3/6/2009.

Sanctions Ordered: Monetary/Fine $317,667.55Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 96 of 158

i

Reporting Source: Regulator

Allegations: SECTION 17(A) OF THE SEC EXCHANGE ACT, RULES 17A-3 AND 17-4THEREUNDER, NASD RULES 2110, 3010(A), 3010(B)(1), 3012, 3012(B), 3110 -WACHOVIA SECURITIES, LLC FAILED TO SEND CUSTOMERSCONFIRMATION OF CHANGES IN INVESTMENT OBJECTIVES, AND THUSFAILED TO KEEP RECORDS OF SUCH MAILINGS. THE FIRM ERRONEOUSLYPROGRAMMED ITS COMPUTER SYSTEMS SO THE SYSTEM DID NOTGENERATE A MAILING TO THE CUSTOMER IF THE REQUIRED MAILINGDATE FELL ON A WEEKEND OR HOLIDAY WHILE NOTIFYING THE SYSTEMTHAT A LETTER HAD BEEN SENT. THE ERRORS WENT UNDETECTEDBECAUSE THE FIRM FAILED TO ASSIGN SUPERVISORY REVIEW ANDADEQUATE TESTING OVER ITS AUTOMATED MAILING SYSTEM AND FAILEDTO IMPLEMENT INTERNAL CONTROLS TO DETECT AND PREVENT ERRORS.THE FIRM FAILED TO SEND REQUIRED NOTIFICATIONS OF CHANGE ININVESTMENT OBJECTIVES TO CUSTOMERS AFFECTED BY A MERGER WITHANOTHER FIRM AND TO KEEP RECORDS REFLECTING THE MAILINGS. THEFIRM SENT DEFECTIVE INVESTMENT OBJECTIVE CHANGECONFIRMATIONS TO CUSTOMERS AS A RESULT OF PROGRAMMINGERRORS. THE FIRM FAILED TO CONFIRM WITH CUSTOMERS AND TO KEEPRECORDS OF CONFIRMATIONS AND CHANGES OF ADDRESS BY THECUSTOMERS AND FAILED TO SEND CHANGE OF ADDRESS NOTIFICATIONSTO CUSTOMERS. THIS ERROR WENT UNDETECTED BECAUSE IT FAILED TOIMPLEMENT ADEQUATE SUPERVISORY REVIEW AND TESTING, AS WELL ASIMPLEMENT INTERNAL CONTROLS OVER ITS AUTOMATED MAILINGSYSTEM. THE FIRM HAD AN ERROR IN ITS OPERATIONAL PROCEDURESUTILIZED BY EMPLOYEES WHO WERE CONDUCTING MANUAL REVIEWS OFCERTAIN TRANSACTIONS, RESULTING IN ITS FAILURE TO SEND REQUIREDNOTIFICATIONS TO CUSTOMERS WHEN ASSETS WERE TRANSFERRED TOA THIRD-PARTY OR AN OUTSIDE ENTITY. THE FIRM FAILED TO SEND ASSETNOTIFICATIONS TO CUSTOMERS RELATED TO THE PAYMENT OF FEES TOOUTSIDE MONEY MANAGERS. THE FIRM FAILED TO SEND COMPLETECUSTOMER PROFILE INFORMATION VERIFICATION FORMS TOCUSTOMERS. [CONTINUED IN COMMENTS]

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 02/23/2009

Docket/Case Number: 2007009470901

Principal Product Type: Other

Other Product Type(s): UNKNOWN TYPES OF SECURITIES

SECTION 17(A) OF THE SEC EXCHANGE ACT, RULES 17A-3 AND 17-4THEREUNDER, NASD RULES 2110, 3010(A), 3010(B)(1), 3012, 3012(B), 3110 -WACHOVIA SECURITIES, LLC FAILED TO SEND CUSTOMERSCONFIRMATION OF CHANGES IN INVESTMENT OBJECTIVES, AND THUSFAILED TO KEEP RECORDS OF SUCH MAILINGS. THE FIRM ERRONEOUSLYPROGRAMMED ITS COMPUTER SYSTEMS SO THE SYSTEM DID NOTGENERATE A MAILING TO THE CUSTOMER IF THE REQUIRED MAILINGDATE FELL ON A WEEKEND OR HOLIDAY WHILE NOTIFYING THE SYSTEMTHAT A LETTER HAD BEEN SENT. THE ERRORS WENT UNDETECTEDBECAUSE THE FIRM FAILED TO ASSIGN SUPERVISORY REVIEW ANDADEQUATE TESTING OVER ITS AUTOMATED MAILING SYSTEM AND FAILEDTO IMPLEMENT INTERNAL CONTROLS TO DETECT AND PREVENT ERRORS.THE FIRM FAILED TO SEND REQUIRED NOTIFICATIONS OF CHANGE ININVESTMENT OBJECTIVES TO CUSTOMERS AFFECTED BY A MERGER WITHANOTHER FIRM AND TO KEEP RECORDS REFLECTING THE MAILINGS. THEFIRM SENT DEFECTIVE INVESTMENT OBJECTIVE CHANGECONFIRMATIONS TO CUSTOMERS AS A RESULT OF PROGRAMMINGERRORS. THE FIRM FAILED TO CONFIRM WITH CUSTOMERS AND TO KEEPRECORDS OF CONFIRMATIONS AND CHANGES OF ADDRESS BY THECUSTOMERS AND FAILED TO SEND CHANGE OF ADDRESS NOTIFICATIONSTO CUSTOMERS. THIS ERROR WENT UNDETECTED BECAUSE IT FAILED TOIMPLEMENT ADEQUATE SUPERVISORY REVIEW AND TESTING, AS WELL ASIMPLEMENT INTERNAL CONTROLS OVER ITS AUTOMATED MAILINGSYSTEM. THE FIRM HAD AN ERROR IN ITS OPERATIONAL PROCEDURESUTILIZED BY EMPLOYEES WHO WERE CONDUCTING MANUAL REVIEWS OFCERTAIN TRANSACTIONS, RESULTING IN ITS FAILURE TO SEND REQUIREDNOTIFICATIONS TO CUSTOMERS WHEN ASSETS WERE TRANSFERRED TOA THIRD-PARTY OR AN OUTSIDE ENTITY. THE FIRM FAILED TO SEND ASSETNOTIFICATIONS TO CUSTOMERS RELATED TO THE PAYMENT OF FEES TOOUTSIDE MONEY MANAGERS. THE FIRM FAILED TO SEND COMPLETECUSTOMER PROFILE INFORMATION VERIFICATION FORMS TOCUSTOMERS. [CONTINUED IN COMMENTS]

Resolution Date: 02/23/2009

Resolution:

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

No

Sanctions Ordered: CensureMonetary/Fine $1,100,000.00

Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered: UNDERTAKINGS: RETAIN, WITHIN 60 DAYS OF NOTICE OF ACCEPTANCE OFTHIS AWC, AN INDEPENDENT CONSULTANT TO CONDUCT ACOMPREHENSIVE REVIEW OF THE ADEQUACY OF THE FIRM'S POLICES,PROCEDURES, TESTING AND SYSTEMS ADOPTED IN RESPONSE TO THEACTIVITY DESCRIBED, TO ENSURE THAT ITS PROCEDURES AREREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULESAND FEDERAL SECURITIES LAWS. AFTER CONCLUSION OF THE REVIEW,THE CONSULTANT SHALL SUBMIT A WRITTEN REPORT TO THE FIRM ANDFINRA ADDRESSING THE FIRM'S POLICIES, SYSTEMS, PROCEDURES ANDTRAINING. WITHIN 90 DAYS AFTER RECEIPT OF THE WRITTEN REPORT,THE FIRM SHALL ADOPT AND IMPLEMENT THE CONSULTANT'SRECOMMENDATIONS OR PROPOSE ALTERNATIVE PROCEDURES INWRITING TO THE CONSULTANT AND FINRA. THE CONSULTANT WILLREVIEW AND EVALUATE THE PROPOSED ALTERNATIVES WITHIN 30 DAYSAND PROVIDE A DECISION. THE FIRM WILL ABIDE BY THE CONSULTANT'SDETERMINATIONS AND, WITHIN 30 DAYS, THE FIRM SHALL PROVIDE FINRAWITH A WRITTEN IMPLEMENTATION REPORT SETTING FORTH THE DETAILSOF ITS IMPLEMENTATION OF THE CONSULTANT'S RECOMMENDATIONS.

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 $1,100,000, JOINTLY ANDSEVERALLY, AND REQUIRED TO COMPLY WITH UNDERTAKINGS.

Regulator Statement THE FORM DISPLAYED "F" AS A NET WORTH CODE, BUT NOCORRESPONDING DOLLAR RANGE APPEARED IN THE FINANCIAL CODELEGEND AND CUSTOMERS WERE UNABLE TO VERIFY THEIR NET WORTHAMOUNT RECORDED BY THE FIRM. THE FIRM HAD AN INADEQUATESYSTEM OF SUPERVISION WITH RESPECT TO VARIOUS REQUIREDMAILINGS BECAUSE THE SUPERVISORY SYSTEMS ESTABLISHED WERENOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASDRULES AND FEDERAL SECURITIES LAWS.

Sanctions Ordered: CensureMonetary/Fine $1,100,000.00

iReporting Source: Firm

Initiated By: FINRA

Date Initiated: 02/23/2009

Docket/Case Number: 2007009470901

Allegations: FINRA HAS ALLEGED THAT WACHOVIA SECURITIES, LLC AND FIRSTCLEARING, LLC FAILED TO ACCURATELY MAKE CERTAIN CUSTOMERMAILINGS.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Principal Product Type: No Product

Other Product Type(s):

Resolution Date: 02/23/2009

Resolution:

Other Sanctions Ordered: AN OUTSIDE CONSULTANT SHALL CONDUCT A REVIEW OF THE FIRM'SPOLICIES, PROCEDURES, TESTING AND SYSTEMS ADOPTED IN RESPONSETO THE ACTIVITY DESCRIBED IN THE AWC.

Sanction Details: WACHOVIA SECURITIES, LLC AND FIRST CLEARING, LLC JOINTLYCONSENTED TO A FINE OF $1,100,000.00.

Sanctions Ordered: CensureMonetary/Fine $1,100,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 97 of 158

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Reporting Source: Firm

Initiated By: STATE OF GEORGIA COMMISSIONER OF SECURITIES

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 02/24/2009

Docket/Case Number: ENSC-1465

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

Resolution Date: 02/24/2009

Resolution: Consent

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Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THATARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANTCLASS.

Sanction Details: FINE IS DUE BY 03/06/2009

Sanctions Ordered: Monetary/Fine $1,076,276.28Disgorgement/RestitutionCease and Desist/Injunction

Disclosure 98 of 158

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Reporting Source: Firm

Initiated By: STATE OF NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATESECURITIES DIVISION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 02/24/2009

Docket/Case Number: 09SEC029

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

Resolution Date: 02/24/2009

Resolution:

Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THATARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANTCLASS.

Sanction Details: PAYMENT OF FINE IS DUE BY 03/06/2009

Sanctions Ordered: Monetary/Fine $1,700,203.25Disgorgement/RestitutionCease and Desist/Injunction

Consent

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Disclosure 99 of 158

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Reporting Source: Firm

Initiated By: MONTANA SECURITIES DEPARTMENT

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 02/17/2009

Docket/Case Number: CASE NO. SEC-2009-5

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

Resolution Date: 02/17/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE WAS FINE PAID ON FEBRUARY 19, 2009

Sanctions Ordered: Monetary/Fine $148,811.54Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 100 of 158

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Reporting Source: Firm

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

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

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

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 02/17/2009

Docket/Case Number: FILE NO. I09-038

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Resolution Date: 02/17/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE WAS PAID ON FEBRUARY 24, 2009

Sanctions Ordered: Monetary/Fine $839,326.74Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 101 of 158

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Reporting Source: Firm

Initiated By: STATE OF SOUTH DAKOTA DEPARTMENT OF REVENUE AND REGULATIONDIVISION OF SECURITIES

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 02/19/2009

Docket/Case Number: ADMINISTRATIVE CONSENT ORDER

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

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Other Sanction(s)/ReliefSought:

Resolution Date: 02/19/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: THE FINE WAS PAID ON FEBRUARY 25, 2009

Sanctions Ordered: Monetary/Fine $155,069.08Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 102 of 158

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Reporting Source: Firm

Initiated By: ATTORNEY GENERAL OF THE STATE OF NEW YORK INVESTORPROTECTION BUREAU

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 02/04/2009

Docket/Case Number: ASSURANCE NO. 08-179

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS

Current Status: Final

Resolution Date: 02/04/2009

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanctions Ordered: Monetary/Fine $50,000,000.00Disgorgement/RestitutionCease and Desist/Injunction

Consent

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Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS

Sanction Details: PAYMENT IS DUE TO STATE OF NEW YORK BY MARCH 31, 2009

Disclosure 103 of 158

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Reporting Source: Firm

Initiated By: COMMON WEALTH OF MASSACHUSETTS SECURITIES DIVISION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 02/19/2009

Docket/Case Number: E-2008-0053

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

Resolution Date: 02/19/2009

Resolution:

Other Sanctions Ordered: OFFER TO PURCHASE AT PAR ARS THAT ARE SUBJECT TO AUCTIONS THATARE NOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION ("ELIGIBLE ARS") FROM ALL INVESTORS IN THE RELEVANTCLASS.

Sanction Details: THE FINE WAS PAID ON FEBRUARY 24, 2009

Sanctions Ordered: Monetary/Fine $782,321.56Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 104 of 158

i

Reporting Source: Firm

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Current Status: Final

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Initiated By: OFFICE OF THE SECRETARY OF STATESTATE OF MISSOURI

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 12/08/2008

Docket/Case Number: AP-08-28

Principal Product Type: Other

Other Product Type(s): AUCTION RATE SECURITIES

Allegations: THE STATE HAS ALLEGED THAT WACHOVIA SECURITIESMISREPRESENTED THE SALE OF AUCTION RATE SECURITIES TOCUSTOMERS.

Resolution Date: 12/08/2008

Resolution:

Other Sanctions Ordered: OFFER TO REPURCHASE ARS THAT ARE SUBJECT TO AUCTIONS THAT ARENOT SUCCESSFUL AND ARE NOT SUBJECT TO CURRENT CALLS ORREDEMPTION IN THE RELEVANT CLASS.

Sanction Details: IN ADDITION TO TO THE FINE PAID ON 12/16/2008 IN THE AMOUNT OF$2,841,550.88. WACHOVIA SHALL PAY $265,000 AS COST FOR THEINVESTIGATION. $15,000 SHALL BE PAID TO NASAA.

Sanctions Ordered: Monetary/Fine $2,841,550.88Disgorgement/RestitutionCease and Desist/Injunction

Consent

Disclosure 105 of 158

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Reporting Source: Regulator

Initiated By: MARYLAND

Date Initiated: 01/01/2006

Docket/Case Number: 2008-0268

Allegations: IN CONNECTION WITH RESPONDENT'S (AND RESPONDENT'SPREDECESSOR'S) EMPLOYMENT OF BROKER MILLIET K. LANHAM,RESPONDENT FAILED TO REASONABLY SUPERVISE WITHIN THE MEANINGOF SECTION 11-412(A)(10) OF THE SECURITIES ACT.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

FINECOMPLIANCE UNDERTAKINGS

Docket/Case Number: 2008-0268

URL for Regulatory Action:

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

Other Product Type(s):

Resolution Date: 12/08/2008

Resolution:

Other Sanctions Ordered: RESTITUTION TO ONE CUSTOMER IN AMOUNT OF $109,673.SUPERVISING BROKER MUST TAKE CERTAIN CONTINUING EDUCATIONCOURSES DEALING WITH SUPERVISION WITHIN SIX MONTHS OFEXECUTION OF ORDER.COMPLIANCE ENHANCEMENTS AND UNDERTAKINGS TO BE PERFORMED.

Sanction Details: FINE = $50,000 PAID UPON ISSUANCE OF ORDER. NO PORTION OFPENALTY WAS WAIVED.

Regulator Statement CONSENT ORDER REFERRED TO FORMER BROKER'S HANDLING OFCERTAIN CUSTOMER ACCOUNTS. SOME CUSTOMERS WERE INVOLVED INPRIVATE SETTLEMENT OF CLAIMS. ONE CUSTOMER, B.L., RECEIVEDRESTITUTION PURSUANT TO THE TERMS OF THE CONSENT ORDER INCONNECTION WITH BROKER'S HANDLING OF HER ACCOUNT.

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

No

Sanctions Ordered: Monetary/Fine $50,000.00Disgorgement/RestitutionCease and Desist/Injunction

Stipulation and Consent

iReporting Source: Firm

Allegations: IN CONNECTION WITH RESPONDENT'S (AND RESPONDENT'SPREDECESSOR'S) EMPLOYMENT OF BROKER MILLIET K. LANHAM,RESPONDENT FAILED TO REASONABLY SUPERVISE WITHIN THE MEANINGOF SECTION 11-412(A)(10) OF THE SECURITIES ACT.

Current Status: Final

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Initiated By: STATE OF MARYLAND

Principal Sanction(s)/ReliefSought:

Undertaking

Other Sanction(s)/ReliefSought:

FINE

Date Initiated: 01/01/2006

Docket/Case Number: 2008-0268

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

Other Product Type(s):

Resolution Date: 12/08/2008

Resolution:

Other Sanctions Ordered: RESTITUTION TO ONE CUSTOMER IN AMOUNT OF $109,673. SUPERVISINGBROKER MUST TAKE CERTAIN CONTINUING EDUCATION COURSESDEALING WITH SUPERVISION WITHIN SIX MONTHS OF EXECUTION OFORDER. COMPLIANCE ENHANCEMENTS AND UNDERTAKINGS TO BEPERFORMED.

Sanction Details: FINE = $50,000 PAID UPON ISSUANCE OF ORDER. NO PORTION OFPENALTY WAS WAIVED.

Firm Statement CONSENT ORDER REFERRED TO FORMER BROKER'S HANDLING OFCERTAIN CUSTOMER ACCOUNTS. SOME CUSTOMERS WERE INVOLVED INPRIVATE SETTLEMENT OF CLAIMS. ONE CUSTOMER, B.L., RECEIVEDRESTITUTION PURSUANT TO THE TERMS OF THE CONSENT ORDER INCONNECTION WITH BROKER'S HANDLING OF HER ACCOUNT.

Sanctions Ordered: Monetary/Fine $50,000.00Disgorgement/RestitutionCease and Desist/Injunction

Stipulation and Consent

Disclosure 106 of 158

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Reporting Source: Regulator

Allegations: NASD RULES 1021, 1022(A)(1), 1022(A)(5), 2110, 3010: RESPONDENTMEMBER FIRM PERMITTED INDIVIDUAL TO FUNCTION AS A PRINCIPALWITHOUT BEING PROPERLY LICENSED AS A GENERAL SECURITIESPRINCIPAL ("GP") AND PERMITTED AN INDIVIDUAL TO SUPERVISE ITSEQUITY RESEARCH ANALYSTS WITHOUT BEING PROPERLY LICENSED AS ARESEARCH PRINCIPAL ("RP"). THE FIRM ALSO FAILED TO ENSURE THAT AGP OR RP MANAGE AND SUPERVISE THE FIRM'S ADVISORY SERVICESGROUP BY FAILING TO ENSURE THAT INDIVIDUAL BE PROPERLYLICENSED.

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 10/30/2008

Docket/Case Number: 2007010115401

Principal Product Type: No Product

Other Product Type(s):

NASD RULES 1021, 1022(A)(1), 1022(A)(5), 2110, 3010: RESPONDENTMEMBER FIRM PERMITTED INDIVIDUAL TO FUNCTION AS A PRINCIPALWITHOUT BEING PROPERLY LICENSED AS A GENERAL SECURITIESPRINCIPAL ("GP") AND PERMITTED AN INDIVIDUAL TO SUPERVISE ITSEQUITY RESEARCH ANALYSTS WITHOUT BEING PROPERLY LICENSED AS ARESEARCH PRINCIPAL ("RP"). THE FIRM ALSO FAILED TO ENSURE THAT AGP OR RP MANAGE AND SUPERVISE THE FIRM'S ADVISORY SERVICESGROUP BY FAILING TO ENSURE THAT INDIVIDUAL BE PROPERLYLICENSED.

Resolution Date: 10/30/2008

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT MEMBERFIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $75,000.

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

No

Sanctions Ordered: CensureMonetary/Fine $75,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Allegations: NASD RULES 1021, 1022(A)(1), 1022(A)(5), 2110, 3010: RESPONDENTMEMBER FIRM PERMITTED INDIVIDUAL TO FUNCTION AS A PRINCIPALWITHOUT BEING PROPERLY LICENSED AS A GENERAL SECURITIESPRINCIPAL ("GP") AND PERMITTED AN INDIVIDUAL TO SUPERVISE ITSEQUITY RESEARCH ANALYSTS WITHOUT BEING PROPERLY LICENSED AS ARESEARCH PRINCIPAL ("RP"). THE FIRM ALSO FAILED TO ENSURE THAT AGP OR RP MANAGE AND SUPERVISE THE FIRM'S ADVISORY SERVICESGROUP BY FAILING TO ENSURE THAT INDIVIDUAL BE PROPERLYLICENSED.

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 10/30/2008

Docket/Case Number: 2007010115401

Principal Product Type: No Product

Other Product Type(s):

NASD RULES 1021, 1022(A)(1), 1022(A)(5), 2110, 3010: RESPONDENTMEMBER FIRM PERMITTED INDIVIDUAL TO FUNCTION AS A PRINCIPALWITHOUT BEING PROPERLY LICENSED AS A GENERAL SECURITIESPRINCIPAL ("GP") AND PERMITTED AN INDIVIDUAL TO SUPERVISE ITSEQUITY RESEARCH ANALYSTS WITHOUT BEING PROPERLY LICENSED AS ARESEARCH PRINCIPAL ("RP"). THE FIRM ALSO FAILED TO ENSURE THAT AGP OR RP MANAGE AND SUPERVISE THE FIRM'S ADVISORY SERVICESGROUP BY FAILING TO ENSURE THAT INDIVIDUAL BE PROPERLYLICENSED.

Resolution Date: 10/30/2008

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT MEMBERFIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $75,000.

Sanctions Ordered: CensureMonetary/Fine $75,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 107 of 158

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Reporting Source: Regulator

Initiated By: NEW JERSEY BUREAU OF SECURITIES

Date Initiated: 03/28/2007

Docket/Case Number: 2007-010

URL for Regulatory Action:

Allegations: AG EDWARDS PERMITTED AN UNREGISTERED PERSON TO USE BRANCHOFFICE FACILITIES TO FACILITATE THE REFERAL AND TRANSFER OFCLIENT FROM PREVIOUS BROKER-DEALER TO AG EDWARDS THROUGHHIS FORMER PARTNER NOW AN AG EDWARDS AGENT. AG EDWARDS DIDNOT SUPERVISE NOR EMPLOY THE INDIVIDUAL IN ANY CAPACITY ANDPERMITTED THE UNREGISTERED PERSON TO TRANSACT SECURITIESTHROUGH HIS FORMER PARTNER.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Principal Product Type: No Product

Other Product Type(s):

Resolution Date: 10/06/2008

Resolution:

Other Sanctions Ordered: WACHOVIA WILL OFFER NO LESS THAN $120,000, RESTITUTION TOCOMPENSATE FOR THE LOSSES OF CERTAIN CUSTOMERS.

Sanction Details: AG EDWARDS ALLOWED AN UNREGISTERED PERSON TO MAINTAIN APRESENCE IN A NEW JERSEY BRANCH OFFICE AND PROVIDE INVESTMENTADVISE TO CLIENTS. AG EDWARDS FAILED TO PREVENT UNSUITABLETRADING STRATEGIES FROM BEING RECOMMENDED TO AG EDWARDSCLIENTS A FAILED TO REASONABLY SUPERVISE AND ESTABLISH ANDENFORCE PROCEDURES NECESSARY TO DEFECT AND PREVENT SUCHCONDUCT.

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

No

Sanctions Ordered: Monetary/Fine $400,000.00Disgorgement/Restitution

Consent

iReporting Source: Firm

Initiated By: NEW JERSEY BUREAU OF SECURITIES

Date Initiated: 03/28/2007

Docket/Case Number: 2007-010

Allegations: AG EDWARDS PERMITTED AN UNREGISTERED PERSON TO USE BRANCHOFFICE FACILITIES TO FACILITATE THE REFERAL AND TRANSFER OFCLIENT FROM PREVIOUS BROKER-DEALER TO AG EDWARDS THROUGHHIS FORMER PARTNER A FORMER AG EDWARDS AGENT. AG EDWARDS DIDNOT SUPERVISE NOR EMPLOY THE INDIVIDUAL IN ANY CAPACITY ANDPERMITTED THE UNREGISTERED PERSON TO TRANSACT SECURITIESTHROUGH HIS FORMER PARTNER

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Docket/Case Number: 2007-010

Principal Product Type: No Product

Other Product Type(s):

Resolution Date: 10/06/2008

Resolution:

Other Sanctions Ordered: WACHOVIA WILL OFFER NO LESS THAN $120,000, RESTITUTION TOCOMPENSATE FOR THE LOSSES OF CERTAIN CUSTOMERS.

Sanction Details: AG EDWARDS ALLOWED AN UNREGISTERED PERSON TO MAINTAIN APRESENCE IN A NEW JERSEY BRANCH OFFICE AND PROVIDE INVESTMENTADVISE TO CLIENTS. AG EDWARDS FAILED TO PREVENT UNSUITABLETRADING STRATEGIES FROM BEING RECOMMENDED TO AG EDWARDSCLIENTS, FAILED TO REASONABLY SUPERVISE AND ESTABLISH ANDENFORCE PROCEDURES NECESSARY TO DEFECT PREVENT SUCHCONDUCT.

Sanctions Ordered: Monetary/Fine $400,000.00Disgorgement/Restitution

Consent

Disclosure 108 of 158

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Reporting Source: Firm

Initiated By: TEXAS STATE SECURITIES BOARD

Principal Sanction(s)/ReliefSought:

Undertaking

Date Initiated: 07/14/2008

Docket/Case Number: IC08-CAF-05

Principal Product Type: Other

Other Product Type(s):

Allegations: THE FIRM THROUGH A REGISTERED REPRESENTATIVE AND OTHERSALLOWED THE CLIENT'S WIFE TO EFFECT THE WITHDRAWALS FROM ACUSTOMER'S ACCOUNT WITHOUT THE REQUIRED DOCUMENTS ASREQUIRED BY A.G. EDWARDS WRITTEN PROCEDURES.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

Undertaking

Other Sanction(s)/ReliefSought:

Resolution Date: 07/14/2008

Resolution:

Other Sanctions Ordered: WITHIN 30 DAYS EDWARDS WILL MAKE A GOOD FAITH AND BINDINGSETTLEMENT OFFER OF AT LEAST $10,000.00 AND PROVIDE THE DIVISIONWITH A COPY OF THE OFFER.

Sanction Details: REPRIMAND AND $5000 FINE.

Sanctions Ordered: Monetary/Fine $5,000.00

Order

Disclosure 109 of 158

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Reporting Source: Regulator

Allegations: NASD RULES 2110, 2310, 3010: WACHOVIA SECURITIES DID NOTADEQUATELY CONSIDER, ON A CONSISTENT BASIS, PERTINENTELEMENTS, SUCH AS BREAKPOINTS, FEES AND EXPENSES, WHENMAKING RECOMMENDATIONS TO CUSTOMERS TO PURCHASE CLASS B ORCLASS C SHARES IN MUTUAL FUNDS INSTEAD OF CLASS A SHARES.WACHOVIA SECURITIES RECOMMENDED AND SOLD CLASS B AND/ORCLASS C SHARES TO CUSTOMERS WHO, DEPENDING UPON AMONGOTHER THINGS, THE AMOUNT OF THE INVESTMENT AND THE CUSTOMER'SCONTEMPLATED HOLDING PERIOD, WOULD HAVE BENEFITED HAD THEYPURCHASED CLASS A SHARES INSTEAD. AS A RESULT, WACHOVIARECEIVED GREATER COMMISSIONS TOTALING $3.86 MILLION MORE THATIT WOULD HAVE RECEIVED HAD IT SOLD CLASS A SHARES IN THE SAMEMUTUAL FUNDS. WACHOVIA FAILED TO ESTABLISH, MAINTAIN ANDENFORCE ADEQUATE SUPERVISORY AND COMPLIANCE POLICIES ANDPROCEDURES THAT WERE REASONABLY DESIGNED TO IDENTIFYPURCHASES OF CLASS B AND/OR CLASS C SHARES BY CUSTOMERS FORWHOM CLASS A SHARES WOULD HAVE BEEN MORE ECONOMICALLYBENEFICIAL, NOR WERE THE FIRM'S PROCEDURES SUFFICIENT ENOUGHTO ENSURE THAT REGISTERED REPRESENTATIVES MADE ADEQUATEDISCLOSURES TO CUSTOMERS ABOUT THE VARIOUS CLASSES OFMUTUAL FUNDS. WACHOVIA FAILED TO ENSURE THAT ELIGIBLEINVESTORS RECEIVED THE BENEFIT OF AVAILABLE NET ASSET VALUE(NAV) TRANSFER PROGRAMS, RESULTING IN CUSTOMERS INCURRINGFRONT-END SALES CHARGES THEY SHOULD NOT HAVE PAID, ORPURCHASED OTHER SHARE CLASSES THAT UNNECESSARILY SUBJECTEDTHEM TO HIGHER FEES AND THE POTENTIAL OF CONTINGENT DEFERREDSALES CHARGES. WACHOVIA FAILED TO EXERCISE REASONABLE DUEDILIGENCE TO IDENTIFY ESSENTIAL TERMS AND CONDITIONS OF THE NAVTRANSFER PROGRAMS OF CERTAIN MUTUAL FUNDS, AND FAILED TOESTABLISH, MAINTAIN AND ENFORCE SYSTEMS AND PROCEDURES TOENSURE THAT ITS CUSTOMERS RECEIVED THE BENEFIT OF NAV PRICINGWHEN THEY QUALIFIED. [CONTINUED IN COMMENTS]

Current Status: Final

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Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 02/12/2009

Docket/Case Number: E9A2005013001

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

NASD RULES 2110, 2310, 3010: WACHOVIA SECURITIES DID NOTADEQUATELY CONSIDER, ON A CONSISTENT BASIS, PERTINENTELEMENTS, SUCH AS BREAKPOINTS, FEES AND EXPENSES, WHENMAKING RECOMMENDATIONS TO CUSTOMERS TO PURCHASE CLASS B ORCLASS C SHARES IN MUTUAL FUNDS INSTEAD OF CLASS A SHARES.WACHOVIA SECURITIES RECOMMENDED AND SOLD CLASS B AND/ORCLASS C SHARES TO CUSTOMERS WHO, DEPENDING UPON AMONGOTHER THINGS, THE AMOUNT OF THE INVESTMENT AND THE CUSTOMER'SCONTEMPLATED HOLDING PERIOD, WOULD HAVE BENEFITED HAD THEYPURCHASED CLASS A SHARES INSTEAD. AS A RESULT, WACHOVIARECEIVED GREATER COMMISSIONS TOTALING $3.86 MILLION MORE THATIT WOULD HAVE RECEIVED HAD IT SOLD CLASS A SHARES IN THE SAMEMUTUAL FUNDS. WACHOVIA FAILED TO ESTABLISH, MAINTAIN ANDENFORCE ADEQUATE SUPERVISORY AND COMPLIANCE POLICIES ANDPROCEDURES THAT WERE REASONABLY DESIGNED TO IDENTIFYPURCHASES OF CLASS B AND/OR CLASS C SHARES BY CUSTOMERS FORWHOM CLASS A SHARES WOULD HAVE BEEN MORE ECONOMICALLYBENEFICIAL, NOR WERE THE FIRM'S PROCEDURES SUFFICIENT ENOUGHTO ENSURE THAT REGISTERED REPRESENTATIVES MADE ADEQUATEDISCLOSURES TO CUSTOMERS ABOUT THE VARIOUS CLASSES OFMUTUAL FUNDS. WACHOVIA FAILED TO ENSURE THAT ELIGIBLEINVESTORS RECEIVED THE BENEFIT OF AVAILABLE NET ASSET VALUE(NAV) TRANSFER PROGRAMS, RESULTING IN CUSTOMERS INCURRINGFRONT-END SALES CHARGES THEY SHOULD NOT HAVE PAID, ORPURCHASED OTHER SHARE CLASSES THAT UNNECESSARILY SUBJECTEDTHEM TO HIGHER FEES AND THE POTENTIAL OF CONTINGENT DEFERREDSALES CHARGES. WACHOVIA FAILED TO EXERCISE REASONABLE DUEDILIGENCE TO IDENTIFY ESSENTIAL TERMS AND CONDITIONS OF THE NAVTRANSFER PROGRAMS OF CERTAIN MUTUAL FUNDS, AND FAILED TOESTABLISH, MAINTAIN AND ENFORCE SYSTEMS AND PROCEDURES TOENSURE THAT ITS CUSTOMERS RECEIVED THE BENEFIT OF NAV PRICINGWHEN THEY QUALIFIED. [CONTINUED IN COMMENTS]

Resolution Date: 02/12/2009

Resolution:

Other Sanctions Ordered: UNDERTAKINGS: WACHOVIA WILL UNDERTAKE TO PROVIDE REMEDIATIONTO CUSTOMERS WHO PURCHASED CLASS B AND/OR CLASS C SHARES OFMUTUAL FUNDS WHEN THE PURCHASE OF CLASS A SHARES WOULD HAVEBEEN MORE BENEFICIAL, EXCLUDING CUSTOMERS WHO SETTLED,CANCELLED THEIR PURCHASES, WERE NOT SUBJECT TO HIGHERCHARGES OR FEES THAN CLASS A SHARES, WERE NOT ELIGIBLE FORBREAKPOINTS, OR WHERE THERE WAS NO DISCERNABLE MATERIALBENEFIT IN PURCHASING CLASS A SHARES OVER CLASS B AND/OR CLASSC SHARES. WITHIN 120 DAYS, WACHOVIA WILL PROVIDE CURRENT CLASSB AND CLASS C SHARE OWNERS THE OPTION TO CONVERT TO CLASS ASHARE OWNERSHIP. WACHOVIA WILL ALSO PROVIDE REMEDIATION TOCUSTOMERS WHO PURCHASED SHARES OF MUTUAL FUNDS ANDQUALIFIED FOR, BUT DID NOT RECEIVE, THE BENEFIT OF A NAV TRANSFERPROGRAM, INCLUDING REFUND OF INITIAL SALES CHARGE PLUSINTEREST AND VARIOUS FEES AND EXPENSES. THE REMEDIATION PLANINCLUDES QUALIFYING CLASS B AND/OR CLASS C SHARES THAT ALSOQUALIFY FOR NAV PURCHASES. WITHIN 60 DAYS OF ACCEPTANCE OF THEAWC, WACHOVIA WILL PROVIDE FINRA WITH A SAMPLE LETTERS TOCUSTOMERS: 1) WISHING TO CONVERT CLASS B AND CLASS C SHARESINTO CLASS A SHARES THE OFFER, AN EXPLANATION OF THEADVANTAGES AND DISADVANTAGES, AND ADVICE TO CONSULT A TAXADVISOR; AND 2) WHO DID NOT RECEIVE THE BENEFITS OF THE NAVTRANSFER PROGRAM DETAILING REMEDIATION PAYMENTS. ALSO, WITHIN60 SAYS, WACHOVIA WILL TRAIN STAFF TO FIELD CUSTOMER INQUIRES,RETAIN A THIRD-PARTY EXAMINER TO EXAMINE THE FIRM'SPERFORMANCE OF ITS OBLIGATIONS UNDER THE TERMS OF THE AWC,BEAR THE EXAMINER'S COSTS AND COOPERATE WITH THE EXAMINER.WACHOVIA SHALL COMPLETE THE REMEDIATION PROCESS WITHIN 270DAYS OF THE AWC AND WITHIN 330 DAYS OF THE EFFECTIVE DATE OF THEAWC FILED A DETAILED REPORT WITH FINRA REGARDING THE RESULTSOF THE REMEDIATION PLAN. THE THIRD PARTY EXAMINER SHALL FILE AFINAL REPORT NO LATER THAN 420 DAYS AFTER THE EFFECTIVE DATE OFTHE AWC.

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

No

Sanctions Ordered: CensureMonetary/Fine $4,410,000.00

Acceptance, Waiver & Consent(AWC)

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UNDERTAKINGS: WACHOVIA WILL UNDERTAKE TO PROVIDE REMEDIATIONTO CUSTOMERS WHO PURCHASED CLASS B AND/OR CLASS C SHARES OFMUTUAL FUNDS WHEN THE PURCHASE OF CLASS A SHARES WOULD HAVEBEEN MORE BENEFICIAL, EXCLUDING CUSTOMERS WHO SETTLED,CANCELLED THEIR PURCHASES, WERE NOT SUBJECT TO HIGHERCHARGES OR FEES THAN CLASS A SHARES, WERE NOT ELIGIBLE FORBREAKPOINTS, OR WHERE THERE WAS NO DISCERNABLE MATERIALBENEFIT IN PURCHASING CLASS A SHARES OVER CLASS B AND/OR CLASSC SHARES. WITHIN 120 DAYS, WACHOVIA WILL PROVIDE CURRENT CLASSB AND CLASS C SHARE OWNERS THE OPTION TO CONVERT TO CLASS ASHARE OWNERSHIP. WACHOVIA WILL ALSO PROVIDE REMEDIATION TOCUSTOMERS WHO PURCHASED SHARES OF MUTUAL FUNDS ANDQUALIFIED FOR, BUT DID NOT RECEIVE, THE BENEFIT OF A NAV TRANSFERPROGRAM, INCLUDING REFUND OF INITIAL SALES CHARGE PLUSINTEREST AND VARIOUS FEES AND EXPENSES. THE REMEDIATION PLANINCLUDES QUALIFYING CLASS B AND/OR CLASS C SHARES THAT ALSOQUALIFY FOR NAV PURCHASES. WITHIN 60 DAYS OF ACCEPTANCE OF THEAWC, WACHOVIA WILL PROVIDE FINRA WITH A SAMPLE LETTERS TOCUSTOMERS: 1) WISHING TO CONVERT CLASS B AND CLASS C SHARESINTO CLASS A SHARES THE OFFER, AN EXPLANATION OF THEADVANTAGES AND DISADVANTAGES, AND ADVICE TO CONSULT A TAXADVISOR; AND 2) WHO DID NOT RECEIVE THE BENEFITS OF THE NAVTRANSFER PROGRAM DETAILING REMEDIATION PAYMENTS. ALSO, WITHIN60 SAYS, WACHOVIA WILL TRAIN STAFF TO FIELD CUSTOMER INQUIRES,RETAIN A THIRD-PARTY EXAMINER TO EXAMINE THE FIRM'SPERFORMANCE OF ITS OBLIGATIONS UNDER THE TERMS OF THE AWC,BEAR THE EXAMINER'S COSTS AND COOPERATE WITH THE EXAMINER.WACHOVIA SHALL COMPLETE THE REMEDIATION PROCESS WITHIN 270DAYS OF THE AWC AND WITHIN 330 DAYS OF THE EFFECTIVE DATE OF THEAWC FILED A DETAILED REPORT WITH FINRA REGARDING THE RESULTSOF THE REMEDIATION PLAN. THE THIRD PARTY EXAMINER SHALL FILE AFINAL REPORT NO LATER THAN 420 DAYS AFTER THE EFFECTIVE DATE OFTHE AWC.

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, WACHOVIA SECURITIESCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $4,410,000AND REQUIRED TO UNDERTAKE A REMEDIATION PLAN.

Regulator Statement [CONTINUED] WACHOVIA FAILED TO APPLY CORRECTLY ROLLOVER ANDBREAKPOINT DISCOUNTS IN CONNECTION WITH UNIT INVESTMENTTRUSTS (UIT) PURCHASES BY CUSTOMERS, RESULTING IN ADDITIONALAND EXCESSIVE SALES CHARGES TOTALING $1.976 MILLION AND $735,000RESPECTIVELY. WACHOVIA HAD NOTICE THAT THE PROPER APPLICATIONOF ROLLOVER AND BREAKPOINT DISCOUNTS TO ELIGIBLE UITPURCHASES BY CUSTOMERS CONSTITUTED A COMPLIANCE MATTER THATNECESSITATED ITS PROMPT AND DILIGENT ATTENTION, BUT DID NOTPROMPTLY UNDERTAKE OR PERFORM ANY REVIEW, TESTING ORANALYSIS TO DETERMINE IF THE FIRM WAS PROPERLY IDENTIFYING ANDAPPLYING ROLLOVER AND BREAKPOINT DISCOUNTS IN CONNECTIONWITH THE SALES OF UITS, THEREBY FAILING TO PROVIDE ALLCUSTOMERS THE BENEFIT OF SALES CHARGE DISCOUNTS. WACHOVIAFAILED TO ESTABLISH, MAINTAIN AND IMPLEMENT A SUPERVISORYSYSTEM AND WRITTEN SUPERVISORY PROCEDURES THAT WEREREASONABLY DESIGNED TO ENSURE THAT SALES CHARGE DISCOUNTSWERE CORRECTLY APPLIED AND PROVIDE SUBSTANTIVE GUIDELINES,INSTRUCTIONS, POLICIES AND PROCEDURES OR STEPS THATREPRESENTATIVES AND/OR MANAGERS WERE OBLIGATED TO TAKE ORPERFORM IN EFFECTING UIT PURCHASES FOR CUSTOMERS TODETERMINE IF THE PURCHASE QUALIFIED FOR A DISCOUNT AND/OR TOENSURE CUSTOMERS RECEIVED THE BENEFIT OF ANY APPLICABLESALES CHARGE DISCOUNT.

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[CONTINUED] WACHOVIA FAILED TO APPLY CORRECTLY ROLLOVER ANDBREAKPOINT DISCOUNTS IN CONNECTION WITH UNIT INVESTMENTTRUSTS (UIT) PURCHASES BY CUSTOMERS, RESULTING IN ADDITIONALAND EXCESSIVE SALES CHARGES TOTALING $1.976 MILLION AND $735,000RESPECTIVELY. WACHOVIA HAD NOTICE THAT THE PROPER APPLICATIONOF ROLLOVER AND BREAKPOINT DISCOUNTS TO ELIGIBLE UITPURCHASES BY CUSTOMERS CONSTITUTED A COMPLIANCE MATTER THATNECESSITATED ITS PROMPT AND DILIGENT ATTENTION, BUT DID NOTPROMPTLY UNDERTAKE OR PERFORM ANY REVIEW, TESTING ORANALYSIS TO DETERMINE IF THE FIRM WAS PROPERLY IDENTIFYING ANDAPPLYING ROLLOVER AND BREAKPOINT DISCOUNTS IN CONNECTIONWITH THE SALES OF UITS, THEREBY FAILING TO PROVIDE ALLCUSTOMERS THE BENEFIT OF SALES CHARGE DISCOUNTS. WACHOVIAFAILED TO ESTABLISH, MAINTAIN AND IMPLEMENT A SUPERVISORYSYSTEM AND WRITTEN SUPERVISORY PROCEDURES THAT WEREREASONABLY DESIGNED TO ENSURE THAT SALES CHARGE DISCOUNTSWERE CORRECTLY APPLIED AND PROVIDE SUBSTANTIVE GUIDELINES,INSTRUCTIONS, POLICIES AND PROCEDURES OR STEPS THATREPRESENTATIVES AND/OR MANAGERS WERE OBLIGATED TO TAKE ORPERFORM IN EFFECTING UIT PURCHASES FOR CUSTOMERS TODETERMINE IF THE PURCHASE QUALIFIED FOR A DISCOUNT AND/OR TOENSURE CUSTOMERS RECEIVED THE BENEFIT OF ANY APPLICABLESALES CHARGE DISCOUNT.

iReporting Source: Firm

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 02/12/2009

Docket/Case Number: E9A2005013001

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations: ALLEGATIONS THAT THE FIRM (1) MADE RECOMMENDATIONS THROUGHITS REGISTERED REPRESENTATIVES TO CUSTOMERS TO PURCHASECLASS B AND CLASS C MUTUAL FUND SHARES WHERE AN EQUALINVESTMENT IN CLASS A SHARES WOULD HAVE BEEN MOREADVANTAGEOUS FOR CERTAIN CLIENTS IN VIOLATION OF NASD RULE2310, (2) DID NOT PROVIDE CERTAIN ELIGIBLE CUSTOMERS WITH THEBENEFIT OF NAV TRANSFER PROGRAMS IN CONNECTION WITH MUTUALFUND PURCHASES AND SALES DISCOUNTS IN CONNECTION WITHPURCHASES OF UNIT INVESTMENT TRUSTS ("UIT") AND (3) FAILED TOESTABLISH, MAINTAIN AND ENFORCE SUPERVISORY SYSTEMS ANDPROCEDURES REASONABLY DESIGNED (A) TO PROVIDE CONSIDERATION,ON A CONSISTENT BASIS, OF THE BENEFITS OF VARIOUS MUTUAL FUNDCLASSES AS THEY APPLIED TO INDIVIDUAL CUSTOMERS, (B) TO IDENTIFYOPPORTUNITIES FOR INVESTORS TO PURCHASE MUTUAL FUNDS AT NAVAND (C) TO ENSURE THAT SALES CHARGE DISCOUNTS WERE APPLIED TOELIGIBLE UIT PURCHASES BY CUSTOMERS IN VIOLATION OF NASD RULES2110 AND 3010.

Current Status: Final

Resolution Date: 02/12/2009

Resolution:

Other Sanctions Ordered: UNDERTAKINGS THAT INCLUDE REMEDIATION TO CERTAIN CUSTOMERSWHO DURING THE PERIOD (A) FROM JANUARY 1, 2002 THROUGHDECEMBER 31, 2004, PURCHASED SHARES OF MUTUAL FUNDS ANDQUALIFIED FOR, BUT DID NOT RECEIVE, THE BENEFIT OF AN NAVTRANSFER PROGRAM AND (B) FROM JANUARY 1, 2003 THROUGH THENOTICE OF ACCEPTANCE OF THIS AWC, PURCHASED CLASS B AND CLASSC MUTUAL FUND SHARES.

Sanctions Ordered: CensureMonetary/Fine $4,410,000.00

Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered: UNDERTAKINGS THAT INCLUDE REMEDIATION TO CERTAIN CUSTOMERSWHO DURING THE PERIOD (A) FROM JANUARY 1, 2002 THROUGHDECEMBER 31, 2004, PURCHASED SHARES OF MUTUAL FUNDS ANDQUALIFIED FOR, BUT DID NOT RECEIVE, THE BENEFIT OF AN NAVTRANSFER PROGRAM AND (B) FROM JANUARY 1, 2003 THROUGH THENOTICE OF ACCEPTANCE OF THIS AWC, PURCHASED CLASS B AND CLASSC MUTUAL FUND SHARES.

