EDWARD JONES - FINRA · EDWARD JONES CRD# 250 SEC# 8-759 Main Office Location 12555 MANCHESTER ROAD...

BrokerCheck Report

EDWARD JONES

Section Title

Report Summary

Firm History

CRD# 250

1

9

Firm Profile 2 - 8

Page(s)

Firm Operations 10 - 19

Disclosure Events 20

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EDWARD JONES

CRD# 250

SEC# 8-759

Main Office Location

12555 MANCHESTER ROADST. LOUIS, MO 63131-3710Regulated by FINRA Kansas City Office

Mailing Address

12555 MANCHESTER ROADST. LOUIS, MO 63131-3710

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

314-515-8001

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 73

Civil Event 2

Arbitration 148

Firm Profile

This firm is classified as a other types of legalformation.

This firm was formed in Missouri on 02/20/1941.

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 19 types of businesses.

This firm is affiliated with financial or investmentinstitutions.

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

This firm is registered with:

• the SEC• 5 Self-Regulatory Organizations• 53 U.S. states and territories

www.finra.org/brokercheck User Guidance

1©2020 FINRA. All rights reserved. Report about EDWARD JONES

https://adviserinfo.sec.gov/firm/summary/250


http://www.finra.org/brokercheck

http://www.finra.org/brokercheck_reports


This firm is classified as a other types of legal formation.

This firm was formed in Missouri on 02/20/1941.

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.

EDWARD D. JONES & CO., L.P.

SEC#

250

8-759

Main Office Location

Mailing Address

Business Telephone Number

Doing business as EDWARD JONES

314-515-8001

Regulated by FINRA Kansas City Office








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

Direct Owners and Executive Officers

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

THE JONES FINANCIAL COMPANIES, L.L.L.P.

LIMITED PARTNER

75% or more

Yes

Domestic Entity

08/1987

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


BASTIEN, KEVIN DWAYNE

PRINCIPAL FINANCIAL OFFICER

Less than 5%

No

Individual

01/2009

Yes

2766980



Position


Position Start Date

CELLA, KENNETH RAY JR

PRINCIPAL OF CLIENT STRATEGIES GROUP

Less than 5%

Individual

07/2014

2089774








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


CURRAN, THOMAS PATRICK

PRINCIPAL OF BRANCH DEVELOPMENT

Less than 5%

No

Individual

01/2019

Yes

2223955



Position



Position Start Date


EDJ HOLDING COMPANY, INC.

GENERAL PARTNER

Less than 5%

No

Domestic Entity

08/1987

Yes



FERRARI, VINCENT JOSEPH

Individual

1961369









Firm Profile

Position



Position Start Date


PRINCIPAL OF FIRM ADMINISTRATION

Less than 5%

No

Individual

01/2017

Yes


Position



Position Start Date


JOHNSON, KRISTIN MICHELE

PRINCIPAL - HUMAN RESOURCES

Less than 5%

No

Individual

11/2019

Yes

2662524



Position


Position Start Date


LEWIS, CHRISTOPHER NORMAN

GENERAL COUNSEL

Less than 5%

Individual

01/2018

Yes

5273186









Firm Profile



No

Yes

Position



Position Start Date


LINK, RICHARD DAVID

CHIEF COMPLIANCE OFFICER

Less than 5%

No

Individual

12/2015

Yes

2017928



Position



Position Start Date


NEY, TIMOTHY JAMES

PRINCIPAL OPERATIONS OFFICER

Less than 5%

No

Individual

01/2017

Yes

2300399



PENNINGTON, PENELOPE

Individual

4037237









Firm Profile

Position



Position Start Date


CHIEF EXECUTIVE OFFICER

Less than 5%

No

Individual

01/2019

Yes







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

Indirect Owners

Firm Profile

THE JONES FINANCIAL COMPANIES, L.L.L.P.

SOLE SHAREHOLDER

EDJ HOLDING CO., INC.

75% or more

Yes

Domestic Entity

08/1987

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established









Firm History

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

No information reported.






Firm Operations

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

This firm is currently registered with the SEC, 5 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 04/26/1941

Self-Regulatory Organization Status Date Effective

FINRA Approved 10/16/1939

NYSE American LLC Approved 12/01/2008

NYSE Chicago, Inc. Approved 11/18/1936

Nasdaq Stock Market Approved 07/12/2006

New York Stock Exchange Approved 11/17/1982






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 10/23/1981

Alaska Approved 06/26/1986

Arizona Approved 02/18/1975

Arkansas Approved 05/05/1966

California Approved 01/01/1971

Colorado Approved 02/01/1983

Connecticut Approved 12/05/1986

Delaware Approved 05/13/1986

District of Columbia Approved 06/12/1986

Florida Approved 04/27/1983

Georgia Approved 09/21/1981

Hawaii Approved 03/27/1987

Idaho Approved 01/01/1967

Illinois Approved 07/01/1942

Indiana Approved 10/20/1981

Iowa Approved 07/14/1983

Kansas Approved 11/20/1961

Kentucky Approved 07/16/1982

Louisiana Approved 04/20/1983

Maine Approved 12/03/1986

Maryland Approved 06/02/1986

Massachusetts Approved 07/31/1981

Michigan Approved 02/02/1983

Minnesota Approved 07/15/1982

Mississippi Approved 10/14/1981

Missouri Approved 07/18/1983

Montana Approved 04/20/1983

Nebraska Approved 10/08/1981

Nevada Approved 07/15/1983

New Hampshire Approved 07/15/1986

New Jersey Approved 02/19/1987

New Mexico Approved 10/07/1981

New York Approved 11/06/1987

U.S. States &Territories

Status Date Effective

North Carolina Approved 07/15/1982

North Dakota Approved 10/21/1981

Ohio Approved 07/16/1982

Oklahoma Approved 07/17/1982

Oregon Approved 10/24/1981

Pennsylvania Approved 02/21/1990

Puerto Rico Approved 03/21/1988

Rhode Island Approved 02/01/1983

South Carolina Approved 10/28/1981

South Dakota Approved 07/15/1982

Tennessee Approved 08/17/1981

Texas Approved 07/25/1983

Utah Approved 04/21/1983

Vermont Approved 11/11/1986

Virgin Islands Approved 06/10/2005

Virginia Approved 09/22/1981

Washington Approved 04/20/1983

West Virginia Approved 09/30/1981

Wisconsin Approved 07/10/1966

Wyoming Approved 11/08/1967






Firm Operations

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

Other Types of Business

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

Non-Securities Business Description: INSURANCE PRODUCER

This firm currently conducts 19 types of businesses.

Types of Business

Exchange member engaged in exchange commission business other than floor activities

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

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

Broker or dealer selling corporate debt securities

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

Mutual fund underwriter or sponsor

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 securities of non-profit organizations (e.g., churches, hospitals)

Investment advisory services

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

Broker or dealer selling tax shelters or limited partnerships in the secondary market

Trading securities for own account

Broker or dealer selling interests in mortgages or other receivables






Firm Operations

Clearing Arrangements

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

Introducing Arrangements

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






Firm Operations

Industry Arrangements

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

Name: CISION US, INC.

Business Address: 130 E. RANDOLPH STREET, FL 7CHICAGO, IL 60601

Effective Date: 11/28/2016

Description: CISION US, INC. MAINTAINS CERTAIN OF APPLICANT'S RECORDS AT ITSPREMISES.

Name: CASS INFORMATION SYSTEMS

Business Address: 12444 POWERSCOURT DRIVE, SUITE 550SAINT LOUIS, MO 63131


Description: CASS INFORMATION SYSTEMS MAINTAINS CERTAIN OF APPLICANT'SRECORDS AT ITS PREMISES.

Name: UNDERGROUND VAULTS & STORAGE

Business Address: 906 NORTH HALSTEADHUTCHINSON, KS 67504


Description: UNDERGROUND VAULTS & STORAGE MAINTAINS CERTAIN OFAPPLICANT'S RECORDS AT ITS PREMISES.

Name: BROADRIDGE FINANCIAL SOLUTIONS, INC.

Business Address: 5 DAKOTA DRIVE, SUITE 300LAKE SUCCESS, NY 11042


Description: BROADRIDGE FINANCIAL SOLUTIONS MAINTAINS CERTAIN OFAPPLICANT'S RECORDS AT ITS PREMISES.

Name: IRON MOUNTAIN INCORPORATED

Business Address: 1 FEDERAL STREETBOSTON, MA 02110


Description: IRON MOUNTAIN MAINTAINS CERTAIN OF APPLICANT'S RECORDS ATITS PREMISES.






Firm Operations

Industry Arrangements (continued)

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

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

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

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

Control Persons/Financing

Name: INTERACTIVE BROKERS LLC

Business Address: ONE PICKWICK PLAZAGREENWICH, CT 06830

CRD #: 36418


Description: AN ACCOUNT, FUNDS, AND SECURITIES OF APPLICANT ARE HELD ORMAINTAINED BY INTERACTIVE BROKERS LLC.






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.

No

Yes

CANADA

Yes

07/19/1995

90 BURNHAMTHORPE ROAD WESTSUSSEX CENTRE, SUITE 902MISSISSAUGA, CANADA L5B 3C3

EDWARD JONES INSURANCE AGENCY is controlled by the firm.

APPLICANT INDIRECTLY OWNS 100% OF EDWARD JONES INSURANCEAGENCY.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

09/30/1997

12555 MANCHESTER ROADST. LOUIS, MO 63131

EDWARD JONES INSURANCE AGENCY OF CALIFORNIA, L.L.C. is controlled by the firm.

APPLICANT INDIRECTLY OWNS 100% OF EDWARD JONES INSURANCEAGENCY OF CALIFORNIA, L.L.C.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:


EDWARD JONES INSURANCE AGENCY (QUEBEC) INC. is controlled by the firm.

Business Address: 16©2020 FINRA. All rights reserved. Report about EDWARD JONES





Firm Operations

Organization Affiliates (continued)

No

Yes

CANADA

Yes

02/27/2002


APPLICANT INDIRECTLY OWNS 100% OF EDWARD JONES INSURANCEAGENCY (QUEBEC) INC.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

05/01/1998


EDWARD JONES INSURANCE AGENCY OF MASSACHUSETTS, L.L.C. is controlled by the firm.

APPLICANT, THROUGH DIRECT AND INDIRECT INTERESTS, OWNS 100% OFEDWARD JONES INSURANCE AGENCY OF MASSACHUSETTS, L.L.C.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

10/20/1997


EDWARD JONES INSURANCE AGENCY OF NEW MEXICO, L.L.C. is controlled by the firm.

APPLICANT DIRECTLY OWNS 100% OF EDWARD JONES INSURANCEAGENCY OF NEW MEXICO, L.L.C.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations


APPLICANT DIRECTLY OWNS 100% OF EDWARD JONES INSURANCEAGENCY OF NEW MEXICO, L.L.C.

Description:

Yes

No

No

12/11/2012

12555 MANCHESTER RD.ST. LOUIS, MO 63131

166710

OLIVE STREET INVESTMENT ADVISERS, LLC is under common control with the firm.

OLIVE STREET INVESTMENT ADVISERS, LLC AND APPLICANT ARE BOTHWHOLLY OWNED BY THE JONES FINANCIAL COMPANIES, L.L.L.P.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

CANADA

Yes

01/06/1998

90 BURNHAMTHORPE ROADWEST SUSSEX CENTREMISSISSAUGA, ONTARIO, CANADA L5B3C3

EDWARD JONES (ONTARIO, L.P.) is controlled by the firm.

APPLICANT, THROUGH DIRECT AND INDIRECT PARTNERSHIP INTERESTS,OWNS 100% OF EDWARD JONES (ONTARIO, L.P.), A CANADIAN BROKER-DEALER.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

02/28/2017


105139

PASSPORT RESEARCH, LTD. is controlled by the firm.

Effective Date:

Business Address:

CRD #:






Firm Operations


Yes

No

No

02/28/2017

APPLICANT, THROUGH DIRECT AND INDIRECT INTERESTS, OWNS 100% OFPASSPORT RESEARCH, LTD., A REGISTERED INVESTMENT ADVISER.

Description:



Country:

Foreign Entity:

Effective Date:

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

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






Disclosure Events

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

Final On AppealPending

Regulatory Event 0 73 0

Civil Event 0 2 0

Arbitration N/A 148 N/A






Disclosure Event Details

What you should know about reported disclosure events:

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

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

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

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

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

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

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

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

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

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

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

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

Regulatory - Final

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

Disclosure 1 of 73

Reporting Source: Firm

Allegations: IN CONNECTION WITH A COMPLAINT BY A SOUTH DAKOTA PUBLICCUSTOMER, THE SOUTH DAKOTA DIVISION OF INSURANCE, DEPARTMENTOF LABOR AND REGULATION ALLEGED THAT EDWARD JONES FAILED TOSUPERVISE A SINGLE FINANCIAL ADVISOR IN CONNECTION WITH THATFINANCIAL ADVISOR'S RECOMMENDATION OF CERTAIN MUTUAL FUNDS TOTHE CUSTOMER IN VIOLATION OF THE SOUTH DAKOTA SECURITIES ACTAND FINRA RULES 2010 AND 3110.

Current Status: Final






Initiated By: SOUTH DAKOTA DIVISION OF INSURANCE, DEPARTMENT OF LABOR ANDREGULATION

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

FOR SANCTIONS, REFER TO ITEM 12 BELOW.

Date Initiated: 12/20/2019

Docket/Case Number:

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations: IN CONNECTION WITH A COMPLAINT BY A SOUTH DAKOTA PUBLICCUSTOMER, THE SOUTH DAKOTA DIVISION OF INSURANCE, DEPARTMENTOF LABOR AND REGULATION ALLEGED THAT EDWARD JONES FAILED TOSUPERVISE A SINGLE FINANCIAL ADVISOR IN CONNECTION WITH THATFINANCIAL ADVISOR'S RECOMMENDATION OF CERTAIN MUTUAL FUNDS TOTHE CUSTOMER IN VIOLATION OF THE SOUTH DAKOTA SECURITIES ACTAND FINRA RULES 2010 AND 3110.

Resolution Date: 12/20/2019

Resolution:

Other Sanctions Ordered: INVESTIGATIVE COSTS OF $10,000; OFFER OF SETTLEMENT TOCUSTOMER OF $2,406.47

Sanction Details: ON DECEMBER 20, 2019, EDWARD JONES, WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, ENTERED INTO A CONSENT ORDER THEWITH THE SOUTH DAKOTA DIVISION OF INSURANCE, DEPARTMENT OFLABOR AND REGULATION (THE "DIVISION") TO RESOLVE THIS MATTER.EDWARD JONES AGREED TO PAY THE DIVISION $10,000 FOR THE COSTSOF THEIR INVESTIGATION AND TO MAKE AN OFFER OF SETTLEMENT TOTHE CUSTOMER IN THE AMOUNT OF $2,406.47. THE OFFER OFSETTLEMENT HAS BEEN TENDERED TO THE CUSTOMER, AND A CHECKFOR THE PAYMENT OF INVESTIGATIVE COSTS WAS MAILED OVERNIGHTTO THE DIVISION ON DECEMBER 19, 2019.

Sanctions Ordered:

Consent

Disclosure 2 of 73

i

Reporting Source: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FILEDFORMS U4 CONTAINING MISLEADING INFORMATION ABOUT THE AMOUNTOF ALLEGED DAMAGES IN CUSTOMERS' COMPLAINTS. THE FINDINGSSTATED THAT THE FIRM'S DISCLOSURES TO FINRA OF CUSTOMERCOMPLAINTS UNDERSTATED THE CUSTOMERS' ALLEGED DAMAGES. THEINACCURACIES IN THE FIRM'S FORM U4 FILINGS RESULTED FROM AMISUNDERSTANDING BY CERTAIN OF ITS ASSOCIATES ABOUT THEAPPLICABLE REQUIREMENTS FOR DISCLOSING CUSTOMERS'COMPLAINTS. WHEN FINRA IDENTIFIED THE INACCURACIES, THE FIRMPROMPTLY UPDATED THE FORMS U4 AT ISSUE TO REFLECT THE SPECIFICAMOUNTS OF THE CUSTOMERS' ALLEGED DAMAGES, PROVIDEDADDITIONAL TRAINING TO ITS ASSOCIATES, AND INSTITUTED ADDITIONALSAFEGUARDS FOR ITS PROCESS OF DISCLOSING CUSTOMERS'COMPLAINTS.







Initiated By: FINRA


Other


N/A


Docket/Case Number: 2018056422401

Principal Product Type: No Product


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FILEDFORMS U4 CONTAINING MISLEADING INFORMATION ABOUT THE AMOUNTOF ALLEGED DAMAGES IN CUSTOMERS' COMPLAINTS. THE FINDINGSSTATED THAT THE FIRM'S DISCLOSURES TO FINRA OF CUSTOMERCOMPLAINTS UNDERSTATED THE CUSTOMERS' ALLEGED DAMAGES. THEINACCURACIES IN THE FIRM'S FORM U4 FILINGS RESULTED FROM AMISUNDERSTANDING BY CERTAIN OF ITS ASSOCIATES ABOUT THEAPPLICABLE REQUIREMENTS FOR DISCLOSING CUSTOMERS'COMPLAINTS. WHEN FINRA IDENTIFIED THE INACCURACIES, THE FIRMPROMPTLY UPDATED THE FORMS U4 AT ISSUE TO REFLECT THE SPECIFICAMOUNTS OF THE CUSTOMERS' ALLEGED DAMAGES, PROVIDEDADDITIONAL TRAINING TO ITS ASSOCIATES, AND INSTITUTED ADDITIONALSAFEGUARDS FOR ITS PROCESS OF DISCLOSING CUSTOMERS'COMPLAINTS.


Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: THE FIRM WAS CENSURED, FINED $40,000, AND ORDERED TO CERTIFY INWRITING THAT THE FIRM HAS REVIEWED ITS SYSTEMS, POLICIES, ANDPROCEDURES, WRITTEN OR OTHERWISE, GOVERNING THE FIRM'SREVIEW, ANALYSIS, AND DISCLOSURE OF ALLEGED DAMAGES INCUSTOMER COMPLAINTS AND THAT THE FIRM HAS ESTABLISHED ANDIMPLEMENTED SYSTEMS, POLICIES, AND PROCEDURES, WRITTEN ANDOTHERWISE, GOVERNING THE REVIEW, ANALYSIS, AND DISCLOSURE OFALLEGED DAMAGES IN CUSTOMER COMPLAINTS THAT ARE REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULES. FINES PAID INFULL ON JULY 10, 2019.

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

No

Sanctions Ordered: CensureMonetary/Fine $40,000.00

Acceptance, Waiver & Consent(AWC)





https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2018056422401


THE FIRM WAS CENSURED, FINED $40,000, AND ORDERED TO CERTIFY INWRITING THAT THE FIRM HAS REVIEWED ITS SYSTEMS, POLICIES, ANDPROCEDURES, WRITTEN OR OTHERWISE, GOVERNING THE FIRM'SREVIEW, ANALYSIS, AND DISCLOSURE OF ALLEGED DAMAGES INCUSTOMER COMPLAINTS AND THAT THE FIRM HAS ESTABLISHED ANDIMPLEMENTED SYSTEMS, POLICIES, AND PROCEDURES, WRITTEN ANDOTHERWISE, GOVERNING THE REVIEW, ANALYSIS, AND DISCLOSURE OFALLEGED DAMAGES IN CUSTOMER COMPLAINTS THAT ARE REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULES. FINES PAID INFULL ON JULY 10, 2019.

iReporting Source: Firm

Initiated By: FINRA


Other


N/A





Allegations: FINRA ALLEGED THAT EDWARD JONES VIOLATED FINRA RULES 1122 AND2010 AND ARTICLE V, SECTION 2 OF FINRA'S BY-LAWS BY FILING FORMS U4CONTAINING MISLEADING INFORMATION ABOUT THE AMOUNT OFALLEGED DAMAGES IN CUSTOMERS' COMPLAINTS. FINRA FURTHERALLEGED THAT THE FIRM'S DISCLOSURES TO FINRA OF CUSTOMERCOMPLAINTS UNDERSTATED THE CUSTOMERS' ALLEGED DAMAGES, ANDRESULTED FROM A MISUNDERSTANDING BY CERTAIN OF ITS ASSOCIATESABOUT THE APPLICABLE REQUIREMENTS FOR DISCLOSURES REGARDINGCUSTOMERS' COMPLAINTS. WHEN FINRA IDENTIFIED THE INACCURACIES,EDWARD JONES PROMPTLY UPDATED THE FORMS U4 AT ISSUE TOREFLECT THE SPECIFIC AMOUNTS OF THE CUSTOMERS' ALLEGEDDAMAGES, PROVIDED ADDITIONAL TRAINING TO ITS ASSOCIATES, ANDINSTITUTED ADDITIONAL SAFEGUARDS FOR ITS PROCESS OFDISCLOSING CUSTOMERS' COMPLAINTS.



Resolution:











Sanction Details: ON JUNE 19, 2019, EDWARD JONES, WITHOUT ADMITTING OR DENYINGTHE ALLEGATIONS, ENTERED INTO AN ACCEPTANCE, WAIVER, ANDCONSENT ("AWC") WITH FINRA TO RESOLVE THIS MATTER. PURSUANT TOTHE AWC, EDWARD JONES WAS CENSURED, FINED $40,000, ANDORDERED TO CERTIFY IN WRITING THAT THE FIRM HAS REVIEWED ITSSYSTEMS, POLICIES, AND PROCEDURES, WRITTEN OR OTHERWISE,GOVERNING THE FIRM'S REVIEW, ANALYSIS, AND DISCLOSURE OFALLEGED DAMAGES IN CUSTOMER COMPLAINTS AND THAT THE FIRM HASESTABLISHED AND IMPLEMENTED SYSTEMS, POLICIES, ANDPROCEDURES, WRITTEN AND OTHERWISE, GOVERNING THE REVIEW,ANALYSIS AND DISCLOSURE OF ALLEGED DAMAGES IN CUSTOMERCOMPLAINTS THAT ARE REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH FINRA RULES. THE FINE WAS PAID ON JULY 5, 2019AND THE CERTIFICATION WAS FILED WITH FINRA ON JULY 9, 2019.

Disclosure 3 of 73

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Initiated By: ARKANSAS SECURITIES DEPARTMENT


Undertaking


EDWARD JONES SHOULD REVIEW CURRENT SUPERVISORY PROVISIONSAND PRACTICES. UPDATE AGENTS U-5. PAY FINE IN THE AMOUNT OF$50,000.00


Docket/Case Number: S-16-0017

URL for Regulatory Action: HTTP://WWW.SECURITIES.ARKANSAS.GOV/!USERFILES/EDWARD%20D_%20JONES%20&%20CO_,%20L_P_%20CONSENT%20ORDER%20S-16-0017-18-OR01.PDF



Allegations: THE ORDER FOUND THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN, ANDENFORCE A SYSTEM TO ADEQUATELY SUPERVISE THE ACTIVITIES OF THEAGENT. THE AGENT WAS ALLOWED TO CONTINUE TO VIOLATE HIS TRADERESTRICTIONS AND FIRM POLICIES WITHOUT SUFFICIENT CONSEQUENCEWHILE ON SPECIAL SUPERVISION. THE FIRM FAILED TO PROPERLYDISCLOSE A COMPLAINT AND SETTLEMENT RELATED TO THE AGENT. THEFIRM FAILED TO UPDATE AND DISCLOSE THE FACT THAT THE AGENT WASTHE SUBJECT OF AN INTERNAL REVIEW RELATING TO CONDUCT WHILEON SPECIAL SUPERVISION AT THE TIME OF TERMINATION.








EDWARD JONES SHOULD REVIEW CURRENT SUPERVISORY PROVISIONSAND PRACTICES. UPDATE AGENTS U-5. PAY FINE IN THE AMOUNT OF$50,000.00


Resolution:

Other Sanctions Ordered:

Sanction Details: EDWARD JONES SHALL CONDUCT A REVIEW OF THEIR SUPERVISORYPROVISIONS AND PRACTICES TO ENSURE THAT THE OVERSIGHTS ANDRESULTING VIOLATIONS THAT OCCURRED DO NOT OCCUR IN THEFUTURE. EDWARD JONES SHALL IMMEDIATELY UPDATE THE AGENTS U-5TO ACCURATELY REFLECT ALL CUSTOMER COMPLAINTS ANDREPORTABLE DISCIPLINARY ACTIONS. EDWARD JONES SHALL PAY A FINEIN THE AMOUNT OF $50,000.00 TO THE DEPARTMENT.

Regulator Statement THE ORDER FOUND THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN, ANDENFORCE A SYSTEM TO ADEQUATELY SUPERVISE THE ACTIVITIES OF THEAGENT. THE AGENT WAS ALLOWED TO CONTINUE TO VIOLATE HIS TRADERESTRICTIONS AND FIRM POLICIES WITHOUT SUFFICIENT CONSEQUENCEWHILE ON SPECIAL SUPERVISION. THE FIRM FAILED TO PROPERLYDISCLOSE A COMPLAINT AND SETTLEMENT RELATED TO THE AGENT. THEFIRM FAILED TO UPDATE AND DISCLOSE THE FACT THAT THE AGENT WASTHE SUBJECT OF AN INTERNAL REVIEW RELATING TO CONDUCT WHILEON SPECIAL SUPERVISION AT THE TIME OF TERMINATION.


No

Sanctions Ordered: Monetary/Fine $50,000.00



Allegations: THE ARKANSAS SECURITIES DEPARTMENT ALLEGED THAT THE FIRMFAILED TO ADEQUATELY SUPERVISE THE ACTIVITIES OF AN AGENT,PROPERLY DISCLOSE A COMPLAINT AND SETTLEMENT RELATED TO THEAGENT, UPDATE AND DISCLOSE INFORMATION THAT THE AGENT WAS THESUBJECT OF AN INTERNAL REVIEW AT THE TIME OF TERMINATION, ANDMAKE AND KEEP BOOKS AND RECORDS IN VIOLATION OF ARK. CODE ANN.§§ 23-42-301(F)(1) AND 23-42-306, RULES OF THE ARKANSAS SECURITIESCOMMISSIONER 301.01(C)(2)(F), 301.01(C)(5), 306.02, AND 308.01(X), ANDFINRA BY-LAW ARTICLE V, SECTION 3.







Initiated By: ARKANSAS SECURITIES DEPARTMENT


Undertaking


EDWARD JONES SHOULD REVIEW CURRENT SUPERVISORY PROVISIONSAND PRACTICES. UPDATE AGENT'S U-5. PAY FINE IN THE AMOUNT OF$50,000.00.


Docket/Case Number: S-16-0017



THE ARKANSAS SECURITIES DEPARTMENT ALLEGED THAT THE FIRMFAILED TO ADEQUATELY SUPERVISE THE ACTIVITIES OF AN AGENT,PROPERLY DISCLOSE A COMPLAINT AND SETTLEMENT RELATED TO THEAGENT, UPDATE AND DISCLOSE INFORMATION THAT THE AGENT WAS THESUBJECT OF AN INTERNAL REVIEW AT THE TIME OF TERMINATION, ANDMAKE AND KEEP BOOKS AND RECORDS IN VIOLATION OF ARK. CODE ANN.§§ 23-42-301(F)(1) AND 23-42-306, RULES OF THE ARKANSAS SECURITIESCOMMISSIONER 301.01(C)(2)(F), 301.01(C)(5), 306.02, AND 308.01(X), ANDFINRA BY-LAW ARTICLE V, SECTION 3.


Resolution:


Sanction Details: ON SEPTEMBER 13, 2018, EDWARD JONES, WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, ENTERED INTO A CONSENT ORDER WITHTHE ARKANSAS SECURITIES DEPARTMENT TO RESOLVE THIS MATTER.PURSUANT TO THE CONSENT ORDER, EDWARD JONES SHALL CONDUCT AREVIEW OF ITS SUPERVISORY PROVISIONS AND PRACTICES, UPDATE THEAGENT'S U-5, AND PAY A FINE OF $50,000. THE FINE WAS PAID ONSEPTEMBER 12, 2018.


Consent

Disclosure 4 of 73

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOESTABLISH, MAINTAIN, AND ENFORCE AN ADEQUATE SUPERVISORYSYSTEM, INCLUDING WRITTEN PROCEDURES, CONCERNING THECREATION AND DISSEMINATION OF CONSOLIDATED REPORTS. THEFINDINGS STATED THAT DURING THIS TIME PERIOD, THE FIRM MADEAVAILABLE TO ITS REGISTERED REPRESENTATIVES TWO CENTRALIZEDAND AUTOMATED TOOLS, WHICH PROVIDED TEMPLATES FOR REPORTSTHAT COULD BE USED TO, AMONG OTHER THINGS, PRESENTCOMPREHENSIVE FINANCIAL INFORMATION TO CUSTOMERS, INCLUDINGOUTSIDE ASSET INFORMATION. DUE TO AN UNINTENTIONAL VENDORCREATED DESIGN FLAW, ONE OF THE TOOLS FOR A TIME ALSO ALLOWEDREGISTERED REPRESENTATIVES TO MANUALLY EDIT ASSETS HELD ATTHE FIRM. WHILE THE FIRM USED INTERNALLY APPROVED TEMPLATES,THE FIRM HAD NO SYSTEM OR WRITTEN PROCEDURES IN PLACEREASONABLY DESIGNED TO MINIMIZE THE RISK THAT THE REPORTSCOULD CONTAIN INACCURATE INFORMATION THAT POTENTIALLY COULDBE MISUSED. IN ADDITION, ALTHOUGH REGISTERED REPRESENTATIVESPRINTED THE REPORTS AND PROVIDED THEM TO CUSTOMERS, THE FIRMCOULD TRACK ONLY WHETHER A REPORT WAS PRINTED. IT HAD NOSYSTEM OR PROCEDURES TO TRACK WHETHER REPORTS WEREPROVIDED TO CUSTOMERS. REGISTERED REPRESENTATIVES AT THEFIRM GENERATED APPROXIMATELY 52 MILLION REPORTS USING THE TWOTOOLS. THE FIRM HAD NO REASONABLY DESIGNED SYSTEM ORPROCEDURES IN PLACE TO MITIGATE THE RISKS DESCRIBED IN FINRAREGULATORY NOTICE 10-19, NOR DID IT HAVE IN PLACE A CENTRALIZEDREVIEW PROCESS. THE FIRM HAD NO POLICIES OR PROCEDURES TOGUIDE ITS REGISTERED REPRESENTATIVES REGARDING THE CREATIONAND USE OF THE REPORTS AND HAD NO GUIDANCE REGARDING HOWREGISTERED REPRESENTATIVES SHOULD INCLUDE OUTSIDE ASSETINFORMATION IN THE REPORTS, AND WHETHER STEPS SHOULD BE TAKENTO VERIFY THAT INFORMATION BEFORE IT WAS INCLUDED. FURTHER,THERE WERE NO PROCEDURES OR GUIDANCE REGARDING UPDATINGTHE OUTSIDE INFORMATION INCLUDED IN THE REPORTS, SUCH AS HOWOFTEN AND WITH WHAT SOURCE MATERIALS. MOREOVER, THE FIRM HADNO ABILITY TO DETERMINE WHETHER THE REPORTS GENERATED BY THEREPRESENTATIVES WERE ACTUALLY DELIVERED TO CUSTOMERS.







Initiated By: FINRA







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOESTABLISH, MAINTAIN, AND ENFORCE AN ADEQUATE SUPERVISORYSYSTEM, INCLUDING WRITTEN PROCEDURES, CONCERNING THECREATION AND DISSEMINATION OF CONSOLIDATED REPORTS. THEFINDINGS STATED THAT DURING THIS TIME PERIOD, THE FIRM MADEAVAILABLE TO ITS REGISTERED REPRESENTATIVES TWO CENTRALIZEDAND AUTOMATED TOOLS, WHICH PROVIDED TEMPLATES FOR REPORTSTHAT COULD BE USED TO, AMONG OTHER THINGS, PRESENTCOMPREHENSIVE FINANCIAL INFORMATION TO CUSTOMERS, INCLUDINGOUTSIDE ASSET INFORMATION. DUE TO AN UNINTENTIONAL VENDORCREATED DESIGN FLAW, ONE OF THE TOOLS FOR A TIME ALSO ALLOWEDREGISTERED REPRESENTATIVES TO MANUALLY EDIT ASSETS HELD ATTHE FIRM. WHILE THE FIRM USED INTERNALLY APPROVED TEMPLATES,THE FIRM HAD NO SYSTEM OR WRITTEN PROCEDURES IN PLACEREASONABLY DESIGNED TO MINIMIZE THE RISK THAT THE REPORTSCOULD CONTAIN INACCURATE INFORMATION THAT POTENTIALLY COULDBE MISUSED. IN ADDITION, ALTHOUGH REGISTERED REPRESENTATIVESPRINTED THE REPORTS AND PROVIDED THEM TO CUSTOMERS, THE FIRMCOULD TRACK ONLY WHETHER A REPORT WAS PRINTED. IT HAD NOSYSTEM OR PROCEDURES TO TRACK WHETHER REPORTS WEREPROVIDED TO CUSTOMERS. REGISTERED REPRESENTATIVES AT THEFIRM GENERATED APPROXIMATELY 52 MILLION REPORTS USING THE TWOTOOLS. THE FIRM HAD NO REASONABLY DESIGNED SYSTEM ORPROCEDURES IN PLACE TO MITIGATE THE RISKS DESCRIBED IN FINRAREGULATORY NOTICE 10-19, NOR DID IT HAVE IN PLACE A CENTRALIZEDREVIEW PROCESS. THE FIRM HAD NO POLICIES OR PROCEDURES TOGUIDE ITS REGISTERED REPRESENTATIVES REGARDING THE CREATIONAND USE OF THE REPORTS AND HAD NO GUIDANCE REGARDING HOWREGISTERED REPRESENTATIVES SHOULD INCLUDE OUTSIDE ASSETINFORMATION IN THE REPORTS, AND WHETHER STEPS SHOULD BE TAKENTO VERIFY THAT INFORMATION BEFORE IT WAS INCLUDED. FURTHER,THERE WERE NO PROCEDURES OR GUIDANCE REGARDING UPDATINGTHE OUTSIDE INFORMATION INCLUDED IN THE REPORTS, SUCH AS HOWOFTEN AND WITH WHAT SOURCE MATERIALS. MOREOVER, THE FIRM HADNO ABILITY TO DETERMINE WHETHER THE REPORTS GENERATED BY THEREPRESENTATIVES WERE ACTUALLY DELIVERED TO CUSTOMERS.


Resolution:


No









Sanction Details: THE FIRM WAS CENSURED AND FINED $725,000. THE FIRM UNDERTOOK ACOMPREHENSIVE REVIEW OF THE CREATION AND USE OF THE REPORTSAND IMPLEMENTED EXTENSIVE REMEDIAL CHANGES. THEENHANCEMENTS TO THE FIRM'S SYSTEM INCLUDE: A RISK-BASED REVIEWOF THE REPORTS, ENHANCED DISCLOSURES, NEW PROCEDURES ANDMECHANISMS FOR VERIFYING OUTSIDE ASSETS, AND SURVEILLANCETHAT DETECTS GAPS IN INFORMATION BETWEEN THE REPORTS AND THEFIRM'S OUTSIDE BUSINESS ACTIVITY DATABASE.THE SANCTION REFLECTS FINRA'S CONSIDERATION OF THE FIRM'SREVIEW AND REMEDIATION. FINES PAID IN FULL ON JULY 27, 2017.


No



Initiated By: FINRA








Allegations: FINRA ALLEGED THAT EDWARD JONES FAILED TO ESTABLISH, MAINTAIN,AND ENFORCE AN ADEQUATE SUPERVISORY SYSTEM, INCLUDINGWRITTEN PROCEDURES, CONCERNING THE CREATION ANDDISSEMINATION OF CONSOLIDATED REPORTS IN VIOLATION OF NASDRULE 3010(A) AND FINRA RULE 2010 DURING THE TIME PERIOD APRIL 2010THROUGH 2014.


Resolution: Acceptance, Waiver & Consent(AWC)









Sanction Details: ON JULY 13, 2017, EDWARD JONES, WITHOUT ADMITTING OR DENYING THEALLEGATIONS, ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER, ANDCONSENT ("AWC") WITH FINRA TO RESOLVE THIS MATTER. PURSUANT TOTHE AWC, EDWARD JONES WAS CENSURED AND FINED $725,000. INRESOLVING THIS MATTER, FINRA ALSO STATED THAT EDWARD JONES HASMADE CHANGES TO ENHANCE ITS SUPERVISORY PROCESSES. THE FINEWAS PAID ON JULY 25, 2017.


Disclosure 5 of 73

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Initiated By: FINRA



Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EFFECTED188 CUSTOMER TRANSACTIONS IN A MUNICIPAL SECURITY IN AN AMOUNTLOWER THAN THE MINIMUM DENOMINATION OF THE ISSUE WHICH WASNOT SUBJECT TO AN EXCEPTION UNDER THE APPLICABLE RULE, ANDTHESE TRANSACTIONS WERE CONCENTRATED IN EIGHT COMMITTEE ONUNIFORM SECURITIES IDENTIFICATION PROCEDURES (CUSIPS). THEFINDINGS STATED THAT PRIOR TO THIS SETTLEMENT, THE FIRM OFFEREDRESCISSION TO EACH OF THE CUSTOMERS WHO PURCHASED THERELATED MUNICIPAL SECURITIES. THE FINDINGS ALSO STATED THAT THEFIRM FAILED, IN FOUR INSTANCES, TO PROVIDE THE CUSTOMER AWRITTEN STATEMENT AT OR BEFORE COMPLETION OF THE TRANSACTIONINFORMING THE CUSTOMER THAT THE SECURITIES BEING SOLD WERE INAN AMOUNT BELOW THE MINIMUM DENOMINATION FOR THE ISSUE. THEFINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO DISCLOSE ALLMATERIAL FACTS CONCERNING 192 MUNICIPAL SECURITIESTRANSACTIONS AT OR PRIOR TO THE TIME OF THE TRADE. SPECIFICALLY,THE FIRM FAILED TO INFORM ITS CUSTOMER THAT THE MUNICIPALSECURITIES TRANSACTION WAS IN AN AMOUNT BELOW THE MINIMUMDENOMINATION OF THE ISSUE, OR THAT THE MUNICIPAL SECURITIESCONTAINED A RESALE RESTRICTION WHICH COULD AFFECT THELIQUIDITY OF THE CUSTOMER'S POSITION.











Principal Product Type: Debt - Municipal



Resolution:


Sanction Details: THE FIRM WAS CENSURED, FINED $210,000, AND REQUIRED TO SUBMIT TOFINRA SATISFACTORY PROOF OF AN OFFER OF RESCISSION, TO EACH OFTHE CUSTOMERS WHO PURCHASED THE RELATED MUNICIPALSECURITIES, OR OF REASONABLE AND DOCUMENTED EFFORTSUNDERTAKEN TO EFFECT RESCISSION, INCLUDING THE OFFERED PRICEAND A DESCRIPTION OF HOW THE OFFERED PRICE WAS DETERMINED.FINE PAID IN FULL ON JUNE 29, 2017.


No




Initiated By: FINRA



Allegations: FINRA ALLEGED THAT EDWARD JONES VIOLATED MUNICIPAL SECURITIESRULEMAKING BOARD RULES G-15(F), G-15(F)(III), G-17, AND G-47 INCONNECTION WITH TRANSACTIONS IN CERTAIN MUNICIPAL SECURITIES INAMOUNTS LOWER THAN THE APPLICABLE MINIMUM DENOMINATIONSOCCURRING DURING THE TIME PERIOD OF DECEMBER 1, 2013 THROUGHDECEMBER 31, 2014.















Resolution:


Sanction Details: ON JUNE 2, 2017, EDWARD JONES, WITHOUT ADMITTING OR DENYING THEALLEGATIONS, ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER, ANDCONSENT ("AWC") WITH FINRA TO RESOLVE THIS MATTER. PURSUANT TOTHE AWC, EDWARD JONES WAS CENSURED, FINED $210,000 ANDREQUIRED TO SUBMIT TO FINRA PROOF OF AN OFFER OF RESCISSION OROF DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESCISSION. THEFINE WAS PAID ON JUNE 29, 2017.



Disclosure 6 of 73

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Initiated By: FINRA

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITOVERCHARGED INTEREST ON MARGIN LOANS TOTALING APPROXIMATELY$708,000 ON LOANS TO THE OWNERS OF CUSTOMER ACCOUNTS. THEFINDINGS STATED THAT THE OVERCHARGES OCCURRED BECAUSE THEFIRM DID NOT ADEQUATELY SUPERVISE ITS SYSTEM FOR DETERMININGTHE INTEREST RATES ON THOSE LOANS. THE FIRM DID NOT TEST ITSAUTOMATED SYSTEM FOR GROUPING ACCOUNTS FOR THE ASSIGNMENTOF INTEREST RATES ON MARGIN LOANS. INSTEAD, THE FIRMSUPERVISED INTEREST ON MARGIN LOANS BY REVIEWING A MONTHLYREPORT FROM ONE OF ITS VENDORS, BUT THAT REPORT INCORPORATEDTHE PROBLEM WITH THE LOGIC OF THE FIRM'S AUTOMATED SYSTEM.ADDITIONALLY, THE FIRM DID NOT DIRECT ITS SUPERVISORS TO USE THEREPORTS TO REVIEW ITS METHOD OF ASSIGNING INTEREST RATES, ANDTHE SUPERVISORS SAMPLED ONLY A SMALL NUMBER OF ACCOUNTS ONTHE REPORTS.