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AS OUTLINE ABOVE. IN DETERMINING APPROPRIATESANCTIONS, FINRA CONSIDERED THE FIRM'S PROACTIVE REMEDIALACTIONS TAKEN UPON DURING ITS DISCOVERY OF -AND BEFORE FINRA'SINQUIRY INTO - CERTAIN VIOLATIVE CONDUCT. AFTER IDENTIFYINGFAILURES TO PROVIDE CERTAIN CUSTOMERS WITH NAV PRICING AND UITSALES DISCOUNTS, THE FIRM ACTED PROMPTLY AND IN GOOD FAITH TOREPAY CUSTOMERS APPROXIMATELY $5.4 MILLION AND CORRECT ITSSYSTEMS AND PROCEDURES.

Disclosure 110 of 158

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Reporting Source: Regulator

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 02/26/2008

Docket/Case Number: 20050001452-03

Principal Product Type: Other

Other Product Type(s): TRACE-ELIGIBLE SECURITIES

Allegations: NASD RULE 6230 - WACHOVIA SECURITIES, LLC FAILED TO REPORT TOTRACE THE CORRECT REPORTING MARKET PARTICIPANT IDENTIFIER(MPID) FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES.

Current Status: Final

Resolution Date: 02/26/2008

Resolution:

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

No

Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $7,500.

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

No

Sanctions Ordered: CensureMonetary/Fine $7,500.00

iReporting Source: Firm

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 02/26/2008

Docket/Case Number: 20050001452-03

Principal Product Type: Other

Other Product Type(s): TRACE-ELIGIBLE SECURITIES

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM HASENTERED INTO AN ACCEPTANCE, WAIVER AND CONSENT WITH FINRACONCERNING CERTAIN FINDINGS REGARDING COMPLIANCE WITH TRADEREPORTING AND COMPLIANCE ENGINE (TRACE) RULES DURING THEPERIOD JULY 1, 2004 THROUGH SEPTEMBER 30, 2004. THESE FINDINGSINVOLVED FAILING TO REPORT THE CORRECT MPID IN TRACE-ELIGIBLESECURITIES. THE FIRM HAS CONSENTED TO A FINE OF $7,500.

Current Status: Final

Resolution Date: 02/26/2008

Resolution:

Other Sanctions Ordered:

Sanctions Ordered: CensureMonetary/Fine $7,500.00

Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEFIRM WAS FINED $7,500.

Disclosure 111 of 158

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Reporting Source: Regulator

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 01/25/2008

Docket/Case Number: 20050032155-01

Principal Product Type: Other

Other Product Type(s): TRACE-ELIGIBLE SECURITIES

Allegations: NASD RULES 6230, 6230(A) - WACHOVIA SECURITIES FAILED TO REPORTTO THE TRADE REPORTING AND COMPLIANCE ENGINE(TRACE)TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES EXECUTED ON ABUSINESS DAY DURING TRACE SYSTEM HOURS WITHIN 15 MINUTES OFTHE TIME OF EXECUTION; AND REPORTED TO TRACE TRANSACTIONS INTRACE-ELIGIBLE SECURITIES THAT IT WAS NOT REQUIRED TO REPORT.

Current Status: Final

Resolution Date: 01/25/2008

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS FINED $5,000.

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

No

Sanctions Ordered: Monetary/Fine $5,000.00

Acceptance, Waiver & Consent(AWC)

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WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS FINED $5,000.

iReporting Source: Firm

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 01/25/2008

Docket/Case Number: 20050032155-01

Principal Product Type: Other

Other Product Type(s): TRACE-ELIGIBLE SECURITIES

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM HASENTERED INTO AN ACCEPTANCE, WAIVER AND CONSENT WITH FINRACONCERNING CERTAIN FINDINGS REGARDING COMPLIANCE WITH TRADEREPORTING AND COMPLIANCE ENGINE (TRACE) RULES DURING THEPERIOD JULY 1, 2005 THROUGH SEPTEMBER 30, 2005. THESE FINDINGSINVOLVED FAILING TO REPORT 1,434 TRANSACTIONS IN TRACE-ELIGIBLESECURITIES WITHIN 15 MINUTES OF TIME OF EXECUTION, AND OVER-REPORTING 4,008 TRANSACTIONS THAT WAS NOT REQUIRED TO BEREPORTED. THE FIRM HAS CONSENTED TO A FINE OF $5,000.

Current Status: Final

Resolution Date: 01/25/2008

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEFIRM WAS FINED $5,000.

Sanctions Ordered: Monetary/Fine $5,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 112 of 158

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Reporting Source: Regulator

Allegations: ORDER OF DISMISSAL PURSUANT TO SETTLEMENT AGREEMENT.WACHOVIA SECURITIES, LLC PAID A $50,000 MONETARY AMOUNT ANDAGREED TO TAKE CERTAIN REMEDIAL MEASURES. THE MATTER WASSETTLED WITHOUT ANY SANCTIONS AGAINST MS. WIEGAND.

Current Status: Final

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Initiated By: ILLINOIS

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

NOTICE OF HEARING

1) REVOCATION OR SUSPENSION OF SALESPERSON AND/OR DEALERREGISTRATION

2) ORDER OF PROHIBITION AGAINST OFFER AND SALE OF SECURITIES

3) $10,000 FINE PER VIOLATION

Date Initiated: 01/04/2008

Docket/Case Number: 0600669

URL for Regulatory Action:

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

Other Product Type(s):

Allegations: ORDER OF DISMISSAL PURSUANT TO SETTLEMENT AGREEMENT.WACHOVIA SECURITIES, LLC PAID A $50,000 MONETARY AMOUNT ANDAGREED TO TAKE CERTAIN REMEDIAL MEASURES. THE MATTER WASSETTLED WITHOUT ANY SANCTIONS AGAINST MS. WIEGAND.

Resolution Date: 06/18/2009

Resolution:

Other Sanctions Ordered: UNDER TOOK CHANGES TO TRAINING AND COMPLIANCE RELATED TOPROHIBITED TRANSACTIONS UNDER ERISA

Sanction Details: ORDER OF DISMISSAL

Regulator Statement SECOND NOTICE OF HEARING WAS ISSUED JANUARY 4, 2008. THEHEARING IS SCHEDULED FOR APRIL 15, 2008. ORDER OF DISMISSAL WASISSUED JUNE 18, 2009. CONTACT (217) 785-4947

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

No

Sanctions Ordered: Monetary/Fine $50,000.00

Order

iReporting Source: Firm

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Initiated By: STATE OF ILLINOIS

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

Date Initiated: 05/18/2007

Docket/Case Number: 0600669

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

Other Product Type(s):

Allegations: FAILURE TO SUPERVISE DECEPTIVE OR FRAUDULENT SECURITIESTRANSACTIONS. **AMENDED NOTICE OF HEARING SECURITIES FRAUD.ALLEGATIONS ADDED 1/4/2008 - AMENDED NOTICE OF HEARINGSECURITIES FRAUD 1) SUZANNE WIEGAND ENGAGED IN FRAUDULENTAND/OR DECEPTIVE SECURITIES TRANSACTIONS BY ACTING AS THESALESPERSON OR INVESTMENT ADVISOR REP FOR SEVERAL PENSIONFUND ACCOUNTS FOR WHICH HER FATHER WAS THE TRUSTEE AND WHODIRECTED TRANSACTIONS TO HER ACCOUNT FOR PURPOSES OFGENERALING COMMISSION 2) A.G. EDWARDS (NOT KNOW AS WACHOVIASECURITIES, LLC) KNEW OR SHOULD HAVE KNOWN OF THE ABOVEACTIVITIES AND FAILED TO TAKE REASONABLE SUPERVISORY STEPS TOPREVENT OR STOP THE ILLEGAL ACTIVITIES

Current Status: Final

Resolution Date: 06/18/2009

Resolution:

Other Sanctions Ordered: UNDER TOOK CHANGES TO TRAINING AND COMPLIANCE RELATED TOPROHIBITED TRANSACTIONS UNDER ERISA.

Sanction Details: ORDER OF DISMISSAL.

Firm Statement NOTICE OF HEARING WAS ISSUED MAY 18, 2007. AMENDED NOTICE OFHEARING WAS ISSUED OCTOBER 10, 2007. SECOND AMENDED NOTICE OFHEARING WAS ISSUED JANUARY 4, 2008. THE HEARING IS SCHEDULEDFOR APRIL 15, 2008. CONTACT (217) 785-4947

Sanctions Ordered: Monetary/Fine $50,000.00

Order

Disclosure 113 of 158

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Reporting Source: Regulator

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Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

Date Initiated: 09/19/2007

Docket/Case Number: SEC FILE 3-12805

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations: SEC ADMIN RELEASES 34-56462, IA RELEASE 40-2648, IC RELEASE 40-27973, SEPTEMBER 19, 2007: THE UNITED STATES SECURITIES ANDEXCHANGE COMMISSION (THE COMMISSION) DEEMS IT APPROPRIATEAND IN THE PUBLIC INTEREST THAT ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TOSECTIONS 15(B)(4), 17A(C)(3) AND 21C OF THE SECURITIES EXCHANGEACT OF 1934 ("EXCHANGE ACT"), SECTIONS 203(E) AND 203(K) OF THEINVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT), AND SECTIONS 9(B)AND 9(F) OF THE INVESTMENT COMPANY ACT OF 1940 (INVESTMENTCOMPANY ACT) AGAINST WACHOVIA SECURITIES, LLC (WACHOVIA). INANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THERESPONDENT SUBMITTED AN OFFER OF SETTLEMENT (THE OFFER) THATTHE COMMISSION HAS DETERMINED TO ACCEPT. THE ORDER ISINSTITUTED AS TO WACHOVIA SECURITIES PURSUANT TO SECTION15(B)(4) OF THE EXCHANGE ACT AND SECTIONS 9(B) AND 9(F) OF THEINVESTMENT COMPANY ACT. THIS PROCEEDING CONCERNS VARIOUSVIOLATIONS OF THE FEDERAL SECURITIES LAWS COMMITTED INCONNECTION WITH THE CREATING AND/OR IMPLEMENTING TWO MARKETTIMING AGREEMENTS (AND THE ROLE OF WACHOVIA SECURITIES INCREATING AND/OR IMPLEMENTING ONE OF THOSE TWO AGREEMENTS)THAT PERMITTED, IN EACH CASE, A REGISTERED REPRESENTATIVE TOMAKE, ON BEHALF OF CERTAIN OF HIS CUSTOMERS, FREQUENT TRADESIN CERTAIN FUNDS IN EXCESS OF THE EXCHANGE LIMITS SET FORTH INTHE FUNDS' PROSPECTUSES.

Current Status: Final

Resolution Date: 09/19/2007

Resolution:

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

No

Order

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Other Sanctions Ordered:

Sanction Details: SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHERPROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION OR INWHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING ORDENYING THE FINDINGS, EXCEPT THOSE FINDINGS PERTAINING TO THEJURISDICTION OF THE COMMISSION OVER RESPONDENT AND THESUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THERESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTIONS 15(B)(4), 17A(C)(3) AND 21C OF THE EXCHANGE ACT, SECTIONS203(E) AND 203(K) OF THE ADVISERS ACT, AND SECTIONS 9(B) AND 9(F) OFTHE INVESTMENT COMPANY ACT, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. WACHOVIASECURITIES WAS AFFILIATED WITH THE SMALL COMPANY GROWTH FUND,WILLFULLY VIOLATED SECTION 17(D) OF THE INVESTMENT COMPANY ACTAND RULE 17D-1 THEREUNDER. WACHOVIA SECURITIES FORMED A JOINTARRANGEMENT WITH AN AFFILIATED FUND. AS A RESULT, WACHOVIASECURITIES WILLFULLY VIOLATED SECTION 17(D) AND RULE 17D-1THEREUNDER. IT IS HEREBY ORDERED PURSUANT TO SECTION 15(B)(4)OF THE EXCHANGE ACT, WACHOVIA SECURITIES IS HEREBY CENSURED.PURSUANT TO SECTION 9(F) OF THE INVESTMENT COMPANY ACT,WACHOVIA SECURITIES SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION17(D) OF THE INVESTMENT COMPANY ACT AND RULE 17D-1 THEREUNDER.WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, WACHOVIA SECURITIESSHALL PAY DISGORGEMENT IN THE AMOUNT OF $1 AND, PURSUANT TOSECTIONS 9(B) AND 9(D) OF THE INVESTMENT COMPANY ACT, A CIVILPENALTY IN THE AMOUNT OF $500,000.THERE SHALL BE, PURSUANT TOSECTION 308(A) OF THE SARBANES-OXLEY ACT OF 2002, A FAIR FUNDESTABLISHED FOR THE FUNDS.

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

No

Sanctions Ordered: CensureMonetary/Fine $500,000.00Disgorgement/RestitutionCease and Desist/Injunction

iReporting Source: Firm

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Initiated By: U.S. SECURITIES AND EXCHANGE COMMISSION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

CENSURE,CEASE AND DESIST

Date Initiated: 09/19/2007

Docket/Case Number: ADMIN PROCEEDING FILE NO. 3-12805

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations: THE FIRM AND AFFILIATES WERE ALLEGED TO HAVE ENTERED INTO ANAGREEMENT TO ALLOW A REGISTERED REPRESENTATIVE TO MARKETTIME IN A SPECIFIC EVERGREEN FUND IN EXCESS OF TRADING LIMITSSET FORTH IN THE FUNDS' PROSPECTUS.

Current Status: Final

Resolution Date: 09/19/2007

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTEREDINTO AN AGREEMENT TO PAY DISGORGEMENT OF $1 AND CIVIL PENALTYOF $500,000, CENSURED, AND CEASE AND DESIST ANY FURTHERVIOLATIONS OF SECTION 17(D) OF THE INVESTMENT COMPANY ACT ANDRULE 17D-1.

Sanctions Ordered: CensureMonetary/Fine $500,000.00Disgorgement/RestitutionCease and Desist/Injunction

Decision & Order of Offer of Settlement

Disclosure 114 of 158

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Reporting Source: Regulator

Initiated By: NORTH DAKOTA SECURITIES DEPARTMENT

Allegations: WACHOVIA THROUGH ITS AGENT ROSS O. HAUGEN CONDUCTEDCOVERED CALL WRITING WHILE EXPOSING CLIENTS TO HIGHCONCENTRATIONS OF CERTAIN SECURITIES THAT WERE NOT SUITABLETO CLIENTS INVESTMENT OBJECTIVES AND RISK TEMPERAMENTS.WACHOVIA DID PROPERLY SUPERVISE ITS AGENT, HAUGEN.

Current Status: Final

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Initiated By: NORTH DAKOTA SECURITIES DEPARTMENT

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

RESTITUTION

Date Initiated: 06/19/2007

Docket/Case Number: 06-556

URL for Regulatory Action:

Principal Product Type: Options

Other Product Type(s):

Resolution Date: 06/19/2007

Resolution:

Other Sanctions Ordered:

Sanction Details: IMMEDIATE PAYMENT OF THE $75,000 PENALTY. WACHOVIA SHALLCONTACT SEVERAL IDENTIFIED CLIENTS TO AND RESOLVE THE SALESPRACTICE ISSUES THROUGH NORMAL RESOLUTION PROCESS. WACHOVIASHALL PROPERLY SUPERVISE THE ACTIVITIES OF ITS AGENTS IN ND.

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

No

Sanctions Ordered: Monetary/Fine $75,000.00Disgorgement/Restitution

Decision & Order of Offer of Settlement

iReporting Source: Firm

Initiated By: NORTH DAKOTA SECURITIES COMMISSIONER

Date Initiated: 06/19/2007

Allegations: THE NORTH DAKOTA SECURITIES COMMISSIONER ALLEGED THAT, FROMDECEMBER 2001 TO JULY 2002, TWO PREDECESSORS TO WACHOVIASECURITIES, LLC (WSLLC) HAD FAILED TO SUPERVISE A FORMERREGISTERED REPRESENTATIVE IN CONNECTION WITH ALLEGEDLYUNSUITABLE TRADING IN OTC STOCKS AND OPTIONS IN THE ACCOUNTSOF SEVERAL CUSTOMERS.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

UNDERTAKING

Date Initiated: 06/19/2007

Docket/Case Number: 06-556

Principal Product Type: Equity - OTC

Other Product Type(s):

Resolution Date: 06/19/2007

Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: $75,000 PAID BY WSLLC. UNDERTAKING IS DESCRIBED IN RESPONSE TOQUESTION 13.

Firm Statement WSLLC AGREED TO CORRESPOND WITH CERTAIN FORMER CLIENTS ANDTO ADDRESS ANY COMPLAINTS THROUGH ITS NORMAL DISPUTERESOLUTION PROCESS.

Sanctions Ordered: Monetary/Fine $75,000.00Disgorgement/Restitution

Consent

Disclosure 115 of 158

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Reporting Source: Regulator

Allegations: NASD RULES 2110, 2210(D) AND 3010(A) AND (B): WACHOVIA SECURITIES,LLC (THE FIRM) OFFERED ITS CUSTOMERS A FEE-BASED BROKERAGEACCOUNT PROGRAM (THE PROGRAM) SINCE 1999. BETWEEN JANUARY 1,2001 AND DECEMBER 31, 2004 (THE REVIEW PERIOD), THE FIRM FAILED TOESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM,INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO REVIEWAND MONITOR THE FEE-BASED PROGRAM. WHILE THE FIRM INFORMEDITS BROKERS THAT THIS PROGRAM WAS NOT APPROPRIATE FORCUSTOMERS WHO MADE A LIMITED NUMBER OF TRADES, BUY-AND-HOLDCUSTOMERS, AND CUSTOMERS WITH SMALLER ACCOUNTS (ASSETSBELOW $50,000), THE FIRM'S SYSTEM AND PROCEDURES NEVERTHELESSWERE NOT REASONABLY DESIGNED TO DETERMINE WHETHER THEPROGRAM WAS APPROPRIATE FOR ITS CUSTOMERS. AS A RESULT OF THEFIRM'S SUPERVISORY DEFICIENCIES DURING THE REVIEW PERIOD, THEFIRM ALLOWED APPROXIMATELY 1,200 CUSTOMERS TO CONTINUE IN FEE-BASED ACCOUNTS WITHOUT ADEQUATELY REASSESSING WHETHER FEE-BASED ACCOUNTS REMAINED APPROPRIATE FOR THOSE CUSTOMERS.THESE CUSTOMERS EITHER CONDUCTED NO TRADES IN THEIR PROGRAMACCOUNTS FOR AT LEAST TWO CONSECUTIVE YEARS OR HAD PROGRAMACCOUNTS WHERE THE TOTAL VALUE OF THE ASSETS IN THE ACCOUNTSAVERAGED BELOW $25,000 FOR AT LEAST ONE FULL YEAR. DURING THEREVIEW PERIOD, APPROXIMATELY 594 CUSTOMERS CONDUCTED NOTRADES IN THE PROGRAM ACCOUNTS FOR AT LEAST TWO CONSECUTIVEYEARS AND PAID THE FIRM APPROXIMATELY $1.9 MILLION IN FEES DURINGTHE TIME WHEN THEIR ACCOUNTS WERE INACTIVE. IN ADDITION,APPROXIMATELY 620 CUSTOMERS HELD ASSETS BELOW $50,000 ANDAVERAGED LESS THAN $25,000 FOR AT LEAST ONE FULL YEAR DURINGTHE REVIEW PERIOD. DURING THE TIME THAT THESE CUSTOMERS'ELIGIBLE ASSETS AVERAGED BELOW $25,000 FOR AT LEAST ONE FULLYEAR, THEY PAID A TOTAL OF APPROXIMATELY $1 MILLION IN PROGRAMFEES. (ALLEGATIONS CONTINUED IN COMMENTS SECTION)

Current Status: Final

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Initiated By: NASD

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 06/21/2007

Docket/Case Number: EAF0400840001

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

NASD RULES 2110, 2210(D) AND 3010(A) AND (B): WACHOVIA SECURITIES,LLC (THE FIRM) OFFERED ITS CUSTOMERS A FEE-BASED BROKERAGEACCOUNT PROGRAM (THE PROGRAM) SINCE 1999. BETWEEN JANUARY 1,2001 AND DECEMBER 31, 2004 (THE REVIEW PERIOD), THE FIRM FAILED TOESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM,INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO REVIEWAND MONITOR THE FEE-BASED PROGRAM. WHILE THE FIRM INFORMEDITS BROKERS THAT THIS PROGRAM WAS NOT APPROPRIATE FORCUSTOMERS WHO MADE A LIMITED NUMBER OF TRADES, BUY-AND-HOLDCUSTOMERS, AND CUSTOMERS WITH SMALLER ACCOUNTS (ASSETSBELOW $50,000), THE FIRM'S SYSTEM AND PROCEDURES NEVERTHELESSWERE NOT REASONABLY DESIGNED TO DETERMINE WHETHER THEPROGRAM WAS APPROPRIATE FOR ITS CUSTOMERS. AS A RESULT OF THEFIRM'S SUPERVISORY DEFICIENCIES DURING THE REVIEW PERIOD, THEFIRM ALLOWED APPROXIMATELY 1,200 CUSTOMERS TO CONTINUE IN FEE-BASED ACCOUNTS WITHOUT ADEQUATELY REASSESSING WHETHER FEE-BASED ACCOUNTS REMAINED APPROPRIATE FOR THOSE CUSTOMERS.THESE CUSTOMERS EITHER CONDUCTED NO TRADES IN THEIR PROGRAMACCOUNTS FOR AT LEAST TWO CONSECUTIVE YEARS OR HAD PROGRAMACCOUNTS WHERE THE TOTAL VALUE OF THE ASSETS IN THE ACCOUNTSAVERAGED BELOW $25,000 FOR AT LEAST ONE FULL YEAR. DURING THEREVIEW PERIOD, APPROXIMATELY 594 CUSTOMERS CONDUCTED NOTRADES IN THE PROGRAM ACCOUNTS FOR AT LEAST TWO CONSECUTIVEYEARS AND PAID THE FIRM APPROXIMATELY $1.9 MILLION IN FEES DURINGTHE TIME WHEN THEIR ACCOUNTS WERE INACTIVE. IN ADDITION,APPROXIMATELY 620 CUSTOMERS HELD ASSETS BELOW $50,000 ANDAVERAGED LESS THAN $25,000 FOR AT LEAST ONE FULL YEAR DURINGTHE REVIEW PERIOD. DURING THE TIME THAT THESE CUSTOMERS'ELIGIBLE ASSETS AVERAGED BELOW $25,000 FOR AT LEAST ONE FULLYEAR, THEY PAID A TOTAL OF APPROXIMATELY $1 MILLION IN PROGRAMFEES. (ALLEGATIONS CONTINUED IN COMMENTS SECTION)

Resolution Date: 06/21/2007

Resolution:

Other Sanctions Ordered: UNDERTAKINGS

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 $2 MILLION AND AGREES TOCOMPLETE UNDERTAKINGS IN ORDER TO IDENTIFY AND PAY RESTITUTIONTO CUSTOMERS WHO WERE INAPPROPRIATELY ALLOWED TO CONTINUEIN THE FEE-BASED PROGRAM WHEN THEIR ACCOUNTS WERE NOTAPPROPRIATE FOR THEM AND/OR INAPPROPRIATELY CHARGED FEES ONA-SHARES FOR WHICH THEY HAD ALREADY PAID A SALES LOAD. THE FIRMMUST ALSO RETAIN AN OUTSIDE CONSULTANT TO EXAMINE AND REPORTTO NASD THE FIRM'S PERFORMANCE OF ITS OBLIGATIONS UNDER THETERMS OF THIS AWC INCLUDING THE FIRM'S METHODOLOGY ANDPROCESS USED, THE IDENTIFICATION OF CUSTOMERS AND CALCULATIONOF RESTITUTION AMOUNTS AND INTEREST.

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

No

Sanctions Ordered: CensureMonetary/Fine $2,000,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

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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 $2 MILLION AND AGREES TOCOMPLETE UNDERTAKINGS IN ORDER TO IDENTIFY AND PAY RESTITUTIONTO CUSTOMERS WHO WERE INAPPROPRIATELY ALLOWED TO CONTINUEIN THE FEE-BASED PROGRAM WHEN THEIR ACCOUNTS WERE NOTAPPROPRIATE FOR THEM AND/OR INAPPROPRIATELY CHARGED FEES ONA-SHARES FOR WHICH THEY HAD ALREADY PAID A SALES LOAD. THE FIRMMUST ALSO RETAIN AN OUTSIDE CONSULTANT TO EXAMINE AND REPORTTO NASD THE FIRM'S PERFORMANCE OF ITS OBLIGATIONS UNDER THETERMS OF THIS AWC INCLUDING THE FIRM'S METHODOLOGY ANDPROCESS USED, THE IDENTIFICATION OF CUSTOMERS AND CALCULATIONOF RESTITUTION AMOUNTS AND INTEREST.

Regulator Statement (ALLEGATIONS CONTINUED) IN ADDITION, THE FIRM EXEMPTED HIGHPRODUCING BROKERS FROM SOME OF THE FIRM'S REVIEW ANDAPPROVAL PROCESSES. CONSEQUENTLY, THESE BROKERS WERE ABLETO OPEN ACCOUNTS FOR CERTAIN CUSTOMERS FOR WHOM FEE-BASEDACCOUNTS MAY NOT HAVE BEEN APPROPRIATE, INCLUDING INACTIVEACCOUNTS AND CUSTOMERS WHOSE ASSETS WERE BELOW THE FIRM'SSTATED $50,000 MINIMUM. THE FIRM ALSO FAILED TO REASONABLYENFORCE ITS WRITTEN PROCEDURES DESIGNED TO PROTECT PROGRAMCUSTOMERS FROM BEING ASSESSED DOUBLE FEES ON THE PURCHASEOF CLASS A SHARES OF MUTUAL FUNDS THAT CARRIED AN UP-FRONTSALES CHARGE; THAT IS PAYING A SALES LOAD, THEN THE ASSET BASEDFEE ON TOP OF THE LOAD. THE FIRM MADE AN INACCURATE MATERIALSTATEMENT IN ITS COMMUNICATION WITH THE PUBLIC IN THAT ITPROVIDED ITS BROKERS WITH A PIECE OF SALES LITERATURE RELATINGTO THE PROGRAM THAT BROKERS COULD USE WITH THEIR CUSTOMERS.THE SALES LITERATURE REFERRED TO THE PROGRAM AS A MONITOREDBROKERAGE ACCOUNT," BUT INACCURATELY STATED IN FOOTNOTE THATTHE PROGRAM WAS A "FEE-BASED, INVESTMENT ADVISORY SERVICEPROVIDED BY THE FIRM.

iReporting Source: Firm

Initiated By: NASD

Allegations: FOR THE PERIOD JANUARY 1, 2001 THROUGH DECEMBER 31, 2004,WACHOVIA SECURITIES, LLC CONSENTED TO, WITHOUT ADMITTING ORDENYING THE FINDINGS, VIOLATIONS OF NASD RULES 3010, 2110 AND2210(D) FOR FAILURE TO SUPERVISOR IN CONNECTION WITH ITS FEE INLIEU OF COMMISSION ACCOUNTS (PILOT PLUS ACCOUNTS) BASED ONLOW ACTIVITY, OPENING ACCOUNTS BELOW STATED MINIMUMS ANDDISTRIBUTING A PIECE OF SALES LITERATURE THAT INACCURATELYSTATED THAT PILOT PLUS WAS A FEE BASED ADVISORY ACCOUNT.

Current Status: Final

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Initiated By: NASD

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

CENSURE AND REMEDIATION TO CLIENTS

Date Initiated: 12/13/2004

Docket/Case Number: AWC# EAF0400840001

Principal Product Type: Other

Other Product Type(s): FEE OF LIEW OF COMMISSION ACCOUNTS

Resolution Date: 06/21/2007

Resolution:

Other Sanctions Ordered: REMEDIATION ON THE FOLLOWING TERMS:

1. REMEDIATE TO CLIENTS WHOSE PILOT PLUS ACCOUNTS WEREINACTIVE FOR TWO CONSECUTIVE YEARS OR MORE, ALL PILOT PLUSFEES CHARGED AFTER THE FIRST YEAR OF INACTIVITY;2. REMEDIATE TO CLIENTS WITH PILOT PLUS ACCOUNTS WITHASSETS LESS THAN THE REQUIRED $50,000 MINIMUM, THE DIFFERENCEBETWEEN THE $1,000 MINIMUM ANNUAL FEE AND A FEE EQUAL TO 2% OFTHE ASSETS WITH AVERAGE BALANCES, FOR FOUR CONSECUTIVEQUARTERS, BELOW $25,0003. REMEDIATE TO CLIENTS WHO PURCHASED LOADED CLASS AMUTUAL FUNDS AND TRANSFERRED THOSE ASSETS INTO A PILOT PLUSACCOUNT WITHIN 13 MONTHS OF THE PURCHASE, THE FEES CHARGEDON THAT ASSET THROUGH THE END OF THE THIRTEENTH MONTH;4. PAY CLIENTS INTEREST AT THE PROSCRIBED IRS RATE FROM THEDATE OF THE REQUIRED REMEDIATION THROUGH THE DATE OFACCEPTANCE OF THE AWC;5. RETAIN AND OUTSIDE CONSULTANT TO VERIFY THAT ALL OF THEAPPROPRIATE CLIENTS WERE IDENIFIED AND THE REMEDIATION WASDONE ACCORDANCE WITH THE TERMS OF THE AWC.

Sanction Details: REMEDIATION ON THE FOLLOWING TERMS:

1. REMEDIATE TO CLIENTS WHOSE PILOT PLUS ACCOUNTS WEREINACTIVE FOR TWO CONSECUTIVE YEARS OR MORE, ALL PILOT PLUSFEES CHARGED AFTER THE FIRST YEAR OF INACTIVITY;2. REMEDIATE TO CLIENTS WITH PILOT PLUS ACCOUNTS WITHASSETS LESS THAN THE REQUIRED $50,000 MINIMUM, THE DIFFERENCEBETWEEN THE $1,000 MINIMUM ANNUAL FEE AND A FEE EQUAL TO 2% OFTHE ASSETS WITH AVERAGE BALANCES, FOR FOUR CONSECUTIVEQUARTERS, BELOW $25,0003. REMEDIATE TO CLIENTS WHO PURCHASED LOADED CLASS AMUTUAL FUNDS AND TRANSFERRED THOSE ASSETS INTO A PILOT PLUSACCOUNT WITHIN 13 MONTHS OF THE PURCHASE, THE FEES CHARGEDON THAT ASSET THROUGH THE END OF THE THIRTEENTH MONTH;4. PAY CLIENTS INTEREST AT THE PROSCRIBED IRS RATE FROM THEDATE OF THE REQUIRED REMEDIATION THROUGH THE DATE OFACCEPTANCE OF THE AWC;5. RETAIN AND OUTSIDE CONSULTANT TO VERIFY THAT ALL OF THEAPPROPRIATE CLIENTS WERE IDENIFIED AND THE REMEDIATION WASDONE ACCORDANCE WITH THE TERMS OF THE AWC.

Sanctions Ordered: CensureMonetary/Fine $2,000,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

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www.finra.org/brokercheck User GuidanceREMEDIATION ON THE FOLLOWING TERMS:

1. REMEDIATE TO CLIENTS WHOSE PILOT PLUS ACCOUNTS WEREINACTIVE FOR TWO CONSECUTIVE YEARS OR MORE, ALL PILOT PLUSFEES CHARGED AFTER THE FIRST YEAR OF INACTIVITY;2. REMEDIATE TO CLIENTS WITH PILOT PLUS ACCOUNTS WITHASSETS LESS THAN THE REQUIRED $50,000 MINIMUM, THE DIFFERENCEBETWEEN THE $1,000 MINIMUM ANNUAL FEE AND A FEE EQUAL TO 2% OFTHE ASSETS WITH AVERAGE BALANCES, FOR FOUR CONSECUTIVEQUARTERS, BELOW $25,0003. REMEDIATE TO CLIENTS WHO PURCHASED LOADED CLASS AMUTUAL FUNDS AND TRANSFERRED THOSE ASSETS INTO A PILOT PLUSACCOUNT WITHIN 13 MONTHS OF THE PURCHASE, THE FEES CHARGEDON THAT ASSET THROUGH THE END OF THE THIRTEENTH MONTH;4. PAY CLIENTS INTEREST AT THE PROSCRIBED IRS RATE FROM THEDATE OF THE REQUIRED REMEDIATION THROUGH THE DATE OFACCEPTANCE OF THE AWC;5. RETAIN AND OUTSIDE CONSULTANT TO VERIFY THAT ALL OF THEAPPROPRIATE CLIENTS WERE IDENIFIED AND THE REMEDIATION WASDONE ACCORDANCE WITH THE TERMS OF THE AWC.

Firm Statement WITHIN 180 DAYS OF THE ACCEPTANCE OF THE AWC, IDENTIFY ALLCUSTOMERS ENTITLED TO REMEDIATION AND, WITHIN 195 DAYS OFACCEPTANCE, REPORT TO THE NASD. WITHIN 315 DAYS OF THEACCEPTANCE OF THE ORDER, REMEDIATE TO CLIENTS WITH INTEREST.

Disclosure 116 of 158

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Reporting Source: Regulator

Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT

Date Initiated: 05/30/2007

Docket/Case Number: HBD# 07-90

Allegations: **5/30/07** STIPULATION AND CONSENT TO PENALTY FILED BY NYSEREGULATION, INC. DIVISION OF ENFORCEMENT AND PENDING.CONSENTED TO FINDINGS: A. FINDINGS BY A HEARING PANEL OR AHEARING OFFICER ACTING ALONE THAT, FROM MARCH 2001 THROUGHJUNE 2005, THE FIRM VIOLATED NYSE RULE 345A, IN THAT IT PERMITTEDREGISTERED REPRESENTATIVES WITH INACTIVE REGISTRATIONS TOPERFORM DUTIES AND FUNCTIONS WHICH REQUIRED REGISTRATION. B.FINDINGS BY THE HEARING PANEL OR A HEARING OFFICER ACTING ALONETHAT, FROM MARCH 2001 THROUGH JUNE 2005, THE FIRM VIOLATED NYSERULE 342, IN THAT IT FAILED TO PROVIDE FOR, ESTABLISH AND MAINTAINADEQUATE SUPERVISORY PROCEDURES AND CONTROLS, INCLUDING ASYSTEM OF FOLLOW-UP AND REVIEW OF ITS BUSINESS ACTIVITIESRELATING TO COMPLIANCE WITH CONTINUING EDUCATION TRAININGREQUIREMENTS BY FIRM REGISTERED REPRESENTATIVES. C. THEIMPOSITION OF A CENSURE AND A FINE OF $90,000.

Current Status: Final

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www.finra.org/brokercheck User Guidance

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Principal Product Type: Other

Other Product Type(s):

Resolution Date: 07/17/2007

Resolution:

Other Sanctions Ordered:

Sanction Details: **6/18/07** 07-90 ISSUED BY THE HEARING BOARD DECISION:1. VIOLATED NYSE RULE 345A BY PERMITTING REGISTEREDREPRESENTATIVES WITH INACTIVE REGISTRATIONS TO PERFORM DUTIESAND FUNCTIONS WHICH REQUIRED REGISTRATION; AND2. VIOLATED NYSE RULE 342 BY FAILING TO PROVIDE FOR, ESTABLISH ANDMAINTAIN ADEQUATE SUPERVISORY PROCEDURES AND CONTROLS,INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW OF BUSINESSACTIVITIES RELATING TO COMPLIANCE WITH CONTINUING EDUCATIONTRAINING REQUIREMENTS BY REGISTERED REPRESENTATIVES. THEHEARING BOARD IMPOSED A PENALTY OF A CENSURE AND $90,000 FINE.

Regulator Statement **7/17/07** THE DECISION BECAME FINAL AS OF THE CLOSE OF BUSINESSON JULY 13, 2007. CONTACT: PEGGY GERMINO 212-656-8450.

Sanctions Ordered: CensureMonetary/Fine $90,000.00

Decision

iReporting Source: Firm

Allegations: ON JUNE 18 2007, AN NYSE HEARING OFFICER ACCEPTED "THESTIPULATION OF FACTS AND CONSENT TO PENALTY" ENTERED INTOBETWEEN NYSE REGULATION AND WACHOVIA SECURITIES LLC , WHEREINWACHOVIA SECURITIES, LLC, WITHOUT ADMITTING OR DENYING GUILT,CONSENTED TO: (I) A FINDING THAT IT VIOLATED NYSE RULE 345A BYPERMITTING REGISTERED REPRESENTATIVES WITH INACTIVEREGISTRATIONS DUE TO CONTINUING EDUCATION REQUIREMENTS TOPERFORM DUTIES AND FUNCTIONS WHICH REQUIRED REGISTRATION ANDVIOLATED NYSE RULE 342 BY FAILING TO PROVIDE FOR , ESTABLISH ANDMAINTAIN ADEQUATE SUPERVISORY PROCEDURES AND CONTROLS,INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW OF BUSINESSACTIVITIES RELATING TO COMPLIANCE WITH CONTINUING EDUCATIONTRAINING REQUIREMENTS BY REGISTERED REPRESENTATIVES; AND, (II)THE PENALTY OF A CENSURE AND A $90,000. FINE.

IF NO REVIEW IS REQUESTED BY A MEMBER OF THE NYSE ENTITIESIDENTIFIED IN NYSE RULE 476(G), THE DECISION WILL BECOME FINAL ATTHE CLOSE OF BUSINESS ON JULY 13, 2007.

Current Status: Final

232©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

FINE OF $90,000.

Date Initiated: 05/30/2007

Docket/Case Number: HBD# 07-90

Principal Product Type: No Product

Other Product Type(s):

ON JUNE 18 2007, AN NYSE HEARING OFFICER ACCEPTED "THESTIPULATION OF FACTS AND CONSENT TO PENALTY" ENTERED INTOBETWEEN NYSE REGULATION AND WACHOVIA SECURITIES LLC , WHEREINWACHOVIA SECURITIES, LLC, WITHOUT ADMITTING OR DENYING GUILT,CONSENTED TO: (I) A FINDING THAT IT VIOLATED NYSE RULE 345A BYPERMITTING REGISTERED REPRESENTATIVES WITH INACTIVEREGISTRATIONS DUE TO CONTINUING EDUCATION REQUIREMENTS TOPERFORM DUTIES AND FUNCTIONS WHICH REQUIRED REGISTRATION ANDVIOLATED NYSE RULE 342 BY FAILING TO PROVIDE FOR , ESTABLISH ANDMAINTAIN ADEQUATE SUPERVISORY PROCEDURES AND CONTROLS,INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW OF BUSINESSACTIVITIES RELATING TO COMPLIANCE WITH CONTINUING EDUCATIONTRAINING REQUIREMENTS BY REGISTERED REPRESENTATIVES; AND, (II)THE PENALTY OF A CENSURE AND A $90,000. FINE.

IF NO REVIEW IS REQUESTED BY A MEMBER OF THE NYSE ENTITIESIDENTIFIED IN NYSE RULE 476(G), THE DECISION WILL BECOME FINAL ATTHE CLOSE OF BUSINESS ON JULY 13, 2007.

Resolution Date: 06/18/2007

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING GUILT, CONSENTED TO THE PENALTYOF A CENSURE AND A $90,000. FINE.

Sanctions Ordered: CensureMonetary/Fine $90,000.00

Stipulation and Consent

Disclosure 117 of 158

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Reporting Source: Regulator

Initiated By: NASD

Date Initiated: 02/26/2007

Docket/Case Number: E8A2003062017

Allegations: NASD RULES 2110, 2830(L)(4) - WACHOVIA SECURITIES, LLC RECEIVED$33,856.35 IN SPECIAL CASH COMPENSATION FOR THE SALE OF SHARESOF PARTICULAR MUTUAL FUNDS DURING AN IRA PROMOTION THAT WASNOT AVAILABLE TO ALL WHO DISTRIBUTED THE MUTUAL FUNDS AND THEDETAILS OF THE ARANGEMENT WERE NOT PROPERLY DISCLOSED IN THEPROSPECTUS OR STATEMENTS OF ADDITIONAL INFORMATION FOR THEMUTUAL FUNDS.

Current Status: Final

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www.finra.org/brokercheck User Guidance

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Docket/Case Number: E8A2003062017

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Resolution Date: 02/26/2007

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $25,000.

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

No

Sanctions Ordered: CensureMonetary/Fine $25,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Initiated By: NASD

Date Initiated: 02/26/2007

Docket/Case Number: AWC #E8A2003062017

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations: THE FIRM WAS ALLEGED TO HAVE VIOLATED NASD RULES 2110, 2830(L)(4)IN RECEIVING SPECIAL COMPENSATION FOR SHARES SOLD IN APARTICULAR MUTUAL FUND DURING AN IRA PROMOTION THAT WAS NOTAVAILABLE TO ALL WHO DISTRIBUTED THE MUTUAL FUND AND THEARRANGEMENT WAS NOT PROPERLY DISCLOSED IN THE PROSPECTUSOR STATEMENTS OF ADDITIONAL INFORMATION FOR THE MUTUAL FUNDS.

Current Status: Final

234©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

CENSURE

Other Product Type(s):

Resolution Date: 02/26/2007

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO THE CENSURE AND FINE OF $25,000.

Sanctions Ordered: CensureMonetary/Fine $25,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 118 of 158

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Reporting Source: Regulator

Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT

Date Initiated: 02/12/2007

Allegations: **2/14/07**STIPULATION AND CONSENT TO PENALTY FILED BY NYSEREGULATION DIVISION OF ENFORCEMENT AND PENDING.CONSENTED TOFINDINGS (WITHOUT ADMITTING OR DENYING GUILT):1.VIOLATEDEXCHANGE ACT RULE 15C3-1(C)(2) IN THAT IT INCORRECTLY CALCULATEDITS REQUIRED NET CAPITAL COMPUTATION BY MISCLASSIFYINGASSETS;2.VIOLATED EXCHANGE ACT RULE 17A-5 IN THAT IT FILED ANINACCURATE FINANCIAL AND OPERATIONAL COMBINED UNIFORM SINGLEREPORT ("FOCUS REPORT") WITH THE NYSE;3.VIOLATED EXCHANGE ACTRULE 15C3-3 IN THAT IT IMPROPERLY COMPUTED ITS CUSTOMERRESERVE FORMULA REQUIREMENTS;4.VIOLATED EXCHANGE ACT RULE17A-3 AND NYSE RULE 440 IN THAT IT FAILED TO MAINTAIN BOOKS ANDRECORDS REGARDING ITS ACCOUNTS NECESSARY FOR COMPUTATIONOF ITS NET CAPITAL AND CUSTOMER RESERVE FORMULAREQUIREMENTS; 5.VIOLATED NYSE RULE 440.20 IN THAT IT DID NOTMAINTAIN PROPER RECORDS IDENTIFYING SUSPENSE ACCOUNTS ANDDID NOT HAVE PROCEDURES IN PLACE FOR SUPERVISORY REVIEW OFSUSPENSE ACCOUNTS; AND 6.VIOLATED NYSE RULES 342(A) AND (B) INTHAT IT FAILED TO PROVIDE FOR APPROPRIATE PROCEDURES OFSUPERVISION AND CONTROL AND TO ESTABLISH A SYSTEM OF FOLLOW-UP AND REVIEW TO PREVENT THE FOREGOING VIOLATIONS.STIPULATED SANCTION:CENSURE AND $100,000 FINE.

Current Status: Final

235©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 02/12/2007

Docket/Case Number: HBD# 07-34

Principal Product Type: Other

Other Product Type(s):

Resolution Date: 04/17/2007

Resolution:

Other Sanctions Ordered:

Sanction Details: **3/12/07** DECISION 07-34 ISSUED BY THE HEARING BOARDDECISION: VIOLATED EXCHANGE ACT RULE15C3-1(C)(2) IN THAT ITINCORRECTLY CALCULATED ITS REQUIRED NET CAPITAL COMPUTATIONBY MISCLASSIFYING ASSETS; VIOLATED EXCHANGE ACT RULE 17A-5 INTHAT IT FILED AN INACCURATE FOCUS REPORT WITH THE NYSE;VIOLATED EXCHANGE ACT RULE 15C3-3 IN THAT IT IMPROPERLYCOMPUTING CUSTOMER RESERVE FORMULA REQUIREMENTS; VIOLATEDEXCHANGE ACT RULE 17A-3 AND NYSE RULE 440 IN THAT IT FAILED TOMAINTAIN BOOKS AND RECORDS REGARDING ACCOUNTS NECESSARYFOR COMPUTATION OF ITS NET CAPITAL AND CUSTOMER RESERVEFORMULA REQUIREMENTS;VIOLATED NYSE RULE 440.20 IN THAT IT DIDNOT MAINTAIN PROPER RECORDS IDENTIFYING SUSPENSE ACCOUNTSAND DID NOT HAVE PROCEDURES IN PLACE FOR SUPERVISORY REVIEWOF SUSPENSE ACCOUNTS; VIOLATED NYSE RULES 342(A) AND (B)IN THATIT FAILED TO PROVIDE FOR APPROPRIATE PROCEDURES OFSUPERVISION AND CONTROL AND TO ESTABLISH A SYSTEM OF FOLLOW-UP AND REVIEW TO PREVENT THE FOREGOING VIOLATIONS - CONSENTEDTO A CENSURE AND $100,000 FINE.

Regulator Statement **4/17/07** THE DECISION BECAME FINAL AS OF THE CLOSE OF BUSINESSON APRIL 6, 2007. CONTACT: PEGGY GERMINO 212-656-8450.

Sanctions Ordered: CensureMonetary/Fine $100,000.00

Decision

iReporting Source: Firm

Allegations: WITHOUT ADMITTING OR DENYING GUILT, THE FIRM HAS ENTERED INTO ASTIPULATION OF FACT AND CONSENT TO PENALTY WITH THE NEW YORKSTOCK EXCHANGE DIVISION OF ENFORCEMENT CONCERNING CERTAINFINDINGS MADE DURING THE FIRM'S 2004 FINANCIAL AND OPERATIONALEXAM. THESE FINDINGS INVOLVED OVERSTATING EXCESS NET CAPITALAS OF SEPTEMBER 30, 2004 AND OVERSTATING EXCESS CUSTOMERDEBITS IN ITS CUSTOMER RESERVE FORMULA AS OF SEPTEMBER 30,2004. ADDITIONAL FINDINGS INCLUDED FAILING TO ADEQUATELYSUPERVISE IN CONNECTION WITH THE FOREGOING AND INADEQUATEINTERNAL CONTROLS IN CONNECTION WITH THE CALCULATION ANDDOCUMENTATION OF ITS NET CAPITAL AND CUSTOMER RESERVEREQUIREMENTS. THE FIRM HAS CONSENTED TO A CENSURE AND$100,000 FINE.

Current Status: Final

236©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Initiated By: NEW YORK STOCK EXCHANGE, INC., DIVISION OF ENFORCEMENT

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

CENSURE

Date Initiated: 02/12/2007

Docket/Case Number: HBD# 07-034

Principal Product Type: No Product

Other Product Type(s):

Allegations: WITHOUT ADMITTING OR DENYING GUILT, THE FIRM HAS ENTERED INTO ASTIPULATION OF FACT AND CONSENT TO PENALTY WITH THE NEW YORKSTOCK EXCHANGE DIVISION OF ENFORCEMENT CONCERNING CERTAINFINDINGS MADE DURING THE FIRM'S 2004 FINANCIAL AND OPERATIONALEXAM. THESE FINDINGS INVOLVED OVERSTATING EXCESS NET CAPITALAS OF SEPTEMBER 30, 2004 AND OVERSTATING EXCESS CUSTOMERDEBITS IN ITS CUSTOMER RESERVE FORMULA AS OF SEPTEMBER 30,2004. ADDITIONAL FINDINGS INCLUDED FAILING TO ADEQUATELYSUPERVISE IN CONNECTION WITH THE FOREGOING AND INADEQUATEINTERNAL CONTROLS IN CONNECTION WITH THE CALCULATION ANDDOCUMENTATION OF ITS NET CAPITAL AND CUSTOMER RESERVEREQUIREMENTS. THE FIRM HAS CONSENTED TO A CENSURE AND$100,000 FINE.

Resolution Date: 04/06/2007

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO A CENSURE AND FINE OF $100,000.

Sanctions Ordered: CensureMonetary/Fine $100,000.00

Stipulation and Consent

Disclosure 119 of 158

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Reporting Source: Regulator

Allegations: NASD RULES 2110, 3010 - WACHOVIA SECURITIES, LLC FAILED TOESTABLISH AND MAINTAIN A SYSTEM TO SUPERVISE THE ACTIVITIES OF AREGISTERED REPRESENTATIVE REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDNASD RULES; ALTHOUGH THE FIRM HAD PROCEDURES REQUIRINGSUPERVISORY REVIEW OF INCOMING/OUTGOING MAIL AND PROHIBITEDTHE RECEIPT OF PERSONAL MAIL AT THE BRANCH OFFICE, THE FIRMFAILED TO REVIEW CORRESPONDENCE; FAILED TO FOLLOW UP ON "REDFLAGS" INDICATING POSSIBLE MISCONDUCT BY THE REPRESENTATIVEREGARDING A FICTITIOUS ENTITY OPERATING AS A PONZI SCHEME;FAILED TO VERIFY THE REPRESENTATIVE'S EXPLANATION OF AN OUTSIDEBUSINESS ACTIVITY; FAILED TO CONTACT CUSTOMERS REGARDING FUNDRECEIVED FROM THE REPRESENTATIVE, DID NOT REVIEW BANKSTATEMENTS THAT WOULD HAVE REVEALED ADDITIONAL PERIODICPAYMENTS TO CUSTOMERS, DID NOT ASK THE REPRESENTATIVE FOR THENAME OF A CONTACT WITHIN THE OUTSIDE BUSINESS ENTITY TO VERIFYFINANCIAL ARRANGEMENTS AND DID NOT REVIEW THEREPRESENTATIVE'S CUSTOMER ACCOUNTS TO SEE IF THE CUSTOMERSHAD WRITTEN CHECKS TO THE ENTITY.

Current Status: Final

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www.finra.org/brokercheck User Guidance

Initiated By: NASD

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 12/20/2006

Docket/Case Number: 2005001720503

Principal Product Type: No Product

Other Product Type(s):

NASD RULES 2110, 3010 - WACHOVIA SECURITIES, LLC FAILED TOESTABLISH AND MAINTAIN A SYSTEM TO SUPERVISE THE ACTIVITIES OF AREGISTERED REPRESENTATIVE REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDNASD RULES; ALTHOUGH THE FIRM HAD PROCEDURES REQUIRINGSUPERVISORY REVIEW OF INCOMING/OUTGOING MAIL AND PROHIBITEDTHE RECEIPT OF PERSONAL MAIL AT THE BRANCH OFFICE, THE FIRMFAILED TO REVIEW CORRESPONDENCE; FAILED TO FOLLOW UP ON "REDFLAGS" INDICATING POSSIBLE MISCONDUCT BY THE REPRESENTATIVEREGARDING A FICTITIOUS ENTITY OPERATING AS A PONZI SCHEME;FAILED TO VERIFY THE REPRESENTATIVE'S EXPLANATION OF AN OUTSIDEBUSINESS ACTIVITY; FAILED TO CONTACT CUSTOMERS REGARDING FUNDRECEIVED FROM THE REPRESENTATIVE, DID NOT REVIEW BANKSTATEMENTS THAT WOULD HAVE REVEALED ADDITIONAL PERIODICPAYMENTS TO CUSTOMERS, DID NOT ASK THE REPRESENTATIVE FOR THENAME OF A CONTACT WITHIN THE OUTSIDE BUSINESS ENTITY TO VERIFYFINANCIAL ARRANGEMENTS AND DID NOT REVIEW THEREPRESENTATIVE'S CUSTOMER ACCOUNTS TO SEE IF THE CUSTOMERSHAD WRITTEN CHECKS TO THE ENTITY.

Resolution Date: 12/20/2006

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $50,000.

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

No

Sanctions Ordered: CensureMonetary/Fine $50,000.00

Acceptance, Waiver & Consent(AWC)

238©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

iReporting Source: Firm

Initiated By: NASD, DEPARTMENT OF ENFORCEMENT

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

MONETARY FINE

Date Initiated: 12/18/2006

Docket/Case Number: AWC NO. 2005001720503

Principal Product Type: No Product

Other Product Type(s):

Allegations: DUE TO THE MISCONDUCT OF A REGISTERED REPRESENTATIVE, THEFIRM WAS ALLEGED TO HAVE VIOLATED NASD CONDUCT RULES 2110 AND3010 IN REGARDS TO THE SUPERVISION OF CERTAIN ACTIVITIES OF THISREGISTERED REPRESENTATIVE.

Current Status: Final

Resolution Date: 12/18/2006

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREEDTO A CENSURE AND FINE OF $50,000.

Sanctions Ordered: CensureMonetary/Fine $50,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 120 of 158

i

Reporting Source: Regulator

Allegations: **8/25/06** STIPULATION AND CONSENT TO PENALTY FILED BY NYSEREGULATION, INC. DIVISION OF ENFORCEMENT AND PENDING.CONSENTED TO FINDING: A FINDING BY THE HEARING PANEL THATWACHOVIA VIOLATED NYSE RULE 342(A) AND (B) BY FAILING TO PROVIDEFOR, ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES AND CONTROLSFOR CERTAIN ACTIVITIES AT ITS BANK-AFFILIATE WHICH AFFECTCOMMAND ASSET PROGRAM ACCOUNTS, INCLUDING A SYSTEM OFFOLLOW-UP AND REVIEW OF ITS BUSINESS ACTIVITIES RELATING TOCHANGES OF CUSTOMER ADDRESS. THE IMPOSITION BY THE EXCHANGEOF THE PENALTY OF A CENSURE AND A FINE OF $300,000.

Current Status: Final

239©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 08/25/2006

Docket/Case Number: HDB# 06-172

Principal Product Type: Other

Other Product Type(s):

**8/25/06** STIPULATION AND CONSENT TO PENALTY FILED BY NYSEREGULATION, INC. DIVISION OF ENFORCEMENT AND PENDING.CONSENTED TO FINDING: A FINDING BY THE HEARING PANEL THATWACHOVIA VIOLATED NYSE RULE 342(A) AND (B) BY FAILING TO PROVIDEFOR, ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES AND CONTROLSFOR CERTAIN ACTIVITIES AT ITS BANK-AFFILIATE WHICH AFFECTCOMMAND ASSET PROGRAM ACCOUNTS, INCLUDING A SYSTEM OFFOLLOW-UP AND REVIEW OF ITS BUSINESS ACTIVITIES RELATING TOCHANGES OF CUSTOMER ADDRESS. THE IMPOSITION BY THE EXCHANGEOF THE PENALTY OF A CENSURE AND A FINE OF $300,000.

Resolution Date: 10/09/2006

Resolution:

Other Sanctions Ordered:

Sanction Details: **9/13/06** DECISION 06-172 ISSUED BY NYSE HEARING BOARD.DECISION: VIOLATED NYSE RULES 342(A) AND (B) BY FAILING TO PROVIDEFOR, ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES AND CONTROLSFOR CERTAIN ACTIVITIES AT ITS BANK-AFFILIATE WHICHAFFECT COMMAND ASSET PROGRAM ACCOUNTS, INCLUDING A SYSTEMOF FOLLOW-UP AND REVIEW OF ITS BUSINESS ACTIVITIES RELATING TOCHANGES OF CUSTOMER ADDRESS. CONSENT TO CENSURE AND $300,000FINE.

Regulator Statement **10/9/06** THE DECISION BECAME FINAL CLOSE OF BUSINESS ONOCTOBER 9, 2006. CONTACT: PEGGY GERMINO 212-656-8450.

Sanctions Ordered: CensureMonetary/Fine $300,000.00

Decision

iReporting Source: Firm

Allegations: IN NYSE HEARING BOARD DECISION 06-172 THE HEARING OFFICERAPPROVED THE STIPULATION AND CONSENT TO PENALTY WHEREINWACHOVIA SECURITIES, WITHOUT ADMITTING OR DENYING GUILTCONSENTED TO FINDING: A FINDING BY THE HEARING PANEL THATWACHOVIA VIOLATED NYSE RULE 342(A) AND (B) BY FAILING TO PROVIDEFOR, ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES AND CONTROLSFOR CERTAIN ACTIVITIES AT ITS BANK AFFILIATE WHICH AFFECTCOMMAND ASSET PROGRAM ACCOUNTS, INCLUDING A SYSTEM OFFOLLOW-UP AND REVIEW OF ITS BUSINESS ACTIVITIES RELATING TOCHANGES OF CUSTOMER ADDRESS.

Current Status: Final

240©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Initiated By: NEW YORK STOCK EXCHANGE, DIVISION OF ENFORCEMENT

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 08/25/2006

Docket/Case Number: HDB# 06-172

Principal Product Type: Other

Other Product Type(s):

IN NYSE HEARING BOARD DECISION 06-172 THE HEARING OFFICERAPPROVED THE STIPULATION AND CONSENT TO PENALTY WHEREINWACHOVIA SECURITIES, WITHOUT ADMITTING OR DENYING GUILTCONSENTED TO FINDING: A FINDING BY THE HEARING PANEL THATWACHOVIA VIOLATED NYSE RULE 342(A) AND (B) BY FAILING TO PROVIDEFOR, ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES AND CONTROLSFOR CERTAIN ACTIVITIES AT ITS BANK AFFILIATE WHICH AFFECTCOMMAND ASSET PROGRAM ACCOUNTS, INCLUDING A SYSTEM OFFOLLOW-UP AND REVIEW OF ITS BUSINESS ACTIVITIES RELATING TOCHANGES OF CUSTOMER ADDRESS.

Resolution Date: 10/09/2006

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING GUILT, THE FIRM CONSENTED TO ACENSURE AND FINE OF $300,000.

Sanctions Ordered: CensureMonetary/Fine $300,000.00

Stipulation and Consent

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Reporting Source: Firm

Initiated By: STATE OF CONNECTICUT

Principal Sanction(s)/ReliefSought:

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

Date Initiated: 01/23/2004

Docket/Case Number: ST-03-6927-S

Principal Product Type: Other

Other Product Type(s): ADVISORY

Allegations: ALLEGED TO HAVE VIOLATED SECTION 36B-6(B) AND SECTION 36B-6(C) OFTHE CONNECTICUT UNIFORM SECURITIES ACT WHERE CERTAIN FINACIALADVISORS AND A SALES ASSISTANT WERE NOT REGISTERED ASINVESTMENT ADVISORY AGENTS.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Resolution Date: 01/23/2004

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO A FINE OF $2500.

Sanctions Ordered: Monetary/Fine $2,500.00

Stipulation and Consent

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Reporting Source: Regulator

Allegations: **7/6/06** STIPULATION AND CONSENT TO PENALTY FILED BY NYSEREGULATION DIVISION OF ENFORCEMENT AND PENDING AGAINSTWACHOVIA CAPITAL MARKETS, LLC; WACHOVIA SECURITIES, LLC; ANDFIRST CLEARING, LLC ("WACHOVIA RESPONDENTS") CONSENTED TOFINDINGS: WITHOUT ADMITTING OR DENYING GUILT, CONSENTED TOFINDINGS: THAT THE WACHOVIA RESPONDENTS VIOLATED SECTION 17(A)OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-4THEREUNDER AND NYSE RULE 440 IN THAT THE WACHOVIARESPONDENTS FAILED TO PRESERVE ELECTRONIC RECORDS RELATINGTO THE BUSINESS OF THE WACHOVIA RESPONDENTS FOR AT LEASTTHREE YEARS, THE FIRST TWO YEARS IN AN EASILY ACCESSIBLELOCATION. THAT THE WACHOVIA RESPONDENTS VIOLATED NYSE RULES342 AND 342.17 IN THAT THE WACHOVIA RESPONDENTS FAILED TOREASONABLY SUPERVISE AND CONTROL THE ACTIVITIES OF THEIREMPLOYEES, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP ANDREVIEW TO ASSURE COMPLIANCE WITH NYSE RULES AND FEDERALSECURITIES LAWS RELATING TO RETENTION AND/OR REVIEW OFELECTRONIC COMMUNICATIONS. CONSENTED TO SANCTION: THEIMPOSITION BY THE EXCHANGE OF THE PENALTY OF A CENSURE, AREGULATORY UNDERTAKING, AND A FINE OF $2,250,000 (TWO MILLIONAND TWO HUNDRED AND FIFTY THOUSAND DOLLARS, TO BE PAYABLE ASFOLLOWS: BY ONE PAYMENT TO NYSE REGULATION, INC. IN THE AMOUNTOF $600,000 (SIX HUNDRED THOUSAND DOLLARS), DUE AND PAYABLEWHEN THE DECISION IN THIS MATTER BECOMES FINAL; AND BY ANOTHERPAYMENT IN THE AMOUNT OF $1,650,000 (ONE MILLION AND SIX HUNDREDAND FIFTY THOUSAND DOLLARS), COLLECTION OF WHICH THE NYSE WILLWAIVE IN RECOGNITION OF AND CONDITIONAL UPON THE PAYMENT BYWACHOVIA CAPITAL MARKETS OF $1,650,000 (ONE MILLION AND SIXHUNDRED AND FIFTY THOUSAND DOLLARS) PURSUANT TO THE TERMS OFTHE SETTLEMENT OF A REGULATORY ACTION, CONCLUDED UNDER THEAUSPICES OF THE NORTH AMERICAN SECURITIES ADMINISTRATORSASSOCIATION, RELATING TO WACHOVIA CAPITAL MARKETS' VIOLATION OFTHE DUTY TO RETAIN E-MAIL COMMUNICATIONS.

Current Status: Final

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Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 07/06/2006

Docket/Case Number: HBD# 06-151

Principal Product Type: Other

Other Product Type(s):

**7/6/06** STIPULATION AND CONSENT TO PENALTY FILED BY NYSEREGULATION DIVISION OF ENFORCEMENT AND PENDING AGAINSTWACHOVIA CAPITAL MARKETS, LLC; WACHOVIA SECURITIES, LLC; ANDFIRST CLEARING, LLC ("WACHOVIA RESPONDENTS") CONSENTED TOFINDINGS: WITHOUT ADMITTING OR DENYING GUILT, CONSENTED TOFINDINGS: THAT THE WACHOVIA RESPONDENTS VIOLATED SECTION 17(A)OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-4THEREUNDER AND NYSE RULE 440 IN THAT THE WACHOVIARESPONDENTS FAILED TO PRESERVE ELECTRONIC RECORDS RELATINGTO THE BUSINESS OF THE WACHOVIA RESPONDENTS FOR AT LEASTTHREE YEARS, THE FIRST TWO YEARS IN AN EASILY ACCESSIBLELOCATION. THAT THE WACHOVIA RESPONDENTS VIOLATED NYSE RULES342 AND 342.17 IN THAT THE WACHOVIA RESPONDENTS FAILED TOREASONABLY SUPERVISE AND CONTROL THE ACTIVITIES OF THEIREMPLOYEES, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP ANDREVIEW TO ASSURE COMPLIANCE WITH NYSE RULES AND FEDERALSECURITIES LAWS RELATING TO RETENTION AND/OR REVIEW OFELECTRONIC COMMUNICATIONS. CONSENTED TO SANCTION: THEIMPOSITION BY THE EXCHANGE OF THE PENALTY OF A CENSURE, AREGULATORY UNDERTAKING, AND A FINE OF $2,250,000 (TWO MILLIONAND TWO HUNDRED AND FIFTY THOUSAND DOLLARS, TO BE PAYABLE ASFOLLOWS: BY ONE PAYMENT TO NYSE REGULATION, INC. IN THE AMOUNTOF $600,000 (SIX HUNDRED THOUSAND DOLLARS), DUE AND PAYABLEWHEN THE DECISION IN THIS MATTER BECOMES FINAL; AND BY ANOTHERPAYMENT IN THE AMOUNT OF $1,650,000 (ONE MILLION AND SIX HUNDREDAND FIFTY THOUSAND DOLLARS), COLLECTION OF WHICH THE NYSE WILLWAIVE IN RECOGNITION OF AND CONDITIONAL UPON THE PAYMENT BYWACHOVIA CAPITAL MARKETS OF $1,650,000 (ONE MILLION AND SIXHUNDRED AND FIFTY THOUSAND DOLLARS) PURSUANT TO THE TERMS OFTHE SETTLEMENT OF A REGULATORY ACTION, CONCLUDED UNDER THEAUSPICES OF THE NORTH AMERICAN SECURITIES ADMINISTRATORSASSOCIATION, RELATING TO WACHOVIA CAPITAL MARKETS' VIOLATION OFTHE DUTY TO RETAIN E-MAIL COMMUNICATIONS.

Resolution Date: 09/01/2006

Resolution:

Other Sanctions Ordered:

Sanction Details: **8/1/06** DECISION 06-151 ISSUED BY NYSE HEARING BOARDVIOLATIONS FOUND: VIOLATED SECTION 17(A) OF THE SECURITIESEXCHANGE ACT OF 1934 AND RULE 17A-4 THEREUNDER AND NYSE RULE440 BY FAILING TO PRESERVE ELECTRONIC RECORDS RELATING TO ITSBUSINESS FOR AT LEAST THREE YEARS, THE FIRST TWO YEARS IN ANEASILY ACCESSIBLE LOCATION; VIOLATED EXCHANGE RULES 342 AND342.17 BY FAILING TO REASONABLY SUPERVISE AND CONTROL ACTIVITIESOF ITS EMPLOYEES, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP ANDREVIEW TO ASSURE COMPLIANCE WITH NYSE RULES AND FEDERALSECURITIES LAWS RELATING TO RETENTION AND/OR REVIEW OFELECTRONIC COMMUNICATIONS.SANCTION: THE HEARING PANEL IMPOSED THE SANCTION, CONSENTEDTO BY THE RESPONDENT, OF A CENSURE, A FINE OF $2,250,000, SUBJECTTO CERTAIN CONDITIONS SET FORTH IN THE DECISION, AND AREGULATORY UNDERTAKING.

Regulator Statement **9/1/06** THE DECISION IS NOW FINAL AND IS EFFECTIVE IMMEDIATELY.CONTACT: PEGGY GERMINO 212-656-8450.

Sanctions Ordered: CensureMonetary/Fine $2,250,000.00

Decision

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Regulator Statement **9/1/06** THE DECISION IS NOW FINAL AND IS EFFECTIVE IMMEDIATELY.CONTACT: PEGGY GERMINO 212-656-8450.

iReporting Source: Firm

Initiated By: NEW YORK STOCK EXCHANGE, INC., DIVISION OF ENFORCEMENT

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

Date Initiated: 07/06/2006

Docket/Case Number: HBD#06-151

Principal Product Type: No Product

Other Product Type(s):

Allegations: THE FIRM, ALONG WITH FIRST CLEARING, LLC ("FC) AND WACHOVIACAPITAL MARKETS, LLC ("WCM"), IS ALLEGED TO HAVE VIOLATED SECTION17(A) OF THE SECURITIES EXCHANGE ACT AND RULE 17A-4 THEREUNDER,ALONG WITH NYSE RULES 440, 342 AND 342.17, BY FAILING TO PRESERVEELECTRONIC RECORDS RELATING TO THE BUSINESS OF THE FIRM FOR ATLEAST THREE YEARS AND BY FAILING TO REASONABLY SUPERVISE THERETENTION AND/OR REVIEW OF ELECTRONIC COMMUNICATIONS.

Current Status: Final

Resolution Date: 08/26/2006

Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE STIPULATIONOF FACTS AND CONSENT TO PENALTY, THE FIRM, ALONG WITH FC ANDWCM, CONSENTED TO THE CENSURE, THE FINE, AND AN UNDERTAKINGTO ENSURE COMPLIANCE WITH THE RULES AND REGULATIONS ON THERETENTION AND REVIEW OF ELECTRONIC COMMUNICATIONS THROUGHENGAGEMENT OF AN INDEPENDENT CONSULTANT. WITH REGARD TO THEFINE, $1,650,000 OF THE $2,250,000 IS WAIVED, CONDITIONAL UPON WCMPAYING THAT AMOUNT PURSUANT TO WCM'S SETTLEMENT OF AREGULATORY ACTION BY STATE SECURITIES REGULATORS RELATING, INPART, TO EMAIL RETENTION. THE BALANCE OF THE FINE WILL BE PAID BYTHE THREE FIRMS ON OR BEFORE 10/16/06.

Sanctions Ordered: CensureMonetary/Fine $2,250,000.00

Stipulation and Consent

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Reporting Source: Firm

Initiated By: NEW YORK STOCK EXCHANGE, INC.

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 01/18/2006

Docket/Case Number:

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

Other Product Type(s):

Allegations: THE FIRM WAS ALLEGED TO HAVE VIOLATED EXCHANGE RULE 123C, INFAILING TO ADHERE TO THE ORDER ENTRY AND CANCELLATIONPROCEDURES FOR MARKET-ON-CLOSE (MOC) AND LIMIT-ON-CLOSE (LOC)ORDERS.

Current Status: Final

Resolution Date: 01/18/2006

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO PAYMENT OF THE TOTAL FINE OF $7500, PAID ON 2/8/2006.

Sanctions Ordered: Monetary/Fine $7,500.00

Other

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Reporting Source: Firm

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Date Initiated: 11/02/1990

Docket/Case Number: NEW-779-AWC

Principal Product Type: No Product

Allegations: FAILURE TO DEVELOP WRITTEN SUPERVISORY PROCEDURES.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

RELIEF SOUGHT

Principal Product Type: No Product

Other Product Type(s):

Resolution Date: 11/02/1990

Resolution:

Other Sanctions Ordered:

Sanction Details: CENSURED AND FINED $2500, JOINTLY AND SEVERALLY.

Firm Statement ON NOVEMBER 2, 1990 THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT NO. NEW-779-AWC (DISTRICT NO. 5) SUBMITTED BYRESPONDENTS SOUTHTRUST SECURITIES, INC. (CRD#17922 - MERGEDINTO WACHOVIA SECURITIES, LLC),JOSEPH C. MARFOGLIO, CHARLES J.SMITH AND JAMES D HOOKS WAS ACCEPTED; THEREFORE THEY ARECENSURED AND FINED $2500 JOINTLY AND SEVERALLY - (ARTICLE III,SECTIONS 1, 21, 27 AND 33, APPENDIX 3 OF THE RULES OF FAIR PRACTICEAND MSRB RULE G-3 IN THAT RESPONDENT MEMBER, ACTING THROUGHRESPONDENTS MARFOGLIO AND SMITH, FAILED TO MAKE THE REQUIREDDEPOSIT IN ITS SPECIAL RESERVE BANK ACCOUNT; FAILED TO PROPERLYCONDUCT A QUARTERLY SECURITY EXAMINATION, COUNT ANDVERIFICATION; FAILED TO PREPARE AND KEEP CURRENT AN ACCURATESECURITIES POSITION RECORD; FAILED TO PREPARE AN ACCURATECOMPUTATION OF NET CAPITAL; RESPONDENT MEMBER, ACTINGTHROUGH RESPONDENT MARFOGLIO, FILED TO DEVELOP ANDIMPLEMENT WRITTEN SUPERVISORY PROCEDURES; AND RESPONDENTMEMBER, ACTING THROUGH RESPONDENTS MARFOGLIO AND HOOKS,FAILED TO PROPERLY REGISTERE AN INDIVIDUAL AS A MUNICIPALSECURITIES PRINCIPAL. ***$2,500 J&S PAID ON 11/20/90, INVOICE #90-05-1262***

Sanctions Ordered: CensureMonetary/Fine $2,500.00

Acceptance, Waiver & Consent(AWC)

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Reporting Source: Firm

Allegations: THE FIRM WAS ALLEGED TO HAVE VIOLATED SECURITIES LAWS BYFAILING TO ADEQUATELY SUPERVISE ITS AGENTS IN THE STATE OFMISSOURI.

Current Status: Final

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Initiated By: MISSOURI SECURITIES DIVISION

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

PAYMENT OF $300,000 TO THE MISSOURI INVESTOR EDUCATION ANDPROTECTION FUND.

Date Initiated: 06/13/2005

Docket/Case Number: CASE NO. AP-05-20

Principal Product Type: Other

Other Product Type(s):

THE FIRM WAS ALLEGED TO HAVE VIOLATED SECURITIES LAWS BYFAILING TO ADEQUATELY SUPERVISE ITS AGENTS IN THE STATE OFMISSOURI.

Resolution Date: 06/13/2005

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO THE ORDER TO CEASE AND DESIST AND PAYMENT OF$300,000 TO THE MISSOURI INVESTOR EDUCATION AND PROTECTIONFUND. IN ADDITION FOR A PERIOD OF TWO YEARS: (1) UPON REQUESTPROVIDE THE STATE OF MISSOURI BRANCH OFFICE REVIEWS BYREGULATORS, INCLUDING THE SEC, NYSE AND THE NASD, (2) PROMPTLYREPORT TO THE STATE OF MISSOURI THE NAME AND CRD NUMBER OFEACH MISSOURI-BASED AGENT IDENTIFIED BY THE SYSTEM WARRANTINGHEIGHTENED SUPERVISION, (3) PROMPTLY REPORT ALL MATERIALCHANGES IN COMPLIANCE SUPERVISORS WITH DIRECT OVERSIGHT OFMISSOURI-BASED AGENTS AND BRANCH OFFICES.

Sanctions Ordered: Monetary/Fine $300,000.00Cease and Desist/Injunction

Consent

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Reporting Source: Firm

Allegations: DURING AUGUST 5, 1999 THROUGH JULY 31, 2000, A REGISTEREDREPRESENTATIVE OF THE FIRM HAD TRANSACTED BUSINESS WITH MAINECLIENTS AND WAS NOT LICENSED OR EXEMPT. THE FIRM WAS ALLEGEDTO HAVE VIOLATED THE REVISED MAINE SECURITIES ACT BY EMPLOYINGTHIS REGISTERED REPRESENTATIVE WHO WAS NOT LICENSED OREXEMPT IN THE STATE AND FAILING TO REASONABLY SUPERVISE ONE OFITS REGISTERED REPRESENTATIVES.

Current Status: Final

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Initiated By: STATE OF MAINE, OFFICE OF SECURITIES

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

ADMINISTRATIVE FINE OF $27,000

Date Initiated: 04/25/2005

Docket/Case Number: 05-026-CAG

Principal Product Type: No Product

Other Product Type(s):

DURING AUGUST 5, 1999 THROUGH JULY 31, 2000, A REGISTEREDREPRESENTATIVE OF THE FIRM HAD TRANSACTED BUSINESS WITH MAINECLIENTS AND WAS NOT LICENSED OR EXEMPT. THE FIRM WAS ALLEGEDTO HAVE VIOLATED THE REVISED MAINE SECURITIES ACT BY EMPLOYINGTHIS REGISTERED REPRESENTATIVE WHO WAS NOT LICENSED OREXEMPT IN THE STATE AND FAILING TO REASONABLY SUPERVISE ONE OFITS REGISTERED REPRESENTATIVES.

Resolution Date: 04/25/2005

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREEDTO THE CENSURE AND PAYMENT OF $27,000.

Sanctions Ordered: CensureMonetary/Fine $27,000.00

Consent

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Reporting Source: Regulator

Allegations: NASD CONDUCT RULES 2110, 2210(D)(1)(A), 2210(D)(1)(B), 2210(C)(1),3010(A)(1), 3010(B)(1), IM-2210-2 - WACHOVIA SECURITIES, LLC ACTINGTHROUGH A REGISTERED REPRESENTATIVE, CREATED AND DISTRIBUTEDWRITTEN COMMUNICATIONS THAT FAILED TO DISCLOSE ADEQUATELYMATERIAL FACTS REGARDING INVESTMENT PRODUCTS AND STRATEGIES,OR MADE EXAGGERATED, UNWARRANTED OR MISLEADING STATEMENTSOR CLAIMS REGARDING THOSE PRODUCTS, OR BOTH. THE FIRM ACTINGPRIMARILY THROUGH A BRANCH MANAGER, FAILED TO SUPERVISEREASONABLY A REGISTERED REPRESENTATIVES WRITTENCOMMUNICATIONS ACTIVITIES IN CONNECTION WITHCORRESPONDENCES AND SALES LITERATURE. IN ADDITION, WACHOVIAFAILED TO FILE THE REGISTERED REPRESENTATIVE'S SALES LITERATUREWITH NASD. THE FIRM ALSO FAILED TO ESTABLISH AND MAINTAINPROCEDURES THAT WERE REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH NASD'S REQUIREMENT FOR FILING SALESLITERATURE WITHIN 10 DAYS OF FIRST USE. THE FIRM ACTING PRIMARILYTHROUGH AN INDIVIDUAL, REVIEWED AND APPROVED A REGISTEREDREPRESENTATIVE'S WRITTEN COMMUNICATIONS THAT WERE DEFICIENTBECAUSE THEY FAILED TO DISCLOSE ADEQUATELY MATERIAL FACTSREGARDING PRODUCTS OR INVESTMENT STRATEGIES RECOMMENDED.BY APPROVING THESE WRITTEN COMMUNICATIONS, WACHOVIA FAILEDTO REASONABLY SUPERVISE THE REGISTERED REPRESENTATIVE. THEFIRM'S WRITTEN SUPERVISORY PROCEDURES INCORRECTLY DEFINED "SALES LITERATURE" WHICH IS REQUIRED TO BE FILED WITH NASDWITHIN 10 DAYS OF FIRST USE. THE FIRM'S MANAGERIAL PERSONNELUSED THE WRITTEN SUPERVISORY PROCEDURES TO DETERMINEWHETHER A WRITTEN COMMUNICATION SHOULD BE FORWARDED TONASD. BY INCORRECTLY DEFINING "SALES LITERATURE," WACHOVIA'SWRITTEN SUPERVISORY PROCEDURES IMPROPERLY INSTRUCTED THEFIRM'S MANAGERIAL PERSONNEL ON WHEN WRITTEN COMMUNICATIONQUALIFIED AS SALES LITERATURE THAT NEEDED TO BE FILED WITH NASD.

Current Status: Final

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Initiated By: NASD

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 04/13/2005

Docket/Case Number: CE2050007

Principal Product Type: Annuity(ies) - Variable

Other Product Type(s): FUNDS

NASD CONDUCT RULES 2110, 2210(D)(1)(A), 2210(D)(1)(B), 2210(C)(1),3010(A)(1), 3010(B)(1), IM-2210-2 - WACHOVIA SECURITIES, LLC ACTINGTHROUGH A REGISTERED REPRESENTATIVE, CREATED AND DISTRIBUTEDWRITTEN COMMUNICATIONS THAT FAILED TO DISCLOSE ADEQUATELYMATERIAL FACTS REGARDING INVESTMENT PRODUCTS AND STRATEGIES,OR MADE EXAGGERATED, UNWARRANTED OR MISLEADING STATEMENTSOR CLAIMS REGARDING THOSE PRODUCTS, OR BOTH. THE FIRM ACTINGPRIMARILY THROUGH A BRANCH MANAGER, FAILED TO SUPERVISEREASONABLY A REGISTERED REPRESENTATIVES WRITTENCOMMUNICATIONS ACTIVITIES IN CONNECTION WITHCORRESPONDENCES AND SALES LITERATURE. IN ADDITION, WACHOVIAFAILED TO FILE THE REGISTERED REPRESENTATIVE'S SALES LITERATUREWITH NASD. THE FIRM ALSO FAILED TO ESTABLISH AND MAINTAINPROCEDURES THAT WERE REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH NASD'S REQUIREMENT FOR FILING SALESLITERATURE WITHIN 10 DAYS OF FIRST USE. THE FIRM ACTING PRIMARILYTHROUGH AN INDIVIDUAL, REVIEWED AND APPROVED A REGISTEREDREPRESENTATIVE'S WRITTEN COMMUNICATIONS THAT WERE DEFICIENTBECAUSE THEY FAILED TO DISCLOSE ADEQUATELY MATERIAL FACTSREGARDING PRODUCTS OR INVESTMENT STRATEGIES RECOMMENDED.BY APPROVING THESE WRITTEN COMMUNICATIONS, WACHOVIA FAILEDTO REASONABLY SUPERVISE THE REGISTERED REPRESENTATIVE. THEFIRM'S WRITTEN SUPERVISORY PROCEDURES INCORRECTLY DEFINED "SALES LITERATURE" WHICH IS REQUIRED TO BE FILED WITH NASDWITHIN 10 DAYS OF FIRST USE. THE FIRM'S MANAGERIAL PERSONNELUSED THE WRITTEN SUPERVISORY PROCEDURES TO DETERMINEWHETHER A WRITTEN COMMUNICATION SHOULD BE FORWARDED TONASD. BY INCORRECTLY DEFINING "SALES LITERATURE," WACHOVIA'SWRITTEN SUPERVISORY PROCEDURES IMPROPERLY INSTRUCTED THEFIRM'S MANAGERIAL PERSONNEL ON WHEN WRITTEN COMMUNICATIONQUALIFIED AS SALES LITERATURE THAT NEEDED TO BE FILED WITH NASD.

Resolution Date: 04/13/2005

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WACHOVIASECURITIES, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TOTHE ENTRY OF FINDINGS THEREFORE, THE FIRM IS CENSURED ANDFINED $25,000.

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

No

Sanctions Ordered: CensureMonetary/Fine $25,000.00

Acceptance, Waiver & Consent(AWC)

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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WACHOVIASECURITIES, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TOTHE ENTRY OF FINDINGS THEREFORE, THE FIRM IS CENSURED ANDFINED $25,000.

iReporting Source: Firm

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

FINE OF $25,000

Date Initiated: 04/13/2005

Docket/Case Number: AWC CE2050007

Principal Product Type: No Product

Other Product Type(s):

Allegations: DURING THE PERIOD OF MAY 25, 2001 THROUGH APRIL 12, 2002,WACHOVIA WAS ALLEGED TO HAVE VIOLATED CONDUCT RULES 2110 AND2210(C)(1)IN FAILING TO FILE SALES LITERATURE WITH THE NASD,ALLEGED TO HAVE VIOLATED RULE 2110 AND 3010(A)(1) IN FAILING TORESONABLY SUPERVISE THE WRITTEN COMMUNICATION OF AREGISTERED REPRESENTATIVE, AND ALLEGED TO HAVE VIOLATED RULE2110 AND 3010(B)(1)IN FAILING TO ESTABLISH, MAINTAIN AND ENFORCEWRITTEN PROCEDURES ON COMMUNICATIONS TO THE PUBLIC.

Current Status: Final

Resolution Date: 04/13/2005

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WACHOVIACONSENTED TO A CENSURE AND FINE OF $25,000. THE FINE WAS PAID ONAPRIL 29, 2005.

Sanctions Ordered: CensureMonetary/Fine $25,000.00

Acceptance, Waiver & Consent(AWC)

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Reporting Source: Regulator

Allegations: AGENT MISAPPROPRIATES CLIENT FUNDS AND WACHOVIA'S FAILURE TOSUPERVISE ITS AGENTS AND TO ENFORCE WRITTEN PROCEDURES

Current Status: Final

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Initiated By: CALIFORNIA DEPARTMENT OF CORPORATIONS.

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

ADMINISTRATIVE ACTION INIATED ON 11/10/04.

Date Initiated: 11/10/2004

Docket/Case Number:

URL for Regulatory Action:

Principal Product Type: Other

Other Product Type(s):

Allegations: AGENT MISAPPROPRIATES CLIENT FUNDS AND WACHOVIA'S FAILURE TOSUPERVISE ITS AGENTS AND TO ENFORCE WRITTEN PROCEDURES

Resolution Date: 11/10/2004

Resolution:

Other Sanctions Ordered:

Sanction Details: NO PART OF PENALTIES WAIVED.

Regulator Statement WACHOVIA STIPULATED TO THE ISSUANCE OF AN ADMINISTRATIVECONSENT ORDER BY THE CALIFORNIA CORPORATIONS COMMISSIONERPER WHICH WACHOVIA WAS ORDERED TO DISCONTINUE THE FOLLOWINGVIOLATIONS: CALIFORNIA CORPORATIONS CODE SECTIONS 25210(B) & (A),AND 25218, AND CALIFORNIA CODE OF REGULATIONS, TITLE 10, SECTIONS260.218 AND 260.218(A) & (C)(2) AND (3). WACHOVIA ALSO AGREED TOMAKE CERTAIN REVISIONS OF ITS AGENT HIRING POLICIES ANDPROCEDURES, AND ITS CLIENT TRANSACTION CONFIRMATIONPROCEDURES, AND TO PAY THE COMMISSIONER A CIVIL PENALTY IN THEAMOUNT OF $250,000, WHICH AMOUNT WAS TIMELY PAID IN FULL. THEADMINISTRATIVE ACTION WAS THE RESULT OF A STIPULATION WHEREBYTHE COMMISSIONER AGREED TO DISMISS A CIVIL COMPLAINT IT HADFILED AGAINST WACHOVIA, JAMES A. MEHALL AND TODD MICHAEL LONGON 9/30/03, REGARDING LONG'S UNAUTHORIZED DISBURSEMENT OFCLIENT FUNDS AND WACHOVIA'S ALLEGED FAILURE TO SUPERVISELONG'S ACTIVITIES.

Sanctions Ordered: Monetary/Fine $250,000.00

Stipulation and Consent

iReporting Source: Firm

Current Status: Final

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Initiated By: STATE OF CALIFORNIA, DEPARTMENT OF CORPORATIONS

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 09/30/2003

Docket/Case Number:

Principal Product Type: No Product

Other Product Type(s):

Allegations: THE FIRM WAS ALLEGED TO HAVE VIOLATED CORPORATIONS CODESECTION 25210(B), 25218, CODE OF REGULATIONS SECTION 260.210(A),260.218, 260.218.4(A), 260.218.4(C)IN THE EMPLOYING OF AN AGENTWITHOUT INVESTIGATING THE EXPERIENCE AND BACKGROUND OF THEINDIVIDUAL, FAILING TO ENFORCE WRITTEN PROCEDURES AND FAILINGTO SUPERVISE THE AGENT.

Resolution Date: 11/12/2004

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM AGREEDTO A PENALTY OF $250,000 PAID ON DECEMBER 20, 2004. THE FIRM ALSOREVISED AND ADOPTED ENHANCED HIRING POLICIES AND REVISED ANDADOPTED ENHANCED POLICIES AND PROCEDURES SURROUNDING WIRETRANSFERS AND JOURNALING OF MONIES OR SECURITIES.

Sanctions Ordered: Monetary/Fine $250,000.00

Order

Disclosure 129 of 158

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Reporting Source: Regulator

Allegations: ARTICLE V, SECTIONS 2(C) AND 3(B) OF NASD'S BY-LAWS, NASD RULES2110, 3010 - WACHOVIA SECURITIES, LLC FILED AT LEAST 610 LATEAMENDMENTS TO FORMS U4 AND U5, REPRESENTING APPROXIMATELY32% 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.

Current Status: Final

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Initiated By: NASD

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 11/30/2004

Docket/Case Number: CAF040089

Principal Product Type: No Product

Other Product Type(s):

Resolution Date: 11/30/2004

Resolution:

Other Sanctions Ordered: PROHIBITION; UNDERTAKINGS

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WACHOVIASECURITIES, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TOTHE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED, FINED$650,000 WHICH SHALL BE PAID WITHIN 10 DAYS OF NOTICE OFACCEPTANCE OF THIS AWC. THE FIRM IS ALSO PROHIBITED FROMREGISTERING ANY ASSOCIATED PERSONS, IN A NON-SUPERVISORYSALES CAPACITY FOR FIVE CONSECUTIVE BUSINESS DAYS. PROMPTLYFOLLOWING NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM'SINTERNAL AUDIT DEPT. OR PERSONNEL NOT DIRECTLY RESPONSIBLE FORTHE FIRM'S ARTICLE V REPORTING OBLIGATIONS AND THEIR IMMEDIATESUPERVISORS SHALL CONDUCT AN AUDIT FOR THE PERIOD JANUARY 1,2004 THROUGH SEPTEMBER 30, 2004 TO ASSESS THE EFFECTIVENESS OFITS SYSTEM AND PROCEDURES FOR ENSURING TIMELY FILING OF FORMU4 AND U5 AMENDMENTS AND SHALL PREPARE A WRITTEN REPORTSUMMARIZING FINDINGS AND RECOMMENDATIONS AND SHALL FOR THENEXT FOUR CALENDAR QUARTERS BEGINNING FOURTH QUARTER 2004,CONDUCT A SIMILAR AUDIT AND PREPARE A SIMILAR WRITTEN AUDITREPORT. NO LATER THAN 90 DAYS AFTER NOTICE OF ACCEPTANCE OFTHIS AWC, AN OFFICER OF THE FIRM SHALL CERTIFY IN WRITING TO NASDTHAT AN AUDIT WAS CONDUCTED AND THE OFFICER HAS REVIEWED THECURRENT AUDIT REPORT. NO LATER THAN 60 DAYS AFTER THE DATE OFTHE REPORT, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THEFIRM HAS IMPLEMENTED, OR HAS BEGUN TO IMPLEMENT, ANYRECOMMENDATIONS WITHIN A SPECIFIED TIME PERIOD. NO LATER THAN60 DAYS AFTER THE LAST DAY OF THE NEXT FOUR QUARTERS, ANOFFICER SHALL CERTIFY IN WRITING TO NASD THAT AN AUDIT WASCONDUCTED, THE CURRENT AUDIT REPORT WAS REVIEWED, ANDRECOMMENDATIONS IMPLEMENTED, OR BEGUN TO BE IMPLEMENTED. NOLATER THAN SIX MONTHS AFTER NOTICE OF ACCEPTANCE OF THIS AWC,AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HASREVIEWED ITS SYSTEM AND PROCEDURES FOR COMPLYING WITH ITSARTICLE V REPORTING OBLIGATIONS AND HAS ESTABLISHED A SYSTEMAND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITH REPORTING REQUIREMENTS.

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

No

Sanctions Ordered: CensureMonetary/Fine $650,000.00

Acceptance, Waiver & Consent(AWC)

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WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WACHOVIASECURITIES, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TOTHE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED, FINED$650,000 WHICH SHALL BE PAID WITHIN 10 DAYS OF NOTICE OFACCEPTANCE OF THIS AWC. THE FIRM IS ALSO PROHIBITED FROMREGISTERING ANY ASSOCIATED PERSONS, IN A NON-SUPERVISORYSALES CAPACITY FOR FIVE CONSECUTIVE BUSINESS DAYS. PROMPTLYFOLLOWING NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM'SINTERNAL AUDIT DEPT. OR PERSONNEL NOT DIRECTLY RESPONSIBLE FORTHE FIRM'S ARTICLE V REPORTING OBLIGATIONS AND THEIR IMMEDIATESUPERVISORS SHALL CONDUCT AN AUDIT FOR THE PERIOD JANUARY 1,2004 THROUGH SEPTEMBER 30, 2004 TO ASSESS THE EFFECTIVENESS OFITS SYSTEM AND PROCEDURES FOR ENSURING TIMELY FILING OF FORMU4 AND U5 AMENDMENTS AND SHALL PREPARE A WRITTEN REPORTSUMMARIZING FINDINGS AND RECOMMENDATIONS AND SHALL FOR THENEXT FOUR CALENDAR QUARTERS BEGINNING FOURTH QUARTER 2004,CONDUCT A SIMILAR AUDIT AND PREPARE A SIMILAR WRITTEN AUDITREPORT. NO LATER THAN 90 DAYS AFTER NOTICE OF ACCEPTANCE OFTHIS AWC, AN OFFICER OF THE FIRM SHALL CERTIFY IN WRITING TO NASDTHAT AN AUDIT WAS CONDUCTED AND THE OFFICER HAS REVIEWED THECURRENT AUDIT REPORT. NO LATER THAN 60 DAYS AFTER THE DATE OFTHE REPORT, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THEFIRM HAS IMPLEMENTED, OR HAS BEGUN TO IMPLEMENT, ANYRECOMMENDATIONS WITHIN A SPECIFIED TIME PERIOD. NO LATER THAN60 DAYS AFTER THE LAST DAY OF THE NEXT FOUR QUARTERS, ANOFFICER SHALL CERTIFY IN WRITING TO NASD THAT AN AUDIT WASCONDUCTED, THE CURRENT AUDIT REPORT WAS REVIEWED, ANDRECOMMENDATIONS IMPLEMENTED, OR BEGUN TO BE IMPLEMENTED. NOLATER THAN SIX MONTHS AFTER NOTICE OF ACCEPTANCE OF THIS AWC,AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HASREVIEWED ITS SYSTEM AND PROCEDURES FOR COMPLYING WITH ITSARTICLE V REPORTING OBLIGATIONS AND HAS ESTABLISHED A SYSTEMAND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITH REPORTING REQUIREMENTS.

Regulator Statement THE FIRM CANNOT REGISTER ANY ASSOCIATED PERSONS, IN A NON-SUPERVISORY SALES CAPACITY EFFECTIVE JANUARY 24, 2005 TO CLOSEOF BUSINESS JANUARY 28, 2005.

iReporting Source: Firm

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

Date Initiated: 11/30/2004

Docket/Case Number: AWC NO. CAF040089

Principal Product Type: No Product

Other Product Type(s):

Allegations: THE FIRM WAS ALLEGED TO HAVE FAILED TO FILE FORM U4 AND U5AMENDMENTS IN A TIMELY MANNER FROM JANUARY, 2002 TO MARCH,2004.

Current Status: Final

Resolution Date: 11/30/2004

Resolution:

Sanctions Ordered: CensureMonetary/Fine $650,000.00

Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered: THE FIRM IS PROHIBITED IN REGISTERING ANY ASSOCIATED PERSON, IN ANONSUPERVISORY SALES CAPACITY, FOR 5 CONSECUTIVE BUSINESSDAYS.