Initiated By: FINRA


Other


N/A



Principal Product Type: Other

Other Product Type(s): MARGIN LOANS


Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $125,000. FINE PAID IN FULL ONFEBRUARY 28, 2017.

Regulator Statement IN RESOLVING THIS MATTER, FINRA RECOGNIZED THE FIRM'SEXTRAORDINARY COOPERATION BY (1) DISCOVERING AND VOLUNTARILYREPORTING THE PROBLEM TO FINRA BEFORE ANY REGULATORSDETECTED THE PROBLEM, AND (2) VOLUNTARILY PAYING RESTITUTION OFAPPROXIMATELY $708,000 PLUS INTEREST TO AFFECTED CUSTOMERS.


No




Initiated By: FINRA


Allegations: FINRA ALLEGED THAT EDWARD JONES DID NOT ADEQUATELY SUPERVISEITS SYSTEM FOR DETERMINING THE INTEREST RATE APPLIED TO CERTAINMARGIN LOANS TO CUSTOMERS IN VIOLATION OF NASD RULE 3010(A) ANDFINRA RULES 2010 AND 3110(A).









Other


N/A






Resolution:


Sanction Details: ON FEBRUARY 1, 2017, EDWARD JONES, WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, ENTERED INTO A LETTER OF ACCEPTANCE,WAIVER, AND CONSENT ("AWC") WITH FINRA TO RESOLVE THIS MATTER.PURSUANT TO THE AWC, EDWARD JONES WAS CENSURED AND FINED$125,000. THE FINE WILL BE PAID IN ACCORDANCE WITH THE AWC. INRESOLVING THIS MATTER, FINRA RECOGNIZED THE EXTRAORDINARYCOOPERATION OF EDWARD JONES.



Disclosure 7 of 73

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Initiated By: PENNSYLVANIA CONTACT: COUNSEL CAROLYN MENDELSON (412)-565-7519


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


Docket/Case Number: 2016-03-02 (#160043)

URL for Regulatory Action:



Allegations: EDWARD D. JONES & CO., L.P. FAILED TO REASONABLY SUPERVISE ITSAGENT WHOSE ACTS AND CONDUCT WERE IN VIOLATION OF THEPENNSYLVANIA SECURITIES ACT OF 1972.












Resolution:


Sanction Details: EDWARD D. JONES & CO., L.P. PAID TO THE DEPARTMENT OF BANKINGAND SECURITIES INVESTIGATIVE AND LEGAL COSTS IN THE AMOUNT OF$10,000.00 AND A $135,000.00 ADMINISTRATIVE ASSESSMENT.

Regulator Statement CONSENT AGREEMENT AND ORDER ISSUED TO EDWARD D. JONES & CO.,L.P.


No


Settled


Initiated By: COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF BANKING ANDSECURITIES





Docket/Case Number: 160043 (SEC-CAO)



Allegations: THE COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF BANKING ANDSECURITIES (THE "DEPARTMENT"), ALLEGED THAT EDWARD JONES FAILEDTO REASONABLY SUPERVISE AN AGENT IN VIOLATION OF SECTION305(A)(VII) OF THE PENNSYLVANIA SECURITIES ACT OF 1972 (THE "ACT").









Resolution:

Other Sanctions Ordered: INVESTIGATIVE COSTS OF $10,000.00

Sanction Details: ON AUGUST 4, 2016, EDWARD JONES, WITHOUT ADMITTING OR DENYINGTHE ALLEGATIONS, ENTERED INTO A CONSENT AGREEMENT AND ORDER("ORDER") WITH THE DEPARTMENT. PURSUANT TO THE ORDER, EDWARDJONES AGREED TO COMPLY WITH THE ACT, AND PAY AN ADMINISTRATIVEASSESSMENT OF $135,000.00 AND INVESTIGATIVE COSTS OF $10,000.00TO THE DEPARTMENT. THESE AMOUNTS WERE PAID ON AUGUST 11, 2016.


Order

Disclosure 8 of 73

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREASONABLY SUPERVISE AND TO HAVE AN ADEQUATE SUPERVISORYSYSTEM, INCLUDING ADEQUATE WRITTEN SUPERVISORY PROCEDURES,DESIGNED TO ENSURE COMPLIANCE WITH MSRB RULES, TO ADDRESSSHORT POSITIONS IN TAX-EXEMPT MUNICIPAL BONDS THAT RESULTEDPRIMARILY FROM TRADING ERRORS. THE FINDINGS STATED THAT AS ARESULT OF THESE SUPERVISORY FAILURES, THE FIRM INACCURATELYREPRESENTED TO ITS CUSTOMERS HOLDING MUNICIPAL BONDS THAT ATLEAST $129,624.06 IN INTEREST THAT THE FIRM PAID TO THOSECUSTOMERS WAS EXEMPT FROM TAXATION. IN FACT, THE FIRM DID NOTHOLD THE BONDS ON BEHALF OF THE CUSTOMERS AND THE INTERESTTHAT THE CUSTOMERS RECEIVED WAS PAID BY THE FIRM AND THUSTAXABLE AS ORDINARY INCOME. THE FIRM FAILED TO CONSIDERWHETHER THE INTEREST PAID TO CUSTOMERS SHOULD BE CODED ASNON-TAXABLE WHEN THE INTEREST WAS PAID BY THE FIRM RATHERTHAN THE MUNICIPAL ISSUER. THE FINDINGS ALSO STATED THAT THEFIRM HELD SHORT POSITIONS IN TAX-EXEMPT MUNICIPAL SECURITIESTHAT CORRESPONDED TO LONG POSITIONS IN CUSTOMER ACCOUNTS.THE SHORT POSITIONS RESULTED PRIMARILY FROM TRADING ANDOPERATIONAL ERRORS. IN THESE INSTANCES, THE FIRM PAID THEINTEREST TO CUSTOMERS AND THE INTEREST WAS TAXABLE. THE FIRM'SMUNICIPAL TRADING DEPARTMENT WAS RESPONSIBLE FOR IDENTIFYINGAND COVERING MUNICIPAL BOND SHORT POSITIONS. HOWEVER, THEFIRM DID NOT PROVIDE ADEQUATE GUIDANCE OR OVERSIGHT ON HOWAND WHEN MUNICIPAL SHORT POSITIONS SHOULD BE COVERED. THISDEFICIENCY MAY HAVE BEEN PROLONGED DUE TO THE DIFFICULTY OFCOVERING THESE POSITIONS IN LIGHT OF THE CHARACTERISTICS OFMUNICIPAL SECURITIES AS WELL AS THE LIMITED AMOUNT OUTSTANDINGOF A PARTICULAR MUNICIPAL BOND. THE FIRM REVIEWED AGED SHORTMUNICIPAL POSITIONS IN ITS INVENTORY ACCOUNT AS PART OF ANEFFORT TO REDUCE THESE POSITIONS IN ANTICIPATION OF CHANGES TOSECURITIES EXCHANGE ACT RULE 15C3-3. THIS REVIEW WAS NOTCOMPLETED UNTIL WHEN FINRA WAS ONSITE WITH THE FIRM. ALSOWHILE FINRA WAS ONSITE, THE FIRM REVISED ITS INTERNAL POLICIES TOPREVENT AND PROMPTLY COVER SHORT MUNICIPAL POSITIONS IN ITSINVENTORY. THROUGH THESE EFFORTS, THE FIRM WAS ABLE TOSUBSTANTIALLY REDUCE ITS SHORT MUNICIPAL BOND POSITIONS BY THEEND OF THAT YEAR. NEVERTHELESS, THE FIRM DID NOT COVER SOME OFITS SHORT POSITIONS FOR MORE THAN A YEAR. THE FIRM ALSO REVISEDITS WRITTEN PROCEDURES IN THE NEXT YEAR TO REFLECT ITS MODIFIEDPOLICIES FOR COVERING SHORT POSITIONS. THE FIRM HAS SINCEPROVIDED AMENDED FORM 1099S TO CUSTOMERS AFFECTED BY THEMISREPORTED INTEREST, AND AGREED TO REIMBURSE SUCHCUSTOMERS FOR THE COST OF ASSESSING THE NEED TO AMEND ANYTAX RETURNS, THE EXPENSE OF MAKING ANY TAX FILING, AS WELL ASANY TAX LIABILITIES INCURRED. THE FINDINGS ALSO INCLUDED THAT THEFIRM'S SYSTEM CLASSIFIED INTEREST PAYMENTS FOR SHORT MUNICIPALBOND POSITIONS AS TAX-EXEMPT, THUS CAUSING TAX REPORTING TOCUSTOMERS TO INCORRECTLY CATEGORIZE TAXABLE INCOME AS TAX-EXEMPT. CONSEQUENTLY, THE FIRM FAILED TO DISCLOSE TOCUSTOMERS THAT THEY WERE NOT RECEIVING TAX-EXEMPT INTERESTWHEN THE FIRM WAS SHORT MUNICIPAL BONDS. IN ADDITION, AS ARESULT OF THE FOREGOING, THE FIRM SENT INACCURATE FORMS 1099TO CUSTOMERS WHO RECEIVED FIRM-PAID INTEREST FOR SEVERALCALENDAR YEARS AND ALSO SENT INACCURATE ACCOUNT STATEMENTSTO CERTAIN CUSTOMERS DURING THE REVIEW PERIOD THATINCORRECTLY CLASSIFIED FIRM-PAID INTEREST AS TAX-EXEMPT WHEN ITSHOULD HAVE BEEN CLASSIFIED AS TAXABLE. FINRA FOUND THAT THEFIRM DID NOT MAINTAIN RECORDS IDENTIFYING PARTICULAR CUSTOMERACCOUNTS THAT OFFSET ITS SHORT MUNICIPAL BOND POSITIONS. THEFIRM'S SHORT POSITIONS WERE HELD IN AGGREGATE AND NOTALLOCATED TO SPECIFIED CUSTOMERS. BECAUSE THE FIRM'S SHORTMUNICIPAL BOND POSITIONS WERE NOT OFFSET AGAINST SPECIFICCUSTOMER HOLDINGS, THE FIRM WAS UNABLE TO ACCURATELY REPORTTAXABLE INCOME TO ITS CUSTOMERS WHO WERE RECEIVING FIRM-PAIDINTEREST AS TAXABLE INCOME.







Initiated By: FINRA


WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREASONABLY SUPERVISE AND TO HAVE AN ADEQUATE SUPERVISORYSYSTEM, INCLUDING ADEQUATE WRITTEN SUPERVISORY PROCEDURES,DESIGNED TO ENSURE COMPLIANCE WITH MSRB RULES, TO ADDRESSSHORT POSITIONS IN TAX-EXEMPT MUNICIPAL BONDS THAT RESULTEDPRIMARILY FROM TRADING ERRORS. THE FINDINGS STATED THAT AS ARESULT OF THESE SUPERVISORY FAILURES, THE FIRM INACCURATELYREPRESENTED TO ITS CUSTOMERS HOLDING MUNICIPAL BONDS THAT ATLEAST $129,624.06 IN INTEREST THAT THE FIRM PAID TO THOSECUSTOMERS WAS EXEMPT FROM TAXATION. IN FACT, THE FIRM DID NOTHOLD THE BONDS ON BEHALF OF THE CUSTOMERS AND THE INTERESTTHAT THE CUSTOMERS RECEIVED WAS PAID BY THE FIRM AND THUSTAXABLE AS ORDINARY INCOME. THE FIRM FAILED TO CONSIDERWHETHER THE INTEREST PAID TO CUSTOMERS SHOULD BE CODED ASNON-TAXABLE WHEN THE INTEREST WAS PAID BY THE FIRM RATHERTHAN THE MUNICIPAL ISSUER. THE FINDINGS ALSO STATED THAT THEFIRM HELD SHORT POSITIONS IN TAX-EXEMPT MUNICIPAL SECURITIESTHAT CORRESPONDED TO LONG POSITIONS IN CUSTOMER ACCOUNTS.THE SHORT POSITIONS RESULTED PRIMARILY FROM TRADING ANDOPERATIONAL ERRORS. IN THESE INSTANCES, THE FIRM PAID THEINTEREST TO CUSTOMERS AND THE INTEREST WAS TAXABLE. THE FIRM'SMUNICIPAL TRADING DEPARTMENT WAS RESPONSIBLE FOR IDENTIFYINGAND COVERING MUNICIPAL BOND SHORT POSITIONS. HOWEVER, THEFIRM DID NOT PROVIDE ADEQUATE GUIDANCE OR OVERSIGHT ON HOWAND WHEN MUNICIPAL SHORT POSITIONS SHOULD BE COVERED. THISDEFICIENCY MAY HAVE BEEN PROLONGED DUE TO THE DIFFICULTY OFCOVERING THESE POSITIONS IN LIGHT OF THE CHARACTERISTICS OFMUNICIPAL SECURITIES AS WELL AS THE LIMITED AMOUNT OUTSTANDINGOF A PARTICULAR MUNICIPAL BOND. THE FIRM REVIEWED AGED SHORTMUNICIPAL POSITIONS IN ITS INVENTORY ACCOUNT AS PART OF ANEFFORT TO REDUCE THESE POSITIONS IN ANTICIPATION OF CHANGES TOSECURITIES EXCHANGE ACT RULE 15C3-3. THIS REVIEW WAS NOTCOMPLETED UNTIL WHEN FINRA WAS ONSITE WITH THE FIRM. ALSOWHILE FINRA WAS ONSITE, THE FIRM REVISED ITS INTERNAL POLICIES TOPREVENT AND PROMPTLY COVER SHORT MUNICIPAL POSITIONS IN ITSINVENTORY. THROUGH THESE EFFORTS, THE FIRM WAS ABLE TOSUBSTANTIALLY REDUCE ITS SHORT MUNICIPAL BOND POSITIONS BY THEEND OF THAT YEAR. NEVERTHELESS, THE FIRM DID NOT COVER SOME OFITS SHORT POSITIONS FOR MORE THAN A YEAR. THE FIRM ALSO REVISEDITS WRITTEN PROCEDURES IN THE NEXT YEAR TO REFLECT ITS MODIFIEDPOLICIES FOR COVERING SHORT POSITIONS. THE FIRM HAS SINCEPROVIDED AMENDED FORM 1099S TO CUSTOMERS AFFECTED BY THEMISREPORTED INTEREST, AND AGREED TO REIMBURSE SUCHCUSTOMERS FOR THE COST OF ASSESSING THE NEED TO AMEND ANYTAX RETURNS, THE EXPENSE OF MAKING ANY TAX FILING, AS WELL ASANY TAX LIABILITIES INCURRED. THE FINDINGS ALSO INCLUDED THAT THEFIRM'S SYSTEM CLASSIFIED INTEREST PAYMENTS FOR SHORT MUNICIPALBOND POSITIONS AS TAX-EXEMPT, THUS CAUSING TAX REPORTING TOCUSTOMERS TO INCORRECTLY CATEGORIZE TAXABLE INCOME AS TAX-EXEMPT. CONSEQUENTLY, THE FIRM FAILED TO DISCLOSE TOCUSTOMERS THAT THEY WERE NOT RECEIVING TAX-EXEMPT INTERESTWHEN THE FIRM WAS SHORT MUNICIPAL BONDS. IN ADDITION, AS ARESULT OF THE FOREGOING, THE FIRM SENT INACCURATE FORMS 1099TO CUSTOMERS WHO RECEIVED FIRM-PAID INTEREST FOR SEVERALCALENDAR YEARS AND ALSO SENT INACCURATE ACCOUNT STATEMENTSTO CERTAIN CUSTOMERS DURING THE REVIEW PERIOD THATINCORRECTLY CLASSIFIED FIRM-PAID INTEREST AS TAX-EXEMPT WHEN ITSHOULD HAVE BEEN CLASSIFIED AS TAXABLE. FINRA FOUND THAT THEFIRM DID NOT MAINTAIN RECORDS IDENTIFYING PARTICULAR CUSTOMERACCOUNTS THAT OFFSET ITS SHORT MUNICIPAL BOND POSITIONS. THEFIRM'S SHORT POSITIONS WERE HELD IN AGGREGATE AND NOTALLOCATED TO SPECIFIED CUSTOMERS. BECAUSE THE FIRM'S SHORTMUNICIPAL BOND POSITIONS WERE NOT OFFSET AGAINST SPECIFICCUSTOMER HOLDINGS, THE FIRM WAS UNABLE TO ACCURATELY REPORTTAXABLE INCOME TO ITS CUSTOMERS WHO WERE RECEIVING FIRM-PAIDINTEREST AS TAXABLE INCOME.













Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $200,000.

FINE PAID IN FULL ON FEBRUARY 10, 2016.


No




Initiated By: FINRA






Allegations: FINRA ALLEGED THAT EDWARD JONES VIOLATED CERTAIN MUNICIPALSECURITIES RULEMAKING BOARD RULES IN CONNECTION WITH SHORTPOSITIONS IN CERTAIN MUNICIPAL SECURITIES.












Resolution:


Sanction Details: ON JANUARY 21, 2016, EDWARD JONES, WITHOUT ADMITTING OR DENYINGTHE FINDINGS, ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER ANDCONSENT (AWC) WITH FINRA TO RESOLVE THIS MATTER. PURSUANT TOTHE AWC, EDWARD JONES WAS CENSURED AND ORDERED TO PAY A FINEOF $200,000. THE FINE WAS PAID ON FEBRUARY 8, 2016.



Disclosure 9 of 73

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT SINCE ATLEAST JULY 1, 2009, THE FIRM DISADVANTAGED CERTAIN RETIREMENTPLAN AND CHARITABLE ORGANIZATION CUSTOMERS THAT WERE ELIGIBLETO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL FUNDS WITHOUT AFRONT-END SALES CHARGE. THE FINDINGS STATED THATNOTWITHSTANDING THE AVAILABILITY OF THE WAIVERS, THE FIRM FAILEDTO APPLY THE WAIVERS TO MUTUAL FUND PURCHASES MADE BYELIGIBLE CUSTOMERS AND INSTEAD SOLD THEM CLASS A SHARES WITH AFRONT-END SALES CHARGE OR CLASS B OR C SHARES WITH BACK-ENDSALES CHARGES AND HIGHER ONGOING FEES AND EXPENSES. THESESALES DISADVANTAGED ELIGIBLE CUSTOMERS BY CAUSING SUCHCUSTOMERS TO PAY HIGHER FEES THAN THEY WERE ACTUALLYREQUIRED TO PAY. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TOESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND PROCEDURESREASONABLY DESIGNED TO ENSURE THAT ELIGIBLE CUSTOMERS WHOPURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OFAPPLICABLE SALES CHARGE WAIVERS. THE FIRM ALSO FAILED TOESTABLISH AND MAINTAIN WRITTEN PROCEDURES TO IDENTIFYAPPLICABLE SALES CHARGE WAIVERS IN FUND PROSPECTUSES FORELIGIBLE CUSTOMERS. THE FIRM FAILED TO REASONABLY SUPERVISETHE APPLICATION OF SALES CHARGE WAIVERS TO ELIGIBLE MUTUALFUND SALES. THE FIRM RELIED ON ITS FINANCIAL ADVISORS TODETERMINE THE APPLICABILITY OF SALES CHARGE WAIVERS, BUT FAILEDTO MAINTAIN ADEQUATE WRITTEN POLICIES OR PROCEDURES TO ASSISTFINANCIAL ADVISORS IN MAKING THIS DETERMINATION. IN ADDITION, THEFIRM FAILED TO ADEQUATELY NOTIFY AND TRAIN ITS FINANCIALADVISORS REGARDING THE AVAILABILITY OF MUTUAL FUND SALESCHARGE WAIVERS FOR ELIGIBLE CUSTOMERS. THE FIRM ALSO FAILED TOADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY DIDNOT PROVIDE SALES CHARGE WAIVERS TO ELIGIBLE CUSTOMERS INCONNECTION WITH THEIR MUTUAL FUND PURCHASES.