Sanction Details: THE FIRM WAS FINED IN THE TOTAL AMOUNT OF $650,000 WHICH WASPAID ON NOVEMBER 16, 2004. THE FIRM IS PROHIBITED IN REGISTERINGANY ASSOCIATED PERSON, IN A NONSUPERVISORY SALES CAPACITY, FOR5 CONSECUTIVE BUSINESS DAYS BEGINNING ON JANUARY 24, 2005 ANDENDING ON JANUARY 28, 2005. THE FIRM'S INTERNAL AUDIT DEPARTMENTIS REQUIRED TO AUDIT U4 AND U5 AMENDMENTS FILED BETWEENJANUARY 1, 2004 AND SEPTEMBER 30, 2004 SUMMARIZING THEIRFINDINGS AND RECOMMENDATIONS WITH AN OFFICER. FURTHER, ANOFFICER SHALL CERTIFY THE FIRM HAS REVIEWED ITS SYSTEM ANDPROCEDURES AND HAVE ESTABLISHED A SYSTEM AND PROCEDURES TOCOMPLY WITH ARTICLE V REPORTING OBLIGATIONS.

Sanctions Ordered: CensureMonetary/Fine $650,000.00

Disclosure 130 of 158

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Reporting Source: Firm

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

RELIEF SOUGHT

Date Initiated: 01/13/1998

Docket/Case Number: C0970033

Principal Product Type: Other

Other Product Type(s):

Allegations: N/A

Current Status: Final

Resolution Date: 01/13/1998

Resolution:

Other Sanctions Ordered:

Sanction Details: RESULTED IN A MONETARY FINE OF $250.00.

Firm Statement ON JANUARY 13, 1998 DISTRICT NO. 5 NOTIFIED RESPONDENT,SOUTHTRUST SECURITIES,INC. (CRD 17322-MERGED INTO WACHOVIASECURITIES, LLC), THAT THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT NO. C05970033 WAS ACCEPTED; THEREFORE THE FIRM WASFINED $250 - MSRB RULE G-36 RESPONDENT MEMBER FAILED TO FILE TOTHE MSRB A FORM G-36 IN A TIMELY MANNER AND FILED INACCURATEFORMS G-36 TO THE MSRB ***$250.00 PAID ON 2/9/98, INVOICE NO. 98-05-129***

Sanctions Ordered: Monetary/Fine $250.00

Acceptance, Waiver & Consent(AWC)

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Firm Statement ON JANUARY 13, 1998 DISTRICT NO. 5 NOTIFIED RESPONDENT,SOUTHTRUST SECURITIES,INC. (CRD 17322-MERGED INTO WACHOVIASECURITIES, LLC), THAT THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT NO. C05970033 WAS ACCEPTED; THEREFORE THE FIRM WASFINED $250 - MSRB RULE G-36 RESPONDENT MEMBER FAILED TO FILE TOTHE MSRB A FORM G-36 IN A TIMELY MANNER AND FILED INACCURATEFORMS G-36 TO THE MSRB ***$250.00 PAID ON 2/9/98, INVOICE NO. 98-05-129***

Disclosure 131 of 158

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Reporting Source: Firm

Initiated By: STATE OF FLORIDA, DEPARTMENT OF BANKING AND FINANCE

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

CEASE AND DESIST

Date Initiated: 05/11/2000

Docket/Case Number: 2970-S-6/00

Principal Product Type: No Product

Other Product Type(s):

Allegations: SOUTHTRUST SECURITIES, INC. (CRD# 17922 - MERGED INTO WACHOVIASECURITIES, LLC) FAILED TO EFFECT RENEWAL OF 7 EXISTINGREGISTERED OFFICES WITH THE STATE OF FLORIDA.

Current Status: Final

Resolution Date: 07/20/2000

Resolution:

Other Sanctions Ordered:

Sanction Details: PAID FINE ON 7/10/2000.

Firm Statement FINAL ORDER WAS ACCEPTED ON 7/20/2000 BY THE STATE OF FLORIDA;ALL SUBJECT OFFICES WERE PROMPTLY APPROVED BY THE STATE.

Sanctions Ordered: Monetary/Fine $5,000.00Cease and Desist/Injunction

Stipulation and Consent

Disclosure 132 of 158

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Reporting Source: Firm

Initiated By: U.S. SECURITIES AND EXCHANGE COMMISSION

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

CIVIL AND ADMINISTRATIVE PENALTY/FINE

Date Initiated: 01/16/1992

Docket/Case Number: NONE

Principal Product Type: Debt - Government

Other Product Type(s):

Allegations: VIOLATED APPLICABLE BOOKS AND RECORDS REQUIREMENTS INCONNECTION WITH CERTAIN PRIMARY DISTRIBUTIONS OF DEBTSECURITIES OF ONE OR MORE OF THE FOLLOWING GOVERNMENTSPONSORED ENTITIES: FHLB, FFCBFC FNMA, FHLMC, AND STUDENTLOAN MARKETING ASSOCIATION. SPEDIFICALLY VIOLATED RULES 17(A),17(A)(3), AND 17(A)(4) OF THE SECURITIES EXCHANGE ACT OF 1934.

Current Status: Final

Resolution Date: 01/16/1992

Resolution:

Other Sanctions Ordered: SOUTHTRUST SECURITIES, INC. (CRD# 17922 - MERGED INTO WACHOVIASECURITIES, LLC) WAS ORDERED TO CEASE AND DESIST FROMCOMMITTING OR CAUSING ANY VIOLATION OR FUTURE VIOLATION OFSAID RULES, AND SSI WAS REQUIRED TO DEVELOP,IMPLEMENT, ANDMAINTAIN POLICIES AND PROCEDURES TO ENSURE FUTURECOMPLIANCE.

Sanction Details: SOUTHTRUST SECURITIES, INC. (CRD# 17922 - MERGED INTO WACHOVIASECURITIES, LLC) WAS ORDERED TO PAY A $10,000 CIVIL MONETARYPENALTY, PAID IN FULL ON 01/16/1992.

Firm Statement SEC INSTITUTED PROCEEDINGS AGAINST SOUTHTRUST SECURITIES, INC.(CRD# 17922 - MERGED INTO WACHOVIA SECURITIES, LLC) AND AT LEAST97 OTHER FIRMS, EACH OF WHICH WAS A BROKER AND/OR DEALER.

Sanctions Ordered: Monetary/Fine $10,000.00

Settled

Disclosure 133 of 158

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Reporting Source: Firm

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Initiated By: STATE OF MAINE, OFFICE OF SECURITIES

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Date Initiated: 09/16/2004

Docket/Case Number: 04-063-CAG

Principal Product Type: No Product

Other Product Type(s):

Allegations: THE FIRM INADVERTENTLY FAILED TO RENEW SALES REPRESENTATIVE,LARRY M MALLES, LICENSE BY DECEMBER 31, 2003 WHICH RESULTED INMR MALLES TRANSACTING BUSINESS UNLICENSED FROM JANUARY 6,2004 THROUGH JANUARY 8, 2004.

Current Status: Final

Resolution Date: 09/16/2004

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING VIOLATION OF THE REVISED MAINESECURITIES ACT, THE FIRM AGREED TO A PENALTY OF $1500 AND WOULDCOMPLY WITH ALL LICENSING AND OTHER LEGAL REQUIREMENTS FORPERSONS ACTING IN A SECURITIES SALES REPRESENTATIVE CAPACITY.

Sanctions Ordered: Monetary/Fine $1,500.00

Consent

Disclosure 134 of 158

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Reporting Source: Regulator

Allegations: MSRB RULES G-17, G-30(A) - WACHOVIA SECURITIES, LLC RECEIVEDREQUESTS FROM PUBLIC CUSTOMERS TO LIQUIDATE EIGHT DIFFERENTMUNICIPAL SECURITY POSITIONS AND CONTACTED A BROKER'S BROKERAND OBTAINED BIDS FOR THE CUSTOMERS' SECURITIES. BASED ON THEBIDS PROVIDED BY THE BROKER'S BROKER, WACHOVIA PURCHASED THESECURITIES FROM THE CUSTOMERS FOR ITS OWN ACCOUNT AND SOLDTHE SECURITIES TO THE BROKER'S BROKER AT A NOMINAL GAIN. IN ALLEIGHT INSTANCES, THE PRICES PAID TO THE CUSTOMERS AND RECEIVEDBY THE FIRM WERE BELOW THE FAIR MARKET VALUE FOR THE SECURITYIN AMOUNTS RANGING FROM 10.94% TO 63.45%. BY RELYING SOLELY ONTHE BIDS PROVIDED BY THE BROKER'S BROKER TO DETERMINE THE FAIRMARKET VALUE OF THE SECURITY, WACHOVIA FAILED TO ENSURE THATTHE TRANSACTIONS WERE EXECUTED AT AGGREGATE PRICES THATWERE FAIR AND REASONABLE.

Current Status: Final

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Initiated By: NASD

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 06/28/2004

Docket/Case Number: C05040043

Principal Product Type: Debt - Municipal

Other Product Type(s):

MSRB RULES G-17, G-30(A) - WACHOVIA SECURITIES, LLC RECEIVEDREQUESTS FROM PUBLIC CUSTOMERS TO LIQUIDATE EIGHT DIFFERENTMUNICIPAL SECURITY POSITIONS AND CONTACTED A BROKER'S BROKERAND OBTAINED BIDS FOR THE CUSTOMERS' SECURITIES. BASED ON THEBIDS PROVIDED BY THE BROKER'S BROKER, WACHOVIA PURCHASED THESECURITIES FROM THE CUSTOMERS FOR ITS OWN ACCOUNT AND SOLDTHE SECURITIES TO THE BROKER'S BROKER AT A NOMINAL GAIN. IN ALLEIGHT INSTANCES, THE PRICES PAID TO THE CUSTOMERS AND RECEIVEDBY THE FIRM WERE BELOW THE FAIR MARKET VALUE FOR THE SECURITYIN AMOUNTS RANGING FROM 10.94% TO 63.45%. BY RELYING SOLELY ONTHE BIDS PROVIDED BY THE BROKER'S BROKER TO DETERMINE THE FAIRMARKET VALUE OF THE SECURITY, WACHOVIA FAILED TO ENSURE THATTHE TRANSACTIONS WERE EXECUTED AT AGGREGATE PRICES THATWERE FAIR AND REASONABLE.

Resolution Date: 06/28/2004

Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WACHOVIASECURITIES, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TOTHE ENTRY OF FINDINGS; THEREFORE, THE FIRM WAS CENSURED, FINED$20,000, AND REQUIRED TO PAY $19,486.25, PLUS INTEREST, INRESTITUTION TO THE CUSTOMER. SATISFACTORY PROOF OF PAYMENT OFTHE RESTITUTION SHALL BE PROVIDED TO NASD NO LATER THAN 90 DAYSAFTER ACCEPTANCE OF THE AWC. THE FIRM SHALL ALSO PROVIDE NASD,WITHIN 90 DAYS OF ACCEPTANCE OF THIS AWC, A COPY OF ITS UPDATEDWRITTEN SUPERVISORY PROCEDURES AS THEY RELATE TO THEDETERMINATION OF THE FAIR MARKET VALUE OF MUNICIPAL SECURITIESBEING BOUGHT OR SOLD FROM A PUBLIC CUSTOMER.

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

No

Sanctions Ordered: CensureMonetary/Fine $20,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

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iReporting Source: Firm

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

RESTITUTION OF $19,486.25

Date Initiated: 06/28/2004

Docket/Case Number: C05040043

Principal Product Type: Debt - Municipal

Other Product Type(s):

Allegations: THE FIRM WAS ALLEGED TO HAVE FAILED TO EXECUTE EIGHT MUNICIPALSECURITY POSITIONS AT PRICES THAT WERE FAIR AND REASONABLE,DURING THE PERIOD FROM ON OR ABOUT AUGUST 22, 2002 THROUGHDECEMBER 10, 2002 IN VIOLATION OF MSRB RULES G-17 AND G-30(A).

Current Status: Final

Resolution Date: 06/28/2004

Resolution:

Other Sanctions Ordered: CUSTOMER RESTITUTION OF $19,486.25 AND WITHIN 90 DAYS OFACCEPTANCE OF AWC THE FIRM SHALL PROVIDE THE NASD WITH A COPYOF ITS UPDATED WRITTEN SUPERVISORY PROCEDURES AS IT RELATESTO DETERMINING FAIR MARKET VALUE OF MUNICIPAL SECURITIES.

Sanction Details: THE FIRM WAS CENSURED, FINED $20,000 AND PAYMENT OF RESTITUTIONTO CLIENTS OF $19,486.25. WITHIN 90 DAYS OF ACCEPTANCE OF AWC THEFIRM SHALL PROVIDE THE NASD WITH A COPY OF ITS UPDATED WRITTENSUPERVISORY PROCEDURES AS IT RELATES TO DETERMINING FAIRMARKET VALUE OF MUNICIPAL SECURITIES.

Sanctions Ordered: CensureMonetary/Fine $20,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

Disclosure 135 of 158

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Reporting Source: Regulator

Allegations: **05/26/2004** STIPULATION AND CONSENT TO PENALTY FILED BY THEDIVISION OF ENFORCEMENT AND PENDING. A. CONSENTED TO FINDINGSTHAT THE FIRM: 1. VIOLATED EXCHANGE RULE 345A AND 345(A) BY: A)PERMITTING EMPLOYEES TO ACT IN A REGISTERED CAPACITY ANDGENERATE COMMISSIONS WHILE THEIR REGISTRATION STATUS WASINACTIVE; AND B) PERMITTING A RETAIL COMPLIANCE MANAGER TOSUPERVISE TEN OR MORE INDIVIDUALS WHO ACTED IN A COMPLIANCECAPACITY EVEN THOUGH THE MANAGER DID NOT POSSESS THEREQUIRED QUALIFICATION. 2. VIOLATED EXCHANGE RULE 345 AND 351 BY:A) FAILING TO REPORT AND/OR PROMPTLY AND ACCURATELY REPORT,CUSTOMER COMPLAINTS AS REQUIRED; AND B) FAILING TO FILE AND/ORPROMPTLY FILE, FORMS U-5 AND A FORM RE-3 WITH THE EXCHANGE. 3.VIOLATED EXCHANGE RULE 440 AND SEC RULES 240.17A-3 AND 17A-4 BYFAILING TO MAINTAIN ACCURATE BOOKS AND RECORDS INCONNECTION WITH THE REPORTING OF CUSTOMERS’COMPLAINTS AND FILING OF FORMS U-5 AND A FORM RE-3. 4. VIOLATEDEXCHANGE RULE 405 BY FAILING TO ENSURE THAT CUSTOMERSRECEIVED MUTUAL FUND SWITCH LETTERS DISCLOSING SPECIFIC FEESINCURRED BY CUSTOMERS. 5. VIOLATED EXCHANGE RULES 342 AND 472IN THAT THE FIRM FAILED TO REASONABLY SUPERVISE AND CONTROLAND PROVIDE APPROPRIATE PROCEDURES OF SUPERVISION ANDCONTROL AND ESTABLISH A SYSTEM OF FOLLOW–UP AND REVIEWWITH RESPECT TO: A) ASSURING COMPLIANCE WITH EXCHANGE RULESREGARDING CONTINUING EDUCATION AND REGISTRATIONREQUIREMENTS; **CONTINUED IN #14**

Current Status: Final

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Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 05/26/2004

Docket/Case Number: HPD# 04-115

Principal Product Type: Other

Other Product Type(s):

Allegations: **05/26/2004** STIPULATION AND CONSENT TO PENALTY FILED BY THEDIVISION OF ENFORCEMENT AND PENDING. A. CONSENTED TO FINDINGSTHAT THE FIRM: 1. VIOLATED EXCHANGE RULE 345A AND 345(A) BY: A)PERMITTING EMPLOYEES TO ACT IN A REGISTERED CAPACITY ANDGENERATE COMMISSIONS WHILE THEIR REGISTRATION STATUS WASINACTIVE; AND B) PERMITTING A RETAIL COMPLIANCE MANAGER TOSUPERVISE TEN OR MORE INDIVIDUALS WHO ACTED IN A COMPLIANCECAPACITY EVEN THOUGH THE MANAGER DID NOT POSSESS THEREQUIRED QUALIFICATION. 2. VIOLATED EXCHANGE RULE 345 AND 351 BY:A) FAILING TO REPORT AND/OR PROMPTLY AND ACCURATELY REPORT,CUSTOMER COMPLAINTS AS REQUIRED; AND B) FAILING TO FILE AND/ORPROMPTLY FILE, FORMS U-5 AND A FORM RE-3 WITH THE EXCHANGE. 3.VIOLATED EXCHANGE RULE 440 AND SEC RULES 240.17A-3 AND 17A-4 BYFAILING TO MAINTAIN ACCURATE BOOKS AND RECORDS INCONNECTION WITH THE REPORTING OF CUSTOMERS’COMPLAINTS AND FILING OF FORMS U-5 AND A FORM RE-3. 4. VIOLATEDEXCHANGE RULE 405 BY FAILING TO ENSURE THAT CUSTOMERSRECEIVED MUTUAL FUND SWITCH LETTERS DISCLOSING SPECIFIC FEESINCURRED BY CUSTOMERS. 5. VIOLATED EXCHANGE RULES 342 AND 472IN THAT THE FIRM FAILED TO REASONABLY SUPERVISE AND CONTROLAND PROVIDE APPROPRIATE PROCEDURES OF SUPERVISION ANDCONTROL AND ESTABLISH A SYSTEM OF FOLLOW–UP AND REVIEWWITH RESPECT TO: A) ASSURING COMPLIANCE WITH EXCHANGE RULESREGARDING CONTINUING EDUCATION AND REGISTRATIONREQUIREMENTS; **CONTINUED IN #14**

Resolution Date: 08/13/2004

Resolution:

Other Sanctions Ordered:

Sanctions Ordered: CensureMonetary/Fine $250,000.00

Decision

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Sanction Details: **07/08/2004** #04-115 ISSUED BY THE NYSE HEARING PANELDECISION: VIOLATED EXCHANGE RULE 345A AND 345(A) BY PERMITTINGEMPLOYEES TO ACT IN A REGISTERED CAPACITY WHILE REGISTRATIONSTATUS WAS INACTIVE AND BY PERMITTING A MANAGER TO SUPERVISEINDIVIDUALS IN A COMPLIANCE CAPACITY WITHOUT THE REQUIREDQUALIFICATION; VIOLATED EXCHANGE RULES 345 AND 351 AND 440 ANDSEC RULES 240.17A-3 AND 17A-4 BY FAILING TO PROMPTLY ANDACCURATELY REPORT CUSTOMER COMPLAINTS AND FAILING TOPROMPTLY FILE FORMS U-5 AND A FORM RE-3; VIOLATED EXCHANGERULE 405 BY FAILING TO ENSURE THAT CUSTOMERS RECEIVED MUTUALFUND SWITCH LETTERS DISCLOSING SPECIFIC FEES; VIOLATEDEXCHANGE RULES 342 AND 472 BY FAILING TO REASONABLY SUPERVISEWITH RESPECT TO CONTINUING EDUCATION AND REGISTRATIONREQUIREMENTS, PROMPT REPORTING OF CUSTOMER COMPLAINTS ANDFILING OF FORMS U-5 AND A FORM RE-3, ASSURING APPROPRIATEREVIEW OF CERTAIN DISCRETIONARY ACCOUNTS, MONITORINGCUSTOMER ACCOUNTS TO ENSURE THAT CUSTOMERS RECEIVED BETTEREXECUTION PRICES THAN REGISTERED REPRESENTATIVES; ANDENSURING THAT RESEARCH REPORTS CONTAINED CLEAR, POSITIVELANGUAGE IN SECURITIES IN WHICH THE FIRM WAS MAKING A MARKET– CONSENT TO CENSURE AND $250,000 FINE

Regulator Statement B) ASSURING COMPLIANCE WITH EXCHANGE RULES TO PROMPTLY ANDACCURATELY REPORT CUSTOMER COMPLAINTS AND FILE FORMS U-5 ANDA FORM RE-3; ASSURING THAT CERTAIN DISCRETIONARY ACCOUNTSWERE RECEIVING THE APPROPRIATE SUPERVISORY REVIEW;D) MONITORING CUSTOMER ACCOUNTS TO ENSURE THAT CUSTOMERSRECEIVED BETTER EXECUTION PRICES THAN REGISTEREDREPRESENTATIVES; AND E) ENSURING THAT RESEARCH REPORTSCONTAINED CLEAR, POSITIVE LANGUAGE IN SECURITIES IN WHICH THEFIRM WAS MAKING A MARKET. B. THE IMPOSITION BY THE EXCHANGE OFTHE PENALTY OF: 1. A CENSURE; AND 2. A FINE OF $250,000. **8/13/04**THEDECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY.CONTACT: MICHELEVAN TASSEL (212) 656-5340.

iReporting Source: Firm

Initiated By: NEW YORK STOCK EXCHANGE, INC.

Allegations: AS A RESULT OF ITS EXAM OF FIRST UNION IN 2000 AND 2001, THE NYSEFOUND REGISTRATION ISSUES, CUSTOMER COMPLAINT REPORTINGDEFICIENCIES, REVIEW OF DISCRETIONARY ACCOUNTS SHORTCOMINGS,INSUFFICENT DISCLOSURE IN MUTUAL FUND SWITCH LETTERS AND LACKOF CLEAR LANGUAGE IN RESEARCH REPORTS.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

FINE OF $250,000

Date Initiated: 07/08/2004

Docket/Case Number: HPD# 04-115

Principal Product Type: No Product

Other Product Type(s):

Resolution Date: 08/13/2004

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING THE ALLEGATIONS, THE FIRM AGREED TO THEENTRY OF A CONSENT ORDER, THE TERMS OF WHICH WERE A CENSUREAND A FINE OF $250,000. PAYMENT OF THE FINE WAS MADE ON AUGUST25, 2004.

Sanctions Ordered: CensureMonetary/Fine $250,000.00

Consent

Disclosure 136 of 158

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Reporting Source: Regulator

Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Date Initiated: 02/12/2004

Docket/Case Number: 3-11410

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE NOS. 33-8380 AND 34-49229,DATED FEBRUARY 12, 2004: THE SECURITIES AND EXCHANGECOMMISSION ("COMMISSION" OR "SEC") DEEMS IT APPROPRIATE AND INTHE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT") ANDSECTIONS 15(B)(4) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934("EXCHANGE ACT") AGAINST WACHOVIA SECURITIES, LLC, F/K/AWACHOVIA SECURITIES, INC. ("RESPONDENT").

Current Status: Final

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Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

CENSURE; FINE; AND DISGORGEMENT, PLUS PREJUDGMENT INTEREST.

Other Product Type(s):

Resolution Date: 02/12/2004

Resolution:

Other Sanctions Ordered:

Sanction Details: IT IS ORDERED: A. PURSUANT TO SECTION 15(B)(4) OF THE EXCHANGEACT, THAT RESPONDENT IS CENSURED; B. PURSUANT TO SECTION 8A OFTHE SECURITIES ACT AND SECTION 21C OF THE EXCHANGE ACT, THATRESPONDENT SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION17(A)(2) OF THE SECURITIES ACT, AND RULE 10B-10 UNDER THEEXCHANGE ACT; C. WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER,RESPONDENT SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF$2,422,232 TO THE UNITED STATES TREASURY; D. RESPONDENT SHALLPAY DISGORGEMENT AND PREJUDGMENT INTEREST; AND E. NOT LATERTHAN 6 MONTHS AFTER THE DATE OF THIS ORDER, UNLESS OTHERWISEEXTENDED BY THE COMMISSION FOR GOOD CAUSE SHOWN,RESPONDENT'S CHIEF EXECUTIVE OFFICER SHALL CERTIFY IN WRITINGTO THE COMMISSION THAT RESPONDENT HAS IMPLEMENTEDPROCEDURES, AND A SYSTEM FOR APPLYING SUCH PROCEDURES, THATCAN REASONABLY BE EXPECTED TO PREVENT AND DETECT FAILURES BYRESPONDENT TO PROVIDE APPROPRIATE BREAKPOINT DISCOUNTS FORWHICH CUSTOMERS ARE ELIGIBLE ON PURCHASES OF FRONT-END LOADMUTUAL FUNDS, BASED ON INFORMATION REASONABLY ASCERTAINABLEBY RESPONDENT.

Regulator Statement RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WITHOUTADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THECOMMISSION'S JURISDICTION, AND CONSENTED TO THE ENTRY OF THISORDER. THE SEC FINDS THAT: DURING 2001 AND 2002 (THE "RELEVANTPERIOD"), RESPONDENT SOLD SHARES ISSUED BY MUTUAL FUNDSWITHOUT PROVIDING CERTAIN CUSTOMERS WITH THE REDUCTIONS INFRONT-END LOADS, OR SALES CHARGES, ALSO KNOWN AS "BREAKPOINT"DISCOUNTS, DESCRIBED IN THE PROSPECTUSES OF THE FUNDS.ACCORDING TO DATA SUBMITTED TO NASD BY RESPONDENT,RESPONDENT IS ESTIMATED TO HAVE FAILED TO GIVE CERTAINCUSTOMERS BREAKPOINT DISCOUNTS TOTALING APPROXIMATELY$4,844,465 DURING THE RELEVANT PERIOD. BY FAILING TO DISCLOSE TOCERTAIN CUSTOMERS THAT THEY WERE NOT RECEIVING THE BENEFIT OFAPPLICABLE BREAKPOINT DISCOUNTS, RESPONDENT WILLFULLYVIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. FURTHER, BECAUSERESPONDENT DID NOT CHARGE THESE CUSTOMERS THE CORRECTSALES LOADS AS SET FORTH IN THE MUTUAL FUNDS' PROSPECTUSES,AND ALSO DID NOT DISCLOSE IN CONFIRMATIONS THE REMUNERATIONRESPONDENT RECEIVED FROM THE SALES LOADS CHARGED TO THESECUSTOMERS, RESPONDENT WILLFULLY VIOLATED RULE 10B-10 UNDERTHE EXCHANGE ACT.

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

No

Sanctions Ordered: CensureMonetary/Fine $2,422,232.00Disgorgement/RestitutionCease and Desist/Injunction

Order

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RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WITHOUTADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THECOMMISSION'S JURISDICTION, AND CONSENTED TO THE ENTRY OF THISORDER. THE SEC FINDS THAT: DURING 2001 AND 2002 (THE "RELEVANTPERIOD"), RESPONDENT SOLD SHARES ISSUED BY MUTUAL FUNDSWITHOUT PROVIDING CERTAIN CUSTOMERS WITH THE REDUCTIONS INFRONT-END LOADS, OR SALES CHARGES, ALSO KNOWN AS "BREAKPOINT"DISCOUNTS, DESCRIBED IN THE PROSPECTUSES OF THE FUNDS.ACCORDING TO DATA SUBMITTED TO NASD BY RESPONDENT,RESPONDENT IS ESTIMATED TO HAVE FAILED TO GIVE CERTAINCUSTOMERS BREAKPOINT DISCOUNTS TOTALING APPROXIMATELY$4,844,465 DURING THE RELEVANT PERIOD. BY FAILING TO DISCLOSE TOCERTAIN CUSTOMERS THAT THEY WERE NOT RECEIVING THE BENEFIT OFAPPLICABLE BREAKPOINT DISCOUNTS, RESPONDENT WILLFULLYVIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. FURTHER, BECAUSERESPONDENT DID NOT CHARGE THESE CUSTOMERS THE CORRECTSALES LOADS AS SET FORTH IN THE MUTUAL FUNDS' PROSPECTUSES,AND ALSO DID NOT DISCLOSE IN CONFIRMATIONS THE REMUNERATIONRESPONDENT RECEIVED FROM THE SALES LOADS CHARGED TO THESECUSTOMERS, RESPONDENT WILLFULLY VIOLATED RULE 10B-10 UNDERTHE EXCHANGE ACT.

iReporting Source: Firm

Initiated By: SECURITIES AND EXCHANGE COMMISSION

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

CENSURE, MONETARY FINE AND DISGORGEMENT, PLUS PREJUDGMENTINTEREST

Date Initiated: 02/12/2004

Docket/Case Number: 3-11410

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM WASALLEGED TO HAVE VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT INFAILING TO NOTIFY CUSTOMERS OF APPROPRIATE BREAKPOINTDISCOUNTS AND VIOLATED RULE 10B-10 UNDER THE EXCHANGE ACT INFAILING TO DISCLOSE THE REMUNERATION THE FIRM RECEIVED FROMFRONT END SALES LOADS.

Current Status: Final

Resolution Date: 02/12/2004

Resolution: Decision & Order of Offer of Settlement

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Resolution Date: 02/12/2004

Other Sanctions Ordered:

Sanction Details: THE TOTAL AMOUNT OF THE FINE WAS $4,844,465. $2,422,232 PAID TO THENASD ON 2/19/04 AND $2,422,232 PAID TO THE SEC ON 2/19/04.

Firm Statement THE FIRM AGREED TO AN OFFER OF SETTLEMENT WITHOUT ADMITTINGOR DENYING THE ALLEGATIONS. IN ADDITION TO THE CENSURE, CEASEAND DESIST ORDER, MONETARY FINE, THE FIRM HAS AGREED TOCERTAIN UNDERTAKINGS SET FORTH UNDER NASD AWC#CAF040008: (1) ATRADE BY TRADE REVIEW OF ALL FRONT END LOADED FUND SALESABOVE $2500 FROM JANUARY 1, 1999 THROUGH NOVEMBER 3, 2003 TOENSURE THAT CUSTOMERS RECEIVE THE APPROPRIATE SALESDISCOUNTS AND PROVIDE REFUNDS WHERE APPLICABLE, AND (2) WITHIN6 MONTHS OF THE DATE OF THE AWC, THE FIRM WILL CERTIFY TO THEREGULATORS THAT A SYSTEM IS IN PLACE REASONABLY DESIGNED TOMAKE CERTAIN CUSTOMERS GET APPROPRIATE BREAKPOINTDISCOUNTS.

Sanctions Ordered: CensureMonetary/Fine $2,422,232.00Disgorgement/RestitutionCease and Desist/Injunction

Disclosure 137 of 158

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Reporting Source: Regulator

Initiated By: NASD

Principal Sanction(s)/ReliefSought:

Date Initiated: 02/12/2004

Docket/Case Number: CAF040008

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations: NASD RULE 2110 - RESPONDENT MEMBER SOLD SHARES ISSUED BYMUTUAL FUNDS WITHOUT PROVIDING CERTAIN CUSTOMERS WITHBREAKPOINT DISCOUNTS DESCRIBED IN THE PROSPECTUSES OF THEFUNDS; FAILED TO GIVE ITS CUSTOMERS BREAKPOINT DISCOUNTS IN28.77% OF ELIGIBLE MUTUAL FUND TRANSACTIONS IN 2001 AND 2002 THATRESULTED IN MISSED BREAKPOINTS THAT WOULD HAVE REDUCEDCUSTOMERS' CHARGES BY AT LEAST $4.8 MILLION ON THEIR PURCHASESOF MUTUAL FUND SHARES WITH FRONT-END LOADS DURING THERELEVANT PERIOD.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Resolution Date: 02/12/2004

Resolution:

Other Sanctions Ordered: UNDERTAKINGS.

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $4,844,465, OFWHICH ONE HALF SHALL BE PAID TO NASD AND ONE HALF SHALL BE PAIDTO THE U.S. TREASURY PURSUANT TO RELATED SEC PROCEEDINGSBEING INSTITUTED AGAINST RESPONDENT ON THIS DATE, AND REQUIREDTO PROVIDE WRITTEN NOTIFICATION TO EACH CUSTOMER WHOPURCHASED FRONT-END LOAD MUTUAL FUNDS THROUGH THE FIRMFROM JANUARY 1, 1999 THROUGH NOVEMBER 3, 2003 THAT THE FIRMEXPERIENCED A PROBLEM DELIVERING BREAKPOINT DISCOUNTS ANDTHAT AS A RESULT, THE CUSTOMER MAY BE ENTITLED TO A REFUND;PERFORM A TRADE-BY-TRADE ANALYSIS OF ALL FRONT-END LOADMUTUAL FUND PURCHASES OF $2,500 OR MORE AND ALL OVERCHARGESIDENTIFIED REFUNDED BY MARCH 31, 2004; PROVIDE REFUNDS TO ALLCUSTOMERS WHO DID NOT RECEIVE ALL APPLICABLE BREAKPOINTDISCOUNTS AS DESCRIBED IN NTM 03-47; PROVIDE NASD A REPORT ONRESPONDENT'S REFUND PROGRAM BY 4/16/04; AND NOT LATER THAN SIXMONTHS AFTER THE DATE OF THIS ORDER, RESPONDENT'S CHIEFEXECUTIVE OFFICER SHALL CERTIFY IN WRITING TO NASD THATRESPONDENT HAS IMPLEMENTED PROCEDURES AND A SYSTEM FORAPPLYING SUCH PROCEDURES THAT CAN REASONABLY BE EXPECTED TOPREVENT AND DETECT FAILURES TO PROVIDE BREAKPOINT DISCOUNTSFOR WHICH CUSTOMERS ARE ELIGIBLE ON PURCHASES OF FRONT-ENDLOAD MUTUAL FUNDS.

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

No

Sanctions Ordered: CensureMonetary/Fine $2,422,232.50

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

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Initiated By: NASD

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

MONETARY FINE AND UNDERTAKINGS

Date Initiated: 02/12/2004

Docket/Case Number: CAF040008

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM WASALLEGED TO HAVE VIOLATED NASD CONDUCT RULE 2110, STANDARDS OFCOMMERCIAL HONOR AND PRINCIPLES OF TRADE, AS IT RELATES TODISLOSING TO CLIENTS THEIR ELIGIBILITY OF RECEIVING MUTUAL FUNDBREAKPOINT DISCOUNTS.

Current Status: Final

Resolution Date: 02/12/2004

Resolution:

Other Sanctions Ordered: UNDERTAKINGS

Sanction Details: THE TOTAL AMOUNT OF THE FINE WAS $4,844,465. $2,422,232 PAID TO THENASD ON 2/19/04 AND $2,422,232 PAID TO THE SEC ON 2/19/04.

Firm Statement THE FIRM AGREED TO THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS. INADDITION TO THE CENSURE AND MONETARY FINE, THE FIRM HAS AGREEDTO CERTAIN UNDERTAKINGS: (1) A TRADE BY TRADE REVIEW OF ALLFRONT END LOADED FUND SALES ABOVE $2500 FROM JANUARY 1, 1999THROUGH NOVEMBER 3, 2003 TO ENSURE THAT CUSTOMERS RECEIVETHE APPROPRIATE SALES DISCOUNTS AND PROVIDE REFUNDS WHEREAPPLICABLE AND (2) WITHIN 6 MONTHS OF THE DATE OF THE AWC, THEFIRM WILL CERTIFY TO THE REGULATORS THAT A SYSTEM IS IN PLACEREASONABLY DESIGNED TO MAKE CERTAIN CUSTOMERS GETAPPROPRIATE BREAKPOINT DISCOUNTS.

Sanctions Ordered: CensureMonetary/Fine $2,422,232.00

Acceptance, Waiver & Consent(AWC)

Disclosure 138 of 158

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Reporting Source: Regulator

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Initiated By: NEW HAMPSHIREBUREAU OF SECURITIES REGULATION

Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 02/10/2003

Docket/Case Number: INV03-010

URL for Regulatory Action:

Principal Product Type: Other

Other Product Type(s): N/A

Allegations: LATE FILED AUDITED FINANCIALS FOR YEAR ENDING 2000.

Current Status: Final

Resolution Date: 06/16/2003

Resolution:

Other Sanctions Ordered: N/A

Sanction Details: RESPONDENT FINED $500.

Regulator Statement WACHOVIA SECURITIES INC, CRD#431 FILED ITS YEAR END AUDITEDFINANCIALS LATE. WACHOVIA MERGED INTO FIRST UNION SECURITIESINC ON 6/15/2002 AND THEN CHANGED ITS NAME TO WACHOVIASECURITIES INC. CRD#19616. THIS ACTION WAS COMMENCED AGAINSTTHE NEW WACHOVIA ALTHOUGH THE VIOLATION WAS COMMITTED BY THELEGACY WACHOVIA.

Sanctions Ordered: Monetary/Fine $500.00

Consent

iReporting Source: Firm

Initiated By: STATE OF NEW HAMPSHIRE

Date Initiated: 03/19/2003

Docket/Case Number: INV03-010

Allegations: FAILURE OF PREDECESSOR FIRM WACHOVIA SECURITIES, INC. (BD 431)TO FILE ANNUAL AUDITED STATEMENTS WITHIN TIMELY MANNER AND TOPAY PENALTY OF $500 FOR LATE FILING.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Principal Product Type: No Product

Other Product Type(s):

Resolution Date: 06/09/2003

Resolution:

Other Sanctions Ordered:

Sanction Details: ADMINISTRATIVE FINE OF $500.00 AND PENALTY FEE OF $500.00 PAID TOSTATE 04/07/2003.

Firm Statement THE RESPONDENT WACHOVIA SECURITIES, INC. (BD 19616)VOLUNTARILYCONSENTED TO THE ENTRY OF THE ORDER AND TO PAY THE PENALTYINCURRED BY THE FORMER WACHOVIA SECURITIES, INC. (BD431), WHICHMERGED WITH FIRST UNION SECURITIES, INC. ON 6/15/2002 TO BECOMEWACHOVIA SECURITIES, INC. (BD19616).

Sanctions Ordered: Monetary/Fine $1,000.00

Order

Disclosure 139 of 158

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Reporting Source: Regulator

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Date Initiated: 10/30/2002

Docket/Case Number: CMS020202

Principal Product Type: Other

Other Product Type(s): UNKNOWN TYPE OF SECURITIES

Allegations: SEC RULE 11AC1-4 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS,THE RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGSTHAT IT FAILED TO DISPLAY IMMEDIATELY THE CUSTOMER LIMIT ORDERSIN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION, WHEN EACH SUCHORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OROFFER IN EACH SUCH SECURITY; OR WHEN THE ORDER WAS PRICEDEQUAL TO THE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OROFFER IN SUCH SECURITY, AND THE SIZE OF THE ORDER REPRESENTEDMORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATEDWITH ITS BID OR OFFER IN EACH SUCH SECURITY.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Other Product Type(s): UNKNOWN TYPE OF SECURITIES

Resolution Date: 10/30/2002

Resolution:

Other Sanctions Ordered:

Sanction Details: A CENSURE AND A FINE OF $10,000.

Sanctions Ordered: CensureMonetary/Fine $10,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 10/30/2002

Docket/Case Number: CMS020202

Principal Product Type: Other

Other Product Type(s): UNKNOWN TYPE OF SECURITIES

Allegations: SEC RULE 11AC1-4 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS,THE RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGSTHAT IT FAILED TO DISPLAY IMMEDIATELY THE CUSTOMER LIMIT ORDERSIN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION, WHEN EACH SUCHORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OROFFER IN EACH SUCH SECURITY; OR WHEN THE ORDER WAS PRICEDEQUAL TO THE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OROFFER IN SUCH SECURITY, AND THE SIZE OF THE ORDER REPRESENTEDMORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATEDWITH ITS BID OR OFFER IN EACH SUCH SECURITY.

Current Status: Final

Resolution Date: 10/30/2002

Resolution: Acceptance, Waiver & Consent(AWC)

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Resolution Date: 10/30/2002

Other Sanctions Ordered:

Sanction Details: A CENSURE AND A FINE OF $10,000.

Sanctions Ordered: CensureMonetary/Fine $10,000.00

Disclosure 140 of 158

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Reporting Source: Regulator

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 10/24/2002

Docket/Case Number: CMS020193

Principal Product Type: Other

Other Product Type(s): UNKNOWN TYPE OF SECURITIES

Allegations: NASD RULE 2110 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS,THE RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGSTHAT IT FAILED TO REPORT TO FIXED INCOME PRICING SYSTEM ("FIPS")TRANSACTIONS IN FIPS SECURITIES WITHIN FIVE MINUTES AFTEREXECUTION. SUCH CONDUCT CONSTITUTES A PATTERN OR PRACTICE OFTHE LATE REPORTING AND IS CONSIDERED CONDUCT INCONSISTENTWITH HIGH STANDARDS OF COMMERCIAL HONOR AND JUST ANDEQUITABLE PRINCIPALS OF TRADE.

Current Status: Final

Resolution Date: 10/24/2002

Resolution:

Other Sanctions Ordered:

Sanction Details: A FINE OF $5,000.

Sanctions Ordered: Monetary/Fine $5,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 10/24/2002

Docket/Case Number: CMS020193

Principal Product Type: Other

Other Product Type(s): UNKNOWN TYPE OF SECURITIES

Allegations: NASD RULE 2110 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS,WACHOVIA SECURITIES, INC. CONSENTED TO THE ENTRY OF FINDINGSTHAT IT FAILED TO REPORT TO THE FIXED INCOME PRICING SYSTEM("FIPS")46 TRANSACTIONS IN FIPS SECURITIES WITHIN FIVE MINUTESAFTER EXECUTION DURING THE PERIOD FROM JANUARY 1, 2001THROUGH JUNE 28,2001, WHICH CONSTITUTES A PATTERN OR PRACTICEOF REPORTING IN VIOLATION OF RULE 2110. THE FIRM PAID A FINE OF$5,000.

Current Status: Final

Resolution Date: 10/24/2002

Resolution:

Other Sanctions Ordered:

Sanction Details: A FINE OF $5000.00

Sanctions Ordered: Monetary/Fine $5,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 141 of 158

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Reporting Source: Regulator

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Date Initiated: 02/07/2002

Docket/Case Number: C07020006

Allegations: NASD RULES 2110, 8210 - WITHOUT ADMITTING OR DENYING THEALLEGATIONS, THE RESPONDENT MEMBER CONSENTED TO THE ENTRYOF FINDINGS THAT IT FAILED TO TIMELY COMPLETE AND RETURN TO THENASD A BRANCH OFFICE INFORMATION QUESTIONNAIRE.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Docket/Case Number: C07020006

Principal Product Type: No Product

Other Product Type(s):

Resolution Date: 02/07/2002

Resolution:

Other Sanctions Ordered:

Sanction Details: CENSURED AND FINED $5,000

Sanctions Ordered: CensureMonetary/Fine $5,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Initiated By: NASD REGULATION, INC.

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

FINE OF $5,000

Date Initiated: 04/03/2000

Docket/Case Number: C07020006-AWC

Principal Product Type: No Product

Other Product Type(s):

Allegations: THE NASD ALLEGES THAT ON OR ABOUT APRIL 3, 2000 NASD REGULATIONSTAFF REQUESTED PURSUANT TO NASD PROCEDURAL RULE 8210 THATFIRST UNION COMPLETE AND RETURN A BRANCH OFFICE INFORMATIONQUESTIONNAIRE BY APRIL 18, 2000. FIRST UNION REQUESTED ANDRECIEVED AN EXTENSION OF THE RESPONSE DEADLINE UNTIL MAY 12,2000. AFTER FURTHER COMMUNICATION WITH FIRST UNION, NASDREGULATION STAFF DID NOT RECEIVE THE REQUESTED INFORMATIONUNTIL MARCH 2001. THE NASD ALLEGES THAT SUCH CONDUCT VIOLATESNASD PROCEDURAL RULE 8210 AND NASD CONDUCT RULE 2110.

Current Status: Final

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Resolution Date: 02/07/2002

Resolution:

Other Sanctions Ordered: N/A

Sanction Details: N/A

Firm Statement WITHOUT ADMITTING OR DENYING GUILT, FIRST UNION SECURITIESCOSENTED TO THE NASD'S FINDINGS THAT ON OR ABOUT APRIL 3, 2000NASD REGULATION STAFF REQUESTED PURSUANT TO NASDPROCEDURAL RULE 8210 THAT FIRST UNION COMPLETE AND RETURN ABRANCH OFFICE INFORMATION QUESTIONNAIRE BY APRIL 18, 2000. THATFIRST UNION REQUESTED AND RECIEVED AN EXTENSION OF THERESPONSE DEADLINE UNTIL MAY 12, 2000. THAT AFTER FURTHERCOMMUNICATION WITH FIRST UNION, NASD REGULATION STAFF DID NOTRECEIVE THE REQUESTED INFORMATION UNTIL MARCH 2001. THAT THENASD ALLEGES THAT SUCH CONDUCT VIOLATES NASD PROCEDURALRULE 8210 AND NASD CONDUCT RULE 2110.

Sanctions Ordered: Monetary/Fine $5,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 142 of 158

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Reporting Source: Regulator

Allegations: **11/05/2001** STIPULATION AND CONSENT TO PENALTY FILED BY NYSEDIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS:WITHOUT ADMITTING OR DENYING GUILT, FIRST UNION SECURITIES, INC.CONSENTED TO A FINDING BY THE HEARING PANEL THAT THE FIRM:EXCHANGE RULE 440 AND SEC REGULATIONS ?240.17A-3 AND 17A-4 BYFAILING TO MAKE AND PRESERVE REQUIRED RECORDS RELATING TOACCOUNT DESIGNATION AND EXECUTION OF CUSTOMER ORDERS.EXCHANGE RULE 410 BY FAILING TO MAKE AND PRESERVE REQUIREDRECORDS REGARDING THE TIMELY ALLOCATION OF ORDERS TOCUSTOMER ACCOUNTS. EXCHANGE RULE 351 BY FAILING TO PROMPTLYREPORT CERTAIN CUSTOMER COMPLAINTS AND/OR SETTLEMENTS TOTHE EXCHANGE AS REQUIRED.EXCHANGE RULE 342 IN THAT IT FAILED TO REASONABLY SUPERVISE ANDCONTROL AND PROVIDE APPROPRIATE PROCEDURES OF SUPERVISIONAND CONTROL AND ESTABLISH A SYSTEM OF FOLLOW-UP AND REVIEWWITH RESPECT TO: ASSURING COMPLIANCE WITH EXCHANGE RULES ANDFEDERAL SECURITIES LAWS REQUIRING THE MAKING AND PRESERVATIONOF TIMELY RECORDS RELATING TO THE ACCOUNT DESIGNATION ANDEXECUTION OF CUSTOMER ORDERS;ASSURING THAT TRADE CORRECTIONS EFFECTED BY BRANCH OFFICEMANAGERS ARE PROPERLY REVIEWED; AND ASSURING COMPLIANCEWITH EXCHANGE RULES TO PROMPTLY AND ACCURATELY REPORTCUSTOMER COMPLAINTS AND/OR SETTLEMENTS TO THE EXCHANGE.STIPULATED SANCTION: THE IMPOSITION BY THE EXCHANGE OF THEPENALTY OF: A CENSURE; AND, A FINE OF $145,000.

Current Status: Final

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Initiated By: NYSE DIVISION OF ENFORCEMENT

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 11/05/2001

Docket/Case Number: HPD#01-232

Principal Product Type: Other

Other Product Type(s):

**11/05/2001** STIPULATION AND CONSENT TO PENALTY FILED BY NYSEDIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS:WITHOUT ADMITTING OR DENYING GUILT, FIRST UNION SECURITIES, INC.CONSENTED TO A FINDING BY THE HEARING PANEL THAT THE FIRM:EXCHANGE RULE 440 AND SEC REGULATIONS ?240.17A-3 AND 17A-4 BYFAILING TO MAKE AND PRESERVE REQUIRED RECORDS RELATING TOACCOUNT DESIGNATION AND EXECUTION OF CUSTOMER ORDERS.EXCHANGE RULE 410 BY FAILING TO MAKE AND PRESERVE REQUIREDRECORDS REGARDING THE TIMELY ALLOCATION OF ORDERS TOCUSTOMER ACCOUNTS. EXCHANGE RULE 351 BY FAILING TO PROMPTLYREPORT CERTAIN CUSTOMER COMPLAINTS AND/OR SETTLEMENTS TOTHE EXCHANGE AS REQUIRED.EXCHANGE RULE 342 IN THAT IT FAILED TO REASONABLY SUPERVISE ANDCONTROL AND PROVIDE APPROPRIATE PROCEDURES OF SUPERVISIONAND CONTROL AND ESTABLISH A SYSTEM OF FOLLOW-UP AND REVIEWWITH RESPECT TO: ASSURING COMPLIANCE WITH EXCHANGE RULES ANDFEDERAL SECURITIES LAWS REQUIRING THE MAKING AND PRESERVATIONOF TIMELY RECORDS RELATING TO THE ACCOUNT DESIGNATION ANDEXECUTION OF CUSTOMER ORDERS;ASSURING THAT TRADE CORRECTIONS EFFECTED BY BRANCH OFFICEMANAGERS ARE PROPERLY REVIEWED; AND ASSURING COMPLIANCEWITH EXCHANGE RULES TO PROMPTLY AND ACCURATELY REPORTCUSTOMER COMPLAINTS AND/OR SETTLEMENTS TO THE EXCHANGE.STIPULATED SANCTION: THE IMPOSITION BY THE EXCHANGE OF THEPENALTY OF: A CENSURE; AND, A FINE OF $145,000.

Resolution Date: 01/28/2002

Resolution:

Other Sanctions Ordered:

Sanction Details: **12/26/2001** DECISION 01-232 ISSUED BY NYSE HEARING PANELDECISION: VIOLATED RULE 440 AND SEC REGULATIONS 240.17A-3 ANDA-4 BY FAILING TO MAKE AND PRESERVE REQUIRED RECORDS, VIOLATEDRULE 410 BY FAILING TO MAKE AND PRESERVE REQUIRED RECORDS;VIOLATED RULE 351 BY FAILING TO PROMPTLY REPORT CERTAINCUSTOMER COMPLAINTS; AND VIOLATED RULE 342 BY FAILING TOREASONABLY SUPERVISE AND PROVIDE APPROPRIATE PROCEDURES OFSUPERVISION AND CONTROL -- CONSENT TO CENSURE AND $145,000FINE.

Regulator Statement **01/28/2002** THE DECISION IS FINAL AND IS EFFECTIVE IMMEDIATELY.CONTACT: PEGGY GERMINO (212) 656-8450.

Sanctions Ordered: CensureMonetary/Fine $145,000.00

Decision

iReporting Source: Firm

Allegations: 1. ALLEGATIONS OF FAILURE TO SUPERVISE TO ENSURE THAT CUSTOMERORDERS WERE PROPERLY ALLOCATED TO CUSTOMER ACCOUNTS PRIORTO OR SIMULTANEOUSLY WITH ORDER EXECUTION BY EVERENSECURITIES (NOW KNOWN AS FIRST UNION SECURITIES) DURING 1997. 2.DURING 1999 & 2000, EVEREN SECURITIES ALLEGEDLY FAILED TO REPORTALL CUSTOMER COMPLAINTS, CUSTOMER SETTLEMENTS AND VIOLATIVECONDUCT IN A TIMELY MANNER.

Current Status: Final

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Initiated By: NEW YORK STOCK EXCHANGE, INC.

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

FINE OF $145,000

Date Initiated: 04/01/2000

Docket/Case Number: 01-232

Principal Product Type: No Product

Other Product Type(s):

1. ALLEGATIONS OF FAILURE TO SUPERVISE TO ENSURE THAT CUSTOMERORDERS WERE PROPERLY ALLOCATED TO CUSTOMER ACCOUNTS PRIORTO OR SIMULTANEOUSLY WITH ORDER EXECUTION BY EVERENSECURITIES (NOW KNOWN AS FIRST UNION SECURITIES) DURING 1997. 2.DURING 1999 & 2000, EVEREN SECURITIES ALLEGEDLY FAILED TO REPORTALL CUSTOMER COMPLAINTS, CUSTOMER SETTLEMENTS AND VIOLATIVECONDUCT IN A TIMELY MANNER.

Resolution Date: 01/28/2002

Resolution:

Other Sanctions Ordered: N/A

Sanction Details: N/A

Firm Statement WITHOUT ADMITTING OR DENYING ANY GUILT, EVEREN SECURITIES (NOWKNOWN AS FIRST UNION SECURITIES) CONSENTED TO THE NYSE'SFINDINGS THAT 1. VIOLATED EXCHANGE RULE 440 AND SEC REGULATIONS240.71A-3 AND 17A-4 BY FAILING IT TO MAKE AND PERSERVE REQUIREDRECORDS RELATING TO ACCOUNT DESIGNATION AND EXECUTION OFCUSTOMER ORDERS, 2. EXCHANGE RULE 410 BY FAILING TO MAKE ANDPERSERVE REQUIRED RECORDS REGARDING THE TIMELY ALLOCATIONOF ORDERS TO CUSTOMER ACCOUNTS, 3. EXCHANGE RULE 351 BYFAILING TO PROMPTLY REPORT CERTAIN CUSTOMER COMPLAINTSAND/OR SETTLEMENTS TO THE EXCHANGE AS REQUIRED, 4. EXCHANGERULE 342 IN THAT IT FAILED TO REASONABLY SUPERVISE AND CONTROLAND PROVIDE APPROPRIATE PROCEDURES OF SUPERVISION ANDCONTROL AND ESTABLISH A SYSTEM OF FOLLOW-UP AND REVIEW WITHRESPECT TO (A)ASSURING COMPLIANCE WITH EXCHANGE RULES ANDFEDERAL SECURITIES LAWS REQUIRING THE MAKING AND PRESERVATIONOF TIMELY RECORDS RELATING TO THE ACCOUNT DESIGNATION ANDEXECUTION OF CUSTOMER ORDERS, (B) ASSURING THAT TRADECORRECTIONS EFFECTED BY BRANCH OFFICE MANAGERS AREPROPERLY REVIEWED, AND (C) ASSURING COMPLIANCE WITH EXCHANGERULES TO PROMPTLY AND ACCURATLEY REPORT CUSTOMERCOMPLAINTS AND/OR SETTLEMENTS TO THE EXCHANGE.

Sanctions Ordered: Monetary/Fine $145,000.00

Consent

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WITHOUT ADMITTING OR DENYING ANY GUILT, EVEREN SECURITIES (NOWKNOWN AS FIRST UNION SECURITIES) CONSENTED TO THE NYSE'SFINDINGS THAT 1. VIOLATED EXCHANGE RULE 440 AND SEC REGULATIONS240.71A-3 AND 17A-4 BY FAILING IT TO MAKE AND PERSERVE REQUIREDRECORDS RELATING TO ACCOUNT DESIGNATION AND EXECUTION OFCUSTOMER ORDERS, 2. EXCHANGE RULE 410 BY FAILING TO MAKE ANDPERSERVE REQUIRED RECORDS REGARDING THE TIMELY ALLOCATIONOF ORDERS TO CUSTOMER ACCOUNTS, 3. EXCHANGE RULE 351 BYFAILING TO PROMPTLY REPORT CERTAIN CUSTOMER COMPLAINTSAND/OR SETTLEMENTS TO THE EXCHANGE AS REQUIRED, 4. EXCHANGERULE 342 IN THAT IT FAILED TO REASONABLY SUPERVISE AND CONTROLAND PROVIDE APPROPRIATE PROCEDURES OF SUPERVISION ANDCONTROL AND ESTABLISH A SYSTEM OF FOLLOW-UP AND REVIEW WITHRESPECT TO (A)ASSURING COMPLIANCE WITH EXCHANGE RULES ANDFEDERAL SECURITIES LAWS REQUIRING THE MAKING AND PRESERVATIONOF TIMELY RECORDS RELATING TO THE ACCOUNT DESIGNATION ANDEXECUTION OF CUSTOMER ORDERS, (B) ASSURING THAT TRADECORRECTIONS EFFECTED BY BRANCH OFFICE MANAGERS AREPROPERLY REVIEWED, AND (C) ASSURING COMPLIANCE WITH EXCHANGERULES TO PROMPTLY AND ACCURATLEY REPORT CUSTOMERCOMPLAINTS AND/OR SETTLEMENTS TO THE EXCHANGE.

Disclosure 143 of 158

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Reporting Source: Firm

Initiated By: NASD REGULATION, INC.

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

Date Initiated: 04/05/2000

Docket/Case Number: C05000014

Principal Product Type: Other

Other Product Type(s): US TREASURY SECURITIES

Allegations: THE NASD ALLEGED THAT FUSI'S PREDECESSORS, BUTCHER & SINGERAND WHEAT FIRST SECURITIES, INC. VIOLATED SECTIONS 17(A)(2) AND17(A)(3) OF THE SECURITIES ACT AND NASD RULE 2001 CONCERNINGSALES OF PORTFOLIOS OF US TREASURY SECURITIES FOR DEFEASANCEESCROW AT EXCESSIVE, UNDISCLOSED MARKUPS TO MUNICIPALITIES INCONNECTION WITH ADVANCE REFUNDINGS. FURTHER, THE NASDALLEGED THAT THE FIRM KNEW OR SHOULD HAVE KNOWN THAT THEMARKUPS WERE NOT REASONABLY RELATED TO THE PREVAILINGWHOLESALE MARKET PRICES AND THEREBY JEOPARDIZED THE TAX-EXEMPT STATUS OF THE BONDS AND DIVERTED THE FUNDS FROM THEUS TREASURY.

Current Status: Final

Resolution Date: 04/05/2000

Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: FUSI, WITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONS,CONSENTED TO THE FINDINGS OF THE NASD AND UNDERTAKES TO MAKEPAYMENTS TOTALING $1,460,110.32 RELATED TO THE SALE OF SECURITIESTO CERTAIN MUNICIPAL ISSUERS IN CONNECTION WITH ADVANCEREFUNDINGS, PAY $6,752,152.49 TO THE US TREASURY AND $478,500 TOTHE NASDR UNDER AN AGREEMENT SIMULTANEOUSLY ENTERED INTOAMONG FUSI, THE INTERNAL REVENUE SERVICE AND THE US ATTORNEYFOR THE SOUTHERN DISTRICT OF NEW YORK.

Sanctions Ordered: Censure

Acceptance, Waiver & Consent(AWC)

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FUSI, WITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONS,CONSENTED TO THE FINDINGS OF THE NASD AND UNDERTAKES TO MAKEPAYMENTS TOTALING $1,460,110.32 RELATED TO THE SALE OF SECURITIESTO CERTAIN MUNICIPAL ISSUERS IN CONNECTION WITH ADVANCEREFUNDINGS, PAY $6,752,152.49 TO THE US TREASURY AND $478,500 TOTHE NASDR UNDER AN AGREEMENT SIMULTANEOUSLY ENTERED INTOAMONG FUSI, THE INTERNAL REVENUE SERVICE AND THE US ATTORNEYFOR THE SOUTHERN DISTRICT OF NEW YORK.

Disclosure 144 of 158

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Reporting Source: Regulator

Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Principal Sanction(s)/ReliefSought:

Cease and Desist

Date Initiated: 10/24/2000

Docket/Case Number: REL. 34-43478; FILE #3-10352

Principal Product Type: Other

Other Product Type(s): U.S. TREASURY NOTES AND BONDS

Allegations: THE SEC ALLEGED THAT FIRST UNION SECURITIES, INC. ("FIRST UNIONSECURITIES" OR "DEFENDANT"), A REGISTERED BROKER-DEALER,VIOLATED THE RECORDKEEPING PROVISIONS OF THE FEDERALSECURITIES LAWS IN CONNECTION WITH THE PURCHASE AND SALE OFUNITED STATES TREASURY NOTES AND BONDS ISSUED THROUGH THENONCOMPETITIVE AUCTION PROCESS ("NONCOMPETITIVE SECURITIES")FROM 1995 THROUGH 1998. FIRST UNION SECURITIES' BOOKS ANDRECORDS FAILED TO REFLECT CERTAIN TERMS OF CUSTOMER ORDERS,WHICH WERE PRE-AUCTION AGREEMENTS BETWEEN FIRST UNIONSECURITIES AND ITS NONCOMPETITIVE BIDDING CUSTOMERS, TO SELLTHE SECURITIES THOSE CUSTOMERS WOULD BE AWARDED THROUGHTHE AUCTION. THOSE PRE-AUCTION AGREEMENTS VIOLATED ATREASURY DEPARTMENT PROHIBITION OF SUCH AGREEMENTS. FIRSTUNION SECURITIES RECEIVED APPROXIMATELY $225,000 IN MARKDOWNSFROM ITS CUSTOMERS ON THE NONCOMPETITIVE SECURITIESTRANSACTIONS. FIRST UNION SECURITIES' FAILURE TO RECORD ON ITSBOOKS AND RECORDS THESE PRE-AUCTION AGREEMENTS WITH ITSCUSTOMERS CONSTITUTED A VIOLATION OF SECTION 17(A) OF THEEXCHANGE ACT AND RULE 17A-3 PROMULGATED THEREUNDER. THEORDER TICKETS RELATING TO THE CUSTOMERS' PURCHASE OF THETREASURY SECURITIES SHOULD HAVE RECORDED THE PRE-AUCTIONAGREEMENTS BETWEEN FIRST UNION SECURITIES AND ITS CUSTOMERSTO SELL THE CUSTOMERS' NONCOMPETITIVE TREASURY SECURITIES ASSOON AS POSSIBLE AFTER THE AUCTIONS. THE PRE-AUCTIONAGREEMENTS CONSTITUTED A TERM OR CONDITION OF THECUSTOMERS' ORDERS TO PURCHASE THE TREASURY SECURITIES ATAUCTION, SINCE THOSE ORDERS WOULD NOT HAVE BEEN PLACEDWITHOUT THE ACCOMPANYING AGREEMENTS TO SELL BEING IN PLACE.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

DISGORGEMENT, PLUS INTEREST; AND A CIVIL MONEY PENALTY.

Resolution Date: 10/24/2000

Resolution:

Other Sanctions Ordered:

Sanction Details: IT IS HEREBY ORDERED: (1) THAT FIRST UNION SECURITIES CEASE ANDDESIST FROM COMMITTING OR CAUSING ANY VIOLATION, AND FROMCOMMITTING OR CAUSING ANY FUTURE VIOLATION, OF SECTION 17(A) OFTHE EXCHANGE ACT AND RULE 17A-3 THEREUNDER; AND (2) THAT FIRSTUNION SECURITIES, WITHIN 30 DAYS OF THE DATE OF THIS ORDER, SHALLPAY THE AMOUNT OF $308,931.00 REPRESENTING DISGORGEMENT ANDINTEREST THEREON TO THE UNITED STATES TREASURY; AND (3) THATFIRST UNION SECURITIES, WITHIN 30 DAYS OF THE DATE OF THIS ORDER,SHALL PAY THE AMOUNT OF $100,000, REPRESENTING A CIVIL MONEYPENALTY, TO THE UNITED STATES TREASURY.

Regulator Statement +11/10/2000+ SEC NEWS DIGEST, ISSUE NO. 2000-204, DATED 10/24/2000,ENFORCEMENT PROCEEDINGS, AND ADMINISTRATIVE PROCEEDINGRELEASE NO. 34-43478, DATED 10/24/2000, DISCLOSES: THE SECINSTITUTED PUBLIC ADMINISTRATIVE PROCEEDINGS PURSUANT TOSECTIONS 15(B)(4) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934("EXCHANGE ACT") AGAINST DEFENDANT FIRST UNION SECURITIES. INANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,DEFENDANT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THECOMMISSION HAS DETERMINED TO ACCEPT. WITHOUT ADMITTING ORDENYING THE ALLEGATIONS DEFENDANT CONSENTED TO THE ISSUANCEOF THIS CEASE AND DESIST ORDER. THE SEC ALLEGED THAT DEFENDANTVIOLATED THE RECORDKEEPING PROVISIONS OF THE FEDERALSECURITIES LAWS IN CONNECTION WITH THE PURCHASE AND SALE OFUNITED STATES TREASURY NOTES AND BONDS ISSUED THROUGH THENONCOMPETITIVE AUCTION PROCESS FROM 1995 THROUGH 1998. THESEC FOUND THAT DEFENDANT WILLFULLY VIOLATED SECTION 17(A) OFTHE EXCHANGE ACT AND RULE 17A-3 THEREUNDER. IT IS HEREBYORDERED THAT DEFENDANT CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATION, AND FROM COMMITTING OR CAUSING ANYFUTURE VIOLATION OF THE SECURITIES LAWS. THE SEC ALSO ORDEREDTHAT DEFENDANT SHALL PAY THE DISGORGEMENT, PLUS INTEREST AND ACIVIL MONEY PENALTY. (REL. 34-43478; FILE #3-10352)

Sanctions Ordered: Monetary/Fine $100,000.00Disgorgement/RestitutionCease and Desist/Injunction

Order

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+11/10/2000+ SEC NEWS DIGEST, ISSUE NO. 2000-204, DATED 10/24/2000,ENFORCEMENT PROCEEDINGS, AND ADMINISTRATIVE PROCEEDINGRELEASE NO. 34-43478, DATED 10/24/2000, DISCLOSES: THE SECINSTITUTED PUBLIC ADMINISTRATIVE PROCEEDINGS PURSUANT TOSECTIONS 15(B)(4) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934("EXCHANGE ACT") AGAINST DEFENDANT FIRST UNION SECURITIES. INANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,DEFENDANT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THECOMMISSION HAS DETERMINED TO ACCEPT. WITHOUT ADMITTING ORDENYING THE ALLEGATIONS DEFENDANT CONSENTED TO THE ISSUANCEOF THIS CEASE AND DESIST ORDER. THE SEC ALLEGED THAT DEFENDANTVIOLATED THE RECORDKEEPING PROVISIONS OF THE FEDERALSECURITIES LAWS IN CONNECTION WITH THE PURCHASE AND SALE OFUNITED STATES TREASURY NOTES AND BONDS ISSUED THROUGH THENONCOMPETITIVE AUCTION PROCESS FROM 1995 THROUGH 1998. THESEC FOUND THAT DEFENDANT WILLFULLY VIOLATED SECTION 17(A) OFTHE EXCHANGE ACT AND RULE 17A-3 THEREUNDER. IT IS HEREBYORDERED THAT DEFENDANT CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATION, AND FROM COMMITTING OR CAUSING ANYFUTURE VIOLATION OF THE SECURITIES LAWS. THE SEC ALSO ORDEREDTHAT DEFENDANT SHALL PAY THE DISGORGEMENT, PLUS INTEREST AND ACIVIL MONEY PENALTY. (REL. 34-43478; FILE #3-10352)

iReporting Source: Firm

Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

FIRST UNION SECURITIES, WITHOUT ADMITTING OR DENYING ANYWRONGDOING, WAS ORDERED TO CEASE AND DESIST FROMCOMMITTING OR CAUSING FUTURE VIOLATIONS OF THE BROKER-DEALERRECORDKEEPING PROVISIONS OF THE FEDERAL SECUIRITIES LAWS.FIRST UNION WAS ORDERED TO A CIVIL PENALTY, DISGORGEMENT ANDPREJUDGEMENT INTEREST.

Date Initiated: 10/24/2000

Docket/Case Number: REL. 34-43478, FILE NO. 3-10352

Principal Product Type: Other

Other Product Type(s): TREASURY SECURITIES

Allegations: FIRST UNION SECURITIES, WITHOUT ADMITTING OR DENYING THECOMMISSION'S FINDINGS, CONSENTED TO A COMMISSION ORDERFINDING THAT THE FIRM VIOLATED THE BROKER-DEALERRECORDKEEPING PROVISIONS OF SECTION 17A AND RULE 17A-3THEREUNDER.

Current Status: Final

Resolution Date: 10/24/2000

Resolution:

Other Sanctions Ordered:

Sanction Details: ORDERED TO PAY CIVIL PENALTIES OF $100,000, DISGORGEMENT ANDPREJUDGEMENT INTEREST OF $308,931.

Firm Statement FIRST UNION SECURITIES, WITHOUT ADMITTING OR DENYING ANYWRONGDOING, WAS ORDERED TO CEASE AND DESIST FROMCOMMITTING OR CAUSING FUTURE VIOLATIONS OF THE BROKER-DEALERRECORDKEEPING PROVISIONS OF THE FEDERAL SECUIRITIES LAWS. THECOMMISSION ORDER FINDS THAT FUSI FAILED TO PROPERLY RECORDCERTAIN TERMS OF CUSTOMER ORDERS MADE IN CONNECTION WITHTHE PURCHASE AND SALE OF U.S. TREASURY SECURITIES ISSUEDTHROUGH THE NONCOMPETATIVE AUCTION PROCESS FROM 1995THROUGH 1998.

Sanctions Ordered: Monetary/Fine $100,000.00Disgorgement/Restitution

Consent

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FIRST UNION SECURITIES, WITHOUT ADMITTING OR DENYING ANYWRONGDOING, WAS ORDERED TO CEASE AND DESIST FROMCOMMITTING OR CAUSING FUTURE VIOLATIONS OF THE BROKER-DEALERRECORDKEEPING PROVISIONS OF THE FEDERAL SECUIRITIES LAWS. THECOMMISSION ORDER FINDS THAT FUSI FAILED TO PROPERLY RECORDCERTAIN TERMS OF CUSTOMER ORDERS MADE IN CONNECTION WITHTHE PURCHASE AND SALE OF U.S. TREASURY SECURITIES ISSUEDTHROUGH THE NONCOMPETATIVE AUCTION PROCESS FROM 1995THROUGH 1998.

Disclosure 145 of 158

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Reporting Source: Regulator

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 10/30/2000

Docket/Case Number: C05000058

Principal Product Type: Other

Other Product Type(s): U.S. TREASURY SECURITIES

Allegations: 11-02-00, SECTIONS 17(A)(2), 17(A)(3) OF THE SECURITIES ACT, NASD RULE2110 - RESPONDENT MEMBER SOLD PORTFOLIOS OF U.S. TREASURYSECURITIES FOR DEFEASANCE ESCROW AT EXCESSIVE, UNDISCLOSEDMARKUPS TO MUNICIPALITIES IN CONNECTION WITH ADVANCEREFUNDINGS. THE FIRM SOLD A PORTFOLIO OF $20,608,015.60 IN U.S.TREASURY SECURITIES TO A MUNICIPALITY. THE FIRM'S MARKUP ANDCARRY ON THAT PORTFOLIO WAS .55 PERCENT OF THE PREVAILINGINTERDEALER MARKET PRICES OF THE TREASURY SECURITIES SOLD TOTHE MUNICIPALITY. AT THE TIME, DEALERS GENERALLY CHARGEDMATERIALLY LOWER MARKUPS ON ESCROW SECURITIES WHEN THEPRICES WERE DETERMINED THROUGH COMPETITION OR BONA FIDEARM'S LENGTH NEGOTIATION. THE FIRM EFFECTED DEFEASANCEESCROW TRANSACTIONS WITH MUNICIPALITIES AT PRICES NOTREASONABLY RELATED TO THE CURRENT WHOLESALE MARKET PRICESFOR THE SECURITIES UNDER THE PARTICULAR FACTS ANDCIRCUMSTANCES, INCLUDING THE PERTINENT TX REGULATIONS;THEFIRM KNEW OR SHOULD HAVE KNOWN THAT THE PRICES IT CHARGEDWERE NOT REASONABLY RELATED TO THE PREVAILING WHOLESALEMARKET PRICES. THE EXCESSIVE MARKUPS ALSO JEOPARDIZED THE TAX-EXEMPT STATUS OF THOSE MUNICIPALITIES' REFUNDING BONDS ANDDIVERTED MONEY FROM THE U.S. TREASURY TO THE FIRM WHEN THETRANSACTION WAS IN POSITIVE ARBITRAGE OR REDUCED THE SAVINGSAVAILABLE TO THE MUNICIPALITIES FROM THE REFUNDINGS WHEN THETRANSACTION WAS IN NEGATIVE ARBITRAGE.

Current Status: Final

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Resolution Date: 10/30/2000

Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: CENSURED,UNDERTAKE TO MAKE PAYMENTS TOTALING $309,775.92RELATED TO THE SALE OF DEFEASANCE ESCROW SECURITIES TOCERTAIN MUNICIPAL ISSUERS IN CONNECTION WITH ADVANCEREFUNDINGS IN NEGATIVE ARBITRAGE SITUATIONS, PAY $11,802,522.08 TOTHE U.S. TREASURY AND $625,000 TO THE NASDR UNDER AN AGREEMENTSIMULTANEOUSLY ENTERED WITH FIRST UNION SECURITIES, INC., THEINTERNAL REVENUE SERVICE AND THE U.S. ATTORNEY FOR THESOUTHERN DISTRICT OF NEW YORK. AT THE TIME PAYMENTS ARE MADETO THE MUNICIPALITIES AND THE U.S. TREASURY, COPIES OF THEPAYMENTS AND ANY ACCOMPANYING COVER LETTERS SHALL BE SENT TOTHE DISTRICT NO. 5 DIRECTOR.

Sanctions Ordered: Censure

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Initiated By: NASD

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

Date Initiated: 10/30/2000

Docket/Case Number: C05000058

Principal Product Type: Other

Other Product Type(s): US TREASURY SECURITIES

Allegations: THE NASD ALLEGED VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OFTHE SECURITIES ACT AND NASD RULE 2110 CONCERNING SALES OFPORTFOLIOS OF US TREASURY SECURITIES FOR DEFEASANCE ESCROWAT EXCESSIVE, UNDISCLOSED MARKUPS TO MUNICIPALITIES INCONNECTION WITH ADVANCE REFUNDINGS. FURTHER, THE NASDALLEGED THAT THE FIRM KNEW, OR SHOULD HAVE KNOWN, THAT THEMARKUPS WERE NOT REASONABLY RELATED TO THE PREVAILINGWHOLESALE MARKET PRICES AND THEREBY JEOPARDIZED THE TAX-EXEMPT STATUS OF THE BONDS AND DIVERTED FUNDS FROM THE USTREASURY.

Current Status: Final

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Other Sanction(s)/ReliefSought:

Resolution Date: 10/30/2000

Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: FIRST UNION SECURITIES, WITHOUT ADMITTING OR DENYING ANY OF THEALLEGATIONS, CONSENTED TO THE FINDINGS OF THE NASD ANDUNDERTAKES TO MAKE PAYMENTS TOTALING $309,775.92 RELATED TOTHE SALE OF SECURITIES TO CERTAIN MUNICIPAL ISSUERS INCONNECTION WITH ADVANCE REFUNDINGS, PAY $11,802,522.08 TO THE USTREASURY AND $625,000 TO THE NASD UNDER AN AGREEMENTSIMULTANEOUSLY ENTERED INTO AMONG FIRST UNION SECURIRITIES,THE INTERNAL REVENUE SERVICE AND THE US ATTORNEY FOR THESOUTHERN DISTRICT OF NEW YORK.

Sanctions Ordered: Censure

Acceptance, Waiver & Consent(AWC)

Disclosure 146 of 158

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Reporting Source: Regulator

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 07/10/2000

Docket/Case Number: C8A000039

Principal Product Type: Other

Other Product Type(s):

Allegations: 07/20/00GS: NASD RULES 2110 AND 3010 - RESPONDENT EFFECTED ORCAUSED TO BE EFFECTED FOR THE ACCOUNT OF PUBLIC CUSTOMERSTHE PURCHASE OF SECURITIES IN INITIAL PUBLIC OFFERINGS AT THEINITIAL PUBLIC OFFERING PRICES WHEN TRADING IN THE SECURITIESTRADED AT A PREMIUM OVER THE PUBLIC OFFERING PRICES, INVIOLATION OF THE NASD'S FREE-RIDING AND WITHHOLDINGINTERPRETATION; AND, FAILED TO ESTABLISH, MAINTAIN AND ENFORCEWRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH THE NASD'S FREE-RIDING ANDWITHHOLDING INTERPRETATION.

Current Status: Final

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Other Sanction(s)/ReliefSought:

Resolution Date: 07/10/2000

Resolution:

Other Sanctions Ordered:

Sanction Details: 11-07-00, $7,500 PAID 8/09/00, INVOICE 00-8A-455

Sanctions Ordered: CensureMonetary/Fine $7,500.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

FINE OF $7,500.

Date Initiated: 07/10/2000

Docket/Case Number: C8A000039

Principal Product Type: Other

Other Product Type(s): IPO

Allegations: ALLEGED VIOLATION OF NASD CONDUCT RULE 2110 AND 3010(B).

Current Status: Final

Resolution Date: 07/10/2000

Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM CONSENTED TO A LETTER OF ACCEPTANCE, WAIVER ANDCONSENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS ANDCONSENTED TO CENSURE AND A FINE OF $7500.

Sanctions Ordered: CensureMonetary/Fine $7,500.00

Acceptance, Waiver & Consent(AWC)

Disclosure 147 of 158

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Reporting Source: Regulator

Initiated By: NATIONAL ASSOCIATION OFSECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 06/13/2000

Docket/Case Number: CAF000022

Principal Product Type: Other

Other Product Type(s):

Allegations: 06-16-00, SEC RULES 17A-3,17A-4, MSRB RULES G-8, G-9, AND G-27 -RESPONDENT MEMBER FAILED TO RECORD FINDER'S FEES PAID TO ANOW DEFUNCTED FIRM AND ITS BOOKS AND RECORDS FAILED TOREFLECT PAYMENTS ON NUMEROUS MUNICIPAL SECURITIESTRANSACTIONS AND OVERSTATED THE AMOUNT OWED; AND ITS BOOKSAND RECORDS FAILED TO RECORD PAYMENTS MADE THROUGH A THIRDPARTY

Current Status: Final

Resolution Date: 06/13/2000

Resolution:

Other Sanctions Ordered:

Sanction Details: CENSURED AND FINED $350,000

Sanctions Ordered: CensureMonetary/Fine $350,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Allegations: NASD ALLEGED THAT FIRST UNION SECURITIES, INC. (F/K/A WHEAT FIRSTSECURITIES, INC.) VIOLATED SECTION 17(A) OF THE EXCHANGE ACT ANDRULES 17A-3 AND 17A-4 THEREUNDER AND MSRB RULES G-8, G-9 AND G-27. FIRST UNION'S BOOKS AND RECORDS FAILED TO ACCURATELYREFLECT FINDERS FEES PAID FOR MUNICIPAL SECURITIESTRANSACTIONS OVER AN EIGHTEEN MONTH PERIOD FROM LATE 1991THROUGH APRIL, 1993.

Current Status: Final

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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

FINE OF $350,000

Date Initiated: 06/13/2000

Docket/Case Number: CAF000022

Principal Product Type: No Product

Other Product Type(s):

Resolution Date: 06/13/2000

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, FIRST UNIONSECURITIES, INC. CONSENTED TO A LETTER OF ACCEPTANCE, WAIVERAND CONSENT WHICH INCLUDED A CONSENT TO CENSURE AND A FINE OF$350,000.

Sanctions Ordered: CensureMonetary/Fine $350,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 148 of 158

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Reporting Source: Firm

Initiated By: U S SECURITIES & EXCHANGE COMMISSION

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

Date Initiated: 01/01/1992

Docket/Case Number: N/A

Principal Product Type: Other

Other Product Type(s): UNSECURED DEBT SECURITIES

Allegations: VIOLATIONS OF CFR PART 404 PROMULGATED PURSUANT TO SECTION15C WITH THE PRIMARY DISTRIBUTION OF CERTAIN UNSECURED DEBTSECURITIES ISSUED BY GOVERNMENTAL SPONSORED ENTERPRISES.

Current Status: Final

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Other Sanction(s)/ReliefSought:

Resolution Date: 01/01/1992

Resolution:

Other Sanctions Ordered:

Sanction Details: CEASE AND DESIST, $100,000 FINE.

Sanctions Ordered: Monetary/Fine $100,000.00Cease and Desist/Injunction

Settled

Disclosure 149 of 158

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Reporting Source: Firm

Initiated By: STATE OF RHODE ISLAND, DIVISION OF SECURITIES

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

CIVIL PENALTY

Date Initiated: 03/16/1995

Docket/Case Number: 95-015

Principal Product Type: No Product

Other Product Type(s):

Allegations: EVEREN SECURITIES, INC. (NAME CHANGED TO FIRST UNION SECURITIES,INC.)VIOLATIONS OF SECTION 201 OF THE RHODE ISLAND UNIFORMSECURITIES ACT OF 1990, SECTION 7-11-101 ET SEQ.

Current Status: Final

Resolution Date: 03/16/1995

Resolution:

Other Sanctions Ordered:

Sanction Details: FINED $2000.00

Sanctions Ordered: Monetary/Fine $2,000.00

Other

Disclosure 150 of 158

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Reporting Source: Firm

Initiated By: STATE OF HAWAII, DEPT OF COMMERCE AND CONSUMER AFFAIRS

Principal Sanction(s)/ReliefSought:

Undertaking

Other Sanction(s)/ReliefSought:

Date Initiated: 08/26/1998

Docket/Case Number: SEU-96-071

Principal Product Type: No Product

Other Product Type(s):

Allegations: EVEREN SECURITIES, INC. (NAME CHANGED TO FIRST UNION SECURITIES,INC.)ALLEGED THAT THE FIRM VIOLATED HAWAII UNIFORM SECURITIESACT PURSUANT TO SECTION 485-15(10) IN THAT IT FAILED TO PREVENTAND DETECT WHETHER OR NOT ITS REPS WERE PROPERLY REGISTEREDAND/OR WERE TRANSACTING SECURITIES BUSINESS IN HAWAII WITHOUTTHE APPROPRIATE REGISTRATION.

Current Status: Final

Resolution Date: 09/29/1998

Resolution:

Other Sanctions Ordered:

Sanction Details: UNDERTAKING TO MODIFY ITS SECURITIES COMPLIANCE PROCEDURESFOR REGISTRATION OF ITS REPS

Sanctions Ordered: Monetary/Fine $6,000.00

Settled

Disclosure 151 of 158

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Reporting Source: Regulator

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Date Initiated: 03/30/1999

Docket/Case Number: CMS990023

Allegations: 09/24/1999JJM -- RESPONDENT MEMBER FAILED TO REPORTTRANSACTIONS IN AN FIPS ELIGIBLE SECURITY TO FIPS WITHIN FIVEMINUTES OF EXECUTION. [NASD RULE 6420(A)]

Current Status: Final

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Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

$2,500.00 FINE

Principal Product Type: Other

Other Product Type(s):

Resolution Date: 03/30/1999

Resolution:

Other Sanctions Ordered:

Sanction Details: $2,500.00 FINE

Regulator Statement NONE

Sanctions Ordered: Monetary/Fine $2,500.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Initiated By: NASD REGULATION, INC

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

Date Initiated: 03/30/1999

Docket/Case Number: CMS9090023AWC

Principal Product Type: No Product

Other Product Type(s):

Allegations: EVEREN SECURITIES, INC. (NAME CHANGED TO FIRST UNION SECURITIES,INC.)VIOLATIONS OF THE ASSOCIATIONS FIXED INCOME PRICING SYSTEM(FIPS) ALLEGING LATE REPORTING OF TRANSACTIONS IN HIGH YIELDCORPORATE DEBT SECURITIES DURING THE PERIOD NOVEMBER 1996THROUGH FEBRUARY 1997.

Current Status: Final

Resolution Date: 03/30/1999

Resolution:

Sanctions Ordered: Monetary/Fine $2,500.00

Settled

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Other Sanctions Ordered:

Sanction Details: FINE OF $2500

Sanctions Ordered: Monetary/Fine $2,500.00

Disclosure 152 of 158

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Reporting Source: Regulator

Initiated By: NYSE DIVISION OF ENFORCEMENT

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 06/01/1999

Docket/Case Number: HPD# 99-91

Principal Product Type: Other

Other Product Type(s):

Allegations: **06/01/1999** STIPULATION AND CONSENT TO PENALTY FILED BY NYSEDIVISION OF ENFORCEMENT AND PENDING. CONSENTED TO FINDINGS: A.A FINDING BY THE HEARING PANEL THAT IT: 1. VIOLATED EXCHANGE RULE440 AND SECTION 17(A) OF THE SEA OF 1934 AND SEC REGULATIONS240.17A-3 AND 17A-4 BY FAILING TO MAKE AND PRESERVE REQUIREDRECORDS RELATING TO RECEIPT AND EXECUTION OF CUSTOMERSORDERS. 2. VIOLATED EXCHANGE RULE 342 IN THAT IT FAILED TOREASONABLY SUPERVISE AND CONTROL THE ACTIVITIES OF TISEMPLOYEES, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP ANDREVIEW, TO ASSURE COMPLIANCE WITH SEC AND EXCHANGE RULES FORMAKING AND PRESERVING TIMELY ORDER RECORDS SHOWINGALLOCATION OF TRADES TO CUSTOMER ACCOUNTS. B. THE IMPOSITIONBY THE EXCHANGE OF A PENALTY OF A CENSURE AND A FINE OF 120,000.

Current Status: Final

Resolution Date: 08/27/1999

Resolution:

Other Sanctions Ordered:

Sanction Details: **07/14/1999** DECISION #99-91 ISSUED BY NYSEHEARING PANEL. DECISION: 1. VIOLATED EXCHANGE RULE 440 ANDSECTION 17(A) OF THE SECURITIES AND EXCHANGE ACT OF 1934 ANDSEC REGULATIONS 240.17A-3 AND 17A-4 BY FAILING TO MAKE ANDPRESERVE REQUIRED RECORDS RELATING TO RECEIPT AND EXECUTIONOFCUSTOMER ORDERS. 2 VIOLATED EXCHANGE RULE 342 IN THAT IF FAILEDTO REASONABLY SUPERVISE AND CONTROL THE ACTIVITIES OF ITSEMPLOYEES, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP ANDREVIEW,TO ASSURE COMPLIANCE WITH SEC AND EXCHANGE RULES FOR MAKINGANDPRESERVING TIMELY ORDER RECORDS SHOWING ALLOCATION OFTRADES TOCUSTOMER ACCOUNTS. CONSENT TO CENSURE AND $120,000.

Sanctions Ordered: CensureMonetary/Fine

Decision

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Sanction Details: **07/14/1999** DECISION #99-91 ISSUED BY NYSEHEARING PANEL. DECISION: 1. VIOLATED EXCHANGE RULE 440 ANDSECTION 17(A) OF THE SECURITIES AND EXCHANGE ACT OF 1934 ANDSEC REGULATIONS 240.17A-3 AND 17A-4 BY FAILING TO MAKE ANDPRESERVE REQUIRED RECORDS RELATING TO RECEIPT AND EXECUTIONOFCUSTOMER ORDERS. 2 VIOLATED EXCHANGE RULE 342 IN THAT IF FAILEDTO REASONABLY SUPERVISE AND CONTROL THE ACTIVITIES OF ITSEMPLOYEES, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP ANDREVIEW,TO ASSURE COMPLIANCE WITH SEC AND EXCHANGE RULES FOR MAKINGANDPRESERVING TIMELY ORDER RECORDS SHOWING ALLOCATION OFTRADES TOCUSTOMER ACCOUNTS. CONSENT TO CENSURE AND $120,000.

Regulator Statement **08/27/1999** THE DECISION IS NOW FINAL AND IS EFFECTIVEIMMEDIATELY. CONTACT: PEGGY GERMINO (212) 656-8450

iReporting Source: Firm

Initiated By: NEW YORK STOCK EXCHANGE, INC

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

Date Initiated: 06/01/1999

Docket/Case Number: HPD#99-91

Principal Product Type: No Product

Other Product Type(s):

Allegations: EVEREN SECURITIES, INC. (CHANGED ITS NAME TO FIRST UNIONSECURITIES, INC.) 1. VIOLATED EXCHANGE RULE 440 AND SEC REGS240.17A-3 AND A-4; 2. VIOLATED RULE 342.

Current Status: Final

Resolution Date: 07/14/1999

Resolution:

Other Sanctions Ordered:

Sanction Details: CENSURE AND FINE OF $120,000.00

Sanctions Ordered: CensureMonetary/Fine $120,000.00

Stipulation and Consent

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Sanction Details: CENSURE AND FINE OF $120,000.00

Disclosure 153 of 158

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Reporting Source: Regulator

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 02/25/1999

Docket/Case Number: CMS990024

Principal Product Type:

Other Product Type(s):

Allegations:

Current Status: Final

Resolution Date: 02/25/1999

Resolution:

Other Sanctions Ordered:

Sanction Details:

Regulator Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS990024 AWC.

ON FEBRUARY 25, 1999, EVEREN SECURITIES, INC. (EVRN) WASNOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT(AWC) IT SUBMITTED WAS ACCEPTED BY NASD REGULATION, INC.'SDISCIPLINARY AFFAIRS AND THE NATIONAL ADJUDICATORY COUNCIL.THE AWC ALLEGES THAT THE FOLLOWING ACTIVITY OCCURRED:

EVRN FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BESTINTER-DEALER MARKET FOR TEN SECURITIES TRANSACTIONS ANDFAILEDTO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TOTHE CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS. THIS CONDUCT CONSTITUTES SEPARATE ANDDISTINCT VIOLATIONS OF NASD CONDUCT RULES 2110 AND 2320.

EVRN FAILED TO PRESERVE FOR A PERIOD OF NOT LESS THAN THREEYEARS MEMORANDA OF 25 BROKERAGE ORDERS THAT SHOWED THETIMERECEIPT OF THE ORDER. THIS CONDUCT CONSTITUTES A VIOLATION OFSEC RULE 17a-4 AND NASD CONDUCT RULE 3110.

EVRN FAILED TO CONTEMPORANEOUSLY EXECUTE NINE CUSTOMERLIMITORDERS AFTER IT TRADED EACH SUCH SUBJECT SECURITY FOR ITS OWNMARKET-MAKING ACCOUNT AT A PRICE THAT WOULD SATISFY EACH SUCHCUSTOMER LIMIT ORDER. THIS CONDUCT CONSTITUTES SEPARATE ANDDISTINCT VIOLATIONS OF NASD CONDUCT RULES 2110 AND IM-2110-2.

EVRN FAILED TO DISPLAY IMMEDIATELY 25 CUSTOMER LIMIT ORDERSWHEN THE ORDERS WERE AT A PRICE THAT WOULD HAVE IMPROVED THEFIRM'S BID OR OFFER IN EACH SECURITY RELATED TO THOSE ORDERS,OR WHEN THE ORDERS WERE PRICED EQUAL TO THE FIRM'S BID OROFFERAND THE NATIONAL BEST BID OR OFFER AND THE ORDERSREPRESENTEDMORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZEASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SECURITY. THISCONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF SECRULE 11Ac1-4.

EVRN WAS CENSURED AND FINED $13,000. EVRN ALSO AGREED TOPROVIDE RESTITUTION AND INTEREST TO EACH CUSTOMER WHOSEORDERSWERE TREATED IN A MANNER INCONSISTENT WITH THE DUTY OF BESTEXECUTION. SUCH RE*See FAQ #1*

Sanctions Ordered: CensureMonetary/Fine $13,000.00Disgorgement/Restitution

Acceptance, Waiver & Consent(AWC)

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LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS990024 AWC.

ON FEBRUARY 25, 1999, EVEREN SECURITIES, INC. (EVRN) WASNOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT(AWC) IT SUBMITTED WAS ACCEPTED BY NASD REGULATION, INC.'SDISCIPLINARY AFFAIRS AND THE NATIONAL ADJUDICATORY COUNCIL.THE AWC ALLEGES THAT THE FOLLOWING ACTIVITY OCCURRED:

EVRN FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BESTINTER-DEALER MARKET FOR TEN SECURITIES TRANSACTIONS ANDFAILEDTO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TOTHE CUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS. THIS CONDUCT CONSTITUTES SEPARATE ANDDISTINCT VIOLATIONS OF NASD CONDUCT RULES 2110 AND 2320.

EVRN FAILED TO PRESERVE FOR A PERIOD OF NOT LESS THAN THREEYEARS MEMORANDA OF 25 BROKERAGE ORDERS THAT SHOWED THETIMERECEIPT OF THE ORDER. THIS CONDUCT CONSTITUTES A VIOLATION OFSEC RULE 17a-4 AND NASD CONDUCT RULE 3110.

EVRN FAILED TO CONTEMPORANEOUSLY EXECUTE NINE CUSTOMERLIMITORDERS AFTER IT TRADED EACH SUCH SUBJECT SECURITY FOR ITS OWNMARKET-MAKING ACCOUNT AT A PRICE THAT WOULD SATISFY EACH SUCHCUSTOMER LIMIT ORDER. THIS CONDUCT CONSTITUTES SEPARATE ANDDISTINCT VIOLATIONS OF NASD CONDUCT RULES 2110 AND IM-2110-2.

EVRN FAILED TO DISPLAY IMMEDIATELY 25 CUSTOMER LIMIT ORDERSWHEN THE ORDERS WERE AT A PRICE THAT WOULD HAVE IMPROVED THEFIRM'S BID OR OFFER IN EACH SECURITY RELATED TO THOSE ORDERS,OR WHEN THE ORDERS WERE PRICED EQUAL TO THE FIRM'S BID OROFFERAND THE NATIONAL BEST BID OR OFFER AND THE ORDERSREPRESENTEDMORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZEASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SECURITY. THISCONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF SECRULE 11Ac1-4.

EVRN WAS CENSURED AND FINED $13,000. EVRN ALSO AGREED TOPROVIDE RESTITUTION AND INTEREST TO EACH CUSTOMER WHOSEORDERSWERE TREATED IN A MANNER INCONSISTENT WITH THE DUTY OF BESTEXECUTION. SUCH RE*See FAQ #1*

iReporting Source: Firm

Allegations: ALLEGED TO HAVE VIOLATED NASD CONDUCT RULES 2110 AND 2320 WITHRESPECT TO THE FIRM'S FAILURE TO ASCERTAIN THE BEST INTERDEALERMARKET IN EXECUTING CUSTOMER TRANSACTIONS. SEC RULE 17A-4AND NASD CONDUCT RULE 3110 WITH RESPECT TO RECORDKEEPINGREGULATIONS. NASD CONDUCT RULES 2110 AND IM-2110-2 WITHRESPECT TO EXECUTION OF CUSTOMER LIMIT ORDERS AND SEC RULE11AC1-4 WITH RESPECT TO THE FIRM'S FAILURE TO DISPLAY IMMEDIATELYCUSTOMER LIMIT ORDERS.