Initiated By: FINRA







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT SINCE ATLEAST JULY 1, 2009, THE FIRM DISADVANTAGED CERTAIN RETIREMENTPLAN AND CHARITABLE ORGANIZATION CUSTOMERS THAT WERE ELIGIBLETO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL FUNDS WITHOUT AFRONT-END SALES CHARGE. THE FINDINGS STATED THATNOTWITHSTANDING THE AVAILABILITY OF THE WAIVERS, THE FIRM FAILEDTO APPLY THE WAIVERS TO MUTUAL FUND PURCHASES MADE BYELIGIBLE CUSTOMERS AND INSTEAD SOLD THEM CLASS A SHARES WITH AFRONT-END SALES CHARGE OR CLASS B OR C SHARES WITH BACK-ENDSALES CHARGES AND HIGHER ONGOING FEES AND EXPENSES. THESESALES DISADVANTAGED ELIGIBLE CUSTOMERS BY CAUSING SUCHCUSTOMERS TO PAY HIGHER FEES THAN THEY WERE ACTUALLYREQUIRED TO PAY. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TOESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND PROCEDURESREASONABLY DESIGNED TO ENSURE THAT ELIGIBLE CUSTOMERS WHOPURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OFAPPLICABLE SALES CHARGE WAIVERS. THE FIRM ALSO FAILED TOESTABLISH AND MAINTAIN WRITTEN PROCEDURES TO IDENTIFYAPPLICABLE SALES CHARGE WAIVERS IN FUND PROSPECTUSES FORELIGIBLE CUSTOMERS. THE FIRM FAILED TO REASONABLY SUPERVISETHE APPLICATION OF SALES CHARGE WAIVERS TO ELIGIBLE MUTUALFUND SALES. THE FIRM RELIED ON ITS FINANCIAL ADVISORS TODETERMINE THE APPLICABILITY OF SALES CHARGE WAIVERS, BUT FAILEDTO MAINTAIN ADEQUATE WRITTEN POLICIES OR PROCEDURES TO ASSISTFINANCIAL ADVISORS IN MAKING THIS DETERMINATION. IN ADDITION, THEFIRM FAILED TO ADEQUATELY NOTIFY AND TRAIN ITS FINANCIALADVISORS REGARDING THE AVAILABILITY OF MUTUAL FUND SALESCHARGE WAIVERS FOR ELIGIBLE CUSTOMERS. THE FIRM ALSO FAILED TOADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY DIDNOT PROVIDE SALES CHARGE WAIVERS TO ELIGIBLE CUSTOMERS INCONNECTION WITH THEIR MUTUAL FUND PURCHASES.


Resolution:

Other Sanctions Ordered: INTEREST

Sanction Details: THE FIRM WAS CENSURED AND AGREED TO PAY $13.5 MILLION,INCLUDING INTEREST, IN RESTITUTION TO ELIGIBLE CUSTOMERS.

Regulator Statement IN JUNE 2014, THE FIRM BEGAN A REVIEW TO DETERMINE WHETHER ITHAD PROVIDED AVAILABLE SALES CHARGE WAIVERS TO ELIGIBLECUSTOMERS. BASED ON THIS REVIEW, IN FEBRUARY 2015, THE FIRMSELF-REPORTED TO FINRA THAT ELIGIBLE CUSTOMERS HAD NOTRECEIVED AVAILABLE SALES CHARGE WAIVERS. THE FIRM ESTIMATESTHAT, SINCE JULY 1, 2009, APPROXIMATELY 18,000 ACCOUNTSPURCHASED MUTUAL FUND SHARES FOR WHICH AN AVAILABLE SALESCHARGE WAIVER WAS NOT APPLIED. AS A RESULT OF THE FAILURE OFTHE FIRM TO APPLY AVAILABLE SALES CHARGE WAIVERS, THE FIRMESTIMATES THAT ELIGIBLE CUSTOMERS WERE OVERCHARGED BYAPPROXIMATELY $12 MILLION FOR MUTUAL FUND PURCHASES MADESINCE JULY 1, 2009. AS PART OF THIS SETTLEMENT, THE FIRM AGREES TOPAY RESTITUTION TO ELIGIBLE CUSTOMERS, WHICH IS ESTIMATED TOTOTAL APPROXIMATELY $13.5 MILLION (I.E., THE AMOUNT ELIGIBLECUSTOMERS WERE OVERCHARGED, INCLUSIVE OF INTEREST). THE FIRMWILL ALSO ENSURE THAT RETIREMENT AND CHARITABLE WAIVERS AREAPPROPRIATELY APPLIED TO ALL FUTURE TRANSACTIONS. IN RESOLVINGTHIS MATTER, FINRA HAS RECOGNIZED THE EXTRAORDINARYCOOPERATION OF THE FIRM FOR HAVING: (1) INITIATED, PRIOR TODETECTION OR INTERVENTION BY A REGULATOR, AN INVESTIGATION TOIDENTIFY WHETHER ELIGIBLE CUSTOMERS RECEIVED SALES CHARGEWAIVERS DURING THE RELEVANT PERIOD; (2) PROMPTLY ESTABLISHED APLAN OF REMEDIATION FOR ELIGIBLE CUSTOMERS WHO DID NOTRECEIVE APPROPRIATE SALES CHARGE WAIVERS; (3) PROMPTLY SELF-REPORTED TO FINRA; (4) PROMPTLY TAKEN ACTION AND REMEDIAL STEPSTO CORRECT THE VIOLATIVE CONDUCT; AND (5) EMPLOYED SUBSEQUENTCORRECTIVE MEASURES, PRIOR TO DETECTION OR INTERVENTION BY AREGULATOR, TO REVISE ITS PROCEDURES TO AVOID RECURRENCE OFTHE MISCONDUCT.


No

Sanctions Ordered: CensureDisgorgement/Restitution







www.finra.org/brokercheck User GuidanceIN JUNE 2014, THE FIRM BEGAN A REVIEW TO DETERMINE WHETHER ITHAD PROVIDED AVAILABLE SALES CHARGE WAIVERS TO ELIGIBLECUSTOMERS. BASED ON THIS REVIEW, IN FEBRUARY 2015, THE FIRMSELF-REPORTED TO FINRA THAT ELIGIBLE CUSTOMERS HAD NOTRECEIVED AVAILABLE SALES CHARGE WAIVERS. THE FIRM ESTIMATESTHAT, SINCE JULY 1, 2009, APPROXIMATELY 18,000 ACCOUNTSPURCHASED MUTUAL FUND SHARES FOR WHICH AN AVAILABLE SALESCHARGE WAIVER WAS NOT APPLIED. AS A RESULT OF THE FAILURE OFTHE FIRM TO APPLY AVAILABLE SALES CHARGE WAIVERS, THE FIRMESTIMATES THAT ELIGIBLE CUSTOMERS WERE OVERCHARGED BYAPPROXIMATELY $12 MILLION FOR MUTUAL FUND PURCHASES MADESINCE JULY 1, 2009. AS PART OF THIS SETTLEMENT, THE FIRM AGREES TOPAY RESTITUTION TO ELIGIBLE CUSTOMERS, WHICH IS ESTIMATED TOTOTAL APPROXIMATELY $13.5 MILLION (I.E., THE AMOUNT ELIGIBLECUSTOMERS WERE OVERCHARGED, INCLUSIVE OF INTEREST). THE FIRMWILL ALSO ENSURE THAT RETIREMENT AND CHARITABLE WAIVERS AREAPPROPRIATELY APPLIED TO ALL FUTURE TRANSACTIONS. IN RESOLVINGTHIS MATTER, FINRA HAS RECOGNIZED THE EXTRAORDINARYCOOPERATION OF THE FIRM FOR HAVING: (1) INITIATED, PRIOR TODETECTION OR INTERVENTION BY A REGULATOR, AN INVESTIGATION TOIDENTIFY WHETHER ELIGIBLE CUSTOMERS RECEIVED SALES CHARGEWAIVERS DURING THE RELEVANT PERIOD; (2) PROMPTLY ESTABLISHED APLAN OF REMEDIATION FOR ELIGIBLE CUSTOMERS WHO DID NOTRECEIVE APPROPRIATE SALES CHARGE WAIVERS; (3) PROMPTLY SELF-REPORTED TO FINRA; (4) PROMPTLY TAKEN ACTION AND REMEDIAL STEPSTO CORRECT THE VIOLATIVE CONDUCT; AND (5) EMPLOYED SUBSEQUENTCORRECTIVE MEASURES, PRIOR TO DETECTION OR INTERVENTION BY AREGULATOR, TO REVISE ITS PROCEDURES TO AVOID RECURRENCE OFTHE MISCONDUCT.


Initiated By: FINRA





Allegations: ON OCTOBER 26, 2015, FINRA ALLEGED EDWARD JONES VIOLATEDCERTAIN FEDERAL SECURITIES LAWS OR RULES BY NOT ENSURINGAPPLICABLE SALES CHARGE WAIVERS WERE RECEIVED FOR MUTUALFUND PURCHASES IN CERTAIN RETIREMENT PLAN AND CHARITABLEORGANIZATION ACCOUNTS. ON MAY 5, 2015, FINRA'S ENFORCEMENTDIVISION ADVISED EDWARD JONES THAT IT WAS INVESTIGATING THISISSUE. PRIOR TO BEING ADVISED OF THE INVESTIGATION, EDWARDJONES HAD COMMENCED A REVIEW OF THIS ISSUE AND SELF-REPORTEDTO FINRA.












Resolution:

Other Sanctions Ordered: INTEREST

Sanction Details: ON OCTOBER 26, 2015, EDWARD JONES, WITHOUT ADMITTING ORDENYING THE FINDINGS, ENTERED INTO AN ACCEPTANCE, WAIVER ANDCONSENT (AWC) WITH FINRA TO RESOLVE THIS MATTER. PURSUANT TOTHE AWC, EDWARD JONES AGREED TO PROVIDE REMEDIATION TOCERTAIN CUSTOMERS, ESTIMATED AT THE TIME OF THE SETTLEMENTAGREEMENT TO BE APPROXIMATELY $13.5 MILLION. A MONETARYPENALTY WAS NOT IMPOSED BY FINRA. IN REACHING THE AWC, FINRARECOGNIZED THE EXTRAORDINARY COOPERATION OF EDWARD JONES,INCLUDING ITS SELF-REPORTING OF THE ISSUE TO FINRA.

Sanctions Ordered: CensureDisgorgement/Restitution


Disclosure 10 of 73

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Allegations: SEC ADMIN RELEASES 33-9955; 34-76052; SEPTEMBER 30, 2015: THESECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE ANDIN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINSTEDWARD D. JONES & CO., L.P., ("RESPONDENT"). RESPONDENT WILLFULLYVIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTERINVOLVES VIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERALSECURITIES LAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITINGOF CERTAIN MUNICIPAL SECURITIES OFFERINGS. RESPONDENT, AREGISTERED BROKER-DEALER, CONDUCTED INADEQUATE DUEDILIGENCE IN CERTAIN OFFERINGS AND AS A RESULT, FAILED TO FORM AREASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAINMATERIAL REPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED INCONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENTOFFERING AND SELLING MUNICIPAL SECURITIES ON THE BASIS OFMATERIALLY MISLEADING DISCLOSURE DOCUMENTS.THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THECOMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION(MCDC) INITIATIVE.







Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION


Cease and Desist



Docket/Case Number: 3-16867



SEC ADMIN RELEASES 33-9955; 34-76052; SEPTEMBER 30, 2015: THESECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE ANDIN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINSTEDWARD D. JONES & CO., L.P., ("RESPONDENT"). RESPONDENT WILLFULLYVIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTERINVOLVES VIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERALSECURITIES LAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITINGOF CERTAIN MUNICIPAL SECURITIES OFFERINGS. RESPONDENT, AREGISTERED BROKER-DEALER, CONDUCTED INADEQUATE DUEDILIGENCE IN CERTAIN OFFERINGS AND AS A RESULT, FAILED TO FORM AREASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAINMATERIAL REPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED INCONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENTOFFERING AND SELLING MUNICIPAL SECURITIES ON THE BASIS OFMATERIALLY MISLEADING DISCLOSURE DOCUMENTS.THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THECOMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION(MCDC) INITIATIVE.


Resolution:

Other Sanctions Ordered: UNDERTAKINGS

Sanction Details: THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION17(A)(2)OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THEAMOUNT OF $100,000.00 AND COMPLY WITH THE UNDERTAKINGSENUMERATED IN THE OFFER OF SETTLEMENT.

Regulator Statement IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER")WHICH THE 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, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THEFOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INRESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THATRESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OFTHE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THISORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $100,000.00 TOTHE SECURITIES AND EXCHANGE COMMISSION; AND RETAIN ANINDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'SPOLICIES AND PROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIESUNDERWRITING DUE DILIGENCE.


Yes

Sanctions Ordered: Monetary/Fine $100,000.00Cease and Desist/Injunction

Order






IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER")WHICH THE 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, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THEFOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INRESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THATRESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OFTHE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THISORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $100,000.00 TOTHE SECURITIES AND EXCHANGE COMMISSION; AND RETAIN ANINDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'SPOLICIES AND PROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIESUNDERWRITING DUE DILIGENCE.




Cease and Desist






Allegations: ON SEPTEMBER 30, 2015, THE SECURITIES AND EXCHANGE COMMISSION("SEC") ALLEGED THAT CERTAIN SECURITY FIRMS, INCLUDING EDWARDJONES, VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT OF 1933("SECURITIES ACT") AS IT RELATES TO CERTAIN STATEMENTS OFMUNICIPAL ISSUERS REGARDING COMPLIANCE WITH PREVIOUSCONTINUING DISCLOSURE OBLIGATIONS IN OFFICIAL STATEMENTS.EDWARD JONES SELF-REPORTED THE AFOREMENTIONED VIOLATIONS TOTHE SEC PURSUANT TO ITS MUNICIPALITIES CONTINUING DISCLOSURECOOPERATION (MCDC) INITIATIVE. EDWARD JONES IS ONE OF FIFTY-EIGHT FIRMS PARTICIPATING IN THE MCDC INITIATIVE.



Resolution: Order








Sanction Details: ON SEPTEMBER 30, 2015, EDWARD JONES, WITHOUT ADMITTING ORDENYING THE FINDINGS, ENTERED INTO A PUBLIC ADMINISTRATIVESETTLEMENT WITH THE SEC REGARDING THE MATTERS SELF-REPORTEDBY EDWARD JONES PURSUANT TO THE SEC'S MCDC INITIATIVE.PURSUANT TO THE SETTLEMENT, THE SEC ALLEGED THAT EDWARDJONES VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT OF 1933 ANDWAS ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSINGANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2). THESETTLEMENT ALSO REQUIRES EDWARD JONES TO PAY A CIVIL MONEYPENALTY IN THE AMOUNT OF $100,000 AND TO COMPLY WITH THEUNDERTAKINGS ENUMERATED IN THE SETTLEMENT. THE CIVIL MONEYPENALTY WAS PAID ON OCTOBER 13, 2015.


Disclosure 11 of 73

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Allegations: SEC ADMIN RELEASE 33-9889/34-75688/AUGUST 13, 2015: THE SECURITIESAND EXCHANGE COMMISSION (COMMISSION) DEEMS IT APPROPRIATEAND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 (SECURITIESACT) AND SECTIONS 15(B), 15B(C), AND 21C OF THE SECURITIESEXCHANGE ACT OF 1934 (EXCHANGE ACT) AGAINST EDWARD D. JONES &CO., L.P. AS AN UNDERWRITING CO-MANAGING SYNDICATE MEMBER FORNEW ISSUE NEGOTIATED MUNICIPAL SECURITIES, IN CERTAIN INSTANCESTHE FIRM FAILED TO MAKE BONA FIDE PUBLIC OFFERINGS TO ITSCUSTOMERS AT INITIAL OFFERING PRICES. IN THE SECONDARY MARKETFOR MUNICIPAL SECURITIES, THE FIRM FAILED TO HAVE INTERNALCONTROLS TO PREVENT CERTAIN IMPROPER TRADING PRACTICES. WITHRESPECT TO UNDERWRITING NEW ISSUE MUNICIPAL BONDS, FROM ATLEAST FEBRUARY 2009 TO DECEMBER 2012, AND IN VIOLATION OF ITSFUNDAMENTAL OBLIGATIONS AS A MEMBER OF THE UNDERWRITINGSYNDICATE, THE FIRM'S MUNICIPAL SYNDICATE DESK, IN SEVERALNEGOTIATED OFFERINGS WHERE IT SERVED AS A CO-MANAGER,OBTAINED NEW ISSUE MUNICIPAL BONDS FOR ITS OWN INVENTORY ANDTHEN OFFERED THOSE BONDS TO CUSTOMERS FOR PRICES HIGHERTHAN THE INITIAL OFFERING PRICES NEGOTIATED WITH THE ISSUERBEFORE THE BONDS BEGAN TRADING. IN SOME OF THESE INSTANCESDURING THE RELEVANT PERIOD, THE FIRM'S MUNICIPAL SYNDICATE DESKREFRAINED ENTIRELY FROM OFFERING NEW ISSUE MUNICIPAL BONDS TOITS CUSTOMERS AT ANY PRICE UNTIL AFTER THE BONDS BEGANTRADING, AT WHICH POINT THE FIRM OFFERED AND SOLD THE BONDS TOITS CUSTOMERS AT PRICES ABOVE THE INITIAL OFFERING PRICES. THEFIRM'S SALE OF MUNICIPAL BONDS TO ITS CUSTOMERS AT PRICESHIGHER THAN INITIAL OFFERING PRICES INCREASED ITS REVENUESFROM MUNICIPAL UNDERWRITING. DURING THE RELEVANT PERIOD, THEFIRM COLLECTED AT LEAST $4.647 MILLION IN REVENUE WITH THESEPRACTICES THROUGH THE OFFER AND SALE OF ABOUT 156 DIFFERENTBONDS IN 75 NEGOTIATED OFFERINGS IN WHICH THE FIRM SERVED AS ACO-MANAGER. THIS AMOUNT WAS IN ADDITION TO FEES THAT THE FIRMEARNED AS A MEMBER OF THE SYNDICATE FOR CERTAIN OF THOSEOFFERINGS. THE FIRM'S MISCONDUCT HARMED ITS CUSTOMERS BYCAUSING THEM TO PAY PRICES HIGHER THAN THE INITIAL OFFERINGPRICES FOR MUNICIPAL BONDS. IN ADDITION, IN ONE INSTANCE, THEFIRM'S MISCONDUCT RESULTED IN AN ADVERSE FEDERAL TAXDETERMINATION FOR ONE MUNICIPAL ISSUER, CREATING A RISK THATTHE ISSUER COULD LOSE VALUABLE FEDERAL TAX SUBSIDIES. WITHRESPECT TO TRADING MUNICIPAL BONDS IN THE SECONDARY MARKET,BETWEEN JANUARY 2011 AND OCTOBER 2013, THE FIRM FAILED TOESTABLISH AN ADEQUATE SUPERVISORY SYSTEM TO IDENTIFY ANDREVIEW CERTAIN OF THE FIRM'S CUSTOMER ORDERS TO BUY AND SELLMUNICIPAL SECURITIES. AS A RESULT, THE FIRM WAS UNABLE TOADEQUATELY MONITOR WHETHER THE MARKUPS IT CHARGED FORCERTAIN TRANSACTIONS WERE REASONABLE. BEGINNING IN 2013, THEFIRM BEGAN TO UNDERTAKE SIGNIFICANT REMEDIAL MEASURESRELATED TO THE UNDERWRITING AND SECONDARY TRADING OFMUNICIPAL BONDS, INCLUDING THE DISCLOSURE OF THE PERCENTAGEAND DOLLAR AMOUNT OF MARKUPS/MARKDOWNS ON ALL OF ITS FIXEDINCOME RETAIL ORDER CONFIRMATIONS, THE HIRING OF ADDITIONALCOMPLIANCE PERSONNEL, AND THE ADOPTION AND IMPLEMENTATION OFNEW AND ENHANCED SUPERVISORY PROCEDURES. AS A RESULT OF ITSCONDUCT, THE FIRM WILLFULLY VIOLATED SECTIONS 17(A)(2) AND (3) OFTHE SECURITIES ACT, SECTION 15B(C)(1) OF THE EXCHANGE ACT, ANDRULES G-17, G-11(B) AND (D), G-27, AND G-30(A) OF THE MUNICIPALSECURITIES RULEMAKING BOARD (MSRB), AND FAILED REASONABLY TOSUPERVISE WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THEEXCHANGE ACT.











SEC ADMIN RELEASE 33-9889/34-75688/AUGUST 13, 2015: THE SECURITIESAND EXCHANGE COMMISSION (COMMISSION) DEEMS IT APPROPRIATEAND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 (SECURITIESACT) AND SECTIONS 15(B), 15B(C), AND 21C OF THE SECURITIESEXCHANGE ACT OF 1934 (EXCHANGE ACT) AGAINST EDWARD D. JONES &CO., L.P. AS AN UNDERWRITING CO-MANAGING SYNDICATE MEMBER FORNEW ISSUE NEGOTIATED MUNICIPAL SECURITIES, IN CERTAIN INSTANCESTHE FIRM FAILED TO MAKE BONA FIDE PUBLIC OFFERINGS TO ITSCUSTOMERS AT INITIAL OFFERING PRICES. IN THE SECONDARY MARKETFOR MUNICIPAL SECURITIES, THE FIRM FAILED TO HAVE INTERNALCONTROLS TO PREVENT CERTAIN IMPROPER TRADING PRACTICES. WITHRESPECT TO UNDERWRITING NEW ISSUE MUNICIPAL BONDS, FROM ATLEAST FEBRUARY 2009 TO DECEMBER 2012, AND IN VIOLATION OF ITSFUNDAMENTAL OBLIGATIONS AS A MEMBER OF THE UNDERWRITINGSYNDICATE, THE FIRM'S MUNICIPAL SYNDICATE DESK, IN SEVERALNEGOTIATED OFFERINGS WHERE IT SERVED AS A CO-MANAGER,OBTAINED NEW ISSUE MUNICIPAL BONDS FOR ITS OWN INVENTORY ANDTHEN OFFERED THOSE BONDS TO CUSTOMERS FOR PRICES HIGHERTHAN THE INITIAL OFFERING PRICES NEGOTIATED WITH THE ISSUERBEFORE THE BONDS BEGAN TRADING. IN SOME OF THESE INSTANCESDURING THE RELEVANT PERIOD, THE FIRM'S MUNICIPAL SYNDICATE DESKREFRAINED ENTIRELY FROM OFFERING NEW ISSUE MUNICIPAL BONDS TOITS CUSTOMERS AT ANY PRICE UNTIL AFTER THE BONDS BEGANTRADING, AT WHICH POINT THE FIRM OFFERED AND SOLD THE BONDS TOITS CUSTOMERS AT PRICES ABOVE THE INITIAL OFFERING PRICES. THEFIRM'S SALE OF MUNICIPAL BONDS TO ITS CUSTOMERS AT PRICESHIGHER THAN INITIAL OFFERING PRICES INCREASED ITS REVENUESFROM MUNICIPAL UNDERWRITING. DURING THE RELEVANT PERIOD, THEFIRM COLLECTED AT LEAST $4.647 MILLION IN REVENUE WITH THESEPRACTICES THROUGH THE OFFER AND SALE OF ABOUT 156 DIFFERENTBONDS IN 75 NEGOTIATED OFFERINGS IN WHICH THE FIRM SERVED AS ACO-MANAGER. THIS AMOUNT WAS IN ADDITION TO FEES THAT THE FIRMEARNED AS A MEMBER OF THE SYNDICATE FOR CERTAIN OF THOSEOFFERINGS. THE FIRM'S MISCONDUCT HARMED ITS CUSTOMERS BYCAUSING THEM TO PAY PRICES HIGHER THAN THE INITIAL OFFERINGPRICES FOR MUNICIPAL BONDS. IN ADDITION, IN ONE INSTANCE, THEFIRM'S MISCONDUCT RESULTED IN AN ADVERSE FEDERAL TAXDETERMINATION FOR ONE MUNICIPAL ISSUER, CREATING A RISK THATTHE ISSUER COULD LOSE VALUABLE FEDERAL TAX SUBSIDIES. WITHRESPECT TO TRADING MUNICIPAL BONDS IN THE SECONDARY MARKET,BETWEEN JANUARY 2011 AND OCTOBER 2013, THE FIRM FAILED TOESTABLISH AN ADEQUATE SUPERVISORY SYSTEM TO IDENTIFY ANDREVIEW CERTAIN OF THE FIRM'S CUSTOMER ORDERS TO BUY AND SELLMUNICIPAL SECURITIES. AS A RESULT, THE FIRM WAS UNABLE TOADEQUATELY MONITOR WHETHER THE MARKUPS IT CHARGED FORCERTAIN TRANSACTIONS WERE REASONABLE. BEGINNING IN 2013, THEFIRM BEGAN TO UNDERTAKE SIGNIFICANT REMEDIAL MEASURESRELATED TO THE UNDERWRITING AND SECONDARY TRADING OFMUNICIPAL BONDS, INCLUDING THE DISCLOSURE OF THE PERCENTAGEAND DOLLAR AMOUNT OF MARKUPS/MARKDOWNS ON ALL OF ITS FIXEDINCOME RETAIL ORDER CONFIRMATIONS, THE HIRING OF ADDITIONALCOMPLIANCE PERSONNEL, AND THE ADOPTION AND IMPLEMENTATION OFNEW AND ENHANCED SUPERVISORY PROCEDURES. AS A RESULT OF ITSCONDUCT, THE FIRM WILLFULLY VIOLATED SECTIONS 17(A)(2) AND (3) OFTHE SECURITIES ACT, SECTION 15B(C)(1) OF THE EXCHANGE ACT, ANDRULES G-17, G-11(B) AND (D), G-27, AND G-30(A) OF THE MUNICIPALSECURITIES RULEMAKING BOARD (MSRB), AND FAILED REASONABLY TOSUPERVISE WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THEEXCHANGE ACT.







Other


N/A




Resolution:

Other Sanctions Ordered: PREJUDGMENT INTEREST; RECORD PRESERVATION

Sanction Details: IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, EDWARDJONES 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, THEFIRM CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTIONS 15(B),15B(C), AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKINGFINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMSIT APPROPRIATE, IN THE PUBLIC INTEREST, AND FOR THE PROTECTIONOF INVESTORS TO IMPOSE THE SANCTIONS AGREED TO IN THE OFFER BYTHE FIRM. ACCORDINGLY, PURSUANT TO SECTION 8A OF THE SECURITIESACT AND SECTIONS 15(B), 15B(C), AND 21C OF THE EXCHANGE ACT, IT ISHEREBY ORDERED THAT: THE FIRM IS CENSURED AND SHALL CEASE ANDDESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANYFUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND (3) OF THE SECURITIESACT, SECTION 15B(C)(1) OF THE EXCHANGE ACT, AND MSRB RULES G-17,G-11, G-30, AND G-27. THE FIRM SHALL PAY DISGORGEMENT OF$4,524,332.60 AND PREJUDGMENT INTEREST OF $670,068.77. EDWARDJONES SHALL, WITHIN TEN DAYS OF THE ENTRY OF THIS ORDER, PAY ACIVIL MONEY PENALTY IN THE AMOUNT OF $15,000,000. EDWARD JONESSHALL PRESERVE, FOR A PERIOD OF NOT LESS THAN SIX YEARS, ALLRECORDS OF ITS COMPLIANCE WITH THE TERMS OF THIS ORDER THATRELATE TO EDWARD JONES' ADMINISTRATION OF THE DISGORGEMENTFUND.


Yes

Sanctions Ordered: CensureMonetary/Fine $15,000,000.00Disgorgement/RestitutionCease and Desist/Injunction

Order






IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, EDWARDJONES 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, THEFIRM CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTIONS 15(B),15B(C), AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKINGFINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMSIT APPROPRIATE, IN THE PUBLIC INTEREST, AND FOR THE PROTECTIONOF INVESTORS TO IMPOSE THE SANCTIONS AGREED TO IN THE OFFER BYTHE FIRM. ACCORDINGLY, PURSUANT TO SECTION 8A OF THE SECURITIESACT AND SECTIONS 15(B), 15B(C), AND 21C OF THE EXCHANGE ACT, IT ISHEREBY ORDERED THAT: THE FIRM IS CENSURED AND SHALL CEASE ANDDESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANYFUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND (3) OF THE SECURITIESACT, SECTION 15B(C)(1) OF THE EXCHANGE ACT, AND MSRB RULES G-17,G-11, G-30, AND G-27. THE FIRM SHALL PAY DISGORGEMENT OF$4,524,332.60 AND PREJUDGMENT INTEREST OF $670,068.77. EDWARDJONES SHALL, WITHIN TEN DAYS OF THE ENTRY OF THIS ORDER, PAY ACIVIL MONEY PENALTY IN THE AMOUNT OF $15,000,000. EDWARD JONESSHALL PRESERVE, FOR A PERIOD OF NOT LESS THAN SIX YEARS, ALLRECORDS OF ITS COMPLIANCE WITH THE TERMS OF THIS ORDER THATRELATE TO EDWARD JONES' ADMINISTRATION OF THE DISGORGEMENTFUND.




Other


N/A





Allegations: ON AUGUST 13, 2015, THE SECURITIES AND EXCHANGE COMMISSION("SEC") ALLEGED THAT EDWARD JONES VIOLATED SECTIONS 17(A)(2) AND(3) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"), SECTIONS15B(C)(1) AND 15(B)(4)(E) OF THE SECURITIES EXCHANGE ACT OF 1934("EXCHANGE ACT"), AND MUNICIPAL SECURITIES RULEMAKING BOARD("MSRB") RULES G-17, G-11(B) AND (D), G-27 AND G-30(A) IN CONNECTIONWITH IMPROPER PRACTICES INVOLVING MUNICIPAL SECURITIES. INENTERING INTO THE SETTLEMENT, THE SEC CONSIDERED REMEDIALACTS UNDERTAKEN BY EDWARD JONES RELATED TO THIS MATTER.



Resolution:

Other Sanctions Ordered: PREJUDGMENT INTEREST; RECORD PRESERVATION

Sanction Details: ON AUGUST 13, 2015, EDWARD JONES, WITHOUT ADMITTING OR DENYINGTHE FINDINGS AND SOLELY FOR THE PURPOSE OF THE PROCEEDINGS,ENTERED INTO A SETTLEMENT IN PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS WITH THE SEC. PURSUANT TO THESETTLEMENT, EDWARD JONES AGREED TO PAY DISGORGEMENT ANDPREJUDGMENT INTEREST OF $5,194,401.37 ("DISGORGEMENT") FOR THEPURPOSE OF MAKING PAYMENTS TO CURRENT AND FORMERCUSTOMERS OF EDWARD JONES AND TO PAY A CIVIL MONEY PENALTY INTHE AMOUNT OF $15,000,000 ("CIVIL PENALTY"). ON AUGUST 21, 2015, THEDISGORGEMENT WAS DEPOSITED INTO A SEGREGATED CASH ACCOUNTAT EDWARD JONES. THE CIVIL PENALTY WAS PAID ON AUGUST 20, 2015.


Order






Sanction Details: ON AUGUST 13, 2015, EDWARD JONES, WITHOUT ADMITTING OR DENYINGTHE FINDINGS AND SOLELY FOR THE PURPOSE OF THE PROCEEDINGS,ENTERED INTO A SETTLEMENT IN PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS WITH THE SEC. PURSUANT TO THESETTLEMENT, EDWARD JONES AGREED TO PAY DISGORGEMENT ANDPREJUDGMENT INTEREST OF $5,194,401.37 ("DISGORGEMENT") FOR THEPURPOSE OF MAKING PAYMENTS TO CURRENT AND FORMERCUSTOMERS OF EDWARD JONES AND TO PAY A CIVIL MONEY PENALTY INTHE AMOUNT OF $15,000,000 ("CIVIL PENALTY"). ON AUGUST 21, 2015, THEDISGORGEMENT WAS DEPOSITED INTO A SEGREGATED CASH ACCOUNTAT EDWARD JONES. THE CIVIL PENALTY WAS PAID ON AUGUST 20, 2015.

Firm Statement REFER TO PART II, ITEM 12(C.) OF THIS REGULATORY ACTIONDISCLOSURE REPORTING PAGE FOR A DISCUSSION OF THE MONETARYSANCTIONS AGREED TO AS PART OF THE SETTLEMENT. THE SETTLEMENTPROVIDES FOR THE FOLLOWING SCHEDULE WITH RESPECT TODISGORGEMENT: (1) EDWARD JONES SHALL BE RESPONSIBLE FORADMINISTERING THE DISGORGEMENT; (2) WITHIN 60 DAYS OF AUGUST 13,2015 (THE "ORDER DATE"), EDWARD JONES SHALL SUBMIT TO THESECURITIES AND EXCHANGE COMMISSION STAFF ("SEC STAFF"), FOR ITSREVIEW AND APPROVAL, A PROPOSED CALCULATION FOR THEDISBURSEMENT OF THE DISGORGEMENT; (3) EDWARD JONES SHALLCOMPLETE THE TRANSMISSION OF ALL AMOUNTS IN ACCORDANCE WITHTHE APPROVED CALCULATION WITHIN 120 DAYS OF THE ORDER DATE;AND (4) EDWARD JONES SHALL SUBMIT TO THE SEC STAFF , FOR ITSREVIEW AND APPROVAL THE FINAL ACCOUNTING FOR THEDISGORGEMENT WITHIN 180 DAYS OF THE ORDER DATE. PURSUANT TOTHE SETTLEMENT, THE SEC STAFF MAY EXTEND THESE DATES FOR GOODCAUSE SHOWN.

Disclosure 12 of 73

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Initiated By: FINRA

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOCAPTURE THE CORRECT TIME OF TRADE EXECUTION FOR 306TRANSACTIONS IN TRADE REPORTING AND COMPLIANCE ENGINE(TRACE)-ELIGIBLE SECURITIZED PRODUCTS. THE FINDINGS STATED THATAS A RESULT, THE FIRM FAILED TO REPORT TO TRACE THE CORRECT TIMEOF TRADE EXECUTION FOR 306 TRANSACTIONS IN TRACE-ELIGIBLESECURITIZED PRODUCTS AND FAILED TO SHOW THE CORRECT TIME OFEXECUTION ON THE MEMORANDUM OF 306 BROKERAGE ORDERS.












Other Product Type(s): SECURITIZED PRODUCTS


Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $10,000.FINE PAID IN FULL ON JUNE 19, 2015.


No




Allegations: ON JUNE 4, 2015, FINRA ALLEGED THAT EDWARD JONES FAILED TOCAPTURE THE CORRECT TIME OF TRADE EXECUTION FORTRANSACTIONS IN TRADE REPORTING AND COMPLIANCE ENGINE(TRACE)-ELIGIBLE SECURITIZED PRODUCTS, FAILED TO REPORT TOTRACE THE CORRECT TIME OF TRADE EXECUTION FOR THOSETRANSACTIONS, AND FAILED TO SHOW THE CORRECT TIME OFEXECUTION ON THE MEMORANDUM OF BROKERAGE ORDERS INVIOLATION OF FINRA RULE 6730(C)(8), RULE 17A-3 UNDER THESECURITIES EXCHANGE ACT OF 1934, AND FINRA RULES 2010 AND 4511.ON JUNE 4, 2015, EDWARD JONES, WITHOUT ADMITTING OR DENYING THEFINDINGS, ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER ANDCONSENT (AWC) WITH FINRA. PURSUANT TO THE AWC, EDWARD JONESWAS CENSURED AND ORDERED TO PAY A FINE OF $10,000. THE FINE WASPAID ON JUNE 18, 2015.








Initiated By: FINRA






Other Product Type(s): SECURITIZED PRODUCTS

ON JUNE 4, 2015, FINRA ALLEGED THAT EDWARD JONES FAILED TOCAPTURE THE CORRECT TIME OF TRADE EXECUTION FORTRANSACTIONS IN TRADE REPORTING AND COMPLIANCE ENGINE(TRACE)-ELIGIBLE SECURITIZED PRODUCTS, FAILED TO REPORT TOTRACE THE CORRECT TIME OF TRADE EXECUTION FOR THOSETRANSACTIONS, AND FAILED TO SHOW THE CORRECT TIME OFEXECUTION ON THE MEMORANDUM OF BROKERAGE ORDERS INVIOLATION OF FINRA RULE 6730(C)(8), RULE 17A-3 UNDER THESECURITIES EXCHANGE ACT OF 1934, AND FINRA RULES 2010 AND 4511.ON JUNE 4, 2015, EDWARD JONES, WITHOUT ADMITTING OR DENYING THEFINDINGS, ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER ANDCONSENT (AWC) WITH FINRA. PURSUANT TO THE AWC, EDWARD JONESWAS CENSURED AND ORDERED TO PAY A FINE OF $10,000. THE FINE WASPAID ON JUNE 18, 2015.


Resolution:


Sanction Details: ON JUNE 4, 2015, EDWARD JONES, WITHOUT ADMITTING OR DENYING THEFINDINGS, ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER ANDCONSENT (AWC) WITH FINRA. PURSUANT TO THE AWC, EDWARD JONESWAS CENSURED AND ORDERED TO PAY A FINE OF $10,000. THE FINE WASPAID ON JUNE 18, 2015.



Disclosure 13 of 73

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM,INCLUDING A WRITTEN SUPERVISORY CONTROL SYSTEM, REASONABLYDESIGNED TO PREVENT UNAUTHORIZED TRANSFERS OF CUSTOMERFUNDS TO THIRD-PARTY ACCOUNTS. THE FINDINGS STATED THAT THEFIRM FAILED TO DETECT FORGERIES AND CONVERSIONS IN A TIMELYMANNER, BY A BRANCH OFFICE ADMINISTRATOR IN ONE OF ITS BRANCHOFFICES, BECAUSE OF ITS INADEQUATE SUPERVISORY SYSTEM ANDPROCEDURES. THE BRANCH OFFICE ADMINISTRATOR FORGED OVERFIFTY LETTERS OF AUTHORIZATION (LOAS) AND CONVERTED MORE THAN$60,000 FROM FIRM CUSTOMERS. THE ADMINISTRATOR TRANSFERREDFUNDS WITHOUT AUTHORIZATION BY FORGING LOAS TO TRANSFERAMOUNTS WITHIN THE FIRM'S THRESHOLDS, THEREBY AVOIDING THEISSUANCE OF THE FIRM'S NEGATIVE CONFIRMATION LETTERS (NCLS).THE FIRM'S SYSTEM FAILED TO PROVIDE AN ADEQUATE MECHANISM TOVERIFY PURPORTED CUSTOMER SIGNATURES ON LOAS OR DETERMINE IFTHE TRANSFER OF FUNDS WAS AUTHORIZED.








Initiated By: FINRA


Other


N/A





WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM,INCLUDING A WRITTEN SUPERVISORY CONTROL SYSTEM, REASONABLYDESIGNED TO PREVENT UNAUTHORIZED TRANSFERS OF CUSTOMERFUNDS TO THIRD-PARTY ACCOUNTS. THE FINDINGS STATED THAT THEFIRM FAILED TO DETECT FORGERIES AND CONVERSIONS IN A TIMELYMANNER, BY A BRANCH OFFICE ADMINISTRATOR IN ONE OF ITS BRANCHOFFICES, BECAUSE OF ITS INADEQUATE SUPERVISORY SYSTEM ANDPROCEDURES. THE BRANCH OFFICE ADMINISTRATOR FORGED OVERFIFTY LETTERS OF AUTHORIZATION (LOAS) AND CONVERTED MORE THAN$60,000 FROM FIRM CUSTOMERS. THE ADMINISTRATOR TRANSFERREDFUNDS WITHOUT AUTHORIZATION BY FORGING LOAS TO TRANSFERAMOUNTS WITHIN THE FIRM'S THRESHOLDS, THEREBY AVOIDING THEISSUANCE OF THE FIRM'S NEGATIVE CONFIRMATION LETTERS (NCLS).THE FIRM'S SYSTEM FAILED TO PROVIDE AN ADEQUATE MECHANISM TOVERIFY PURPORTED CUSTOMER SIGNATURES ON LOAS OR DETERMINE IFTHE TRANSFER OF FUNDS WAS AUTHORIZED.


Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $75,000.

FINE PAID IN FULL FEBRUARY 4, 2015.


No




Allegations: ON JANUARY 23, 2015, FINRA ALLEGED THAT EDWARD JONES FAILED TOESTABLISH, MAINTAIN, AND ENFORCE AN ADEQUATE SUPERVISORYSYSTEM, INCLUDING A WRITTEN SUPERVISORY CONTROL SYSTEM, TOPREVENT UNAUTHORIZED TRANSFERS OF CLIENT FUNDS TO THIRD-PARTY ACCOUNTS IN VIOLATION OF NASD RULES 3010, 3012(A)(2)(B)(I),AND 2110 AND FINRA RULE 2010. ON JANUARY 23, 2015, EDWARD JONES,WITHOUT ADMITTING OR DENYING THE FINDINGS, ENTERED INTO ALETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WITH FINRA.PURSUANT TO THE AWC, EDWARD JONES WAS CENSURED AND ORDEREDTO PAY A FINE OF $75,000. THE FINE WAS PAID ON FEBRUARY 3, 2015.








Initiated By: FINRA


Other


N/A





ON JANUARY 23, 2015, FINRA ALLEGED THAT EDWARD JONES FAILED TOESTABLISH, MAINTAIN, AND ENFORCE AN ADEQUATE SUPERVISORYSYSTEM, INCLUDING A WRITTEN SUPERVISORY CONTROL SYSTEM, TOPREVENT UNAUTHORIZED TRANSFERS OF CLIENT FUNDS TO THIRD-PARTY ACCOUNTS IN VIOLATION OF NASD RULES 3010, 3012(A)(2)(B)(I),AND 2110 AND FINRA RULE 2010. ON JANUARY 23, 2015, EDWARD JONES,WITHOUT ADMITTING OR DENYING THE FINDINGS, ENTERED INTO ALETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WITH FINRA.PURSUANT TO THE AWC, EDWARD JONES WAS CENSURED AND ORDEREDTO PAY A FINE OF $75,000. THE FINE WAS PAID ON FEBRUARY 3, 2015.