Current Status: Final

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Initiated By: NASD REGULATION, INC.

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

FINE

Date Initiated: 02/25/1999

Docket/Case Number: CMS990024AWC

Principal Product Type: No Product

Other Product Type(s):

ALLEGED TO HAVE VIOLATED NASD CONDUCT RULES 2110 AND 2320 WITHRESPECT TO THE FIRM'S FAILURE TO ASCERTAIN THE BEST INTERDEALERMARKET IN EXECUTING CUSTOMER TRANSACTIONS. SEC RULE 17A-4AND NASD CONDUCT RULE 3110 WITH RESPECT TO RECORDKEEPINGREGULATIONS. NASD CONDUCT RULES 2110 AND IM-2110-2 WITHRESPECT TO EXECUTION OF CUSTOMER LIMIT ORDERS AND SEC RULE11AC1-4 WITH RESPECT TO THE FIRM'S FAILURE TO DISPLAY IMMEDIATELYCUSTOMER LIMIT ORDERS.

Resolution Date: 03/02/1999

Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM AGREED TO A CENSURE AND A $13,000 FINE (COMPOSED OF A$1,000 FINE FOR RECORDKEEPING VIOLATIONS AND FINE OF $7,500 FORBEST EXECUTION VIOLATIONS, A FINE OF $2,500 FOR THE LIMIT ORDERPROTECTION INTERPRETATION VIOLATIONS, AND A FINE OF $2,000 FORTHE LIMIT ORDER DISPLAY RULE VIOLATIONS.)

Sanctions Ordered: CensureMonetary/Fine $13,000.00

Settled

Disclosure 154 of 158

i

Reporting Source: Regulator

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 03/30/1998

Docket/Case Number: CMS980025 AWC

Principal Product Type:

Other Product Type(s):

Allegations:

Current Status: Final

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Other Sanction(s)/ReliefSought:

Resolution Date: 03/30/1998

Resolution:

Other Sanctions Ordered:

Sanction Details:

Regulator Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS980025 AWC.

ON MARCH 30, 1998, EVEREN SECURITIES, INC. (EVRN) WAS NOTIFIEDTHAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) ITSUBMITTED WAS ACCEPTED BY NASD REGULATION, INC.'S DEPARTMENTOFENFORCEMENT AND THE NATIONAL ADJUDICATORY COUNCIL. THE AWCALLEGES THAT THE FOLLOWING ACTIVITY OCCURRED:

EVRN FAILED TO DESIGNATE AS LATE TO ACT TWO TRANSACTIONS INNASDAQ NATIONAL MARKET SECURITIES; AND FAILED TO REPORT ONETRANSACTION IN A NASDAQ NATIONAL MARKET SECURITY THAT IT WASREQUIRED TO REPORT. THIS CONDUCT CONSTITUTES SEPARATE ANDDISTINCT VIOLATIONS OF NASD MARKETPLACE RULE 4632.

EVRN FAILED TO REPORT TO ACT THE CONTRA SIDE EXECUTING BROKERIN 35 TRANSACTIONS IN ELIGIBLE SECURITIES IN SEPARATE AND

DISTINCT VIOLATIONS OF NASD MARKETPLACE RULE 6130(d). EVRNFAILED TO REPORT ONE TRANSACTION IN AN OTC EQUITY SECURITYTHATIT WAS REQUIRED TO REPORT, IN VIOLATION OF NASD CONDUCT RULE6620; AND FAILED TO REPORT ONE TRANSACTION IN A LISTED SECURITYTHAT IT WAS REQUIRED TO REPORT, IN VIOLATION OF NASD CONDUCTRULE 6420.

EVRN FAILED TO CONTEMPORANEOOUSLY EXECUTE SEVEN CUSTOMERLIMITORDERS AFTER IT TRADED FOR ITS MARKET MAKING ACCOUNT AT APRICETHAT WOULD SATISFY EACH CUSTOMER LIMIT ORDER. THISCONSTITUTESVIOLATIONS OF NASD CONDUCT RULE 2110 AND IM-2110-2.

EVRN FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTENSUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH THE APPLICABLE SECURITIES LAWS, REGULATIONSANDRULES REGARDING TRADE REPORTING, RECORD KEEPING,REGISTRATIONAND LIMIT ORDERS. THIS CONSTITUTES A VIOLATION OF NASD CONDUCTRULES 2110 AND 3010.

EVRN WAS CENSURED AND FINED $18,500.

**$18,500.00 PAID ON 5/11/98, INVOICE # 98-MS-378**

Sanctions Ordered: CensureMonetary/Fine $18,500.00

Acceptance, Waiver & Consent(AWC)

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LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS980025 AWC.

ON MARCH 30, 1998, EVEREN SECURITIES, INC. (EVRN) WAS NOTIFIEDTHAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) ITSUBMITTED WAS ACCEPTED BY NASD REGULATION, INC.'S DEPARTMENTOFENFORCEMENT AND THE NATIONAL ADJUDICATORY COUNCIL. THE AWCALLEGES THAT THE FOLLOWING ACTIVITY OCCURRED:

EVRN FAILED TO DESIGNATE AS LATE TO ACT TWO TRANSACTIONS INNASDAQ NATIONAL MARKET SECURITIES; AND FAILED TO REPORT ONETRANSACTION IN A NASDAQ NATIONAL MARKET SECURITY THAT IT WASREQUIRED TO REPORT. THIS CONDUCT CONSTITUTES SEPARATE ANDDISTINCT VIOLATIONS OF NASD MARKETPLACE RULE 4632.

EVRN FAILED TO REPORT TO ACT THE CONTRA SIDE EXECUTING BROKERIN 35 TRANSACTIONS IN ELIGIBLE SECURITIES IN SEPARATE AND

DISTINCT VIOLATIONS OF NASD MARKETPLACE RULE 6130(d). EVRNFAILED TO REPORT ONE TRANSACTION IN AN OTC EQUITY SECURITYTHATIT WAS REQUIRED TO REPORT, IN VIOLATION OF NASD CONDUCT RULE6620; AND FAILED TO REPORT ONE TRANSACTION IN A LISTED SECURITYTHAT IT WAS REQUIRED TO REPORT, IN VIOLATION OF NASD CONDUCTRULE 6420.

EVRN FAILED TO CONTEMPORANEOOUSLY EXECUTE SEVEN CUSTOMERLIMITORDERS AFTER IT TRADED FOR ITS MARKET MAKING ACCOUNT AT APRICETHAT WOULD SATISFY EACH CUSTOMER LIMIT ORDER. THISCONSTITUTESVIOLATIONS OF NASD CONDUCT RULE 2110 AND IM-2110-2.

EVRN FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTENSUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH THE APPLICABLE SECURITIES LAWS, REGULATIONSANDRULES REGARDING TRADE REPORTING, RECORD KEEPING,REGISTRATIONAND LIMIT ORDERS. THIS CONSTITUTES A VIOLATION OF NASD CONDUCTRULES 2110 AND 3010.

EVRN WAS CENSURED AND FINED $18,500.

**$18,500.00 PAID ON 5/11/98, INVOICE # 98-MS-378**

iReporting Source: Firm

Initiated By: NASD REGULATION, INC.

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

Date Initiated: 04/07/1998

Docket/Case Number: CMS980025

Principal Product Type: No Product

Other Product Type(s):

Allegations: ALLEGED VIOLATIONS OF RULES SET FORTH UNDER NASD CONDUCTRULES 2110 AND 3010 AND VIOLATIONS OF NASD MARKETPLACE RULE4632(A).

Current Status: Final

Resolution Date: 04/23/1998

Resolution:

Other Sanctions Ordered:

Sanction Details: CENSURE AND FINE OF $18,500 (COMPOSED OF $5000 FINE FOR THETRADE REPORTING VIOLATION, $3500 FOR THE LIMIT ORDER VIOLATIONSAND $10,000 FINE FOR THE SUPERVISION VIOLATION).

Sanctions Ordered: CensureMonetary/Fine $18,500.00

Settled

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Disclosure 155 of 158

i

Reporting Source: Regulator

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 05/29/1998

Docket/Case Number: C8A980037

Principal Product Type:

Other Product Type(s):

Allegations:

Current Status: Final

Resolution Date: 05/29/1998

Resolution:

Other Sanctions Ordered:

Sanction Details:

Regulator Statement ON MAY 29, 1998, DISTRICT NO. 8 NOTIFIED RESPONDENT EVERENSECURITIES, INC. THAT THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT NO. C8A980037 WAS ACCEPTED; THEREFORE, THE FIRM ISCENSURED AND FINED $3,000 - MSRB RULE G-8 AND G-36 - RESPONDENTMEMBER FAILED TO FILE COPIES OF THE FINAL OFFICIAL STATEMENTAND COPIES OF A COMPLETED FORM G-36(OS) WITH THE MSRB ON ATIMELY BASIS; FAILED TO ACCURATELY RECORD THE DATE OF FINALAGREEMENTS TO PURCHASE, OFFER OR SELL MUNICIPAL SECURITIES ASAPRIMARY OFFERING OF SECURITIES; AND, FAILED TO MAINTAIN ARECORD OF THE DATE THAT THE COPIES OF THE FINAL OFFICIALSTATEMENT AND COMPLETED FORM G-36(0S) WERE SENT TO THE MSRBFORFINAL AGREEMENTS TO PURCHASE, OFFER OR SELL MUNICIPALSECURITIES AS AN UNDERWRITER IN A PRIMARY OFFERING OF MUNICIPALSECURITIES).

**$3,000.00 PAID ON 6/22/98, INVOICE # 98-8A-517**

Sanctions Ordered: CensureMonetary/Fine $3,000.00

Acceptance, Waiver & Consent(AWC)

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ON MAY 29, 1998, DISTRICT NO. 8 NOTIFIED RESPONDENT EVERENSECURITIES, INC. THAT THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT NO. C8A980037 WAS ACCEPTED; THEREFORE, THE FIRM ISCENSURED AND FINED $3,000 - MSRB RULE G-8 AND G-36 - RESPONDENTMEMBER FAILED TO FILE COPIES OF THE FINAL OFFICIAL STATEMENTAND COPIES OF A COMPLETED FORM G-36(OS) WITH THE MSRB ON ATIMELY BASIS; FAILED TO ACCURATELY RECORD THE DATE OF FINALAGREEMENTS TO PURCHASE, OFFER OR SELL MUNICIPAL SECURITIES ASAPRIMARY OFFERING OF SECURITIES; AND, FAILED TO MAINTAIN ARECORD OF THE DATE THAT THE COPIES OF THE FINAL OFFICIALSTATEMENT AND COMPLETED FORM G-36(0S) WERE SENT TO THE MSRBFORFINAL AGREEMENTS TO PURCHASE, OFFER OR SELL MUNICIPALSECURITIES AS AN UNDERWRITER IN A PRIMARY OFFERING OF MUNICIPALSECURITIES).

**$3,000.00 PAID ON 6/22/98, INVOICE # 98-8A-517**

iReporting Source: Firm

Initiated By: NASD REGULATION, INC.

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

Date Initiated: 03/30/1998

Docket/Case Number: C8A980037

Principal Product Type: No Product

Other Product Type(s):

Allegations: ALLEGED VIOLATIONS OF MSRB RULE G36.

Current Status: Final

Resolution Date: 05/29/1998

Resolution:

Other Sanctions Ordered:

Sanction Details: CENSURE AND FINE OF $3,000.

Firm Statement 3/23/2000 - CORRECTED DOCKET NO. AND DATE SETTLED DUE TO DATAENTRY ERROR.

Sanctions Ordered: CensureMonetary/Fine $3,000.00

Settled

Disclosure 156 of 158

i

Reporting Source: Regulator

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Date Initiated: 04/23/1997

Docket/Case Number: CMS960098

Allegations:

Current Status: Final

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Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Principal Product Type:

Other Product Type(s):

Resolution Date: 04/23/1997

Resolution:

Other Sanctions Ordered:

Sanction Details:

Regulator Statement LETTER OF ACCEPTANCE, WAIVER & CONSENT NO. CMS960098 AWC. ONAPRIL 23, 1997, EVEREN SECURITIES, INC. (EVRN) WAS NOTIFIEDTHAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) ITSUBMITTED WAS ACCEPTED BY THE MARKET REGULATION AND THENATIONAL BUSINESS CONDUCT COMMITTEES. THE AWC ALLEGES THATEVRNVIOLATED MARKETPLACE RULES 6240(a)(4), 6240(a)(2)(A),6240(a)(1) AND 6240(b)(1) AND CONDUCT RULE 2110 IN THAT: EVRNINACCURATELY REPORTED UNIT PRICES, EXECUTION TIMES AND ISSUESYMBOLS FOR SIX TRANSACTIONS IN MANDATORY FIPS BONDS; FAILEDTODEMONSTRATE THAT 35 TRANSACTIONS IN FIPS BONDS WERE REPORTEDINA TIMELY MANNER; AND, FAILED TO REPORT 23 TRANSACTIONS IN FIPSBONDS. EVRN WAS FINED $2,500.

***$2,500.00 PAID ON 5/22/97, INVOICE #97-MS-398***

Sanctions Ordered: Monetary/Fine $2,500.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Date Initiated: 12/22/1995

Docket/Case Number: CMS960098AWC

Allegations: ALLEGED VIOLATION OF RULES SET FORTH UNDER PART IV(A)4, (A)2(A),AND PART IV(A) AND PART IV(B) OF FIPS RULES AND ARTICLE III, SECTION1 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

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

Other Sanction(s)/ReliefSought:

Docket/Case Number: CMS960098AWC

Principal Product Type: No Product

Other Product Type(s):

Resolution Date: 05/13/1997

Resolution:

Other Sanctions Ordered:

Sanction Details: FINE OF $2,500 AND AN UNDERTAKING TO SUBMIT REVISED WRITTENSUPERVISORY PROCEDURES CONCERNING FIPS IN A FORM NOTUNACCEPTABLE TO THE STAFF.

Sanctions Ordered: Monetary/Fine $2,500.00

Settled

Disclosure 157 of 158

i

Reporting Source: Regulator

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 12/01/1995

Docket/Case Number: CMS950180

Principal Product Type:

Other Product Type(s):

Allegations:

Current Status: Final

Resolution Date: 04/10/1996

Resolution:

Other Sanctions Ordered:

Sanctions Ordered: Monetary/Fine $1,500.00

Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered:

Sanction Details:

Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT NO. CMS950180 AWC

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILED ONDECEMBER 1, 1995 AGAINST EVEREN SECURITIES INC. f/k/a KEMPERSECURITIES INC. (KEMP) ALLEGING VIOLATIONS OF SECTION c)2(E) OFTHE RULES OF PRACTICE AND PROCEDURE FOR SOES AND ARTICLE III,SECTION 1 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE IN THATON 8 OCCASIONS, KEMP ENTERED ORDERS ON AN AGENCY BASIS INTOSOES FOR SECURITIES FOR WHICH KEMP WAS A REGISTERED MARKETMAKER.

ON APRIL 10, 1996 EVEREN SECURITIES WAS NOTIFIED THAT THE AWCWAS ACCEPTED BY THE MARKET SURVEILLANCE AND THE NATIONALBUSINESS CONDUCT COMMITTEES. KEMP WAS FINED $1,500. THE AWCBECAME FINAL ON APRIL 10, 1996.

***$1,500.00 PAID ON 5/02/96, INVOICE #96-MS-311***

iReporting Source: Firm

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

Date Initiated: 11/05/1995

Docket/Case Number: CMS950180

Principal Product Type: No Product

Other Product Type(s):

Allegations: ALLEGED VIOLATION OF RULES SET FORTH UNDER PART V, SECTION 2(D)OF SCHEDULE TO THE ASSOCIATION'S BY-LAWS CONCERNINGQUOTATIONS ENTERED IN THE NASDAQ SYSTEM THAT EXCEEDED THEPARAMETERS FOR THE MAXIMUM ALLOWABLE SPREAD.

Current Status: Final

Resolution Date: 04/25/1996

Resolution: Settled

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Resolution Date: 04/25/1996

Other Sanctions Ordered:

Sanction Details: CENSURE AND FINE OF $8,000.

Sanctions Ordered: CensureMonetary/Fine $8,000.00

Disclosure 158 of 158

i

Reporting Source: Regulator

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 11/15/1995

Docket/Case Number: CMS950122 AWC

Principal Product Type:

Other Product Type(s):

Allegations:

Current Status: Final

Resolution Date: 04/10/1996

Resolution:

Other Sanctions Ordered:

Sanction Details:

Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT NO. CMS950122 AWC

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILED ONNOVEMBER 15, 1995 AGAINST EVEREN SECURITIES INC. f/k/a KEMPERSECURITIES INC. (KEMP) ALLEGING VIOLATIONS OF PART V, SECTION2(d) OF SCHEDULE D TO THE ASSOCIATION'S BY-LAWS IN THAT KEMPENTERED QUOTATIONS INTO THE NASDAQ SYSTEM THAT EXCEEDED THEPARAMETERS FOR THE MAXIMUM ALLOWABLE SPREAD.

ON APRIL 10, 1996 EVEREN SECURITIES INC. WAS NOTIFIED THAT THEAWC WAS ACCEPTED BY THE MARKET SURVEILLANCE AND THE NATIONALBUSINESS CONDUCT COMMITTEES. AS SANCTIONS, KEMP WASCENSUREDAND FINED $8,000.

THE AWC BECAME FINAL ON APRIL 10, 1996.

***$8,000.00 PAID ON 5/02/96, INVOICE #96-MS-308***

Sanctions Ordered: CensureMonetary/Fine $8,000.00

Acceptance, Waiver & Consent(AWC)

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MARKET SURVEILLANCE COMMITTEE COMPLAINT NO. CMS950122 AWC

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) FILED ONNOVEMBER 15, 1995 AGAINST EVEREN SECURITIES INC. f/k/a KEMPERSECURITIES INC. (KEMP) ALLEGING VIOLATIONS OF PART V, SECTION2(d) OF SCHEDULE D TO THE ASSOCIATION'S BY-LAWS IN THAT KEMPENTERED QUOTATIONS INTO THE NASDAQ SYSTEM THAT EXCEEDED THEPARAMETERS FOR THE MAXIMUM ALLOWABLE SPREAD.

ON APRIL 10, 1996 EVEREN SECURITIES INC. WAS NOTIFIED THAT THEAWC WAS ACCEPTED BY THE MARKET SURVEILLANCE AND THE NATIONALBUSINESS CONDUCT COMMITTEES. AS SANCTIONS, KEMP WASCENSUREDAND FINED $8,000.

THE AWC BECAME FINAL ON APRIL 10, 1996.

***$8,000.00 PAID ON 5/02/96, INVOICE #96-MS-308***

iReporting Source: Firm

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

Date Initiated: 11/15/1995

Docket/Case Number: CMS950122

Principal Product Type: No Product

Other Product Type(s):

Allegations: ALLEGED VIOLATION OF RULES SET FORTH UNDER PART V, SECTION 2(D)OF SCHEDULE TO THE ASSOCIATION'S BY-LAWS CONCERNINGQUOTATIONS ENTERED IN THE NASDAQ SYSTEM THAT EXCEEDED THEPARAMETERS FOR THE MAXIMUM ALLOWABLE SPREAD.

Current Status: Final

Resolution Date: 04/25/1996

Resolution:

Other Sanctions Ordered:

Sanction Details: CENSURE AND FINE OF $1500.

Sanctions Ordered: CensureMonetary/Fine $1,500.00

Settled

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Regulatory - Pending

This type of disclosure event may include a pending formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulatory agency such as the Securities and ExchangeCommission, foreign financial regulatory body) for alleged violations of investment-related rules or regulations.

Disclosure 1 of 1

Reporting Source: Firm

Initiated By: STATE OF SOUTH DAKOTADEPARTMENT OF REVENUE & REGULATIONDIVISION OF SECURITIES

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

ORDER TO SHOW CAUSE

Date Initiated: 08/07/2008

Docket/Case Number: N/A

Principal Product Type: No Product

Other Product Type(s):

Allegations: ON AUGUST 11, 2008, WACHOVIA SECURITIES RECEIVED AN ORDER TOSHOW CAUSE FROM THE STATE OF SOUTH DAKOTA DATED AUGUST 7,2008, COMMENCING DISCIPLINARY PROCEEDINGS AGAINST THE FIRMBASED ON THE STATE'S INVESTIGATION OF TWO SEPARATE CUSTOMERSALES PRACTICE COMPLAINTS.

Current Status: Pending

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Civil - Final

This type of disclosure event involves (1) an injunction issued by a foreign or domestic court within the last 10 years inconnection with investment-related activity, (2) a finding by a court of a violation of any investment-related statute orregulation, or (3) an action dismissed by a court pursuant to a settlement agreement.

Disclosure 1 of 2

Reporting Source: Regulator

Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Date Court Action Filed: 02/05/2009

Principal Product Type: Other

Court Details: UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OFILLINOIS, SECURITIES AND EXCHANGE COMMISSION V. WACHOVIASECURITIES, LLC, CIVIL CASE NO. 09 CV 743 (N.D. ILL.)

SEC LITIGATION RELEASE 20885, FEBRUARY 5, 2009: SECTION 15(C) OFTHE SECURITIES EXCHANGE ACT OF 1934 - THE SECURITIES ANDEXCHANGE COMMISSION ANNOUNCED A SETTLEMENT WITH WACHOVIASECURITIES, LLC THAT WILL PROVIDE MORE THAN $7 BILLION INLIQUIDITY TO THOUSANDS OF CUSTOMERS WHO INVESTED IN AUCTIONRATE SECURITIES (ARS) BEFORE THE MARKET FOR THOSE SECURITIESCOLLAPSED. THE SETTLEMENT RESOLVES THE SEC'S CHARGES THATWACHOVIA MISLED INVESTORS REGARDING THE LIQUIDITY RISKSASSOCIATED WITH ARS THAT IT UNDERWROTE, MARKETED AND SOLD.THE SEC'S COMPLAINT ALLEGES THAT WACHOVIA AND ANOTHER FIRM,WHOSE BROKER-DEALER OPERATIONS WERE CONSOLIDATED INTOWACHOVIA MISREPRESENTED TO CUSTOMERS THAT ARS WERE SAFE,HIGHLY LIQUID INVESTMENTS THAT WERE COMPARABLE TO CASH ORMONEY MARKET INSTRUMENTS. ACCORDING TO THE SEC'S COMPLAINT,WACHOVIA REINFORCED THE PERCEPTION OF LIQUIDITY BY ROUTINELYPURCHASING ARS FROM THE OTHER FIRM'S CUSTOMERS BETWEENAUCTIONS, WITHOUT TELLING CUSTOMERS THAT WACHOVIA'SWILLINGNESS TO DO SO DEPENDED UPON THE CONTINUED SUCCESS OFTHE AUCTIONS. THE SEC'S COMPLAINT ALLEGES THAT WACHOVIABECAME AWARE OF MOUNTING EVIDENCE THAT PUT THE FIRM ON NOTICETHAT THE RISK OF AUCTION FAILURES HAD MATERIALLY INCREASED.WACHOVIA, NEVERTHELESS, CONTINUED TO MARKET ARS TO ITSCUSTOMERS AS HIGHLY LIQUID INVESTMENTS. WACHOVIA FOLLOWEDTHE LEAD OF OTHER BROKER-DEALERS AND DECIDED TO STOPSUPPORTING AUCTIONS. WITHOUT BROKER-DEALER SUPPORT, ARSAUCTIONS FAILED AND THOUSANDS OF WACHOVIA'S CUSTOMERS WERELEFT HOLDING BILLIONS OF DOLLARS IN ILLIQUID ARS, WITHOUT ANYPRACTICAL MEANS OF REDEEMING, SELLING OR DERIVING VALUE FROMTHEM.

Allegations:

Current Status: Final

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Relief Sought: Injunction

Other Relief Sought: PERMANENT INJUNCTION, FINANCIAL PENALTIES

Principal Product Type: Other

Other Product Types: AUCTION RATE SECURITIES

Resolution: Judgment Rendered

Resolution Date: 02/17/2009

Other Sanctions: UNDERTAKINGS: THE SETTLEMENT, WHICH IS SUBJECT TO COURTAPPROVAL, PROVIDES, AMONG OTHER THINGS, THAT: WACHOVIA WILLOFFER TO BUY BACK ARS FROM ALL INVESTORS WHO PURCHASED ARSFROM WACHOVIA INTO ACCOUNTS MAINTAINED AT WACHOVIA ON ORBEFORE FEB. 13, 2008. WACHOVIA'S BUYBACK HAS TWO PHASES. IN THEFIRST PHASE, WHICH ENDED ON NOV. 28, 2008, WACHOVIA OFFERED TOPURCHASE ARS HELD BY NATURAL PERSONS, NOT-FOR-PROFIT ANDRELIGIOUS ORGANIZATIONS AND FOR OTHER ACCOUNTS WITH ACCOUNTVALUES OR HOUSEHOLD VALUES UP TO $10 MILLION. AS OF NOV. 28, ITPURCHASED OVER $6.2 BILLION OF ELIGIBLE ARS FROM CUSTOMERS.SECOND, BEGINNING NO LATER THAT JUNE 10 AND ENDING NO LATERTHAN JUNE 30, 2009, WACHOVIA WILL OFFER TO PURCHASE ARS HELD BYALL OTHER INVESTORS. WACHOVIA WILL PAY CUSTOMERS WHO SOLDTHEIR ARS BELOW PAR BETWEEN FEB. 13, 2008, AND NOV. 10, 2008, THEDIFFERENCE BETWEEN PAR AND THE SALE PRICE OF THE ARS, PLUSREASONABLE INTEREST. WACHOVIA WILL COMPENSATE CUSTOMERSWHO TOOK OUT LOANS FROM WACHOVIA AFTER FEB. 13, 2008, BECAUSEOF LIQUIDITY CONCERNS BY REIMBURSING CUSTOMERS FOR NO LESSTHAN THE NEGATIVE CARRY ASSOCIATED WITH ANY SUCH LOANS.WACHOVIA WILL OFFER TO LEND ITS CUSTOMERS THE FULL PAR VALUEOF THEIR ARS, PENDING THE CONTEMPLATED BUYBACK, WITH INTERESTRATES SET SO THAT CUSTOMERS WILL HAVE NO NEGATIVE CARRY ONTHEIR LOANS. FURTHER, IF ELIGIBLE CUSTOMERS INCURREDCONSEQUENTIAL DAMAGES BECAUSE OF THE ILLIQUIDITY OF THEIR ARS,THEY MAY PARTICIPATE IN SPECIAL FINANCIAL INDUSTRY REGULATORYAUTHORITY (FINRA) ARBITRATIONS.

Sanction Details: SEC JUDGMENT CIVIL CASE 09-CV-743, FEBRUARY 17, 2009: THESECURITIES AND EXCHANGE COMMISSION HAVING FILED A COMPLAINTAND DEFENDANT WACHOVIA SECURITIES, LLC HAVING ENTERED AGENERAL APPEARANCE; CONSENTED TO THE COURT'S JURISDICTIONOVER DEFENDANT AND THE SUBJECT MATTER OF THIS ACTION;CONSENTED TO ENTRY OF THIS JUDGMENT WITHOUT ADMITTING ORDENYING THE ALLEGATIONS OF THE COMPLAINT (EXCEPT AS TOJURISDICTION); WAIVED FINDINGS OF FACT AND CONCLUSIONS OF LAW;AND WAIVED ANY RIGHT TO APPEAL FROM THIS JUDGMENT:IT IS HEREBY ORDERED, ADJUDGED, AND DECREED THAT DEFENDANTAND DEFENDANT'S AGENTS, SERVANTS, EMPLOYEES, ATTORNEYS, ANDALL PERSONS IN ACTIVE CONCERT OR PARTICIPATION WITH THEM WHORECEIVE ACTUAL NOTICE OF THIS JUDGMENT BY PERSONAL SERVICE OROTHERWISE ARE PERMANENTLY RESTRAINED AND ENJOINED FROMVIOLATING, DIRECTLY OR INDIRECTLY, SECTION 15(C)(1) OF THESECURITIES EXCHANGE ACT OF 1934; THE COURT SHALL DETERMINEWHETHER IT IS APPROPRIATE TO ORDER A CIVIL PENALTY AND, IF SO, THEAMOUNT OF THE CIVIL PENALTY; THE CONSENT IS INCORPORATEDHEREIN WITH THE SAME FORCE AND EFFECT AS IF FULLY SET FORTHHEREIN, AND THAT DEFENDANT SHALL COMPLY WITH ALL OF THEUNDERTAKINGS AND AGREEMENTS SET FORTH THEREIN; THIS COURTSHALL RETAIN JURISDICTION OF THIS MATTER FOR THE PURPOSES OFENFORCING THE TERMS OF THIS JUDGMENT.WITHOUT ADMITTING ORDENYING THE SEC'S ALLEGATIONS, WACHOVIA AGREED TO BEPERMANENTLY ENJOINED FROM VIOLATIONS OF SECTION 15(C) OF THESECURITIES EXCHANGE ACT OF 1934, THE BROKER-DEALER FRAUDPROVISION, AND TO COMPLY WITH A NUMBER OF UNDERTAKINGS. AFTERWACHOVIA HAS COMPLETED ITS OBLIGATIONS UNDER THE SETTLEMENTAGREEMENT, THE SEC WILL DECIDE WHETHER TO SEEK A FINANCIALPENALTY.

Cease and Desist/InjunctionSanctions Ordered or ReliefGranted:

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SEC JUDGMENT CIVIL CASE 09-CV-743, FEBRUARY 17, 2009: THESECURITIES AND EXCHANGE COMMISSION HAVING FILED A COMPLAINTAND DEFENDANT WACHOVIA SECURITIES, LLC HAVING ENTERED AGENERAL APPEARANCE; CONSENTED TO THE COURT'S JURISDICTIONOVER DEFENDANT AND THE SUBJECT MATTER OF THIS ACTION;CONSENTED TO ENTRY OF THIS JUDGMENT WITHOUT ADMITTING ORDENYING THE ALLEGATIONS OF THE COMPLAINT (EXCEPT AS TOJURISDICTION); WAIVED FINDINGS OF FACT AND CONCLUSIONS OF LAW;AND WAIVED ANY RIGHT TO APPEAL FROM THIS JUDGMENT:IT IS HEREBY ORDERED, ADJUDGED, AND DECREED THAT DEFENDANTAND DEFENDANT'S AGENTS, SERVANTS, EMPLOYEES, ATTORNEYS, ANDALL PERSONS IN ACTIVE CONCERT OR PARTICIPATION WITH THEM WHORECEIVE ACTUAL NOTICE OF THIS JUDGMENT BY PERSONAL SERVICE OROTHERWISE ARE PERMANENTLY RESTRAINED AND ENJOINED FROMVIOLATING, DIRECTLY OR INDIRECTLY, SECTION 15(C)(1) OF THESECURITIES EXCHANGE ACT OF 1934; THE COURT SHALL DETERMINEWHETHER IT IS APPROPRIATE TO ORDER A CIVIL PENALTY AND, IF SO, THEAMOUNT OF THE CIVIL PENALTY; THE CONSENT IS INCORPORATEDHEREIN WITH THE SAME FORCE AND EFFECT AS IF FULLY SET FORTHHEREIN, AND THAT DEFENDANT SHALL COMPLY WITH ALL OF THEUNDERTAKINGS AND AGREEMENTS SET FORTH THEREIN; THIS COURTSHALL RETAIN JURISDICTION OF THIS MATTER FOR THE PURPOSES OFENFORCING THE TERMS OF THIS JUDGMENT.WITHOUT ADMITTING ORDENYING THE SEC'S ALLEGATIONS, WACHOVIA AGREED TO BEPERMANENTLY ENJOINED FROM VIOLATIONS OF SECTION 15(C) OF THESECURITIES EXCHANGE ACT OF 1934, THE BROKER-DEALER FRAUDPROVISION, AND TO COMPLY WITH A NUMBER OF UNDERTAKINGS. AFTERWACHOVIA HAS COMPLETED ITS OBLIGATIONS UNDER THE SETTLEMENTAGREEMENT, THE SEC WILL DECIDE WHETHER TO SEEK A FINANCIALPENALTY.

Regulator Statement SEC LITIGATION RELEASE 21585, JUNE 30, 2010: THE SECURITIES ANDEXCHANGE COMMISSION ANNOUNCED THAT WACHOVIA SECURITIES LLCTHAT SETTLED THE COMMISSION'S AUCTION RATE SECURITIES (ARS)CHARGES AGAINST IT HAS SATISFIED ITS OBLIGATIONS UNDER THESETTLEMENT. WACHOVIA WAS REQUIRED TO OFFER TO PURCHASE ARSAT PAR FROM INDIVIDUAL, CHARITABLE, AND SMALL BUSINESSCUSTOMERS. WACHOVIA ALSO AGREED TO OFFER TO PURCHASE ARSFROM ALL OF ITS INSTITUTIONAL CUSTOMERS AS WELL. NEARLY 100% OFTHESE CUSTOMERS HAVE ACCEPTED THE OFFER. WACHOVIAPURCHASED ARS FROM ITS ELIGIBLE CUSTOMERS IN THE AMOUNT OF$7.45 BILLION. WACHOVIA ALSO MET ITS OTHER SETTLEMENTOBLIGATIONS, INCLUDING COMPENSATING INVESTORS WHO SOLD ARSBELOW PAR, REIMBURSING INVESTORS FOR EXCESS INTEREST COSTSASSOCIATED WITH LOANS TAKEN OUT DUE TO ARS ILLIQUIDITY, ANDPARTICIPATING IN SPECIAL ARBITRATION PROCEEDINGS BEFORE THEFINANCIAL INDUSTRY REGULATORY AUTHORITY. THE FIRM ALSOSUBMITTED PERIODIC REPORTS TO, AND MET QUARTERLY WITH, SECSTAFF REGARDING ITS PROGRESS ON MEETING THE SETTLEMENTOBLIGATIONS. TO ENSURE COMPLIANCE WITH THE TERMS, THESETTLEMENT PROVIDED FOR A POTENTIAL DEFERRED PENALTY IF THEFIRM DID NOT MEET ITS SETTLEMENT OBLIGATIONS. THE SEC HASDETERMINED THAT BASED ON THE FIRM'S COMPLIANCE WITH THESETTLEMENT, AS WELL AS OTHER FACTORS, NO PENALTIES WILL BEPURSUED.

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Page 311: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

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SEC LITIGATION RELEASE 21585, JUNE 30, 2010: THE SECURITIES ANDEXCHANGE COMMISSION ANNOUNCED THAT WACHOVIA SECURITIES LLCTHAT SETTLED THE COMMISSION'S AUCTION RATE SECURITIES (ARS)CHARGES AGAINST IT HAS SATISFIED ITS OBLIGATIONS UNDER THESETTLEMENT. WACHOVIA WAS REQUIRED TO OFFER TO PURCHASE ARSAT PAR FROM INDIVIDUAL, CHARITABLE, AND SMALL BUSINESSCUSTOMERS. WACHOVIA ALSO AGREED TO OFFER TO PURCHASE ARSFROM ALL OF ITS INSTITUTIONAL CUSTOMERS AS WELL. NEARLY 100% OFTHESE CUSTOMERS HAVE ACCEPTED THE OFFER. WACHOVIAPURCHASED ARS FROM ITS ELIGIBLE CUSTOMERS IN THE AMOUNT OF$7.45 BILLION. WACHOVIA ALSO MET ITS OTHER SETTLEMENTOBLIGATIONS, INCLUDING COMPENSATING INVESTORS WHO SOLD ARSBELOW PAR, REIMBURSING INVESTORS FOR EXCESS INTEREST COSTSASSOCIATED WITH LOANS TAKEN OUT DUE TO ARS ILLIQUIDITY, ANDPARTICIPATING IN SPECIAL ARBITRATION PROCEEDINGS BEFORE THEFINANCIAL INDUSTRY REGULATORY AUTHORITY. THE FIRM ALSOSUBMITTED PERIODIC REPORTS TO, AND MET QUARTERLY WITH, SECSTAFF REGARDING ITS PROGRESS ON MEETING THE SETTLEMENTOBLIGATIONS. TO ENSURE COMPLIANCE WITH THE TERMS, THESETTLEMENT PROVIDED FOR A POTENTIAL DEFERRED PENALTY IF THEFIRM DID NOT MEET ITS SETTLEMENT OBLIGATIONS. THE SEC HASDETERMINED THAT BASED ON THE FIRM'S COMPLIANCE WITH THESETTLEMENT, AS WELL AS OTHER FACTORS, NO PENALTIES WILL BEPURSUED.

iReporting Source: Firm

Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Date Court Action Filed: 02/05/2009

Principal Product Type: Other

Other Product Types: AUCTION RATE SECURITIES (ARS)

Court Details: UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OFILLINOIS, SECURITIES AND EXCHANGE COMMISSION V. WACHOVIASECURITIES, LLC, CIVIL CASE NO. 09 CV 743 (N.D. ILL.)

SEC LITIGATION RELEASE 20885, FEBRUARY 5, 2009: SECTION 15(C) OFTHE SECURITIES EXCHANGE ACT OF 1934 - THE SECURITIES ANDEXCHANGE COMMISSION ANNOUNCED A SETTLEMENT WITH WACHOVIASECURITIES, LLC THAT WILL PROVIDE MORE THAN $7 BILLION INLIQUIDITY TO THOUSANDS OF CUSTOMERS WHO INVESTED IN AUCTIONRATE SECURITIES (ARS) BEFORE THE MARKET FOR THOSE SECURITIESCOLLAPSED. THE SETTLEMENT RESOLVES THE SEC'S CHARGES THATWACHOVIA MISLED INVESTORS REGARDING THE LIQUIDITY RISKSASSOCIATED WITH ARS THAT IT UNDERWROTE, MARKETED AND SOLD.THE SEC'S COMPLAINT ALLEGES THAT WACHOVIA AND ANOTHER FIRM,WHOSE BROKER-DEALER OPERATIONS WERE CONSOLIDATED INTOWACHOVIA MISREPRESENTED TO CUSTOMERS THAT ARS WERE SAFE,HIGHLY LIQUID INVESTMENTS THAT WERE COMPARABLE TO CASH ORMONEY MARKET INSTRUMENTS. ACCORDING TO THE SEC'S COMPLAINT,WACHOVIA REINFORCED THE PERCEPTION OF LIQUIDITY BY ROUTINELYPURCHASING ARS FROM THE OTHER FIRM'S CUSTOMERS BETWEENAUCTIONS, WITHOUT TELLING CUSTOMERS THAT WACHOVIA'SWILLINGNESS TO DO SO DEPENDED UPON THE CONTINUED SUCCESS OFTHE AUCTIONS. THE SEC'S COMPLAINT ALLEGES THAT WACHOVIABECAME AWARE OF MOUNTING EVIDENCE THAT PUT THE FIRM ON NOTICETHAT THE RISK OF AUCTION FAILURES HAD MATERIALLY INCREASED.WACHOVIA, NEVERTHELESS, CONTINUED TO MARKET ARS TO ITSCUSTOMERS AS HIGHLY LIQUID INVESTMENTS. WACHOVIA FOLLOWEDTHE LEAD OF OTHER BROKER-DEALERS AND DECIDED TO STOPSUPPORTING AUCTIONS. WITHOUT BROKER-DEALER SUPPORT, ARSAUCTIONS FAILED AND THOUSANDS OF WACHOVIA'S CUSTOMERS WERELEFT HOLDING BILLIONS OF DOLLARS IN ILLIQUID ARS, WITHOUT ANYPRACTICAL MEANS OF REDEEMING, SELLING OR DERIVING VALUE FROMTHEM.

Allegations:

Current Status: Final

309©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Relief Sought: Injunction

Other Relief Sought: PERMANENT INJUNCTION, FINANCIAL PENALTIES

Other Product Types: AUCTION RATE SECURITIES (ARS)

Resolution: Judgment Rendered

Resolution Date: 02/17/2009

Other Sanctions: UNDERTAKINGS: THE SETTLEMENT, WHICH IS SUBJECT TO COURTAPPROVAL, PROVIDES, AMONG OTHER THINGS, THAT: WACHOVIA WILLOFFER TO BUY BACK ARS FROM ALL INVESTORS WHO PURCHASED ARSFROM WACHOVIA INTO ACCOUNTS MAINTAINED AT WACHOVIA ON ORBEFORE FEB. 13, 2008. WACHOVIA'S BUYBACK HAS TWO PHASES. IN THEFIRST PHASE, WHICH ENDED ON NOV. 28, 2008, WACHOVIA OFFERED TOPURCHASE ARS HELD BY NATURAL PERSONS, NOT-FOR-PROFIT ANDRELIGIOUS ORGANIZATIONS AND FOR OTHER ACCOUNTS WITH ACCOUNTVALUES OR HOUSEHOLD VALUES UP TO $10 MILLION. AS OF NOV. 28, ITPURCHASED OVER $6.2 BILLION OF ELIGIBLE ARS FROM CUSTOMERS.SECOND, BEGINNING NO LATER THAT JUNE 10 AND ENDING NO LATERTHAN JUNE 30, 2009, WACHOVIA WILL OFFER TO PURCHASE ARS HELD BYALL OTHER INVESTORS. WACHOVIA WILL PAY CUSTOMERS WHO SOLDTHEIR ARS BELOW PAR BETWEEN FEB. 13, 2008, AND NOV. 10, 2008, THEDIFFERENCE BETWEEN PAR AND THE SALE PRICE OF THE ARS, PLUSREASONABLE INTEREST. WACHOVIA WILL COMPENSATE CUSTOMERSWHO TOOK OUT LOANS FROM WACHOVIA AFTER FEB. 13, 2008, BECAUSEOF LIQUIDITY CONCERNS BY REIMBURSING CUSTOMERS FOR NO LESSTHAN THE NEGATIVE CARRY ASSOCIATED WITH ANY SUCH LOANS.WACHOVIA WILL OFFER TO LEND ITS CUSTOMERS THE FULL PAR VALUEOF THEIR ARS, PENDING THE CONTEMPLATED BUYBACK, WITH INTERESTRATES SET SO THAT CUSTOMERS WILL HAVE NO NEGATIVE CARRY ONTHEIR LOANS. FURTHER, IF ELIGIBLE CUSTOMERS INCURREDCONSEQUENTIAL DAMAGES BECAUSE OF THE ILLIQUIDITY OF THEIR ARS,THEY MAY PARTICIPATE IN SPECIAL FINANCIAL INDUSTRY REGULATORYAUTHORITY (FINRA) ARBITRATIONS.

Sanction Details: SEC JUDGMENT CIVIL CASE 09-CV-743, FEBRUARY 17, 2009: THESECURITIES AND EXCHANGE COMMISSION HAVING FILED A COMPLAINTAND DEFENDANT WACHOVIA SECURITIES, LLC HAVING ENTERED AGENERAL APPEARANCE; CONSENTED TO THE COURT'S JURISDICTIONOVER DEFENDANT AND THE SUBJECT MATTER OF THIS ACTION;CONSENTED TO ENTRY OF THIS JUDGMENT WITHOUT ADMITTING ORDENYING THE ALLEGATIONS OF THE COMPLAINT (EXCEPT AS TOJURISDICTION); WAIVED FINDINGS OF FACT AND CONCLUSIONS OF LAW;AND WAIVED ANY RIGHT TO APPEAL FROM THIS JUDGMENT: IT IS HEREBYORDERED, ADJUDGED, AND DECREED THAT DEFENDANT ANDDEFENDANT'S AGENTS, SERVANTS, EMPLOYEES, ATTORNEYS, AND ALLPERSONS IN ACTIVE CONCERT OR PARTICIPATION WITH THEM WHORECEIVE ACTUAL NOTICE OF THIS JUDGMENT BY PERSONAL SERVICE OROTHERWISE ARE PERMANENTLY RESTRAINED AND ENJOINED FROMVIOLATING, DIRECTLY OR INDIRECTLY, SECTION 15(C)(1) OF THESECURITIES EXCHANGE ACT OF 1934; THE COURT SHALL DETERMINEWHETHER IT IS APPROPRIATE TO ORDER A CIVIL PENALTY AND, IF SO, THEAMOUNT OF THE CIVIL PENALTY; THE CONSENT IS INCORPORATEDHEREIN WITH THE SAME FORCE AND EFFECT AS IF FULLY SET FORTHHEREIN, AND THAT DEFENDANT SHALL COMPLY WITH ALL OF THEUNDERTAKINGS AND AGREEMENTS SET FORTH THEREIN; THIS COURTSHALL RETAIN JURISDICTION OF THIS MATTER FOR THE PURPOSES OFENFORCING THE TERMS OF THIS JUDGMENT.WITHOUT ADMITTING ORDENYING THE SEC'S ALLEGATIONS, WACHOVIA AGREED TO BEPERMANENTLY ENJOINED FROM VIOLATIONS OF SECTION 15(C) OF THESECURITIES EXCHANGE ACT OF 1934, THE BROKER-DEALER FRAUDPROVISION, AND TO COMPLY WITH A NUMBER OF UNDERTAKINGS. AFTERWACHOVIA HAS COMPLETED ITS OBLIGATIONS UNDER THE SETTLEMENTAGREEMENT, THE SEC WILL DECIDE WHETHER TO SEEK A FINANCIALPENALTY.

Cease and Desist/InjunctionSanctions Ordered or ReliefGranted:

310©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 313: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

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SEC JUDGMENT CIVIL CASE 09-CV-743, FEBRUARY 17, 2009: THESECURITIES AND EXCHANGE COMMISSION HAVING FILED A COMPLAINTAND DEFENDANT WACHOVIA SECURITIES, LLC HAVING ENTERED AGENERAL APPEARANCE; CONSENTED TO THE COURT'S JURISDICTIONOVER DEFENDANT AND THE SUBJECT MATTER OF THIS ACTION;CONSENTED TO ENTRY OF THIS JUDGMENT WITHOUT ADMITTING ORDENYING THE ALLEGATIONS OF THE COMPLAINT (EXCEPT AS TOJURISDICTION); WAIVED FINDINGS OF FACT AND CONCLUSIONS OF LAW;AND WAIVED ANY RIGHT TO APPEAL FROM THIS JUDGMENT: IT IS HEREBYORDERED, ADJUDGED, AND DECREED THAT DEFENDANT ANDDEFENDANT'S AGENTS, SERVANTS, EMPLOYEES, ATTORNEYS, AND ALLPERSONS IN ACTIVE CONCERT OR PARTICIPATION WITH THEM WHORECEIVE ACTUAL NOTICE OF THIS JUDGMENT BY PERSONAL SERVICE OROTHERWISE ARE PERMANENTLY RESTRAINED AND ENJOINED FROMVIOLATING, DIRECTLY OR INDIRECTLY, SECTION 15(C)(1) OF THESECURITIES EXCHANGE ACT OF 1934; THE COURT SHALL DETERMINEWHETHER IT IS APPROPRIATE TO ORDER A CIVIL PENALTY AND, IF SO, THEAMOUNT OF THE CIVIL PENALTY; THE CONSENT IS INCORPORATEDHEREIN WITH THE SAME FORCE AND EFFECT AS IF FULLY SET FORTHHEREIN, AND THAT DEFENDANT SHALL COMPLY WITH ALL OF THEUNDERTAKINGS AND AGREEMENTS SET FORTH THEREIN; THIS COURTSHALL RETAIN JURISDICTION OF THIS MATTER FOR THE PURPOSES OFENFORCING THE TERMS OF THIS JUDGMENT.WITHOUT ADMITTING ORDENYING THE SEC'S ALLEGATIONS, WACHOVIA AGREED TO BEPERMANENTLY ENJOINED FROM VIOLATIONS OF SECTION 15(C) OF THESECURITIES EXCHANGE ACT OF 1934, THE BROKER-DEALER FRAUDPROVISION, AND TO COMPLY WITH A NUMBER OF UNDERTAKINGS. AFTERWACHOVIA HAS COMPLETED ITS OBLIGATIONS UNDER THE SETTLEMENTAGREEMENT, THE SEC WILL DECIDE WHETHER TO SEEK A FINANCIALPENALTY.