Resolution:


Sanction Details: ON JANUARY 23, 2015, EDWARD JONES, WITHOUT ADMITTING OR DENYINGTHE FINDINGS, ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER ANDCONSENT (AWC) WITH FINRA. PURSUANT TO THE AWC, EDWARD JONESWAS CENSURED AND ORDERED TO PAY A FINE OF $75,000. THE FINE WASPAID ON FEBRUARY 3, 2015.

Firm Statement SEE ABOVE.



Disclosure 14 of 73

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOESTABLISH, MAINTAIN AND ENFORCE AN ADEQUATE SUPERVISORYSYSTEM AND WRITTEN POLICIES AND PROCEDURES REASONABLYDESIGNED TO ENSURE THE PROPER COMPLETION OF THE SIGNATURECERTIFICATION CLAUSE ON DOCUMENTS THAT HAD TO BE SIGNATUREGUARANTEED. THE FINDINGS STATED THAT FOR APPROXIMATELY 11YEARS THE FIRM DID NOT HAVE WRITTEN POLICIES CONCERNINGSIGNATURE CERTIFICATION AND DID NOT PROVIDE TRAININGADDRESSING THE COMPLETION OF SIGNATURE CERTIFICATION CLAUSESWHICH RESULTED IN FIRM ASSOCIATES FALSELY COMPLETING THEM. THEFINDINGS ALSO STATED THAT THE FIRM FAILED TO PREVENT AND DETECTFALSIFICATION OF SIGNATURE CERTIFICATION CLAUSES FORAPPROXIMATELY 11 YEARS.








Initiated By: FINRA


Other


N/A





WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOESTABLISH, MAINTAIN AND ENFORCE AN ADEQUATE SUPERVISORYSYSTEM AND WRITTEN POLICIES AND PROCEDURES REASONABLYDESIGNED TO ENSURE THE PROPER COMPLETION OF THE SIGNATURECERTIFICATION CLAUSE ON DOCUMENTS THAT HAD TO BE SIGNATUREGUARANTEED. THE FINDINGS STATED THAT FOR APPROXIMATELY 11YEARS THE FIRM DID NOT HAVE WRITTEN POLICIES CONCERNINGSIGNATURE CERTIFICATION AND DID NOT PROVIDE TRAININGADDRESSING THE COMPLETION OF SIGNATURE CERTIFICATION CLAUSESWHICH RESULTED IN FIRM ASSOCIATES FALSELY COMPLETING THEM. THEFINDINGS ALSO STATED THAT THE FIRM FAILED TO PREVENT AND DETECTFALSIFICATION OF SIGNATURE CERTIFICATION CLAUSES FORAPPROXIMATELY 11 YEARS.


Resolution:


Sanction Details: THE FIRM IS CENSURED AND FINED $60,000.

FINE PAID IN FULL ON JANUARY 23, 2015.


No




Allegations: ON JANUARY 15, 2015, FINRA ALLEGED THAT EDWARD JONES FAILED TOESTABLISH, MAINTAIN, AND ENFORCE AN ADEQUATE SUPERVISORYSYSTEM AND WRITTEN POLICIES AND PROCEDURES CONCERNING THECERTIFICATION OF CUSTOMER SIGNATURES ON CERTAIN DOCUMENTS INVIOLATION OF NASD RULES 3010(A) AND (B), NASD RULE 2110 (FOR THEPERIOD BEFORE DECEMBER 15, 2008) AND FINRA RULE 2010 (FOR THEPERIOD ON OR AFTER DECEMBER 15, 2008). ON JANUARY 15, 2015,EDWARD JONES, WITHOUT ADMITTING OR DENYING THE FINDINGS,ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC)WITH FINRA. PURSUANT TO THE AWC, EDWARD JONES WAS CENSUREDAND ORDERED TO PAY A FINE OF $60,000. THE FINE WAS PAID ONJANUARY 21, 2015.








Initiated By: FINRA


Other


N/A





ON JANUARY 15, 2015, FINRA ALLEGED THAT EDWARD JONES FAILED TOESTABLISH, MAINTAIN, AND ENFORCE AN ADEQUATE SUPERVISORYSYSTEM AND WRITTEN POLICIES AND PROCEDURES CONCERNING THECERTIFICATION OF CUSTOMER SIGNATURES ON CERTAIN DOCUMENTS INVIOLATION OF NASD RULES 3010(A) AND (B), NASD RULE 2110 (FOR THEPERIOD BEFORE DECEMBER 15, 2008) AND FINRA RULE 2010 (FOR THEPERIOD ON OR AFTER DECEMBER 15, 2008). ON JANUARY 15, 2015,EDWARD JONES, WITHOUT ADMITTING OR DENYING THE FINDINGS,ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC)WITH FINRA. PURSUANT TO THE AWC, EDWARD JONES WAS CENSUREDAND ORDERED TO PAY A FINE OF $60,000. THE FINE WAS PAID ONJANUARY 21, 2015.


Resolution:


Sanction Details: ON JANUARY 15, 2015, EDWARD JONES, WITHOUT ADMITTING OR DENYINGTHE FINDINGS, ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER ANDCONSENT (AWC) WITH FINRA. PURSUANT TO THE AWC, EDWARD JONESWAS CENSURED AND ORDERED TO PAY A FINE OF $60,000. THE FINE WASPAID ON JANUARY 21, 2015.



Disclosure 15 of 73

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TODEVELOP AND IMPLEMENT ADEQUATE ANTI-MONEY LAUNDERING (AML)PROCEDURES FOR REVIEWING DEPOSITS AND LIQUIDATIONS OF THIRD-PARTY STOCK CERTIFICATES IN CUSTOMER ACCOUNTS. THE FINDINGSSTATED THAT THE FIRM FAILED TO OBTAIN ANY INFORMATION REGARDINGTHE RELATIONSHIP BETWEEN THE STOCKHOLDER AND THE ACCOUNTHOLDER AND FAILED TO HAVE PROCEDURES BY WHICH TO TRACK ORINVESTIGATE SITUATIONS WHERE THIRD-PARTY STOCK CERTIFICATESWERE DEPOSITED INTO A FIRM ACCOUNT. THE FIRM DID DOCUMENT THEREASON FOR A STOCK'S CHANGE OF OWNERSHIP FROM THE ORIGINALOWNER TO A FIRM ACCOUNT HOLDER. AS A RESULT, CERTAIN FIRMCUSTOMERS DEPOSITED AND LIQUIDATED VARIOUS THIRD-PARTY STOCKCERTIFICATES THAT WERE BENEFICIALLY OWNED BY INDIVIDUALS WHOWERE EITHER PREVIOUSLY DENIED THEIR OWN ACCOUNT WITH THE FIRMOR WHO WERE OTHERWISE INELIGIBLE TO ESTABLISH AN ACCOUNT ATTHE FIRM.








Initiated By: FINRA







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TODEVELOP AND IMPLEMENT ADEQUATE ANTI-MONEY LAUNDERING (AML)PROCEDURES FOR REVIEWING DEPOSITS AND LIQUIDATIONS OF THIRD-PARTY STOCK CERTIFICATES IN CUSTOMER ACCOUNTS. THE FINDINGSSTATED THAT THE FIRM FAILED TO OBTAIN ANY INFORMATION REGARDINGTHE RELATIONSHIP BETWEEN THE STOCKHOLDER AND THE ACCOUNTHOLDER AND FAILED TO HAVE PROCEDURES BY WHICH TO TRACK ORINVESTIGATE SITUATIONS WHERE THIRD-PARTY STOCK CERTIFICATESWERE DEPOSITED INTO A FIRM ACCOUNT. THE FIRM DID DOCUMENT THEREASON FOR A STOCK'S CHANGE OF OWNERSHIP FROM THE ORIGINALOWNER TO A FIRM ACCOUNT HOLDER. AS A RESULT, CERTAIN FIRMCUSTOMERS DEPOSITED AND LIQUIDATED VARIOUS THIRD-PARTY STOCKCERTIFICATES THAT WERE BENEFICIALLY OWNED BY INDIVIDUALS WHOWERE EITHER PREVIOUSLY DENIED THEIR OWN ACCOUNT WITH THE FIRMOR WHO WERE OTHERWISE INELIGIBLE TO ESTABLISH AN ACCOUNT ATTHE FIRM.


Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $100,000.FINE PAID IN FULL ON OCTOBER 24, 2014.


No



iReporting Source:








Initiated By: FINRA







Allegations: ON OCTOBER 10, 2014, FINRA ALLEGED THAT EDWARD JONES FAILED TODEVELOP AND IMPLEMENT ADEQUATE ANTI-MONEY LAUNDERING (AML)PROCEDURES FOR REVIEWING DEPOSITS AND LIQUIDATIONS OF THIRD-PARTY STOCK CERTIFICATES IN CUSTOMER ACCOUNTS IN VIOLATION OFNASD RULES 3011(A) AND 2110 AND FINRA RULES 3310(A) AND 2010. ONOCTOBER 10, 2014, EDWARD JONES, WITHOUT ADMITTING OR DENYINGTHE FINDINGS, ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER ANDCONSENT (AWC) WITH FINRA. PURSUANT TO THE AWC, EDWARD JONESWAS CENSURED AND ORDERED TO PAY A FINE OF $100,000. THE FINEWAS PAID ON OCTOBER 23, 2014.



Resolution:


Sanction Details: ON OCTOBER 10, 2014, EDWARD JONES, WITHOUT ADMITTING ORDENYING THE FINDINGS, ENTERED INTO A LETTER OF ACCEPTANCE,WAIVER AND CONSENT (AWC) WITH FINRA. PURSUANT TO THE AWC,EDWARD JONES WAS CENSURED AND ORDERED TO PAY A FINE OF$100,000. THE FINE WAS PAID ON OCTOBER 23, 2014.



Disclosure 16 of 73

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT 1) IN SIX (6)GOVERNMENT AGENCY SECURITIES 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, AND 2) IN TEN (10) TRANSACTIONS THE FIRMPURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM ACUSTOMER AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWNACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING MARK-DOWN OR MARK-UP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTOCONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BESTJUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALERAS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THETRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED INCONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED INEFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER,OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THETOTAL DOLLAR AMOUNT OF THE TRANSACTION.








Initiated By: FINRA







Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT 1) IN SIX (6)GOVERNMENT AGENCY SECURITIES 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, AND 2) IN TEN (10) TRANSACTIONS THE FIRMPURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM ACUSTOMER AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWNACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING MARK-DOWN OR MARK-UP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTOCONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BESTJUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALERAS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THETRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED INCONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED INEFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER,OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THETOTAL DOLLAR AMOUNT OF THE TRANSACTION.


Resolution:


No

Sanctions Ordered: CensureMonetary/Fine $21,100.00Disgorgement/Restitution








Other Sanctions Ordered: RESTITUTION IN THE AMOUNT OF $3,392.65, PLUS INTEREST FOR ONEMATTER; RESTITUTION IN THE AMOUNT OF $6,391.60, PLUS INTEREST FORA SEPARATE MATTER

Sanction Details: FINE PAID IN FULL ON AUGUST 5, 2014.

CensureMonetary/Fine $21,100.00Disgorgement/Restitution


Initiated By: FINRA







Allegations: ON JULY 9, 2014, EDWARD JONES AGREED TO AN ACCEPTANCE, WAIVERAND CONSENT (AWC) WITH FINRA. PURSUANT TO THE AWC, THE FIRMWILL MAKE RESTITUTION TO SIXTEEN PUBLIC CUSTOMERS (IN THEAMOUNT OF $9,784.25, PLUS INTEREST) FOR FAILING TO OBTAIN THE BESTEXECUTION PRICE FOR TRADES OCCURRING IN 2011, IN VARIOUSGOVERNMENT FIXED INCOME PRODUCTS. THE FIRM WILL ALSO PAY AFINE OF $21,100.



Resolution:

Other Sanctions Ordered: RESTITUTION IN THE AMOUNT OF $9,784.25, PLUS INTEREST.

Sanction Details: ON JULY 9, 2014, EDWARD JONES AGREED TO AN ACCEPTANCE, WAIVERAND CONSENT (AWC). PURSUANT TO THE AWC, THE FIRM WILL MAKERESTITUTION TO SIXTEEN PUBLIC CUSTOMERS (IN THE AMOUNT OF$9,784.25, PLUS INTEREST) AND WILL PAY A FINE OF $21,100. THE FINEWILL BE PAID IMMEDIATELY AFTER RECEIVING THE APPROPRIATE FORMSFROM FINRA'S FINANCE DEPARTMENT. THE RESTITUTION WILL BE PAIDON OR BEFORE 120 DAYS FROM JULY 9, 2014.








www.finra.org/brokercheck User GuidanceON JULY 9, 2014, EDWARD JONES AGREED TO AN ACCEPTANCE, WAIVERAND CONSENT (AWC). PURSUANT TO THE AWC, THE FIRM WILL MAKERESTITUTION TO SIXTEEN PUBLIC CUSTOMERS (IN THE AMOUNT OF$9,784.25, PLUS INTEREST) AND WILL PAY A FINE OF $21,100. THE FINEWILL BE PAID IMMEDIATELY AFTER RECEIVING THE APPROPRIATE FORMSFROM FINRA'S FINANCE DEPARTMENT. THE RESTITUTION WILL BE PAIDON OR BEFORE 120 DAYS FROM JULY 9, 2014.

Disclosure 17 of 73

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Initiated By: NEW HAMPSHIRE


Cease and Desist



Docket/Case Number: C-2012000002




Allegations: VIOLATIONS OF N.H. RSA 421-B:8, X WHICH REQUIRES LICENSEE COMPLYWITH RULES OF SECURITIES AND EXCHANGE COMMISSION, FINRA,NATIONAL AND REGIONAL STOCK EXCHANGES, AND OTHER SELF-REGULATING ORGANIZATIONS WHICH HAVE JURISDICTION OVER THELICENSEE.

ALLEGATIONS INCLUDED SOLICITATIONS CALLS BEING MADE INVIOLATION OF APPLICABLE TELEPHONE SOLICITATION RULES, FAILURE TOPROPERLY TRAIN AND SUPERVISE AGENTS IN THE AREA OF TELEPHONESOLICITATION, AND FAILURE TO ESTABLISH SYSTEM AND PROCEDURESREASONABLY DESIGNED TO ENSURE COMPLIANCE WITH APPLICABLETELEPHONE SOLICITATION RULES.



Resolution:


No


Consent






Other Sanctions Ordered: REQUIRED PROCEDURAL CHANGES IN THE AREA OF TRAINING,COMPLIANCE, AND SUPERVISION OF AGENT TELEPHONE SOLICITATIONACTIVITY.

REPORTING ON COMPLIANCE AT SIX MONTHS AND ONE YEAR FROM DATEOF EXECUTION OF CONSENT.

Sanction Details: TOTAL AMOUNT OF MONETARY SETTLEMENT: $750,000

MONETARY SETTLEMENT BREAKDOWN: $175,000 IN COSTS, $175,000 INCONTRIBUTION TO NH INVESTOR EDUCATION, $400,000 ADMINISTRATIVEFINE.

SETTLEMENT PAID IN FULL 3/3/2014.



Initiated By: STATE OF NEW HAMPSHIRE, DEPARTMENT OF STATE, BUREAU OFSECURITIES REGULATION


Cease and Desist


MONETARY FINE - SEE QUESTION 12.C.


Docket/Case Number: C-201200002



Allegations: THE STATE OF NEW HAMPSHIRE, DEPARTMENT OF STATE, BUREAU OFSECURITIES REGULATION ALLEGED THAT EDWARD JONES VIOLATED N.H.RSA 421-B:8, X, WHICH REQUIRES EDWARD JONES TO COMPLY WITH THERULES OF THE SECURITIES AND EXCHANGE COMMISSION, FINRA,NATIONAL AND REGIONAL STOCK EXCHANGES, AND OTHER SELF-REGULATING ORGANIZATIONS WHICH HAVE JURISDICTION OVER EDWARDJONES. THE ALLEGED VIOLATIONS INCLUDED THAT: 1) SOLICITATIONCALLS WERE BEING MADE IN VIOLATION OF APPLICABLE TELEPHONESOLICITATION RULES; 2) EDWARD JONES FAILED TO PROPERLY TRAINAND SUPERVISE FINANCIAL ADVISORS IN THE AREA OF TELEPHONESOLICITATION; AND 3) EDWARD JONES FAILED TO ESTABLISH A SYSTEMAND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCEWITH APPLICABLE TELEPHONE SOLICITATION RULES.








MONETARY FINE - SEE QUESTION 12.C.


Resolution:

Other Sanctions Ordered: WITHOUT ADMITTING OR DENYING THE FINDINGS, EDWARD JONESENTERED INTO A CONSENT ORDER REQUIRING EDWARD JONES TOIMPLEMENT PROCEDURAL CHANGES IN THE AREAS OF TRAINING,COMPLIANCE, AND SUPERVISION OF FINANCIAL ADVISORS' TELEPHONESOLICITATION ACTIVITY AND REPORT ON COMPLIANCE WITH THECONSENT ORDER AT SIX MONTHS AND ONE YEAR FROM THE DATE OFEXECUTION OF THE CONSENT ORDER.

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, EDWARD JONESENTERED INTO A CONSENT ORDER WITH A MONETARY SETTLEMENTAMOUNT OF $750,000. THE BREAKDOWN IS $175,000 IN COSTS, A $175,000CONTRIBUTION TO NH INVESTOR EDUCATION, AND A $400,000ADMINISTRATIVE FINE. THE MONETARY SETTLEMENT WAS PAID IN FULLON 3/3/2014.


Consent

Disclosure 18 of 73

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Allegations: FINRA RULE 2010, NASD RULES 2110, 2310, 3010: FOR ALMOST A YEAR ANDA HALF, THE FIRM ALLOWED ITS REGISTERED REPRESENTATIVES TORECOMMEND NONTRADITIONAL EXCHANGE TRADED FUNDS (ETFS) TOCUSTOMERS WITHOUT FIRST CONDUCTING REASONABLE DUE DILIGENCECONCERNING THOSE PRODUCTS. THE FIRM ALSO DID NOT TRAIN ORADEQUATELY EDUCATE ITS BROKERS REGARDING NONTRADITIONALETFS BEFORE PERMITTING THEM TO RECOMMEND THEM TOCUSTOMERS. NONETHELESS, THE FIRM REGISTERED REPRESENTATIVESPLACED NUMEROUS NONTRADITIONAL ETF TRANSACTIONS, AT ACOMBINED VALUE OF APPROXIMATELY $164 MILLION, IN RETAILCUSTOMERS' ACCOUNTS, DURING THE PERIOD. CERTAIN REGISTEREDREPRESENTATIVES OF THE FIRM RECOMMENDED NONTRADITIONAL ETFSTO CUSTOMERS WHO HAD NOT INDICATED A DESIRE TO TAKEAGGRESSIVE RISKS WITH THEIR ACCOUNTS AT THE FIRM. SOME OFTHESE CUSTOMERS HELD THEIR NONTRADITIONAL ETF POSITIONS FORWEEKS OR MONTHS AT A TIME. NONTRADITIONAL ETFS ARE TYPICALLYNOT SUITABLE FOR RETAIL INVESTORS WHO PLAN TO HOLD THEM FORMORE THAN ONE TRADING SESSION, PARTICULARLY IN VOLATILEMARKETS. THE FIRM FAILED TO ESTABLISH AND MAINTAIN ASUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORYPROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE NASD OR FINRA RULES IN CONNECTION WITH THE SALE OFNONTRADITIONAL ETFS. THE FIRM FAILED TO ESTABLISH AND MAINTAINAN ADEQUATE SUPERVISORY SYSTEM TO MONITOR TRANSACTIONS INNONTRADITIONAL ETFS INVOLVING ITS RETAIL CUSTOMERS. THE FIRM DIDNOT EXERCISE DUE DILIGENCE IN INVESTIGATING NONTRADITIONALETFS. FURTHER, THE FIRM DID NOT ENSURE THAT ITS BROKERSOBTAINED ADEQUATE INFORMATION AND INSTRUCTION REGARDINGNONTRADITIONAL ETFS BEFORE RECOMMENDING THOSE PRODUCTS TOCUSTOMERS. FOR THE PERIOD, THE FIRM DID NOT PROVIDE SUCHINFORMATION DIRECTLY TO BROKERS OR REQUIRE THAT THEY OBTAIN ITFROM OTHER SOURCES. THE FIRM'S SUPERVISORY SYSTEM WAS ALSOINADEQUATE WITH RESPECT TO ITS OVERSIGHT OF NONTRADITIONALETF TRANSACTIONS. UNTIL THE TIME, WHEN FINRA ISSUED REGULATORYNOTICE 09-31, THE FIRM RELIED ON ITS GENERAL SUPERVISORYPROCEDURES TO OVERSEE TRANSACTIONS IN NONTRADITIONAL ETFS.THOSE PROCEDURES, HOWEVER, DID NOT ADDRESS THE PRODUCTS'UNIQUE FEATURES AND RISKS. FOR EXAMPLE, THE FIRM'S SALES-EXCEPTION REPORTS AND OTHER SUPERVISORY TOOLS DID NOTDIFFERENTIATE BETWEEN EXCHANGE-TRADED EQUITY SECURITIES,TRADITIONAL ETFS, AND NONTRADITIONAL ETFS. IN ADDITION, THE FIRM'SGENERAL SUPERVISORY PROCEDURES DID NOT REQUIRE IT TO MONITOREITHER THE LENGTH OF TIME CUSTOMERS HELD OPEN POSITIONS INNONTRADITIONAL ETFS OR THE EFFECT OF LONG HOLDING PERIODS ONTHOSE POSITIONS.







Initiated By: FINRA


Other


N/A




Other Product Type(s): NONTRADITIONAL EXCHANGE TRADED FUNDS (ETFS)

FINRA RULE 2010, NASD RULES 2110, 2310, 3010: FOR ALMOST A YEAR ANDA HALF, THE FIRM ALLOWED ITS REGISTERED REPRESENTATIVES TORECOMMEND NONTRADITIONAL EXCHANGE TRADED FUNDS (ETFS) TOCUSTOMERS WITHOUT FIRST CONDUCTING REASONABLE DUE DILIGENCECONCERNING THOSE PRODUCTS. THE FIRM ALSO DID NOT TRAIN ORADEQUATELY EDUCATE ITS BROKERS REGARDING NONTRADITIONALETFS BEFORE PERMITTING THEM TO RECOMMEND THEM TOCUSTOMERS. NONETHELESS, THE FIRM REGISTERED REPRESENTATIVESPLACED NUMEROUS NONTRADITIONAL ETF TRANSACTIONS, AT ACOMBINED VALUE OF APPROXIMATELY $164 MILLION, IN RETAILCUSTOMERS' ACCOUNTS, DURING THE PERIOD. CERTAIN REGISTEREDREPRESENTATIVES OF THE FIRM RECOMMENDED NONTRADITIONAL ETFSTO CUSTOMERS WHO HAD NOT INDICATED A DESIRE TO TAKEAGGRESSIVE RISKS WITH THEIR ACCOUNTS AT THE FIRM. SOME OFTHESE CUSTOMERS HELD THEIR NONTRADITIONAL ETF POSITIONS FORWEEKS OR MONTHS AT A TIME. NONTRADITIONAL ETFS ARE TYPICALLYNOT SUITABLE FOR RETAIL INVESTORS WHO PLAN TO HOLD THEM FORMORE THAN ONE TRADING SESSION, PARTICULARLY IN VOLATILEMARKETS. THE FIRM FAILED TO ESTABLISH AND MAINTAIN ASUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORYPROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE NASD OR FINRA RULES IN CONNECTION WITH THE SALE OFNONTRADITIONAL ETFS. THE FIRM FAILED TO ESTABLISH AND MAINTAINAN ADEQUATE SUPERVISORY SYSTEM TO MONITOR TRANSACTIONS INNONTRADITIONAL ETFS INVOLVING ITS RETAIL CUSTOMERS. THE FIRM DIDNOT EXERCISE DUE DILIGENCE IN INVESTIGATING NONTRADITIONALETFS. FURTHER, THE FIRM DID NOT ENSURE THAT ITS BROKERSOBTAINED ADEQUATE INFORMATION AND INSTRUCTION REGARDINGNONTRADITIONAL ETFS BEFORE RECOMMENDING THOSE PRODUCTS TOCUSTOMERS. FOR THE PERIOD, THE FIRM DID NOT PROVIDE SUCHINFORMATION DIRECTLY TO BROKERS OR REQUIRE THAT THEY OBTAIN ITFROM OTHER SOURCES. THE FIRM'S SUPERVISORY SYSTEM WAS ALSOINADEQUATE WITH RESPECT TO ITS OVERSIGHT OF NONTRADITIONALETF TRANSACTIONS. UNTIL THE TIME, WHEN FINRA ISSUED REGULATORYNOTICE 09-31, THE FIRM RELIED ON ITS GENERAL SUPERVISORYPROCEDURES TO OVERSEE TRANSACTIONS IN NONTRADITIONAL ETFS.THOSE PROCEDURES, HOWEVER, DID NOT ADDRESS THE PRODUCTS'UNIQUE FEATURES AND RISKS. FOR EXAMPLE, THE FIRM'S SALES-EXCEPTION REPORTS AND OTHER SUPERVISORY TOOLS DID NOTDIFFERENTIATE BETWEEN EXCHANGE-TRADED EQUITY SECURITIES,TRADITIONAL ETFS, AND NONTRADITIONAL ETFS. IN ADDITION, THE FIRM'SGENERAL SUPERVISORY PROCEDURES DID NOT REQUIRE IT TO MONITOREITHER THE LENGTH OF TIME CUSTOMERS HELD OPEN POSITIONS INNONTRADITIONAL ETFS OR THE EFFECT OF LONG HOLDING PERIODS ONTHOSE POSITIONS.


Resolution:


No









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 $200,000, AND ORDERED TO PAY$51,581.25 IN RESTITUTION, TO CUSTOMERS.A REGISTERED PRINCIPAL ON BEHALF OF THE FIRM SHALL SUBMITSATISFACTORY PROOF OF PAYMENT OF RESTITUTION OR OFREASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECTRESTITUTION. THIS PROOF SHALL BE PROVIDED TO THE FINRA NO LATERTHAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. IF FOR ANY REASONTHE FIRM CANNOT LOCATE ANY CUSTOMER WITHIN 90 DAYS OF THE DATETHE AWC IS ACCEPTED, DESPITE MAKING AND DOCUMENTINGREASONABLE EFFORTS TO DO SO, THE FIRM SHALL FORWARD ANYUNDISTRIBUTED RESTITUTION AMOUNTS TO THE APPROPRIATE ESCHEAT,UNCLAIMED PROPERTY, OR ABANDONED-PROPERTY FUND FOR THESTATE IN WHICH THE CUSTOMER IS LAST KNOWN TO HAVE RESIDED. THEFIRM SHALL PROVIDE SATISFACTORY PROOF OF SUCH ACTION TO FINRAIN THE MANNER DESCRIBED ABOVE, WITHIN 14 DAYS OF FORWARDINGTHE UNDISTRIBUTED RESTITUTION TO THE APPROPRIATE AUTHORITY.


No



Allegations: ON JANUARY 9, 2014, FINRA ALLEGED THAT EDWARD JONES VIOLATEDFINRA RULE 2010 AND NASD RULES 2110, 2310, AND 3010. FINRA ALLEGEDTHAT, FOR ALMOST A YEAR AND A HALF, EDWARD JONES ALLOWED ITSREGISTERED REPRESENTATIVES TO RECOMMEND NONTRADITIONALEXCHANGE TRADED FUNDS (ETFS) TO CLIENTS WITHOUT FIRSTCONDUCTING REASONABLE DUE DILIGENCE CONCERNING THOSEPRODUCTS. FINRA ALSO ALLEGED THAT EDWARD JONES DID NOT TRAINOR ADEQUATELY EDUCATE ITS REGISTERED REPRESENTATIVESREGARDING NONTRADITIONAL ETFS BEFORE PERMITTING THEM TORECOMMEND THEM TO CLIENTS AND THAT EDWARD JONES' REGISTEREDREPRESENTATIVES PLACED NUMEROUS NONTRADITIONAL ETFTRANSACTIONS, AT A COMBINED VALUE OF APPROXIMATELY $164MILLION, IN RETAIL CLIENTS' ACCOUNTS, DURING THE PERIOD. FINRAALLEGED THAT CERTAIN EDWARD JONES REGISTEREDREPRESENTATIVES RECOMMENDED NONTRADITIONAL ETFS TO CLIENTSWHO HAD NOT INDICATED A DESIRE TO TAKE AGGRESSIVE RISKS WITHTHEIR ACCOUNTS AT EDWARD JONES AND THAT SOME OF THESE CLIENTSHELD THEIR NONTRADITIONAL ETF POSITIONS FOR WEEKS OR MONTHSAT A TIME. FINRA ASSERTED THAT NONTRADITIONAL ETFS ARE TYPICALLYNOT SUITABLE FOR RETAIL INVESTORS WHO PLAN TO HOLD THEM FORMORE THAN ONE TRADING SESSION, PARTICULARLY IN VOLATILEMARKETS. FINRA ALLEGED THAT EDWARD JONES: (1) FAILED TOESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTENSUPERVISORY PROCEDURES, REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE NASD OR FINRA RULES IN CONNECTIONWITH THE SALE OF NONTRADITIONAL ETFS; (2) FAILED TO ESTABLISH ANDMAINTAIN AN ADEQUATE SUPERVISORY SYSTEM TO MONITORTRANSACTIONS IN NONTRADITIONAL ETFS INVOLVING ITS RETAILCLIENTS; (3) DID NOT EXERCISE DUE DILIGENCE IN INVESTIGATINGNONTRADITIONAL ETFS; (4) DID NOT ENSURE THAT ITS REGISTEREDREPRESENTATIVES OBTAINED ADEQUATE INFORMATION ANDINSTRUCTION REGARDING NONTRADITIONAL ETFS BEFORERECOMMENDING THOSE PRODUCTS TO CLIENTS; AND (5) FOR THEPERIOD, DID NOT PROVIDE SUCH INFORMATION DIRECTLY TOREGISTERED REPRESENTATIVES OR REQUIRE THAT THEY OBTAIN ITFROM OTHER SOURCES. FINRA ALSO ALLEGED THAT EDWARD JONES'SUPERVISORY SYSTEM WAS INADEQUATE WITH RESPECT TO ITSOVERSIGHT OF NONTRADITIONAL ETF TRANSACTIONS AND UNTIL THETIME WHEN FINRA ISSUED REGULATORY NOTICE 09-31, RELIED ON ITSGENERAL SUPERVISORY PROCEDURES TO OVERSEE TRANSACTIONS INNONTRADITIONAL ETFS. FINRA ALLEGED THAT THOSE PROCEDURES DIDNOT ADDRESS THE PRODUCTS' UNIQUE FEATURES AND RISKS, E.G.,EDWARD JONES' SALES-EXCEPTION REPORTS AND OTHER SUPERVISORYTOOLS DID NOT DIFFERENTIATE BETWEEN EXCHANGED-TRADED EQUITYSECURITIES, TRADITIONAL ETFS, AND NONTRADITIONAL ETFS. FINRAALLEGED THAT EDWARD JONES' GENERAL SUPERVISORY PROCEDURESDID NOT REQUIRE IT TO MONITOR EITHER THE LENGTH OF TIME CLIENTSHELD OPEN POSITIONS IN NONTRADITIONAL ETFS OR THE EFFECT OFLONG HOLDING PERIODS ON THOSE POSITIONS.







Initiated By: FINRA


Other




Other Product Type(s): NONTRADITIONAL EXCHANGE TRADED FUNDS (ETFS)

ON JANUARY 9, 2014, FINRA ALLEGED THAT EDWARD JONES VIOLATEDFINRA RULE 2010 AND NASD RULES 2110, 2310, AND 3010. FINRA ALLEGEDTHAT, FOR ALMOST A YEAR AND A HALF, EDWARD JONES ALLOWED ITSREGISTERED REPRESENTATIVES TO RECOMMEND NONTRADITIONALEXCHANGE TRADED FUNDS (ETFS) TO CLIENTS WITHOUT FIRSTCONDUCTING REASONABLE DUE DILIGENCE CONCERNING THOSEPRODUCTS. FINRA ALSO ALLEGED THAT EDWARD JONES DID NOT TRAINOR ADEQUATELY EDUCATE ITS REGISTERED REPRESENTATIVESREGARDING NONTRADITIONAL ETFS BEFORE PERMITTING THEM TORECOMMEND THEM TO CLIENTS AND THAT EDWARD JONES' REGISTEREDREPRESENTATIVES PLACED NUMEROUS NONTRADITIONAL ETFTRANSACTIONS, AT A COMBINED VALUE OF APPROXIMATELY $164MILLION, IN RETAIL CLIENTS' ACCOUNTS, DURING THE PERIOD. FINRAALLEGED THAT CERTAIN EDWARD JONES REGISTEREDREPRESENTATIVES RECOMMENDED NONTRADITIONAL ETFS TO CLIENTSWHO HAD NOT INDICATED A DESIRE TO TAKE AGGRESSIVE RISKS WITHTHEIR ACCOUNTS AT EDWARD JONES AND THAT SOME OF THESE CLIENTSHELD THEIR NONTRADITIONAL ETF POSITIONS FOR WEEKS OR MONTHSAT A TIME. FINRA ASSERTED THAT NONTRADITIONAL ETFS ARE TYPICALLYNOT SUITABLE FOR RETAIL INVESTORS WHO PLAN TO HOLD THEM FORMORE THAN ONE TRADING SESSION, PARTICULARLY IN VOLATILEMARKETS. FINRA ALLEGED THAT EDWARD JONES: (1) FAILED TOESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTENSUPERVISORY PROCEDURES, REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE NASD OR FINRA RULES IN CONNECTIONWITH THE SALE OF NONTRADITIONAL ETFS; (2) FAILED TO ESTABLISH ANDMAINTAIN AN ADEQUATE SUPERVISORY SYSTEM TO MONITORTRANSACTIONS IN NONTRADITIONAL ETFS INVOLVING ITS RETAILCLIENTS; (3) DID NOT EXERCISE DUE DILIGENCE IN INVESTIGATINGNONTRADITIONAL ETFS; (4) DID NOT ENSURE THAT ITS REGISTEREDREPRESENTATIVES OBTAINED ADEQUATE INFORMATION ANDINSTRUCTION REGARDING NONTRADITIONAL ETFS BEFORERECOMMENDING THOSE PRODUCTS TO CLIENTS; AND (5) FOR THEPERIOD, DID NOT PROVIDE SUCH INFORMATION DIRECTLY TOREGISTERED REPRESENTATIVES OR REQUIRE THAT THEY OBTAIN ITFROM OTHER SOURCES. FINRA ALSO ALLEGED THAT EDWARD JONES'SUPERVISORY SYSTEM WAS INADEQUATE WITH RESPECT TO ITSOVERSIGHT OF NONTRADITIONAL ETF TRANSACTIONS AND UNTIL THETIME WHEN FINRA ISSUED REGULATORY NOTICE 09-31, RELIED ON ITSGENERAL SUPERVISORY PROCEDURES TO OVERSEE TRANSACTIONS INNONTRADITIONAL ETFS. FINRA ALLEGED THAT THOSE PROCEDURES DIDNOT ADDRESS THE PRODUCTS' UNIQUE FEATURES AND RISKS, E.G.,EDWARD JONES' SALES-EXCEPTION REPORTS AND OTHER SUPERVISORYTOOLS DID NOT DIFFERENTIATE BETWEEN EXCHANGED-TRADED EQUITYSECURITIES, TRADITIONAL ETFS, AND NONTRADITIONAL ETFS. FINRAALLEGED THAT EDWARD JONES' GENERAL SUPERVISORY PROCEDURESDID NOT REQUIRE IT TO MONITOR EITHER THE LENGTH OF TIME CLIENTSHELD OPEN POSITIONS IN NONTRADITIONAL ETFS OR THE EFFECT OFLONG HOLDING PERIODS ON THOSE POSITIONS.








Other


N/A


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, ON JANUARY 9, 2014,EDWARD JONES ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER ANDCONSENT IN WHICH EDWARD JONES WAS CENSURED, FINED $200,000,AND ORDERED TO PAY $51,581.25 IN RESTITUTION TO CLIENTS. THERESTITUTION IS TO BE PAID ON OR ABOUT MAY 9, 2014.



Disclosure 19 of 73

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Initiated By: NEBRASKA DEPARTMENT OF BANKING & FINANCE





Docket/Case Number:



Allegations: THE NEBRASKA DEPARTMENT OF BANKING AND FINANCE ALLEGED THATEDWARD JONES: (1) FAILED TO MAINTAIN TRUE AND ACCURATE RECORDS;AND (2) FAILED TO MAINTAIN REQUIRED BOOKS AND RECORDS. THEALLEGATIONS STEM FROM A SINGLE FINANCIAL ADVISOR'S HANDLING OFHER MINOR CHILD'S CUSTODIAL ACCOUNT.



Resolution: Consent








Other Sanctions Ordered: COSTS OF $2,500.

Sanction Details: ON NOVEMBER 20, 2013, EDWARD JONES, WITHOUT ADMITTING ORDENYING THE FINDINGS, ENTERED INTO A CONSENT ORDER IN WHICHEDWARD JONES WAS FINED $10,000 AND AGREED TO PAY $2,500 INCOSTS.


Disclosure 20 of 73

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Initiated By: FINRA







Allegations: MSRB RULES G-17, G-30(A) - EDWARD D. JONES & CO., L.P. DBA EDWARDJONES PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNTFROM CUSTOMERS AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWNACCOUNT TO CUSTOMERS AT AN AGGREGATE PRICE (INCLUDING ANYMARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE, TAKINGINTO CONSIDERATION ALL RELEVANT FACTS, INCLUDING THE BESTJUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALERAS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THETRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED INCONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED INEFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER,OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THETOTAL DOLLAR AMOUNT OF THE TRANSACTION.



Resolution:


No









Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $160,000 FOR MSRBRULE VIOLATIONS. NO RESTITUTION PAYMENT IS PROVIDED FOR IN THEAWC IN LIGHT OF THE FACT THAT THE FIRM PREVIOUSLY PROVIDEDRESTITUTION TO ITS CUSTOMERS, WHICH THE FIRM COMMENCED PAYINGAS EARLY AS DECEMBER 31, 2008. FINE PAID ON JUNE 24, 2013.


No



Initiated By: FINRA




Allegations: ON JUNE 7, 2013, FINRA ALLEGED THAT EDWARD JONES VIOLATED MSRBRULES G-17 AND G-30(A) BY PURCHASING MUNICIPAL SECURITIES FOR ITSOWN ACCOUNT FROM CUSTOMERS AND/OR SELLING MUNICIPALSECURITIES FOR ITS OWN ACCOUNT TO CUSTOMERS AT AN AGGREGATEPRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIRAND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTS,INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER ORMUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THESECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIESEXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THEEXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THATTHE BROKER, DEALER, OR MUNICIPAL SECURITIES DEALER IS ENTITLEDTO A PROFIT, AND THE TOTAL AMOUNT OF THE TRANSACTION. ON JUNE 7,2013, EDWARD JONES, WITHOUT ADMITTING OR DENYING THE FINDINGS,ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT INWHICH EDWARD JONES WAS CENSURED AND ORDERED TO PAY A FINE OF$160,000.













Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, EDWARD JONESCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE EDWARD JONES WAS CENSURED AND FINED$160,000.00.



Disclosure 21 of 73

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Initiated By: FINRA





Allegations: ARTICLE V, SECTION 2(C) OF THE FINRA BY-LAWS, FINRA RULE 2010, ANDNASD RULES 2110 AND 3010(B): THE FIRM'S PAYROLL DEPARTMENTPERIODICALLY RECEIVED GARNISHMENTS FROM JUDGMENT CREDITORS,TAX LEVIES FROM FEDERAL AND STATE TAXING AUTHORITIES, AND/ORBANKRUPTCY WAGE WITHHOLDING ORDER INVOLVING REGISTEREDREPRESENTATIVES OF THE FIRM. THE FIRM DID NOT ESTABLISH ANDMAINTAIN WRITTEN SUPERVISORY PROCEDURES TO ENSURE THATREGISTERED REPRESENTATIVES' UNIFORM APPLICATIONS FORSECURITIES INDUSTRY REGISTRATION OR TRANSFER (FORMS U4) WEREUPDATED TO REFLECT DISCLOSURES OF WHICH THE FIRM'S PAYROLLDEPARTMENT WAS ON NOTICE AND DID NOT TIMELY FILE FORM U4AMENDMENTS. THE FIRM HAS SINCE UPDATED THE AFFECTEDREGISTERED REPRESENTATIVES' FORMS U4.









Other


N/A



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED AND FINED $35,000. FINE PAID INFULL ON 1/8/2013.