Firm Statement SEC LITIGATION RELEASE 21585, JUNE 30, 2010: THE SECURITIES ANDEXCHANGE COMMISSION ANNOUNCED THAT WACHOVIA SECURITIES LLCTHAT SETTLED THE COMMISSION'S AUCTION RATE SECURITIES (ARS)CHARGES AGAINST IT HAS SATISFIED ITS OBLIGATIONS UNDER THESETTLEMENT. WACHOVIA WAS REQUIRED TO OFFER TO PURCHASE ARSAT PAR FROM INDIVIDUAL, CHARITABLE, AND SMALL BUSINESSCUSTOMERS. WACHOVIA ALSO AGREED TO OFFER TO PURCHASE ARSFROM ALL OF ITS INSTITUTIONAL CUSTOMERS AS WELL. NEARLY 100% OFTHESE CUSTOMERS HAVE ACCEPTED THE OFFER. WACHOVIAPURCHASED ARS FROM ITS ELIGIBLE CUSTOMERS IN THE AMOUNT OF$7.45 BILLION. WACHOVIA ALSO MET ITS OTHER SETTLEMENTOBLIGATIONS, INCLUDING COMPENSATING INVESTORS WHO SOLD ARSBELOW PAR, REIMBURSING INVESTORS FOR EXCESS INTEREST COSTSASSOCIATED WITH LOANS TAKEN OUT DUE TO ARS ILLIQUIDITY, ANDPARTICIPATING IN SPECIAL ARBITRATION PROCEEDINGS BEFORE THEFINANCIAL INDUSTRY REGULATORY AUTHORITY. THE FIRM ALSOSUBMITTED PERIODIC REPORTS TO, AND MET QUARTERLY WITH, SECSTAFF REGARDING ITS PROGRESS ON MEETING THE SETTLEMENTOBLIGATIONS. TO ENSURE COMPLIANCE WITH THE TERMS, THESETTLEMENT PROVIDED FOR A POTENTIAL DEFERRED PENALTY IF THEFIRM DID NOT MEET ITS SETTLEMENT OBLIGATIONS. THE SEC HASDETERMINED THAT BASED ON THE FIRM'S COMPLIANCE WITH THESETTLEMENT, AS WELL AS OTHER FACTORS, NO PENALTIES WILL BEPURSUED.

311©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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SEC LITIGATION RELEASE 21585, JUNE 30, 2010: THE SECURITIES ANDEXCHANGE COMMISSION ANNOUNCED THAT WACHOVIA SECURITIES LLCTHAT SETTLED THE COMMISSION'S AUCTION RATE SECURITIES (ARS)CHARGES AGAINST IT HAS SATISFIED ITS OBLIGATIONS UNDER THESETTLEMENT. WACHOVIA WAS REQUIRED TO OFFER TO PURCHASE ARSAT PAR FROM INDIVIDUAL, CHARITABLE, AND SMALL BUSINESSCUSTOMERS. WACHOVIA ALSO AGREED TO OFFER TO PURCHASE ARSFROM ALL OF ITS INSTITUTIONAL CUSTOMERS AS WELL. NEARLY 100% OFTHESE CUSTOMERS HAVE ACCEPTED THE OFFER. WACHOVIAPURCHASED ARS FROM ITS ELIGIBLE CUSTOMERS IN THE AMOUNT OF$7.45 BILLION. WACHOVIA ALSO MET ITS OTHER SETTLEMENTOBLIGATIONS, INCLUDING COMPENSATING INVESTORS WHO SOLD ARSBELOW PAR, REIMBURSING INVESTORS FOR EXCESS INTEREST COSTSASSOCIATED WITH LOANS TAKEN OUT DUE TO ARS ILLIQUIDITY, ANDPARTICIPATING IN SPECIAL ARBITRATION PROCEEDINGS BEFORE THEFINANCIAL INDUSTRY REGULATORY AUTHORITY. THE FIRM ALSOSUBMITTED PERIODIC REPORTS TO, AND MET QUARTERLY WITH, SECSTAFF REGARDING ITS PROGRESS ON MEETING THE SETTLEMENTOBLIGATIONS. TO ENSURE COMPLIANCE WITH THE TERMS, THESETTLEMENT PROVIDED FOR A POTENTIAL DEFERRED PENALTY IF THEFIRM DID NOT MEET ITS SETTLEMENT OBLIGATIONS. THE SEC HASDETERMINED THAT BASED ON THE FIRM'S COMPLIANCE WITH THESETTLEMENT, AS WELL AS OTHER FACTORS, NO PENALTIES WILL BEPURSUED.

Disclosure 2 of 2

i

Reporting Source: Regulator

Initiated By: STATE OF CALIFORNIA - DEPARTMENT OF CORPORATIONS

Relief Sought: Other

Other Relief Sought: CIV - CIVIL COMPLAINT FILED.

Date Court Action Filed: 09/30/2003

Principal Product Type: Other

Other Product Types: EQUITY - LISTED (COMMON PREFERRED STOCK).

Court Details: ORANGE COUNTY SUPERIOR COURT - SANTA ANA - CALIFORNIACASE NO. 03CC00433.

AGENT MISAPPORPRIATED CLIENT FUNDS AND WACHOVIA FAILED TOSUPERVISE ITS AGENTS AND TO ENFORCE WRITTEN PROCEDURES.

Allegations:

Current Status: Final

Date Notice/Process Served: 09/30/2003

Resolution: Dismissed

Resolution Date: 01/10/2005

Other Sanctions:

Sanction Details:

Regulator Statement LONG MISAPPROPRIATED FUNDS FROM 16 CLIENT ACCOUNTS WITHINVESTOR LOSSES TOTALING CLOSE TO 2 MILLION. THE BD FAILED TOSUPERVISE ITS AGENTS AND FAILED TO ENFORCE WRITTENPROCEDURES.

WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, A CONSENT ORDERWAS AGREED TO BY THE FIRM.

Sanctions Ordered or ReliefGranted:

iReporting Source: Firm

THE CALIFORNIA CORPORATIONS COMMISSIONER ALLEGES A FORMERBRANCH MANAGER FAILED TO SUPERVISE A FORMER REGISTEREDREPRESENTATIVE WHO MISAPPROPRIATED MONEY FROM HIS CLIENTS,ALL OF WHOM HAVE BEEN REIMBURSED BY THE FIRM.

Allegations:

Current Status: Final

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Initiated By: STATE OF CALIFORNIA , DEPARTMENT OF CORPORATIONS

Relief Sought: Other

Other Relief Sought: CIV - CIVIL COMPLAINT FILED

Date Court Action Filed: 09/30/2003

Principal Product Type: No Product

Other Product Types: MISAPPROPRIATION OF FUNDS

Court Details: ORANGE COUNTY SUPERIOR COURT; SANTA ANA; CALIFORNIA CASE NO.03CC00433

THE CALIFORNIA CORPORATIONS COMMISSIONER ALLEGES A FORMERBRANCH MANAGER FAILED TO SUPERVISE A FORMER REGISTEREDREPRESENTATIVE WHO MISAPPROPRIATED MONEY FROM HIS CLIENTS,ALL OF WHOM HAVE BEEN REIMBURSED BY THE FIRM.

Allegations:

Date Notice/Process Served: 11/12/2004

Resolution: Dismissed

Resolution Date: 01/10/2005

Other Sanctions:

Sanction Details:

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, A CONSENT ORDERWAS AGREED TO BY THE FIRM.

Sanctions Ordered or ReliefGranted:

313©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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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 337

Reporting Source: Regulator

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

04/03/2000

00-00937

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE

CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$115,000.00

AWARD AGAINST PARTY

06/04/2001

$90,000.00

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 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

NASD

04/12/2000

00-01242

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-SUITABILITY

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE314©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$300,000.00

AWARD AGAINST PARTY

03/01/2001

$23,076.00

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

Disclosure 3 of 337

i

Reporting Source: Regulator

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

05/11/2000

00-01331

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$784,000.00

AWARD AGAINST PARTY

12/09/2002

$21,600.00

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

Disclosure 4 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Allegations:

NASD

04/10/2000

ACCOUNT ACTIVITY-OTHER; DO NOT USE-NO OTHER CONTROVERSYINVOLVED

315©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

04/10/2000

00-01428

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

$500,000.00

AWARD AGAINST PARTY

03/20/2002

$101,300.01

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

Disclosure 5 of 337

i

Reporting Source: Regulator

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

05/22/2000

00-01980

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

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$34,000.00

AWARD AGAINST PARTY

01/22/2002

$8,000.00

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

Disclosure 6 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

316©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

07/05/2000

00-02369

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$589,496.00

AWARD AGAINST PARTY

04/09/2002

$46,000.00

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

Disclosure 7 of 337

i

Reporting Source: Regulator

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

08/25/2000

00-03566

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; DONOT USE-EXECUTIONS-FAILURE TO EXECUTE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$18,816.48

AWARD AGAINST PARTY

07/16/2001

$8,816.48

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

Disclosure 8 of 337

i

Reporting Source: Regulator

317©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 320: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

11/01/2000

00-03623

ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSYINVOLVED

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

$14,388.00

AWARD AGAINST PARTY

04/27/2001

$62.50

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

Disclosure 9 of 337

i

Reporting Source: Regulator

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

10/27/2000

00-04266

ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-OTHER;DO NOT USE-NO OTHER CONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$2,075.00

AWARD AGAINST PARTY

05/18/2001

$575.00

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

Disclosure 10 of 337

i

318©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Disclosure 10 of 337

Reporting Source: Regulator

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

10/11/2000

00-04341

ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NOOTHER CONTROVERSY INVOLVED

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

$30,000.00

AWARD AGAINST PARTY

07/16/2001

$29,306.00

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

Disclosure 11 of 337

i

Reporting Source: Regulator

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

10/12/2000

00-04456

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$285,043.29

AWARD AGAINST PARTY

09/18/2002

$72,380.54

319©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

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

Disclosure 12 of 337

i

Reporting Source: Regulator

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

11/30/2000

00-05242

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; DONOT USE-NO OTHER CONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$31,800.00

AWARD AGAINST PARTY

07/19/2002

$6,300.00

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

Disclosure 13 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

NASD

01/29/2001

00-05490

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DONOT USE-EXECUTIONS-LIMIT V MRKT ORDR

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$1,000,000.00

AWARD AGAINST PARTY

07/23/2002 320©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Disposition Date:

Sum of All Relief Awarded:

07/23/2002

$50,000.00

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

Disclosure 14 of 337

i

Reporting Source: Regulator

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

03/05/2001

01-00878

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$375,104.00

AWARD AGAINST PARTY

09/11/2002

$52,375.00

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

Disclosure 15 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

NASD

04/04/2001

01-01630

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

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

321©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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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; UNKNOWN TYPE OFSECURITIES

$3,000,000.00

AWARD AGAINST PARTY

01/14/2003

$368,428.00

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

Disclosure 16 of 337

i

Reporting Source: Regulator

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

06/19/2001

01-01785

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

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$3,926,541.84

AWARD AGAINST PARTY

06/25/2002

$600.00

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

Disclosure 17 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Allegations:

NASD

05/08/2001

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-FAILURE TO SUPERVISE

322©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

05/08/2001

01-02319

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

$63,178.50

AWARD AGAINST PARTY

06/11/2002

$306,292.50

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

Disclosure 18 of 337

i

Reporting Source: Regulator

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

09/04/2001

01-03235

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$117,493.00

AWARD AGAINST PARTY

09/23/2002

$108,000.01

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

Disclosure 19 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

323©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

07/03/2001

01-03307

ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$300,000.00

AWARD AGAINST PARTY

08/05/2003

$53,615.00

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

Disclosure 20 of 337

i

Reporting Source: Regulator

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

08/23/2001

01-03451

ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-MARGIN CALLS; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUTUAL FUNDS; OPTIONS

$500,000.00

AWARD AGAINST PARTY

07/30/2002

$35,000.00

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

Disclosure 21 of 337

i

324©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

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www.finra.org/brokercheck User Guidance

Reporting Source: Regulator

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

07/06/2001

01-03469

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-BREACH OF CONTRACT

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

$410,000.00

AWARD AGAINST PARTY

04/22/2003

$60,300.00

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

Disclosure 22 of 337

i

Reporting Source: Regulator

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

08/15/2001

01-03781

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-OMISSION OF FACTS

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$501,125.00

AWARD AGAINST PARTY

10/24/2002

$86,546.84

325©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 328: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Disclosure 23 of 337

i

Reporting Source: Regulator

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

07/24/2001

01-03824

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;OPTIONS

AWARD AGAINST PARTY

06/20/2003

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

Disclosure 24 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

NASD

08/03/2001

01-04057

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHERTYPES OF SECURITIES; REAL ESTATE INVESTMENT TRUST

$34,763.73

AWARD AGAINST PARTY 326©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 329: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition:

Disposition Date:

Sum of All Relief Awarded:

AWARD AGAINST PARTY

05/15/2002

$212.50

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

Disclosure 25 of 337

i

Reporting Source: Regulator

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

08/16/2001

01-04244

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

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

$20,000.00

AWARD AGAINST PARTY

04/19/2002

$212.50

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

Disclosure 26 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

NASD

09/17/2001

01-04580

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-TRANSFER

327©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 330: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

01-04580

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUTUAL FUNDS

$58,234.35

AWARD AGAINST PARTY

05/17/2002

$17,460.15

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

Disclosure 27 of 337

i

Reporting Source: Regulator

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

09/07/2001

01-04743

ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-TRANSFER

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$200,000.00

AWARD AGAINST PARTY

07/02/2002

$0.00

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

Disclosure 28 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Allegations:

NASD

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

328©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 331: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

09/27/2001

01-04907

ANNUITIES; COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SECINVOLVE; OTHER TYPES OF SECURITIES

$33,086.34

AWARD AGAINST PARTY

09/23/2002

$10,000.00

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

Disclosure 29 of 337

i

Reporting Source: Regulator

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

10/17/2001

01-05146

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

Unspecified Damages

AWARD AGAINST PARTY

09/13/2002

$17,585.00

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

Disclosure 30 of 337

i

Reporting Source: Regulator

329©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 332: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

11/29/2001

01-05436

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$9,164.00

AWARD AGAINST PARTY

04/22/2002

$425.00

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

Disclosure 31 of 337

i

Reporting Source: Regulator

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

11/14/2001

01-05629

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

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

$733,157.20

AWARD AGAINST PARTY

07/03/2003

$92,000.00

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

330©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 333: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 32 of 337

i

Reporting Source: Regulator

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

11/14/2001

01-06003

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING;ACCOUNT RELATED-MARGIN CALLS

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;OPTIONS

$391,323.06

AWARD AGAINST PARTY

05/13/2003

$77,550.01

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

Disclosure 33 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

NASD

12/26/2001

01-06427

ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZEDTRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE; TRADINGDISPUTES-TRANSFERS

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$5,386.03

AWARD AGAINST PARTY

05/21/2002

331©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 334: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $175.00

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

Disclosure 34 of 337

i

Reporting Source: Regulator

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

01/02/2002

01-06890

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-SUITABILITY

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHERTYPES OF SECURITIES

$1,400,000.00

AWARD AGAINST PARTY

01/14/2003

$612,674.00

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

Disclosure 35 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

NASD

03/18/2002

02-00424

ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TOEXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$19,589.50

332©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 335: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition:

Disposition Date:

Sum of All Relief Awarded:

AWARD AGAINST PARTY

10/31/2002

$15,699.85

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

Disclosure 36 of 337

i

Reporting Source: Regulator

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

03/15/2002

02-01371

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

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS;MUTUAL FUNDS; OTHER TYPES OF SECURITIES

$18,425.00

AWARD AGAINST PARTY

08/28/2002

$425.00

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

Disclosure 37 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

NASD

03/28/2002

02-01681

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING

333©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 336: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

02-01681

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$5,000,000.00

AWARD AGAINST PARTY

02/26/2003

$65,765.11

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

Disclosure 38 of 337

i

Reporting Source: Regulator

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

04/22/2002

02-02172

DO NOT USE-NO OTHER CONTROVERSY INVOLVED; UNKNOWN TYPE OFCONTROVERSIES

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

$11,900,000.00

AWARD AGAINST PARTY

08/11/2003

$318,288.00

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

Disclosure 39 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Allegations:

NASD

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

334©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 337: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

05/10/2002

02-02491

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

$188,535.00

AWARD AGAINST PARTY

06/11/2003

$0.00

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

Disclosure 40 of 337

i

Reporting Source: Regulator

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

09/03/2002

02-04961

ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$120,905.60

AWARD AGAINST PARTY

10/23/2003

$50,608.00

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

Disclosure 41 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT RELATED-EXCHANGES; ACCOUNT RELATED-NEGLIGENCE

335©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 338: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

10/17/2002

02-05151

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT RELATED-EXCHANGES; ACCOUNT RELATED-NEGLIGENCE

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

$19,355.37

AWARD AGAINST PARTY

10/11/2004

$2,125.00

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

Disclosure 42 of 337

i

Reporting Source: Regulator

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

10/21/2002

02-05447

DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$25,278.00

AWARD AGAINST PARTY

08/01/2003

$3,385.00

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

Disclosure 43 of 337

i

336©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 339: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Reporting Source: Regulator

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

10/23/2002

02-06220

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$601,746.51

AWARD AGAINST PARTY

07/20/2004

$300,907.00

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

Disclosure 44 of 337

i

Reporting Source: Regulator

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

11/05/2002

02-06253

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE; TRADINGDISPUTES-MANIPULATION

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$7,505.02

AWARD AGAINST PARTY

03/12/2003

$1,765.00

There may be a non-monetary award associated with this arbitration.

337©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 340: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Please select the Case Number above to view more detailed information.

Disclosure 45 of 337

i

Reporting Source: Regulator

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

11/07/2002

02-06567

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-NEGLIGENCE

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

$1,000,000.00

AWARD AGAINST PARTY

03/03/2004

$335,000.01

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

Disclosure 46 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

NASD

11/22/2002

02-06786

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; CORPORATE BONDS; MUTUAL FUNDS; OPTIONS

$7,309,475.77

AWARD AGAINST PARTY

09/15/2004338©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 341: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition Date:

Sum of All Relief Awarded:

09/15/2004

$420,494.94

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

Disclosure 47 of 337

i

Reporting Source: Regulator

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

11/29/2002

02-06799

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACHOF CONTRACT

COMMON STOCK; CORPORATE BONDS; MUNICIPAL BONDS; MUTUALFUNDS

$768,315.00

AWARD AGAINST PARTY

02/02/2004

$98,375.01

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

Disclosure 48 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

NASD

12/09/2002

02-07178

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE339©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 342: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$10,575,140.76

AWARD AGAINST PARTY

07/08/2004

$2,692,591.01

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

Disclosure 49 of 337

i

Reporting Source: Regulator

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

12/17/2002

02-07435

ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSYINVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

Unspecified Damages

AWARD AGAINST PARTY

01/15/2004

$22,500.00

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

Disclosure 50 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Allegations:

NASD

12/27/2002

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE

340©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 343: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

12/27/2002

02-07610

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$342,264.50

AWARD AGAINST PARTY

03/22/2004

$57,475.04

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

Disclosure 51 of 337

i

Reporting Source: Regulator

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

01/08/2003

02-07847

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

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

$521,295.00

AWARD AGAINST PARTY

02/23/2004

$343,116.09

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

Disclosure 52 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-MARGIN CALLS

341©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 344: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

02/19/2003

03-00704

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-MARGIN CALLS

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

$101,099,408.39

AWARD AGAINST PARTY

11/18/2004

$566,932.12

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

Disclosure 53 of 337

i

Reporting Source: Regulator

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

02/05/2003

03-00738

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-BREACH OF CONTRACT

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUTUAL FUNDS

$150,000.00

AWARD AGAINST PARTY

12/18/2003

$36,000.01

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

Disclosure 54 of 337

i

342©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 345: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 54 of 337

Reporting Source: Regulator

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

02/11/2003

03-00824

ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSYINVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$93,000.00

AWARD AGAINST PARTY

03/15/2004

$28,776.00

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

Disclosure 55 of 337

i

Reporting Source: Regulator

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

03/24/2003

03-01817

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY

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

$364,930.75

AWARD AGAINST PARTY

03/11/2004

$106,997.00

343©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 346: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Disclosure 56 of 337

i

Reporting Source: Regulator

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

05/02/2003

03-01897

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE; ACCOUNTRELATED-OTHER

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

$130,000.00

AWARD AGAINST PARTY

05/09/2006

$70,000.01

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

Disclosure 57 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

NASD

04/01/2003

03-02046

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-NEGLIGENCE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUTUAL FUNDS

$999,990.69

AWARD AGAINST PARTY 344©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 347: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition:

Disposition Date:

Sum of All Relief Awarded:

AWARD AGAINST PARTY

09/12/2006

$300,000.00

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

Disclosure 58 of 337

i

Reporting Source: Regulator

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

05/05/2003

03-02298

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

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

$155,000.00

AWARD AGAINST PARTY

09/10/2004

$6,000.00

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

Disclosure 59 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

NASD

04/14/2003

03-02491

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-FAILURE TO SUPERVISE

COMMON STOCK; MUTUAL FUNDS; OPTIONS; OTHER TYPES OFSECURITIES

345©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 348: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

COMMON STOCK; MUTUAL FUNDS; OPTIONS; OTHER TYPES OFSECURITIES

$875,000.00

AWARD AGAINST PARTY

10/26/2004

$360,000.00

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

Disclosure 60 of 337

i

Reporting Source: Regulator

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

05/14/2003

03-03132

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-UNAUTHORIZED TRADING

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$448,018.00

AWARD AGAINST PARTY

04/29/2004

$27,700.00

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

Disclosure 61 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Allegations:

NASD

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

346©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 349: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

07/10/2003

03-04949

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

$221,230.78

AWARD AGAINST PARTY

08/06/2004

$93,399.01

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

Disclosure 62 of 337

i

Reporting Source: Regulator

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

09/17/2003

03-05072

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$40,000.00

AWARD AGAINST PARTY

11/03/2004

$31,959.93

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

Disclosure 63 of 337

i

Reporting Source: Regulator

347©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 350: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

07/24/2003

03-05384

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-NEGLIGENCE

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

$156,000.00

AWARD AGAINST PARTY

09/27/2004

$61,371.01

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

Disclosure 64 of 337

i

Reporting Source: Regulator

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

08/13/2003

03-05692

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT

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

$205,000.00

AWARD AGAINST PARTY

10/22/2004

$141,800.01

There may be a non-monetary award associated with this arbitration.

348©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 351: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Please select the Case Number above to view more detailed information.

Disclosure 65 of 337

i

Reporting Source: Regulator

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

08/08/2003

03-05764

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

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$21,748.07

AWARD AGAINST PARTY

02/09/2004

$13,295.35

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

Disclosure 66 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

NASD

09/17/2003

03-06298

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$21,336.00

AWARD AGAINST PARTY

02/11/2004

349©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 352: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $21,336.00

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

Disclosure 67 of 337

i

Reporting Source: Regulator

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

09/16/2003

03-06583

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$750,000.00

AWARD AGAINST PARTY

09/10/2004

$122,500.00

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

Disclosure 68 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

NASD

10/08/2003

03-07234

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

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

$140,000.00

350©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 353: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition:

Disposition Date:

Sum of All Relief Awarded:

AWARD AGAINST PARTY

12/07/2005

$30,300.01

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

Disclosure 69 of 337

i

Reporting Source: Regulator

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

12/03/2003

03-08306

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

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUTUAL FUNDS; OTHER TYPES OF SECURITIES

$1,983,248.00

AWARD AGAINST PARTY

05/02/2005

$140,224.71

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

Disclosure 70 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

NASD

12/04/2003

03-08495

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE

351©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 354: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

03-08495

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

$681,310.00

AWARD AGAINST PARTY

12/01/2004

$295,875.93

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

Disclosure 71 of 337

i

Reporting Source: Regulator

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

02/06/2004

04-00705

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURETO SUPERVISE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUNICIPAL BONDS

$3,685,000.00

AWARD AGAINST PARTY

04/15/2005

$450,000.01

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

Disclosure 72 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE 352©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 355: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

03/01/2004

04-00842

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUTUAL FUNDS

$440,418.00

AWARD AGAINST PARTY

06/14/2005

$300.00

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

Disclosure 73 of 337

i

Reporting Source: Regulator

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

04/30/2004

04-01727

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-NEGLIGENCE

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

$1,500,000.00

AWARD AGAINST PARTY

02/01/2006

$397,044.00

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

Disclosure 74 of 337

i

353©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 356: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 74 of 337

Reporting Source: Regulator

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

03/26/2004

04-01979

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE

ANNUITIES; COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SECINVOLVE; MUTUAL FUNDS

$250,000.00

AWARD AGAINST PARTY

12/29/2005

$135,000.01

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

Disclosure 75 of 337

i

Reporting Source: Regulator

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

04/05/2004

04-02277

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

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

Unspecified Damages

AWARD AGAINST PARTY

05/26/2005

$86,864.00

354©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 357: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Disclosure 76 of 337

i

Reporting Source: Regulator

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

04/22/2004

04-02907

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

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

$313,390.00

AWARD AGAINST PARTY

11/28/2005

$25,000.00

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

Disclosure 77 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

NASD

05/18/2004

04-03070

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-NEGLIGENCE

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

$949,604.00

355©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 358: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition:

Disposition Date:

Sum of All Relief Awarded:

AWARD AGAINST PARTY

09/08/2005

$185,000.00

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

Disclosure 78 of 337

i

Reporting Source: Regulator

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

06/22/2004

04-03314

ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED-NEGLIGENCE

CERTIFICATE OF DEPOSIT; COMMON STOCK; OTHER TYPES OFSECURITIES; PREFERRED STOCK

$6,700,000.00

AWARD AGAINST PARTY

04/03/2006

$35,000.00

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

Disclosure 79 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

NASD

05/14/2004

04-03410

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

356©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 359: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

04-03410

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

$241,646.67

AWARD AGAINST PARTY

12/27/2005

$12,000.00

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

Disclosure 80 of 337

i

Reporting Source: Regulator

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

06/21/2004

04-03813

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

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

$25,000.00

AWARD AGAINST PARTY

05/02/2005

$23,024.32

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

Disclosure 81 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Allegations:

NASD

ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-OTHER; DO NOTUSE-NO OTHER CONTROVERSY INVOLVED

357©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 360: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

06/30/2004

04-03907

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

$18,000.00

AWARD AGAINST PARTY

12/27/2004

$106.25

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

Disclosure 82 of 337

i

Reporting Source: Regulator

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

06/23/2004

04-04336

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

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

$3,600,000.00

AWARD AGAINST PARTY

10/10/2005

$369,850.01

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

Disclosure 83 of 337

i

Reporting Source: Regulator

358©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 361: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

08/03/2004

04-05459

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

COMMON STOCK; CORPORATE BONDS; GOVERNMENT SECURITIES;MUTUAL FUNDS

$869,060.59

AWARD AGAINST PARTY

06/29/2006

$28,000.01

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

Disclosure 84 of 337

i

Reporting Source: Regulator

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

08/30/2004

04-05743

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING

CORPORATE BONDS; FANNIE MAE; MUNICIPAL BOND FUNDS; MUTUALFUNDS

$25,000.00

AWARD AGAINST PARTY

06/15/2005

$212.50

There may be a non-monetary award associated with this arbitration.

359©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 362: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Please select the Case Number above to view more detailed information.

Disclosure 85 of 337

i

Reporting Source: Regulator

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

10/08/2004

04-07044

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

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

$1,200,000.00

AWARD AGAINST PARTY

07/18/2006

$240,000.00

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

Disclosure 86 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

NASD

12/02/2004

04-08079

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-NEGLIGENCE

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

$2,000,000.00

AWARD AGAINST PARTY360©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 363: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition:

Disposition Date:

Sum of All Relief Awarded:

AWARD AGAINST PARTY

04/13/2006

$1,701,930.00

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

Disclosure 87 of 337

i

Reporting Source: Regulator

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

11/29/2004

04-08117

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

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

$425,000.00

AWARD AGAINST PARTY

03/12/2008

$421,031.00

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

Disclosure 88 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

NASD

12/01/2004

04-08161

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED-NEGLIGENCE

361©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 364: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

04-08161

COMMON STOCK; CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OFSEC INVOLVE

$110,643.78

AWARD AGAINST PARTY

08/16/2005

$14,654.00

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

Disclosure 89 of 337

i

Reporting Source: Regulator

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

05/20/2005

04-08571

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE

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

Unspecified Damages

AWARD AGAINST PARTY

04/24/2006

$243,250.01

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

Disclosure 90 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE; DONOT USE-NO OTHER CONTROVERSY INVOLVED 362©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 365: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

02/04/2005

04-08618

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE; DONOT USE-NO OTHER CONTROVERSY INVOLVED

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

$90,000.00

AWARD AGAINST PARTY

04/13/2006

$41,900.00

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

Disclosure 91 of 337

i

Reporting Source: Regulator

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

01/06/2005

05-00019

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-TRANSFER

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

$80,000.00

AWARD AGAINST PARTY

12/22/2005

$72,342.01

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

Disclosure 92 of 337

i

363©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 366: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 92 of 337

Reporting Source: Regulator

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

01/07/2005

05-00058

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE

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

$193,879.35

AWARD AGAINST PARTY

05/04/2006

$300.00

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

Disclosure 93 of 337

i

Reporting Source: Regulator

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

03/10/2005

05-01222

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS

$30,525.00

AWARD AGAINST PARTY

09/16/2005

$26,775.00

364©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 367: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Disclosure 94 of 337

i

Reporting Source: Regulator

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

03/22/2005

05-01452

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;OPTIONS

$2,500,000.00

AWARD AGAINST PARTY

06/09/2006

$9,600.00

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

Disclosure 95 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

NASD

03/31/2005

05-01616

ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$32,199.47

AWARD AGAINST PARTY

12/19/2005 365©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 368: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition Date:

Sum of All Relief Awarded:

12/19/2005

$16,000.00

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

Disclosure 96 of 337

i

Reporting Source: Regulator

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

04/13/2005

05-01870

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$19,153.00

AWARD AGAINST PARTY

11/29/2005

$212.50

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

Disclosure 97 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

NASD

04/25/2005

05-02096

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-FAILURE TO SUPERVISE

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

366©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 369: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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; UNKNOWN TYPE OFSECURITIES

$624,771.00

AWARD AGAINST PARTY

01/03/2007

$295,822.01

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

Disclosure 98 of 337

i

Reporting Source: Regulator

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

06/10/2005

05-02573

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

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

$999,999.00

AWARD AGAINST PARTY

11/30/2005

$431,042.00

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

Disclosure 99 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Allegations:

NASD

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

367©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 370: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

08/11/2005

05-03586

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

$12,000,000.00

AWARD AGAINST PARTY

05/23/2006

$2,021,200.00

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

Disclosure 100 of 337

i

Reporting Source: Regulator

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

10/07/2005

05-05190

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

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

$2,500.00

AWARD AGAINST PARTY

04/21/2006

$1,877.21

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

Disclosure 101 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

368©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 371: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

12/13/2005

05-05339

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-NEGLIGENCE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$450,000.00

AWARD AGAINST PARTY

01/08/2007

$40,000.00

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

Disclosure 102 of 337

i

Reporting Source: Regulator

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

10/20/2005

05-05346

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING;ACCOUNT RELATED-BREACH OF CONTRACT

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$80,000.00

AWARD AGAINST PARTY

09/11/2006

$30,000.00

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

Disclosure 103 of 337

i

369©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 372: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Reporting Source: Regulator

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

11/09/2005

05-05673

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

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS; OTHERTYPES OF SECURITIES

$500,000.00

AWARD AGAINST PARTY

12/19/2006

$12,833.00

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

Disclosure 104 of 337

i

Reporting Source: Regulator

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

12/02/2005

05-06026

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

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

$25,000.00

AWARD AGAINST PARTY

05/04/2006

$10,619.98

There may be a non-monetary award associated with this arbitration.

370©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 373: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Please select the Case Number above to view more detailed information.

Disclosure 105 of 337

i

Reporting Source: Regulator

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

08/15/2006

05-06078

ACCOUNT RELATED-MARGIN CALLS; DO NOT USE-EXECUTIONS-INCORRECT QUANTITY; DO NOT USE-NO OTHER CONTROVERSYINVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$99,000.00

AWARD AGAINST PARTY

04/23/2007

$11,099.00

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

Disclosure 106 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

NASD

01/31/2006

05-06113

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

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUTUAL FUNDS

$600,000.00

AWARD AGAINST PARTY

02/11/2009371©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 374: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition Date:

Sum of All Relief Awarded:

02/11/2009

$375.00

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

Disclosure 107 of 337

i

Reporting Source: Regulator

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

01/23/2006

06-00085

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

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

$1,500,000.00

AWARD AGAINST PARTY

05/05/2008

$775,012.00

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

Disclosure 108 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

NASD

01/17/2006

06-00170

ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$288,954.88 372©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 375: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

$288,954.88

AWARD AGAINST PARTY

01/19/2007

$25,712.09

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

Disclosure 109 of 337

i

Reporting Source: Regulator

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

04/28/2006

06-02094

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; REAL ESTATEINVESTMENT TRUST

$11,550,000.00

AWARD AGAINST PARTY

10/10/2007

$343,000.01

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

Disclosure 110 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Allegations:

NASD

06/05/2006

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURETO SUPERVISE

373©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 376: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

06/05/2006

06-02660

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$11,602,637.06

AWARD AGAINST PARTY

08/01/2007

$10,513.00

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

Disclosure 111 of 337

i

Reporting Source: Regulator

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

06/22/2006

06-02953

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$25,000.00

AWARD AGAINST PARTY

03/26/2007

$425.00

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

Disclosure 112 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-DIVIDENDS; ACCOUNT RELATED-NEGLIGENCE 374©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 377: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

07/12/2006

06-03014

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-DIVIDENDS; ACCOUNT RELATED-NEGLIGENCE

ANNUITIES; COMMON STOCK; MUNICIPAL BONDS; OTHER TYPES OFSECURITIES

$499,000.00

AWARD AGAINST PARTY

05/19/2008

$98,709.35

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

Disclosure 113 of 337

i

Reporting Source: Regulator

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

07/19/2006

06-03324

ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSYINVOLVED

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

$25,000.00

AWARD AGAINST PARTY

03/30/2007

$25,000.00

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

Disclosure 114 of 337

i

Reporting Source: Regulator

375©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 378: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

11/09/2006

06-04869

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

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

$400,000.00

AWARD AGAINST PARTY

11/08/2007

$293,659.25

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

Disclosure 115 of 337

i

Reporting Source: Regulator

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

02/14/2007

07-00417

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$32,851.00

AWARD AGAINST PARTY

11/12/2007

$13,713.36

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

i376©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 379: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 116 of 337

i

Reporting Source: Regulator

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

04/05/2007

07-00666

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

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; HEDGEFUND

$120,000,000.00

AWARD AGAINST PARTY

04/02/2012

$852,000.01

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

Disclosure 117 of 337

i

Reporting Source: Regulator

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

04/05/2007

07-00905

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-OMISSION OF FACTS

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

Unspecified Damages

AWARD AGAINST PARTY

08/05/2008

$136,289.00 377©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 380: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $136,289.00

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

Disclosure 118 of 337

i

Reporting Source: Regulator

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

04/24/2007

07-01186

ACCOUNT RELATED-OTHER; DO NOT USE-EXECUTIONS-FAILURE TOEXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$4,058.73

AWARD AGAINST PARTY

11/16/2007

$87.50

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

Disclosure 119 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

NASD

06/12/2007

07-01557

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-NEGLIGENCE

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

Unspecified Damages

AWARD AGAINST PARTY 378©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 381: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition:

Disposition Date:

Sum of All Relief Awarded:

AWARD AGAINST PARTY

03/19/2009

$162,135.89

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

Disclosure 120 of 337

i

Reporting Source: Regulator

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:

FINRA

09/14/2007

07-01706

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUTUAL FUNDS

$410,000.00

AWARD AGAINST PARTY

04/13/2010

$18,384.40

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

Disclosure 121 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

FINRA

07/31/2007

07-01716

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-FAILURE TO SUPERVISE

379©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 382: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

07-01716

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

Unspecified Damages

AWARD AGAINST PARTY

11/12/2010

$1,817,900.00

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

Disclosure 122 of 337

i

Reporting Source: Regulator

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

07/16/2007

07-01729

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

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

$6,354,498.00

AWARD AGAINST PARTY

07/30/2008

$5,297,001.72

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

Disclosure 123 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE

380©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 383: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

FINRA

08/13/2007

07-02263

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUTUAL FUNDS

$7,000.00

AWARD AGAINST PARTY

01/23/2008

$162.50

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

Disclosure 124 of 337

i

Reporting Source: Regulator

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:

FINRA

11/02/2007

07-03084

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE

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

$25,000.00

AWARD AGAINST PARTY

04/17/2008

$212.50

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

Disclosure 125 of 337

i

Reporting Source: Regulator

381©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 384: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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:

FINRA

11/07/2007

07-03105

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS

$15,000,000.00

AWARD AGAINST PARTY

11/26/2008

$250,000.00

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

Disclosure 126 of 337

i

Reporting Source: Regulator

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:

FINRA

11/26/2007

07-03227

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

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; FUTURES (OTHER THANCOMMODITIES)

$650,000.00

AWARD AGAINST PARTY

11/12/2008

$525,000.00

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

382©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 385: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 127 of 337

i

Reporting Source: Regulator

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:

FINRA

01/07/2008

07-03507

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

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$924,613.84

AWARD AGAINST PARTY

08/31/2009

$375.00

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

Disclosure 128 of 337

i

Reporting Source: Regulator

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:

FINRA

03/20/2008

08-00408

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BOND FUNDS

$24,491.00

AWARD AGAINST PARTY

11/06/2008

$212.50383©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 386: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $212.50

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

Disclosure 129 of 337

i

Reporting Source: Regulator

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:

FINRA

04/14/2008

08-00751

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

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$9,935.72

AWARD AGAINST PARTY

11/13/2008

$162.50

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

Disclosure 130 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

FINRA

04/03/2008

08-00956

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-OTHER; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUTUAL FUNDS

$98,000.00384©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 387: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

$98,000.00

AWARD AGAINST PARTY

04/13/2009

$89,338.37

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

Disclosure 131 of 337

i

Reporting Source: Regulator

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:

FINRA

04/07/2008

08-01002

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;TRADING DISPUTES-TRANSFERS

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$25,000.00

AWARD AGAINST PARTY

05/20/2009

$32,182.86

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

Disclosure 132 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

FINRA

07/15/2008

08-02037

DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

385©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 388: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

08-02037

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS;UNKNOWN TYPE OF SECURITIES

$24,916.12

AWARD AGAINST PARTY

02/26/2009

$212.50

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

Disclosure 133 of 337

i

Reporting Source: Regulator

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:

FINRA

06/30/2008

08-02041

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUTUAL FUNDS; OTHER TYPES OF SECURITIES

$700,000.00

AWARD AGAINST PARTY

06/24/2010

$375.00

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

Disclosure 134 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

386©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 389: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

FINRA

07/30/2008

08-02454

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

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

Unspecified Damages

AWARD AGAINST PARTY

07/21/2009

$108,000.00

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

Disclosure 135 of 337

i

Reporting Source: Regulator

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:

FINRA

09/03/2008

08-02610

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$12,000.00

AWARD AGAINST PARTY

02/12/2009

$425.00

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

Disclosure 136 of 337

i

Reporting Source: Regulator

387©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 390: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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:

FINRA

10/07/2008

08-03219

ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZEDTRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED; UNKNOWNTYPE OF CONTROVERSIES

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$440,000.00

AWARD AGAINST PARTY

05/27/2010

$391,375.00

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

Disclosure 137 of 337

i

Reporting Source: Regulator

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:

FINRA

10/31/2008

08-03999

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHERTYPES OF SECURITIES

$241,169.00

AWARD AGAINST PARTY

06/19/2009

$60,000.00

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

388©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 391: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 138 of 337

i

Reporting Source: Regulator

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:

FINRA

12/09/2008

08-04027

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS

$8,400,000.00

AWARD AGAINST PARTY

03/29/2010

$82,837.00

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

Disclosure 139 of 337

i

Reporting Source: Regulator

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:

FINRA

07/09/2009

08-04431

DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE

COMMON STOCK

$25,000.00

AWARD AGAINST PARTY

12/15/2009

$340.00

389©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 392: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Disclosure 140 of 337

i

Reporting Source: Regulator

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:

FINRA

12/09/2008

08-04559

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

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

$376,691.07

AWARD AGAINST PARTY

12/23/2009

$123,324.22

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

Disclosure 141 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

FINRA

12/18/2008

08-04797

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING;ACCOUNT RELATED-FAILURE TO SUPERVISE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUNICIPAL BOND FUNDS

$10,000.00

AWARD AGAINST PARTY 390©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 393: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition:

Disposition Date:

Sum of All Relief Awarded:

AWARD AGAINST PARTY

06/09/2009

$3,995.94

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

Disclosure 142 of 337

i

Reporting Source: Regulator

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:

FINRA

01/05/2009

08-05005

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE

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

$50,000.00

AWARD AGAINST PARTY

03/17/2010

$14,376.85

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

Disclosure 143 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

FINRA

01/22/2009

09-00314

ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

391©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 394: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

09-00314

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; STOCK INDEX FUTURES

$61,842.33

AWARD AGAINST PARTY

04/29/2010

$17,533.74

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

Disclosure 144 of 337

i

Reporting Source: Regulator

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:

FINRA

04/17/2009

09-00958

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

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

$9,118.00

AWARD AGAINST PARTY

11/11/2009

$9,443.00

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

Disclosure 145 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-EXECUTION PRICE; DONOT USE-EXECUTIONS-FAILURE TO EXECUTE

392©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 395: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

FINRA

03/12/2009

09-01271

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-EXECUTION PRICE; DONOT USE-EXECUTIONS-FAILURE TO EXECUTE

COMMON STOCK; MUTUAL FUNDS

$8,320.21

AWARD AGAINST PARTY

07/21/2009

$212.50

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

Disclosure 146 of 337

i

Reporting Source: Regulator

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:

FINRA

04/06/2009

09-01766

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

MUTUAL FUNDS

$66,000.00

AWARD AGAINST PARTY

07/08/2010

$20,000.00

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

Disclosure 147 of 337

i

393©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 396: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Reporting Source: Regulator

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:

FINRA

04/13/2009

09-01827

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE

$95,000.00

AWARD AGAINST PARTY

05/18/2010

$26,225.00

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

Disclosure 148 of 337

i

Reporting Source: Regulator

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:

FINRA

04/16/2009

09-01981

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-FAILURE TO SUPERVISE

COMMON STOCK; MUTUAL FUNDS

$155,000.00

AWARD AGAINST PARTY

05/05/2010

$15,000.00

394©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 397: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Disclosure 149 of 337

i

Reporting Source: Regulator

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:

FINRA

04/29/2009

09-02283

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT

ANNUITIES; MUTUAL FUNDS

$7,127.70

AWARD AGAINST PARTY

02/11/2010

$1,106.25

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

Disclosure 150 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

FINRA

05/08/2009

09-02513

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

VARIABLE ANNUITIES

$75,000.00

AWARD AGAINST PARTY395©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 398: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition:

Disposition Date:

Sum of All Relief Awarded:

AWARD AGAINST PARTY

12/21/2009

$50,000.00

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

Disclosure 151 of 337

i

Reporting Source: Regulator

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:

FINRA

05/07/2009

09-02527

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK

$19,995.87

AWARD AGAINST PARTY

10/14/2009

$9,412.51

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

Disclosure 152 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Allegations:

FINRA

07/10/2009

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER; TRADINGDISPUTES-OTHER

396©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 399: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

09-02748

FANNIE MAE; PREFERRED STOCK

$1,937,806.00

AWARD AGAINST PARTY

08/23/2010

$25,000.00

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

Disclosure 153 of 337

i

Reporting Source: Regulator

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:

FINRA

06/02/2009

09-03013

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZEDTRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; FANNIE MAE; FREDDIE MACS; PREFERRED STOCK;VARIABLE ANNUITIES

$1,440,000.00

AWARD AGAINST PARTY

05/19/2010

$276,844.00

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

Disclosure 154 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

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

397©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 400: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

FINRA

06/12/2009

09-03471

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

UNKNOWN TYPE OF SECURITIES

$46,489.00

AWARD AGAINST PARTY

02/14/2011

$25,000.00

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

Disclosure 155 of 337

i

Reporting Source: Regulator

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:

FINRA

06/12/2009

09-03489

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

$226,865.86

AWARD AGAINST PARTY

07/12/2010

$90,000.01

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

Disclosure 156 of 337

i

398©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 401: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 156 of 337

Reporting Source: Regulator

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:

FINRA

06/18/2009

09-03593

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; FANNIE MAE; MUTUAL FUNDS; PREFERRED STOCK

$50,000.00

AWARD AGAINST PARTY

03/21/2011

$10,000.01

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

Disclosure 157 of 337

i

Reporting Source: Regulator

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:

FINRA

07/15/2009

09-03773

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

COMMON STOCK

$1,248,000.00

AWARD AGAINST PARTY

03/31/2010

$91,128.70

399©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 402: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Disclosure 158 of 337

i

Reporting Source: Regulator

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:

FINRA

06/30/2009

09-03803

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURETO SUPERVISE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE

OTHER TYPES OF SECURITIES

$66,945.00

AWARD AGAINST PARTY

02/22/2011

$34,304.92

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

Disclosure 159 of 337

i

Reporting Source: Regulator

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:

FINRA

07/01/2009

09-03903

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY

FANNIE MAE; PREFERRED STOCK

$24,320.00

AWARD AGAINST PARTY

12/15/2009

$212.50400©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 403: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $212.50

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

Disclosure 160 of 337

i

Reporting Source: Regulator

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:

FINRA

07/15/2009

09-04136

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

COMMON STOCK; MUTUAL FUNDS; OTHER TYPES OF SECURITIES

$74,518.00

AWARD AGAINST PARTY

09/14/2010

$49,000.00

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

Disclosure 161 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

FINRA

08/05/2009

09-04471

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

401©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 404: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

09-04471

MUNICIPAL BOND FUNDS

Unspecified Damages

AWARD AGAINST PARTY

12/20/2010

$210,891.01

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

Disclosure 162 of 337

i

Reporting Source: Regulator

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:

FINRA

08/18/2009

09-04773

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; DO NOT USE-EXECUTIONS-OTHER

COMMON STOCK; MUTUAL FUNDS; REAL ESTATE INVESTMENT TRUST

$1,467,091.06

AWARD AGAINST PARTY

01/04/2011

$208,000.01

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

Disclosure 163 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE 402©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 405: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

FINRA

08/21/2009

09-04887

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK

$130,085.96

AWARD AGAINST PARTY

07/23/2010

$39,000.00

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

Disclosure 164 of 337

i

Reporting Source: Regulator

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:

FINRA

10/01/2009

09-05158

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-NEGLIGENCE; ACCOUNTRELATED-TRANSFER

MUNICIPAL BOND FUNDS; MUNICIPAL BONDS; MUTUAL FUNDS

Unspecified Damages

AWARD AGAINST PARTY

12/14/2010

$53,000.00

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

Disclosure 165 of 337

i

Reporting Source: Regulator

403©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 406: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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:

FINRA

09/30/2009

09-05301

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; OPTIONS

$237,000.00

AWARD AGAINST PARTY

08/05/2011

$260,000.00

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

Disclosure 166 of 337

i

Reporting Source: Regulator

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:

FINRA

09/24/2009

09-05435

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; CORPORATE BONDS; MUTUAL FUNDS

$250,000.00

AWARD AGAINST PARTY

11/16/2010

$100,300.01

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

404©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 407: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 167 of 337

i

Reporting Source: Regulator

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:

FINRA

10/06/2009

09-05626

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

PRIVATE EQUITIES

$130,000.00

AWARD AGAINST PARTY

04/02/2012

$50,000.00

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

Disclosure 168 of 337

i

Reporting Source: Regulator

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:

FINRA

10/07/2009

09-05655

ACCOUNT RELATED-OTHER

Unspecified Damages

AWARD AGAINST PARTY

04/16/2010

$0.00405©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 408: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $0.00

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

Disclosure 169 of 337

i

Reporting Source: Regulator

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:

FINRA

11/03/2009

09-06162

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

AUCTION RATE SECURITIES; FREDDIE MACS

$100,000.00

AWARD AGAINST PARTY

09/09/2011

$225.00

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

Disclosure 170 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

FINRA

12/16/2009

09-06534

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

VARIABLE ANNUITIES

406©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 409: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

$29,145.22

AWARD AGAINST PARTY

11/04/2010

$20,000.00

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

Disclosure 171 of 337

i

Reporting Source: Regulator

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:

FINRA

01/07/2010

09-06730

ACCOUNT RELATED-TRANSFER; DO NOT USE-EXECUTIONS-FAILURE TOEXECUTE; TRADING DISPUTES-TRANSFERS

EXCHANGE-TRADED FUNDS; OTHER TYPES OF SECURITIES

$22,088.72

AWARD AGAINST PARTY

08/04/2010

$20,368.44

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

Disclosure 172 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

FINRA

12/31/2009

09-07137

ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

OTHER TYPES OF SECURITIES407©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 410: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

OTHER TYPES OF SECURITIES

$809,677.92

AWARD AGAINST PARTY

03/24/2011

$292,952.71

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

Disclosure 173 of 337

i

Reporting Source: Regulator

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:

FINRA

01/06/2010

09-07145

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURETO SUPERVISE

COMMON STOCK; MUTUAL FUNDS

$600,000.00

AWARD AGAINST PARTY

04/14/2011

$100,000.00

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

Disclosure 174 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Allegations:

FINRA

01/15/2010

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

408©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 411: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

01/15/2010

09-07236

ANNUITIES; COMMON STOCK; MUTUAL FUNDS

$2,575.00

AWARD AGAINST PARTY

07/20/2010

$37.50

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

Disclosure 175 of 337

i

Reporting Source: Regulator

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:

FINRA

02/22/2010

10-00742

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

OTHER TYPES OF SECURITIES; STRUCTURED PRODUCTS

$18,207.15

AWARD AGAINST PARTY

07/30/2010

$28,582.55

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

Disclosure 176 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

409©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 412: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

FINRA

03/12/2010

10-01040

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

OTHER TYPES OF SECURITIES

$425,000.00

AWARD AGAINST PARTY

04/25/2011

$153,000.00

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

Disclosure 177 of 337

i

Reporting Source: Regulator

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:

FINRA

03/12/2010

10-01051

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

MUNICIPAL BOND FUNDS; MUTUAL FUNDS

$375,000.00

AWARD AGAINST PARTY

07/07/2011

$217,928.40

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

Disclosure 178 of 337

i

410©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 413: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 178 of 337

Reporting Source: Regulator

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:

FINRA

04/22/2010

10-01102

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-TRANSFER; TRADING DISPUTES-SELLOUTS

$750,000.00

AWARD AGAINST PARTY

03/16/2012

$37,645.87

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

Disclosure 179 of 337

i

Reporting Source: Regulator

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:

FINRA

03/26/2010

10-01194

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

MUTUAL FUNDS; OTHER TYPES OF SECURITIES

$4,100,000.00

AWARD AGAINST PARTY

06/26/2013

$100,000.00

411©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 414: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Disclosure 180 of 337

i

Reporting Source: Regulator

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:

FINRA

03/17/2010

10-01209

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

OTHER TYPES OF SECURITIES; PREFERRED STOCK

Unspecified Damages

AWARD AGAINST PARTY

08/03/2011

$60,000.00

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

Disclosure 181 of 337

i

Reporting Source: Regulator

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:

FINRA

05/05/2010

10-01585

ACCOUNT ACTIVITY-UNAUTHORIZED TRADING

COMMON STOCK

$1,445.32

AWARD AGAINST PARTY

10/26/2010

$37.50412©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 415: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $37.50

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

Disclosure 182 of 337

i

Reporting Source: Regulator

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:

FINRA

05/27/2010

10-01775

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZEDTRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

COMMON STOCK; MUTUAL FUNDS

Unspecified Damages

AWARD AGAINST PARTY

07/20/2012

$227,750.00

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

Disclosure 183 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

FINRA

04/30/2010

10-01950

ACCOUNT ACTIVITY-UNAUTHORIZED TRADING

OTHER TYPES OF SECURITIES

$5,642.15

AWARD AGAINST PARTY 413©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 416: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition:

Disposition Date:

Sum of All Relief Awarded:

AWARD AGAINST PARTY

09/24/2010

$5,804.65

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

Disclosure 184 of 337

i

Reporting Source: Regulator

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:

FINRA

06/14/2010

10-01997

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

$48,000.00

AWARD AGAINST PARTY

06/29/2011

$43,579.00

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

Disclosure 185 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

FINRA

05/14/2010

10-02160

ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER; ACCOUNT RELATED-TRANSFER

CERTIFICATE OF DEPOSIT; COMMON STOCK; MUTUAL FUNDS 414©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 417: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

CERTIFICATE OF DEPOSIT; COMMON STOCK; MUTUAL FUNDS

$180,000.00

AWARD AGAINST PARTY

08/05/2011

$78,343.24

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

Disclosure 186 of 337

i

Reporting Source: Regulator

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:

FINRA

07/06/2010

10-03013

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

COMMON STOCK; MUTUAL FUNDS

$25,000.00

AWARD AGAINST PARTY

12/22/2010

$31,673.00

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

Disclosure 187 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Allegations:

FINRA

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-NEGLIGENCE

415©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 418: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

FINRA

08/26/2010

10-03052

$95,000.00

AWARD AGAINST PARTY

07/30/2012

$49,500.00

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

Disclosure 188 of 337

i

Reporting Source: Regulator

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:

FINRA

07/16/2010

10-03084

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

COMMON STOCK; MUTUAL FUNDS; VARIABLE ANNUITIES

$540,000.00

AWARD AGAINST PARTY

11/11/2011

$55,860.71

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

Disclosure 189 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

416©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 419: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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:

FINRA

07/22/2010

10-03151

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY

AUCTION RATE SECURITIES

$925,000.00

AWARD AGAINST PARTY

06/07/2011

$250,000.00

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

Disclosure 190 of 337

i

Reporting Source: Regulator

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:

FINRA

08/30/2010

10-03357

ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

FANNIE MAE; PREFERRED STOCK

$23,467.51

AWARD AGAINST PARTY

03/07/2011

$23,892.51

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

Disclosure 191 of 337

i

Reporting Source: Regulator

417©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 420: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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:

FINRA

08/04/2010

10-03416

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

COMMON STOCK; GOVERNMENT SECURITIES; OPTIONS

$5,400,000.01

AWARD AGAINST PARTY

02/14/2012

$370,882.53

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

Disclosure 192 of 337

i

Reporting Source: Regulator

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:

FINRA

08/18/2010

10-03554

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

OTHER TYPES OF SECURITIES

$6,000,000.00

AWARD AGAINST PARTY

07/03/2013

$2,752,049.01

418©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 421: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Disclosure 193 of 337

i

Reporting Source: Regulator

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:

FINRA

08/19/2010

10-03674

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

COLLATERALIZED MORTGAGE OBLIGATIONS; FANNIE MAE; FREDDIEMACS; PREFERRED STOCK

$952,666.88

AWARD AGAINST PARTY

09/16/2011

$0.00

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

Disclosure 194 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

FINRA

09/21/2010

10-03782

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

$78,000.00

419©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 422: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition:

Disposition Date:

Sum of All Relief Awarded:

AWARD AGAINST PARTY

06/01/2011

$225.00

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

Disclosure 195 of 337

i

Reporting Source: Regulator

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:

FINRA

09/28/2010

10-04159

ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

$500,000.00

AWARD AGAINST PARTY

10/12/2011

$3,536.82

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

Disclosure 196 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

FINRA

09/30/2010

10-04321

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE

420©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 423: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

10-04321

ANNUITIES; MUTUAL FUNDS; OTHER TYPES OF SECURITIES; PRIVATEEQUITIES

$652,204.30

AWARD AGAINST PARTY

12/03/2013

$297,516.01

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

Disclosure 197 of 337

i

Reporting Source: Regulator

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:

FINRA

12/07/2010

10-04904

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK

$811,867.00

AWARD AGAINST PARTY

10/21/2011

$375.01

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

Disclosure 198 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-DIVIDENDS;ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED-NEGLIGENCE

421©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 424: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

FINRA

11/23/2010

10-05212

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-DIVIDENDS;ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK

$780,000.00

AWARD AGAINST PARTY

12/08/2011

$214,100.00

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

Disclosure 199 of 337

i

Reporting Source: Regulator

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:

FINRA

11/24/2010

10-05215

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

FANNIE MAE; FREDDIE MACS; PREFERRED STOCK

$100,000.00

AWARD AGAINST PARTY

03/05/2012

$62,515.01

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

422©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 425: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 200 of 337

i

Reporting Source: Regulator

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:

FINRA

12/01/2010

10-05260

ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-OTHER

PREFERRED STOCK

$34,411.80

AWARD AGAINST PARTY

02/16/2012

$5,000.00

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

Disclosure 201 of 337

i

Reporting Source: Regulator

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:

FINRA

01/11/2011

10-05826

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

COMMON STOCK; MUTUAL FUNDS

$154,000.00

AWARD AGAINST PARTY

12/01/2011

$130,300.00423©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 426: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $130,300.00

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

Disclosure 202 of 337

i

Reporting Source: Regulator

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:

FINRA

01/13/2011

11-00052

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

PREFERRED STOCK

$425,000.00

AWARD AGAINST PARTY

03/05/2012

$90,297.79

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

Disclosure 203 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

FINRA

01/21/2011

11-00185

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; MUTUAL FUNDS

$300,000.00424©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 427: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

$300,000.00

AWARD AGAINST PARTY

04/17/2012

$61,894.00

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

Disclosure 204 of 337

i

Reporting Source: Regulator

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:

FINRA

01/21/2011

11-00216

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

OTHER TYPES OF SECURITIES

$13,624.24

AWARD AGAINST PARTY

08/05/2011

$425.00

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

Disclosure 205 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

FINRA

02/05/2011

11-00416

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

425©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 428: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

11-00416

UNIT INVESTMENT TRUST

$64,000.00

AWARD AGAINST PARTY

01/17/2012

$24,879.79

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

Disclosure 206 of 337

i

Reporting Source: Regulator

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:

FINRA

02/11/2011

11-00482

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

MUTUAL FUNDS

$987,015.00

AWARD AGAINST PARTY

08/13/2012

$50,000.00

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

Disclosure 207 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

426©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 429: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

FINRA

03/17/2011

11-00484

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

ANNUITIES; MUNICIPAL BOND FUNDS; MUTUAL FUNDS

$10,000,000.00

AWARD AGAINST PARTY

10/10/2012

$97,250.00

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

Disclosure 208 of 337

i

Reporting Source: Regulator

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:

FINRA

02/18/2011

11-00556

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE

COMMON STOCK; MUNICIPAL BONDS

$1,904,290.00

AWARD AGAINST PARTY

01/09/2013

$1,333,933.01

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

Disclosure 209 of 337

i

Reporting Source: Regulator

427©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 430: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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:

FINRA

04/14/2011

11-01076

ACCOUNT ACTIVITY-OTHER

CORPORATE BONDS

$23,993.00

AWARD AGAINST PARTY

11/15/2011

$20,819.30

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

Disclosure 210 of 337

i

Reporting Source: Regulator

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:

FINRA

05/18/2011

11-01444

ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-NEGLIGENCE

MUNICIPAL BOND FUNDS; MUTUAL FUNDS

$11,500.00

AWARD AGAINST PARTY

11/18/2011

$141.66

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

Disclosure 211 of 337

i

Reporting Source: Regulator

428©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 431: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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:

FINRA

06/03/2011

11-01510

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

FANNIE MAE; LIMITED PARTNERSHIPS; MUNICIPAL BONDS

$100,348.00

AWARD AGAINST PARTY

02/17/2012

$225.00

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

Disclosure 212 of 337

i

Reporting Source: Regulator

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:

FINRA

05/12/2011

11-01830

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; MUTUAL FUNDS; STRUCTURED PRODUCTS

$100,000.00

AWARD AGAINST PARTY

02/27/2012

$21,000.01

429©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 432: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Disclosure 213 of 337

i

Reporting Source: Regulator

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:

FINRA

08/23/2011

11-03046

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK

$500,000.00

AWARD AGAINST PARTY

06/14/2012

$70,000.00

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

Disclosure 214 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

FINRA

12/01/2011

11-04241

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

AUCTION RATE SECURITIES

$80,000,000.00430©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 433: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

$80,000,000.00

AWARD AGAINST PARTY

12/24/2013

$0.00

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

Disclosure 215 of 337

i

Reporting Source: Regulator

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:

FINRA

11/21/2011

11-04268

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS

$9,000.00

AWARD AGAINST PARTY

06/11/2012

$325.00

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

Disclosure 216 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

FINRA

02/06/2012

11-04377

ACCOUNT ACTIVITY-CHURNING; ACCOUNT RELATED-TRANSFER

COMMON STOCK; MUTUAL FUNDS; VARIABLE ANNUITIES

431©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 434: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

$9,325.00

AWARD AGAINST PARTY

08/27/2012

$162.50

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

Disclosure 217 of 337

i

Reporting Source: Regulator

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:

FINRA

12/15/2011

11-04556

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK

Unspecified Damages

AWARD AGAINST PARTY

03/08/2013

$70,930.20

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

Disclosure 218 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNTRELATED-BREACH OF CONTRACT; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-EXCHANGES; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE

432©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 435: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

FINRA

12/30/2011

11-04763

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNTRELATED-BREACH OF CONTRACT; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-EXCHANGES; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE

VARIABLE ANNUITIES

$737,733.14

AWARD AGAINST PARTY

01/15/2013

$306,127.28

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

Disclosure 219 of 337

i

Reporting Source: Regulator

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:

FINRA

01/27/2012

11-04797

DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE

$8,692.83

AWARD AGAINST PARTY

10/16/2012

$8,692.84

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

Disclosure 220 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-SUITABILITY

433©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 436: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

FINRA

03/02/2012

12-00515

ACCOUNT ACTIVITY-SUITABILITY

ANNUITIES

$71,775.00

AWARD AGAINST PARTY

12/27/2012

$15,786.45

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

Disclosure 221 of 337

i

Reporting Source: Regulator

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:

FINRA

04/04/2012

12-00793

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNTACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK

$9,000,000.00

AWARD AGAINST PARTY

07/30/2013

$1,802,508.08

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

Disclosure 222 of 337

i

434©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 437: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 222 of 337

Reporting Source: Regulator

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:

FINRA

03/26/2012

12-00996

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; FANNIE MAE; GOVERNMENT SECURITIES; PREFERREDSTOCK

$50,000.00

AWARD AGAINST PARTY

02/06/2013

$48,399.70

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

Disclosure 223 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

FINRA

07/11/2012

12-02349

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

COMMON STOCK

Unspecified Damages

AWARD AGAINST PARTY

11/26/2013435©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 438: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition Date:

Sum of All Relief Awarded:

11/26/2013

$1,307,920.80

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

Disclosure 224 of 337

i

Reporting Source: Regulator

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:

FINRA

09/25/2012

12-02817

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-OTHER; ACCOUNT RELATED-TRANSFER; DO NOT USE-OTHER-OTHER

COMMON STOCK; EXCHANGE-TRADED FUNDS; MUTUAL FUNDS

$50,000.00

AWARD AGAINST PARTY

07/02/2013

$300.00

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

Disclosure 225 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

FINRA

10/09/2012

12-03473

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING;ACCOUNT RELATED-ERRORS-CHARGES

EXCHANGE-TRADED FUNDS

$50,000.00 436©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 439: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

$50,000.00

AWARD AGAINST PARTY

01/22/2014

$35,952.94

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

Disclosure 226 of 337

i

Reporting Source: Regulator

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:

FINRA

12/26/2012

12-03924

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZEDTRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK

$100,000.00

AWARD AGAINST PARTY

03/02/2015

$60,000.01

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

Disclosure 227 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZEDTRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-NEGLIGENCE; TRADING DISPUTES-SELL OUTS

437©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 440: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

FINRA

01/28/2013

13-00033

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZEDTRADING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-NEGLIGENCE; TRADING DISPUTES-SELL OUTS

MUTUAL FUNDS; OTHER TYPES OF SECURITIES; PREFERRED STOCK

Unspecified Damages

AWARD AGAINST PARTY

12/16/2013

$10,000.00

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

Disclosure 228 of 337

i

Reporting Source: Regulator

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:

FINRA

01/09/2013

13-00034

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

VARIABLE ANNUITIES

$420,150.21

AWARD AGAINST PARTY

11/06/2013

$300.00

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

Disclosure 229 of 337

i

Reporting Source: Regulator

438©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 441: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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:

FINRA

03/21/2013

13-00333

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

VARIABLE ANNUITIES

Unspecified Damages

AWARD AGAINST PARTY

11/06/2014

$144,808.00

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

Disclosure 230 of 337

i

Reporting Source: Regulator

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:

FINRA

03/15/2013

13-00469

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-EXECUTION PRICE; DO NOT USE-EXECUTIONS-FAILURE TOEXECUTE; DO NOT USE-EXECUTIONS-INCORRECT QUANTITY; DO NOTUSE-EXECUTIONS-OTHER; OTHER-UNDERWRITING; TRADING DISPUTES-OTHER

COMMON STOCK

$4,914.32

AWARD AGAINST PARTY

10/29/2013

$3,289.00 439©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 442: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $3,289.00

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

Disclosure 231 of 337

i

Reporting Source: Regulator

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:

FINRA

04/16/2013

13-00779

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

COMMON STOCK; MUTUAL FUNDS

$500,000.00

AWARD AGAINST PARTY

07/30/2014

$144,125.00

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

Disclosure 232 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

FINRA

06/07/2013

13-01405

ACCOUNT ACTIVITY-UNAUTHORIZED TRADING

$4,999.00

AWARD AGAINST PARTY 440©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 443: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition:

Disposition Date:

Sum of All Relief Awarded:

AWARD AGAINST PARTY

02/11/2014

$2,881.92

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

Disclosure 233 of 337

i

Reporting Source: Regulator

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:

FINRA

07/08/2013

13-01756

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE

CERTIFICATE OF DEPOSIT

$193,327.68

AWARD AGAINST PARTY

03/28/2014

$61,725.00

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

Disclosure 234 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Allegations:

FINRA

08/19/2013

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

441©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 444: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

13-02375

ANNUITIES; VARIABLE ANNUITIES

$49,292.36

AWARD AGAINST PARTY

02/19/2014

$34,982.02

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

Disclosure 235 of 337

i

Reporting Source: Regulator

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:

FINRA

08/27/2013

13-02468

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER; TRADINGDISPUTES-OTHER

COMMON STOCK

$12,000.00

AWARD AGAINST PARTY

03/27/2015

$600.00

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

Disclosure 236 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

442©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 445: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

FINRA

08/30/2013

13-02508

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

MUTUAL FUNDS

$60,000.00

AWARD AGAINST PARTY

07/09/2015

$60,545.10

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

Disclosure 237 of 337

i

Reporting Source: Regulator

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:

FINRA

10/11/2013

13-02910

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TOEXECUTE

COMMON STOCK

$11,923.00

AWARD AGAINST PARTY

04/25/2014

$2,225.01

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

Disclosure 238 of 337

i

443©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 446: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 238 of 337

Reporting Source: Regulator

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:

FINRA

10/25/2013

13-02939

DO NOT USE-EMPLOYMENT-DISCRIMINATION AGE; DO NOT USE-EMPLOYMENT-EMPLOYMENT DISCRM ; EMPLOYMENT-BREACH OFCONTRACT; EMPLOYMENT-COMMISSIONS; EMPLOYMENT-COMPENSATION;EMPLOYMENT-WRONGFUL TERMINATION

$81,131.63

AWARD AGAINST PARTY

03/03/2016

$0.01

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

Disclosure 239 of 337

i

Reporting Source: Regulator

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:

FINRA

10/17/2013

13-03009

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE

PREFERRED STOCK

$49,999.00

AWARD AGAINST PARTY

05/01/2014

$49,999.01444©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 447: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $49,999.01

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

Disclosure 240 of 337

i

Reporting Source: Regulator

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:

FINRA

11/21/2013

13-03327

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE

COLLATERALIZED DEBT OBLIGATIONS; COLLATERALIZED MORTGAGEOBLIGATIONS; COMMON STOCK; MUTUAL FUNDS

$100,000.00

AWARD AGAINST PARTY

12/15/2015

$10,600.00

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

Disclosure 241 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

FINRA

01/29/2014

14-00189

ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-FAILURE TO SUPERVISE

OTHER TYPES OF SECURITIES

$87,500.00445©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 448: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

$87,500.00

AWARD AGAINST PARTY

02/10/2015

$94,500.00

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

Disclosure 242 of 337

i

Reporting Source: Regulator

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:

FINRA

03/27/2014

14-00455

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

$24,000.00

AWARD AGAINST PARTY

12/05/2014

$866.14

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

Disclosure 243 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Allegations:

FINRA

03/26/2014

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

446©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 449: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

03/26/2014

14-00895

COMMON STOCK; MUTUAL FUNDS; OPTIONS; OTHER TYPES OFSECURITIES

$41,441.66

AWARD AGAINST PARTY

11/05/2014

$300.00

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

Disclosure 244 of 337

i

Reporting Source: Regulator

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:

FINRA

05/21/2014

14-01404

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNTACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

COMMON STOCK

$300,000.00

AWARD AGAINST PARTY

06/19/2015

$50,300.01

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

Disclosure 245 of 337

i

Reporting Source: Regulator

447©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 450: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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:

FINRA

06/05/2014

14-01701

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

PREFERRED STOCK

$65,895.23

AWARD AGAINST PARTY

05/21/2015

$300.00

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

Disclosure 246 of 337

i

Reporting Source: Regulator

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:

FINRA

06/06/2014

14-01741

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE; TRADING DISPUTES-OTHER

COMMON STOCK

$473,603.60

AWARD AGAINST PARTY

01/07/2016

$346,881.41 448©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 451: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $346,881.41

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

Disclosure 247 of 337

i

Reporting Source: Regulator

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:

FINRA

10/21/2014

14-02593

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE

VARIABLE ANNUITIES

$95,930.00

AWARD AGAINST PARTY

12/16/2015

$3,600.00

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

Disclosure 248 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

FINRA

09/03/2014

14-02644

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE;ACCOUNT RELATED-OTHER

OTHER TYPES OF SECURITIES

449©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 452: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

Unspecified Damages

AWARD AGAINST PARTY

05/09/2016

$113,607.84

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

Disclosure 249 of 337

i

Reporting Source: Regulator

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:

FINRA

10/23/2014

14-02759

ACCOUNT RELATED-OTHER

$100,000.00

AWARD AGAINST PARTY

12/09/2015

$225.00

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

Disclosure 250 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Allegations:

FINRA

10/17/2014

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

450©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 453: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

14-02849

MUTUAL FUNDS

$100,000.00

AWARD AGAINST PARTY

05/31/2016

$66,225.00

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

Disclosure 251 of 337

i

Reporting Source: Regulator

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:

FINRA

10/21/2014

14-02953

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER; DO NOT USE-EXECUTIONS-EXECUTION PRICE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-EXECUTIONS-OTHER;TRADING DISPUTES-OTHER

MUTUAL FUNDS

$150,000.01

AWARD AGAINST PARTY

07/18/2016

$181,757.12

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

Disclosure 252 of 337

i

Reporting Source: Regulator

451©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 454: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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:

FINRA

01/13/2015

15-00074

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

COMMON STOCK; MUTUAL FUNDS

$342,077.89

AWARD AGAINST PARTY

06/16/2016

$423,770.50

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

Disclosure 253 of 337

i

Reporting Source: Regulator

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:

FINRA

02/10/2015

15-00235

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-FRAUD;ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

COMMON STOCK

Unspecified Damages

AWARD AGAINST PARTY

10/24/2016

$5,987.76

452©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 455: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Disclosure 254 of 337

i

Reporting Source: Regulator

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:

FINRA

04/30/2015

15-00949

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

VARIABLE ANNUITIES

$47,169.00

AWARD AGAINST PARTY

09/21/2015

$600.00

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

Disclosure 255 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

FINRA

07/20/2015

15-01676

$275,000.01

AWARD AGAINST PARTY

09/12/2016 453©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 456: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition Date:

Sum of All Relief Awarded:

09/12/2016

$262,354.00

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

Disclosure 256 of 337

i

Reporting Source: Regulator

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:

FINRA

08/28/2015

15-01842

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-FRAUD;ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY;ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT ACTIVITY-VIOLATE OF BLUE SKY LWS; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-MARGINCALLS; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

COMMON STOCK; MUTUAL FUNDS

$100,000.01

AWARD AGAINST PARTY

08/02/2016

$98,750.00

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

Disclosure 257 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

FINRA

04/11/2016

16-00066

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

454©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 457: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

16-00066

ANNUITIES; VARIABLE ANNUITIES

Unspecified Damages

AWARD AGAINST PARTY

10/11/2016

$300.00

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

Disclosure 258 of 337

i

Reporting Source: Regulator

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:

FINRA

02/10/2016

16-00213

$10,600.00

AWARD AGAINST PARTY

08/23/2016

$212.50

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

Disclosure 259 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Allegations:

FINRA

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE

455©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 458: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

FINRA

05/03/2016

16-01123

COMMON STOCK; LIMITED PARTNERSHIPS; MUTUAL FUNDS; REAL ESTATEINVESTMENT TRUST; STRUCTURED PRODUCTS

$1,000,000.00

AWARD AGAINST PARTY

03/09/2017

$357,000.00

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

Disclosure 260 of 337

i

Reporting Source: Regulator

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:

FINRA

07/20/2016

16-01810

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-FRAUD;ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-VIOLATEOF BLUE SKY LWS; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

OTHER TYPES OF SECURITIES

$150,000.00

AWARD AGAINST PARTY

04/26/2018

$76,257.01

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

Disclosure 261 of 337

i

Reporting Source: Regulator

456©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 459: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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:

FINRA

03/22/2017

17-00704

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

$50,000.00

AWARD AGAINST PARTY

09/08/2017

$50,600.01

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

Disclosure 262 of 337

i

Reporting Source: Regulator

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:

FINRA

07/11/2017

17-01341

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-OMISSION OF FACTS

ANNUITIES

$4,433.16

AWARD AGAINST PARTY

03/08/2018

$58.33

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

Disclosure 263 of 337

i

457©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 460: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 263 of 337

Reporting Source: Regulator

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:

FINRA

07/18/2017

17-01522

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; TRADINGDISPUTES-OTHER

WARRANTS/RIGHTS

$2,500.00

AWARD AGAINST PARTY

01/04/2018

$37.50

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

Disclosure 264 of 337

i

Reporting Source: Regulator

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:

FINRA

06/21/2017

17-01621

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-VIOLATE OF BLUE SKY LWS; ACCOUNTRELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-OTHER

COMMON STOCK; OTHER TYPES OF SECURITIES; REAL ESTATEINVESTMENT TRUST

$50,000.00

AWARD AGAINST PARTY

01/16/2018

$70,600.00

458©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 461: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Disclosure 265 of 337

i

Reporting Source: Regulator

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

01/01/1989

89-01661

ACCOUNT ACTIVITY-OMISSION OF FACTS; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

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

$10,000.00

AWARD AGAINST PARTY

12/11/1989

$10,000.00

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

Disclosure 266 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

NASD

01/01/1990

90-00374

ACCOUNT RELATED-TRANSFER; DO NOT USE-NO OTHER CONTROVERSYINVOLVED

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

$7,261.00

AWARD AGAINST PARTY

07/06/1990 459©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 462: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition Date:

Sum of All Relief Awarded:

07/06/1990

$2,547.25

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

Disclosure 267 of 337

i

Reporting Source: Regulator

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

05/15/1991

91-01469

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BOND FUNDS

$139,000.00

AWARD AGAINST PARTY

09/01/1992

$31,833.00

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

Disclosure 268 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

NASD

08/09/1991

91-01908

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; CORPORATE BONDS; UNKNOWN TYPE OF SECURITIES

$90,383.00

460©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 463: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

$90,383.00

AWARD AGAINST PARTY

11/23/1992

$20,000.00

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

Disclosure 269 of 337

i

Reporting Source: Regulator

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

01/21/1992

91-03839

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-SUITABILITY

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS

$45,906.00

AWARD AGAINST PARTY

10/21/1992

$10,000.00

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

Disclosure 270 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

NASD

05/18/1992

92-01018

ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

461©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 464: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

92-01018

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS

$9,800.00

AWARD AGAINST PARTY

12/29/1992

$6,600.00

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

Disclosure 271 of 337

i

Reporting Source: Regulator

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

04/28/1992

92-01252

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS

Unspecified Damages

AWARD AGAINST PARTY

10/12/1992

$20,000.00

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

Disclosure 272 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Allegations:

NASD

05/06/1993

ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

462©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 465: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

05/06/1993

92-03851

CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$30,000.00

AWARD AGAINST PARTY

03/16/1994

$6,500.00

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

Disclosure 273 of 337

i

Reporting Source: Regulator

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

04/22/1993

92-04217

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER;ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSYINVOLVED

GINNIE MAES; GOVERNMENT SECURITIES; LIMITED PARTNERSHIPS;MUTUAL FUNDS

$45,240.00

AWARD AGAINST PARTY

12/28/1993

$15,000.00

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

Disclosure 274 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTACTIVITY-UNAUTHORIZED TRADING

463©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 466: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

03/25/1993

93-00889

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTACTIVITY-UNAUTHORIZED TRADING

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

$110,404.00

AWARD AGAINST PARTY

03/28/1994

$110,000.00

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

Disclosure 275 of 337

i

Reporting Source: Regulator

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

04/29/1993

93-00971

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-SUITABILITY

ANNUITIES; COMMON STOCK; CORPORATE BONDS; MUNICIPAL BONDFUNDS

$100,000.00

AWARD AGAINST PARTY

12/20/1994

$98,159.63

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

Disclosure 276 of 337

i

464©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 467: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 276 of 337

Reporting Source: Regulator

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

05/10/1993

93-01849

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-FAILURE TO SUPERVISE

CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUTUAL FUNDS; OPTIONS

$680,000.00

AWARD AGAINST PARTY

02/09/1994

$134,053.16

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

Disclosure 277 of 337

i

Reporting Source: Regulator

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

01/04/1994

93-04411

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$44,000.00

AWARD AGAINST PARTY

11/30/1994

$13,211.40

465©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 468: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Disclosure 278 of 337

i

Reporting Source: Regulator

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

03/02/1994

94-00149

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$7,911.00

AWARD AGAINST PARTY

02/16/1995

$810.00

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

Disclosure 279 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

NASD

04/14/1994

94-00197

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTACTIVITY-UNAUTHORIZED TRADING

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$1,500,000.00

AWARD AGAINST PARTY

03/31/1995 466©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 469: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition Date:

Sum of All Relief Awarded:

03/31/1995

$305,000.00

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

Disclosure 280 of 337

i

Reporting Source: Regulator

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

07/05/1994

94-01485

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-OTHER; DO NOT USE-NOOTHER CONTROVERSY INVOLVED

CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$10,600.00

AWARD AGAINST PARTY

06/27/1995

$10,600.00

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

Disclosure 281 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

NASD

08/10/1994

94-02471

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$100,000.00

467©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 470: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

$100,000.00

AWARD AGAINST PARTY

05/29/1996

$15,000.00

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

Disclosure 282 of 337

i

Reporting Source: Regulator

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

07/19/1994

94-02529

ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

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

$425,000.00

AWARD AGAINST PARTY

06/10/1996

$13,164.00

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

Disclosure 283 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

NASD

08/17/1994

94-02866

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

468©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 471: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

94-02866

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS

$10,000.00

AWARD AGAINST PARTY

08/21/1995

$4,000.00

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

Disclosure 284 of 337

i

Reporting Source: Regulator

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

09/15/1994

94-03482

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-NEGLIGENCE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS

$106,689.75

AWARD AGAINST PARTY

06/28/1995

$70,968.00

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

Disclosure 285 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Allegations:

NASD

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-NEGLIGENCE

469©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 472: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

11/09/1994

94-03639

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITEDPARTNERSHIPS

$425,000.00

AWARD AGAINST PARTY

08/02/1996

$23,000.00

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

Disclosure 286 of 337

i

Reporting Source: Regulator

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

11/08/1994

94-03991

ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$23,375.85

AWARD AGAINST PARTY

12/07/1995

$30,109.00

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

Disclosure 287 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NOOTHER CONTROVERSY INVOLVED

470©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 473: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

11/15/1994

94-04168

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NOOTHER CONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$73,920.34

AWARD AGAINST PARTY

02/23/1996

$22,000.00

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

Disclosure 288 of 337

i

Reporting Source: Regulator

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

12/07/1994

94-04341

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUNICIPAL BONDS; MUTUAL FUNDS

$2,799,104.00

AWARD AGAINST PARTY

04/16/1996

$193,350.00

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

Disclosure 289 of 337

i

471©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 474: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 289 of 337

Reporting Source: Regulator

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

12/22/1994

94-04806

ACCOUNT RELATED-ERRORS-CHARGES; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$2,320.80

AWARD AGAINST PARTY

06/23/1995

$1,182.00

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

Disclosure 290 of 337

i

Reporting Source: Regulator

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

01/11/1995

94-05052

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

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

Unspecified Damages

AWARD AGAINST PARTY

10/13/1995

$109,992.00

472©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 475: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Disclosure 291 of 337

i

Reporting Source: Regulator

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

12/14/1994

94-05072

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$343,637.24

AWARD AGAINST PARTY

07/15/1996

$23,931.00

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

Disclosure 292 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

NASD

02/10/1995

95-00161

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; FANNIE MAE

$3,005,642.14

AWARD AGAINST PARTY

08/01/1996

473©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 476: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $77,250.00

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

Disclosure 293 of 337

i

Reporting Source: Regulator

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

03/02/1995

95-00354

ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; DO NOTUSE-NO OTHER CONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$4,000.00

AWARD AGAINST PARTY

08/25/1995

$2,714.00

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

Disclosure 294 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

NASD

05/03/1995

95-00462

ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSYINVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; FREDDIE MACS

$10,000.00

AWARD AGAINST PARTY

12/21/1995474©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 477: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition Date:

Sum of All Relief Awarded:

12/21/1995

$150.00

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

Disclosure 295 of 337

i

Reporting Source: Regulator

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

03/29/1995

95-00571

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; DO NOTUSE-NO OTHER CONTROVERSY INVOLVED

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

$40,000.00

AWARD AGAINST PARTY

04/22/1996

$12,000.00

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

Disclosure 296 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

NASD

02/21/1995

95-00735

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE475©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 478: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$272,841.56

AWARD AGAINST PARTY

05/04/1998

$91,912.00

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

Disclosure 297 of 337

i

Reporting Source: Regulator

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

03/07/1995

95-00874

ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

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

$2,000,000.00

AWARD AGAINST PARTY

03/20/1996

$400,000.00

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

Disclosure 298 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Allegations:

NASD

03/16/1995

ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSYINVOLVED

476©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 479: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

95-01190

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$10,000.00

AWARD AGAINST PARTY

09/25/1995

$662.00

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

Disclosure 299 of 337

i

Reporting Source: Regulator

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

08/16/1995

95-03876

ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$3,852.25

AWARD AGAINST PARTY

02/14/1996

$3,915.02

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

Disclosure 300 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Allegations:

NASD

09/12/1995

ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSYINVOLVED

477©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 480: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

09/12/1995

95-04229

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$7,014.86

AWARD AGAINST PARTY

03/28/1996

$2,949.06

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

Disclosure 301 of 337

i

Reporting Source: Regulator

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

10/18/1995

95-04646

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-FAILURE TO SUPERVISE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$180,000.00

AWARD AGAINST PARTY

02/18/1997

$77,000.00

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

Disclosure 302 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURETO SUPERVISE 478©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 481: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

01/24/1996

96-00060

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURETO SUPERVISE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS

$512,500.00

AWARD AGAINST PARTY

04/09/1997

$287,130.75

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

Disclosure 303 of 337

i

Reporting Source: Regulator

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

01/29/1996

96-00347

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$201,245.40

AWARD AGAINST PARTY

05/06/1997

$129,661.04

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

Disclosure 304 of 337

i

Reporting Source: Regulator

479©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 482: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

02/09/1996

96-00589

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

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHERTYPES OF SECURITIES

$121,462.50

AWARD AGAINST PARTY

09/09/1996

$143,809.41

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

Disclosure 305 of 337

i

Reporting Source: Regulator

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

03/21/1996

96-00877

ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY; DO NOTUSE-NO OTHER CONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS

$100,000.00

AWARD AGAINST PARTY

03/31/1997

$9,750.00

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

i480©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 483: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 306 of 337

i

Reporting Source: Regulator

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

03/08/1996

96-00885

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-OTHER

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$53,500.00

AWARD AGAINST PARTY

01/28/1997

$7,500.00

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

Disclosure 307 of 337

i

Reporting Source: Regulator

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

04/11/1996

96-01455

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS

$45,000.00

AWARD AGAINST PARTY

03/09/1998

$10,520.00

481©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 484: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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

Disclosure 308 of 337

i

Reporting Source: Regulator

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

03/21/1997

97-00915

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$772,105.00

AWARD AGAINST PARTY

11/03/1999

$3,700.00

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

Disclosure 309 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

NASD

05/01/1997

97-02147

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY

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

$236,318.67

AWARD AGAINST PARTY482©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 485: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disposition:

Disposition Date:

Sum of All Relief Awarded:

AWARD AGAINST PARTY

10/14/1997

$76,721.69

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

Disclosure 310 of 337

i

Reporting Source: Regulator

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

07/31/1997

97-02255

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

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

$2,000,000.00

AWARD AGAINST PARTY

06/08/1999

$203,101.00

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

Disclosure 311 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

NASD

06/12/1997

97-02831

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-FAILURE TO SUPERVISE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE 483©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 486: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$208,000.00

AWARD AGAINST PARTY

02/06/1998

$25,000.00

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

Disclosure 312 of 337

i

Reporting Source: Regulator

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

09/16/1997

97-04296

ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-OTHER; DONOT USE-NO OTHER CONTROVERSY INVOLVED

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

$27,012.00

AWARD AGAINST PARTY

07/15/1998

$3,700.00

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

Disclosure 313 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Allegations:

NASD

10/02/1997

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING;ACCOUNT RELATED-FAILURE TO SUPERVISE

484©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 487: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

10/02/1997

97-04300

ANNUITIES; COMMON STOCK; GOVERNMENT SECURITIES; PREFERREDSTOCK

$311,607.53

AWARD AGAINST PARTY

03/29/1999

$75,000.00

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

Disclosure 314 of 337

i

Reporting Source: Regulator

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

04/15/1998

98-01192

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE

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

$169,000.00

AWARD AGAINST PARTY

05/19/1999

$114,850.00

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

Disclosure 315 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-FAILURE TO SUPERVISE

485©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 488: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

04/13/1998

98-01226

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-FAILURE TO SUPERVISE

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

$5,000,000.00

AWARD AGAINST PARTY

09/22/1999

$100,000.00

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

Disclosure 316 of 337

i

Reporting Source: Regulator

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

04/13/1998

98-01226

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-FAILURE TO SUPERVISE

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

$5,000,000.00

AWARD AGAINST PARTY

09/22/1999

$100,000.00

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

486©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 489: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 317 of 337

i

Reporting Source: Regulator

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

09/03/1998

98-02926

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

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

$890,537.00

AWARD AGAINST PARTY

09/10/1999

$250.00

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

Disclosure 318 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

NASD

09/09/1998

98-03100

DO NOT USE-EMPLOYMENT-DISCRIMINATION AGE; DO NOT USE-NOOTHER CONTROVERSY INVOLVED; EMPLOYMENT-BREACH OF CONTRACT;EMPLOYMENT-COMPENSATION

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$2,150,000.00

AWARD AGAINST PARTY

12/10/1999

487©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 490: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $117,610.01

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

Disclosure 319 of 337

i

Reporting Source: Regulator

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

12/11/1998

98-03452

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-FAILURE TO SUPERVISE

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

$1,100,000.00

AWARD AGAINST PARTY

08/23/2001

$65,000.00

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

Disclosure 320 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

NASD

12/15/1998

98-04080

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-FAILURE TO SUPERVISE

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

488©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 491: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

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

$166,496.00

AWARD AGAINST PARTY

01/26/2000

$54,969.00

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

Disclosure 321 of 337

i

Reporting Source: Regulator

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

12/30/1998

98-04168

ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-EXECUTIONS-FAILURE TOEXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$5,538.63

AWARD AGAINST PARTY

07/16/1999

$5,538.63

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

Disclosure 322 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

NASD

03/10/1999

98-04822

DO NOT USE-NO OTHER CONTROVERSY INVOLVED; UNKNOWN TYPE OFCONTROVERSIES

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

489©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 492: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

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; UNKNOWN TYPE OFSECURITIES

$84,000.00

AWARD AGAINST PARTY

06/09/2000

$0.00

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

Disclosure 323 of 337

i

Reporting Source: Regulator

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

03/24/1999

99-00292

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

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

$16,000,000.00

AWARD AGAINST PARTY

02/20/2002

$408,646.31

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

Disclosure 324 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Allegations:

NASD

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

490©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 493: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

02/25/1999

99-00579

CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$50,000.00

AWARD AGAINST PARTY

02/04/2000

$28,000.00

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

Disclosure 325 of 337

i

Reporting Source: Regulator

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

05/06/1999

99-01034

ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSYINVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$1,300.00

AWARD AGAINST PARTY

02/10/2000

$25.00

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

Disclosure 326 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT 491©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 494: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

05/21/1999

99-02222

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUNICIPAL BONDS; OPTIONS

$650,000.00

AWARD AGAINST PARTY

09/07/2000

$31,000.00

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

Disclosure 327 of 337

i

Reporting Source: Regulator

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

08/11/1999

99-02526

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$148,061.41

AWARD AGAINST PARTY

07/16/2001

$21,000.00

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

Disclosure 328 of 337

i

492©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 495: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Reporting Source: Regulator

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

07/27/1999

99-02596

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTRELATED-FAILURE TO SUPERVISE

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

$798,416.21

AWARD AGAINST PARTY

08/22/2001

$70,194.00

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

Disclosure 329 of 337

i

Reporting Source: Regulator

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

07/28/1999

99-03182

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$5,653.00

AWARD AGAINST PARTY

06/07/2000

$162.50

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

493©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 496: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Disclosure 330 of 337

i

Reporting Source: Regulator

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

08/26/1999

99-03288

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-NEGLIGENCE

CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$59,000.00

AWARD AGAINST PARTY

09/25/2000

$30,210.00

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

Disclosure 331 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

NASD

10/12/1999

99-03729

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSYINVOLVED

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

$537,501.66

AWARD AGAINST PARTY

12/21/2000

494©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 497: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $221,954.03

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

Disclosure 332 of 337

i

Reporting Source: Regulator

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

09/22/1999

99-03778

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTACTIVITY-UNAUTHORIZED TRADING

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;OPTIONS

$1,000,000.00

AWARD AGAINST PARTY

05/03/2001

$10,041.00

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

Disclosure 333 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

NASD

10/14/1999

99-04019

ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSYINVOLVED

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

$98,325.16495©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 498: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

$98,325.16

AWARD AGAINST PARTY

04/24/2002

$40,990.17

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

Disclosure 334 of 337

i

Reporting Source: Regulator

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

10/18/1999

99-04104

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$5,000.00

AWARD AGAINST PARTY

10/30/2000

$87.50

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

Disclosure 335 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

NASD

11/15/1999

99-04914

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-NEGLIGENCE

496©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 499: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

99-04914

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS

$54,870.65

AWARD AGAINST PARTY

11/30/2000

$9,220.43

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

Disclosure 336 of 337

i

Reporting Source: Regulator

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

01/18/2000

99-04915

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;OPTIONS; WARRANTS/RIGHTS

$1,726,929.46

AWARD AGAINST PARTY

10/23/2001

$208,925.91

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

Disclosure 337 of 337

i

Reporting Source: Regulator

Type of Event: ARBITRATION

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-BREACH OF CONTRACT

497©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 500: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

Arbitration Forum:

Case Initiated:

Case Number:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

01/31/2000

99-05550

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

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$6,319.05

AWARD AGAINST PARTY

10/24/2000

$5,221.33

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

498©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC

Page 501: WELLS FARGO CLEARING SERVICES, LLC FARGO CLEARING SERVICES, LLC CRD# 19616 SEC# 8-37180 Main Office Location ONE NORTH JEFFERSON AVENUE MAIL CODE: H0004-050 ST. LOUIS, MO 63103 Regulated

www.finra.org/brokercheck User Guidance

End of Report

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499©2018 FINRA. All rights reserved. Report about WELLS FARGO CLEARING SERVICES, LLC