No




Allegations: ON JULY 13, 2012, FINRA ALLEGED THAT EDWARD JONES' PAYROLLDEPARTMENT PERIODICALLY RECEIVED GARNISHMENTS FROMJUDGMENT CREDITORS, TAX LEVIES FROM FEDERAL AND STATE TAXINGAUTHORITIES, AND/OR BANKRUPTCY WAGE WITHHOLDING ORDERSINVOLVING EDWARD JONES FINANCIAL ADVISORS. FINRA ALLEGED THATEDWARD JONES DID NOT ESTABLISH AND MAINTAIN WRITTENSUPERVISORY PROCEDURES TO ENSURE THAT FINANCIAL ADVISORS'UNIFORM APPLICATIONS FOR SECURITIES INDUSTRY REGISTRATION ORTRANSFER (FORMS U4) WERE UPDATED TO REFLECT DISCLOSURES OFWHICH THE FIRM'S PAYROLL DEPARTMENT WAS ON NOTICE AND DID NOTTIMELY FILE FORM U4 AMENDMENTS, IN VIOLATION OF ARTICLE V,SECTION 2(C) OF THE FINRA BY-LAWS, FINRA RULE 2010, AND NASD RULES2110 AND 3010(B). ON DECEMBER 17, 2012, EDWARD JONES, WITHOUTADMITTING OR DENYING THE FINDINGS, ENTERED INTO A LETTER OFACCEPTANCE, WAIVER AND CONSENT IN WHICH EDWARD JONES WASCENSURED AND ORDERED TO PAY A FINE OF $35,000.







Initiated By: FINRA


Other


N/A






Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, EDWARD JONESCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE EDWARD JONES WAS CENSURED AND FINED$35,000.00.



Disclosure 22 of 73

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Allegations: FINRA RULE 2010, NASD RULES 2110, 3010(B) - A CUSTOMER'S ACCOUNTWAS THE SUBJECT OF HEIGHTENED SCRUTINY BY EDWARD JONES & CO.,L.P. BECAUSE, AMONG OTHER THINGS, THERE WAS INTERNATIONAL WIREACTIVITY IN THE ACCOUNT INVOLVING WIRES OVER A MILLION DOLLARSAND THE ACCOUNT BECAME SUBJECT TO A GRAND JURY SUBPOENA ANDAN INVESTIGATION BY LAW ENFORCEMENT. A BRANCH OFFICE ASSISTANTWAS STILL ABLE TO CONVERT $167,249 FROM THAT CUSTOMER'SACCOUNT BY USING FORGED LETTERS OF AUTHORIZATION (LOAS) TOEFFECT WIRE TRANSFERS OUT OF THE ACCOUNT WITHOUT PERMISSIONOR AUTHORITY. EXCEPT FOR TWO, THE IMPROPER TRANSFERS WEREEACH FOR LESS THAN $10,000 AND OCCURRED SEVERAL TIMES PERMONTH. THE FUNDS WERE WIRED TO AN OUTSIDE BANK ACCOUNTBELONGING TO THE ASSISTANT'S RELATIVE NOT ASSOCIATED WITH THECUSTOMER OR HIS ACCOUNTS. DESPITE THE HEIGHTENED SCRUTINY,INQUIRIES BY LAW ENFORCEMENT AND THE SIZE AND FREQUENCY OFTHE WIRE ACTIVITY TO A THIRD-PARTY ACCOUNT, THE FIRM FAILED TOPERFORM AN ADEQUATE REVIEW OF THE ACCOUNT ACTIVITY AND FAILEDTO RESPOND TO RED FLAGS THAT WOULD HAVE ALERTED IT TO THEMISCONDUCT. THE FIRM PROMPTLY REIMBURSED THE CUSTOMER FORTHE LOSSES.








Initiated By: FINRA






Other Product Type(s): WIRED FUNDS

FINRA RULE 2010, NASD RULES 2110, 3010(B) - A CUSTOMER'S ACCOUNTWAS THE SUBJECT OF HEIGHTENED SCRUTINY BY EDWARD JONES & CO.,L.P. BECAUSE, AMONG OTHER THINGS, THERE WAS INTERNATIONAL WIREACTIVITY IN THE ACCOUNT INVOLVING WIRES OVER A MILLION DOLLARSAND THE ACCOUNT BECAME SUBJECT TO A GRAND JURY SUBPOENA ANDAN INVESTIGATION BY LAW ENFORCEMENT. A BRANCH OFFICE ASSISTANTWAS STILL ABLE TO CONVERT $167,249 FROM THAT CUSTOMER'SACCOUNT BY USING FORGED LETTERS OF AUTHORIZATION (LOAS) TOEFFECT WIRE TRANSFERS OUT OF THE ACCOUNT WITHOUT PERMISSIONOR AUTHORITY. EXCEPT FOR TWO, THE IMPROPER TRANSFERS WEREEACH FOR LESS THAN $10,000 AND OCCURRED SEVERAL TIMES PERMONTH. THE FUNDS WERE WIRED TO AN OUTSIDE BANK ACCOUNTBELONGING TO THE ASSISTANT'S RELATIVE NOT ASSOCIATED WITH THECUSTOMER OR HIS ACCOUNTS. DESPITE THE HEIGHTENED SCRUTINY,INQUIRIES BY LAW ENFORCEMENT AND THE SIZE AND FREQUENCY OFTHE WIRE ACTIVITY TO A THIRD-PARTY ACCOUNT, THE FIRM FAILED TOPERFORM AN ADEQUATE REVIEW OF THE ACCOUNT ACTIVITY AND FAILEDTO RESPOND TO RED FLAGS THAT WOULD HAVE ALERTED IT TO THEMISCONDUCT. THE FIRM PROMPTLY REIMBURSED THE CUSTOMER FORTHE LOSSES.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $95,000. FINE PAID INFULL ON JULY 16, 2012.


No




Allegations: FINRA ALLEGES THAT EDWARD JONES VIOLATED NASD CONDUCT RULES2110 AND 3010(B) AND FINRA RULE 2010. FINRA ALLEGES THAT EDWARDJONES FAILED TO ADEQUATELY REVIEW A CUSTOMER ACCOUNT THATWAS UNDER HEIGHTENED SCRUTINY, AND FAILED TO RESPOND TO REDFLAGS THAT WOULD HAVE ALERTED IT TO THE ACTIVITIES OF ANASSOCIATE WHO CONVERTED MONEY FROM THE ACCOUNT. THEASSOCIATE WAS ABLE TO CONVERT $167,249 FROM THE CUSTOMER'SACCOUNT BY USING FORGED LETTERS OF AUTHORIZATION TO EFFECT 51WIRE TRANSFERS OUT OF THE ACCOUNT WITHOUT PERMISSION ORAUTHORITY.








Initiated By: FINRA


Censure


FINE




Other Product Type(s): WIRED FUNDS

FINRA ALLEGES THAT EDWARD JONES VIOLATED NASD CONDUCT RULES2110 AND 3010(B) AND FINRA RULE 2010. FINRA ALLEGES THAT EDWARDJONES FAILED TO ADEQUATELY REVIEW A CUSTOMER ACCOUNT THATWAS UNDER HEIGHTENED SCRUTINY, AND FAILED TO RESPOND TO REDFLAGS THAT WOULD HAVE ALERTED IT TO THE ACTIVITIES OF ANASSOCIATE WHO CONVERTED MONEY FROM THE ACCOUNT. THEASSOCIATE WAS ABLE TO CONVERT $167,249 FROM THE CUSTOMER'SACCOUNT BY USING FORGED LETTERS OF AUTHORIZATION TO EFFECT 51WIRE TRANSFERS OUT OF THE ACCOUNT WITHOUT PERMISSION ORAUTHORITY.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM WAS CENSURED AND FINED $95,000.



Disclosure 23 of 73

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

Allegations: IN JULY 2009, THE INDIANA SECRETARY OF STATE, SECURITIES DIVISION(THE "STATE") ALLEGED THAT EDWARD JONES FAILED TO SUPERVISE THEACTIVITIES OF A NOW DECEASED FINANCIAL ADVISOR. SPECIFICALLY,THE STATE ALLEGED THE FINANCIAL ADVISOR WAS ABLE TO CHANGE THEPRIMARY ACCOUNT HOLDER AND SOCIAL SECURITY NUMBER ON ANACCOUNT BY SUBMITTING A FORM TO THE HEADQUARTERS OFFICEWITHOUT THE REQUIRED NUMBER OF SIGNATURES, IN VIOLATION OFFIRM POLICY.








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





Docket/Case Number: 10-0504 CA


Other Product Type(s): SECURITIES


Resolution:


Sanction Details: ON MARCH 1, 2011, EDWARD JONES AND THE STATE ENTERED INTO ACONSENT AGREEMENT IN WHICH EDWARD JONES AGREED TO PAY THESTATE $10,000 TO RESOLVE THE MATTER, WITHOUT ANY ADMISSION OFFAULT OR WRONGDOING.


Consent

Disclosure 24 of 73

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Initiated By: MAINE OFFICE OF SECURITIES




Principal Product Type: CD(s)

Allegations: EDWARD JONES COMMITTED TWO FAILURES TO REASONABLY SUPERVISEWARREN SPENCER BY FAILING TO DETECT OR TAKE TIMELY ACTION TOADDRESS SPENCER'S CONFLICTING EXPLANATIONS REGARDING ACLIENT'S CD TRANSACTION AND BY FAILING TO DETECT OR ADEQUATELYINVESTIGATE SPENCER'S ROUTINE USE OF DISCRETION IN THE THEACCOUNTS OF TWO CLIENTS. FURTHER, EDWARD JONES DID NOTEXERCISE SUFFICIENT DILIGENCE IN CONFIRMING THE ACCURACY OF ITSREPRESENTATIONS TO THE MAINE OFFICE OF SECURITIES.













Resolution:

Other Sanctions Ordered: NONE.

Sanction Details: EDWARD JONES WAS FINED $10,000 FOR TWO FINDINGS OF FAILURE TOREASONABLY SUPERVISE ONE OF ITS AGENTS. THE FINE WAS PAID ON11/4/2010.


No


Order


Initiated By: MAINE OFFICE OF SECURITIES








Allegations: THE STATE OF MAINE OFFICE OF SECURITIES INVESTIGATED THEACTIONS OF A FORMER FINANCIAL ADVISOR FOR ALLEGEDLY EXERCISINGDISCRETION IN TWO CUSTOMER ACCOUNTS, AND INVESTIGATED EDWARDJONES TO DETERMINE WHETHER IT FAILED TO REASONABLY SUPERVISETHE FINANCIAL ADVISOR.









Resolution:


Sanction Details: EDWARD JONES AND THE OFFICE OF SECURITIES HAVE ENTERED INTO ACONSENT ORDER WHICH INCLUDES EDWARD JONES PAYING A $10,000FINE, AND WHICH STATES THAT EDWARD JONES FAILED TO REASONABLYSUPERVISE THE FINANCIAL ADVISOR BY FAILING TO DETECT OR TAKETIMELY ACTION REGARDING CONFLICTING INFORMATION PROVIDED BYTHE FINANCIAL ADVISOR, AND FAILED TO DETECT OR ADEQUATELYINVESTIGATE THE FINANCIAL ADVISOR'S USE OF DISCRETION IN TWOCLIENT ACCOUNTS AND TO CONFIRM THE ACCURACY OF ITSREPRESENTATIONS TO THE OFFICE OF SECURITIES.

Firm Statement THIS MATTER HAS BEEN RESOLVED AS SET FORTH ABOVE.


Order

Disclosure 25 of 73

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Initiated By: STATE OF MONTANA




Docket/Case Number: SEC-2010-32



Allegations: THE MONTANA SECURITIES DEPARTMENT INVESTIGATED THE ACTIONS OFA FORMER FINANCIAL ADVISOR FOR ALLEGEDLY MISAPPROPRIATINGCUSTOMER FUNDS.



Resolution: Consent







Sanction Details: EDWARD JONES TERMINATED THE FINANCIAL ADVISOR AND REPORTEDTHE MATTER TO THE MONTANA SECURITIES DEPARTMENT. EDWARDJONES AND THE MONTANA SECURITIES DEPARTMENT HAVE ENTEREDINTO A CONSENT AGREEMENT WHICH INCLUDES EDWARD JONES PAYINGA $100,000 FINE FOR A BOOKS AND RECORDS VIOLATION, PAYING SIXCUSTOMERS A TOTAL OF $349,464.92 IN RESTITUTION, STORING EXACTDUPLICATES OF CERTAIN TYPES OF IDENTIFIED NEGATIVE CONFIRMATIONLETTERS, AND UNDERTAKING A REVIEW OF ITS WRITTEN SUPERVISORYPROCEDURES WITH RESPECT TO THE EXECUTION OF BLANK LETTERS OFAUTHORIZATION.

Firm Statement THIS MATTER HAS BEEN RESOLVED AS SET FORTH ABOVE.

Sanctions Ordered: Monetary/Fine $100,000.00Disgorgement/Restitution

Disclosure 26 of 73

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Initiated By: MISSOURI SECURITIES DIVISION


Other


CONSENT


Docket/Case Number: AP-10-15


Principal Product Type: Annuity(ies) - Variable


Allegations: FAILURE TO RESONABLY SUPERVISION A MISSOURI-REGISTERED AGENTIN CONNECTION WITH THE UNSUITABLE SALE OF A VARIABLE ANNUITY TOA MISSOURI RESIDENT



Resolution:


No

Consent







Sanction Details: EDWARD JONES WTILL TENDER TO MISSOURI RESIDENT I'SBENEFICIARIES RESTITUTION IN THE AMOUNT OF $10,500. EDWARDJONES IS ORDERED TO PAY TO THE MISSOURI SECRETARY OF STATE'SINVESTOR EDUCATION AND PROTECTION FUND THE SUM OF $25,000.EDWARD JONES SHALL PAY $5,000 AS THE COST OF THIS INVESTIGATION.


No



Initiated By: MISSOURI SECURITIES DIVISION


Other


CONSENT



Principal Product Type: Annuity(ies) - Variable


Allegations: IN JULY 2009, THE MISSOURI SECURITIES DIVISION (THE "DIVISION")BEGAN AN INVESTIGATION REGARDING THE SALE OF A VARIABLE ANNUITYTO A CLIENT OF EDWARD JONES WHO IS NOW DECEASED. UPONCOMPLETING ITS INVESTIGATION, THE DIVISION ALLEGED EDWARDJONES FAILED TO REASONABLY SUPERVISE ITS FINANCIAL ADVISOR BYFAILING TO REASONABLY REVIEW THE DEATH BENEFIT OPTIONSAVAILABLE FOR THE VARIABLE ANNUITY.



Resolution:


Consent







Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, EDWARD JONESENTERED INTO A CONSENT ORDER WITH THE DIVISION AND AGREED TOPAY RESTITUTION OF $10,500 TO THE CLIENT'S BENEFICIARIES, $25,000 TOTHE STATE'S INVESTOR EDUCATION FUND, AND $5,000 AS THE COST OFTHE INVESTIGATION.


Disclosure 27 of 73

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Initiated By: FINRA




Other Product Type(s): CORPORATE FIXED INCOME TRANSACTIONS

Allegations: FINRA RULE 4560, NASD RULES 2110, 2320, 3010, 3360, MSRB RULES G-17,G-30(A) - EDWARD D. JONES & CO., L.P. IN CORPORATE FIXED INCOMETRANSACTIONS FOR OR WITH A CUSTOMER, FAILED TO USE REASONABLEDILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILEDTO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS. THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDNASD RULES CONCERNING BEST EXECUTION OF CORPORATE FIXEDINCOME TRANSACTIONS. THE FIRM PURCHASED MUNICIPAL SECURITIESFOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPALSECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATEPRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIRAND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANTFACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER ORMUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THESECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIESEXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTIONS, THEEXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THATTHE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER IS ENTITLEDTO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION.THE FIRM SUBMITTED INCORRECT SHORT INTEREST POSITION REPORTSTO NASD OR FINRA.










Other Product Type(s): CORPORATE FIXED INCOME TRANSACTIONS


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $55,000, OF WHICH $15,000IS FOR MSRB VIOLATIONS, AND ORDERED TO PAY $13,231.52, PLUSINTEREST IN RESTITUTION TO CUSTOMERS. A REGISTERED FIRMPRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THERESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTSUNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATER THAN 120DAYS AFTER ACCEPTANCE OF THIS AWC. ANY UNDISTRIBUTEDRESTITUTION AND INTEREST SHALL BE FORWARDED TO THEAPPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED. FINE PAID IN FULL ON MAY 1, 2012.


No




Allegations: FINRA RULE 4560, NASD RULES 2110, 2320, 3010, 3360, MSRB RULES G-17,G-30(A) - FINRA ALLEGED THAT:1. IN 31 CORPORATE FIXED INCOME TRANSACTIONS FOR OR WITH ACUSTOMER, EDWARD D. JONES & CO., L.P. FAILED TO USE REASONABLEDILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILEDTO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS.2. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULESCONCERNING BEST EXECUTION OF CORPORATE FIXED INCOMETRANSACTIONS.3. IN 10 TRANSACTIONS, THE FIRM PURCHASED MUNICIPAL SECURITIESFOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPALSECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATEPRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIRAND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANTFACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER ORMUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THESECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIESEXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTIONS, THEEXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THATTHE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER WAS ENTITLEDTO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION.4. THE FIRM SUBMITTED INACCURATE SHORT INTEREST POSITIONREPORTS TO NASD OR FINRA.







Initiated By: FINRA


Censure


FINE; RESTITUTION



Principal Product Type: Debt - Corporate

Other Product Type(s): DEBT - MUNICIPAL

FINRA RULE 4560, NASD RULES 2110, 2320, 3010, 3360, MSRB RULES G-17,G-30(A) - FINRA ALLEGED THAT:1. IN 31 CORPORATE FIXED INCOME TRANSACTIONS FOR OR WITH ACUSTOMER, EDWARD D. JONES & CO., L.P. FAILED TO USE REASONABLEDILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILEDTO BUY OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS.2. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULESCONCERNING BEST EXECUTION OF CORPORATE FIXED INCOMETRANSACTIONS.3. IN 10 TRANSACTIONS, THE FIRM PURCHASED MUNICIPAL SECURITIESFOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPALSECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATEPRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIRAND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANTFACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER ORMUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THESECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIESEXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTIONS, THEEXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THATTHE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER WAS ENTITLEDTO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION.4. THE FIRM SUBMITTED INACCURATE SHORT INTEREST POSITIONREPORTS TO NASD OR FINRA.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM WAS CENSURED, FINED $55,000, OF WHICH$15,000 WAS FOR MSRB VIOLATIONS, AND ORDERED TO PAY $13,231.52PLUS INTEREST IN RESTITUTION TO CUSTOMERS.









WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM WAS CENSURED, FINED $55,000, OF WHICH$15,000 WAS FOR MSRB VIOLATIONS, AND ORDERED TO PAY $13,231.52PLUS INTEREST IN RESTITUTION TO CUSTOMERS.

Disclosure 28 of 73

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Initiated By: FINRA


Other


N/A





Allegations: NASD RULES 2110, 3010(A), 3012(A)(2)(B)(I): THE FIRM FAILED TOESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM,INCLUDING WRITTEN SUPERVISORY PROCEDURES THAT WEREREASONABLY DESIGNED TO REVIEW AND MONITOR ALL TRANSMITTALSOF FUNDS FROM THE ACCOUNTS OF CUSTOMERS TO THIRD PARTYACCOUNTS. THE FIRM RELIED ON A DEFECTIVE REPORT, WHICH WEREINCOMPLETE AND INACCURATE, TO REVIEW AND MONITOR THIRD PARTYWIRES FROM CUSTOMER ACCOUNT, AND FAILED TO PROPERLY TEST ANDVERIFY THAT THE SYSTEM PROVIDING THE REPORT WAS FUNCTIONINGPROPERLY. AS A RESULT, THE REPORT FAILED TO IDENTIFY WIRES FROMACCOUNTS FROM WHICH A REGISTERED REPRESENTATIVE OF THE FIRMWAS CONVERTING FUNDS, AND THE REGISTERED REPRESENTATIVEULTIMATELY CONVERTED OVER $3 MILLION IN CUSTOMER FUNDS.



Resolution:


No










Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED AND FINED $200,000.



Initiated By: FINRA


Other


N/A





Allegations: FINRA ALLEGED EDWARD JONES VIOLATED NASD RULES 2110, 3010(A),3012(A)(2)(B)(I) BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE ASUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORYPROCEDURES THAT WERE REASONABLY DESIGNED TO REVIEW ANDMONITOR ALL TRANSMITTALS OF FUNDS FROM THE ACCOUNTS OFCUSTOMERS TO THIRD PARTY ACCOUNTS. EDWARD JONES ALLEGEDLYRELIED ON A DEFECTIVE REPORT, WHICH WAS INCOMPLETE ANDINACCURATE, TO REVIEW AND MONITOR THIRD PARTY WIRES FROMCUSTOMER ACCOUNTS, AND FAILED TO PROPERLY TEST AND VERIFY THESYTEM PROVIDING THE REPORT WAS FUNCTIONING PROPERLY. AS ARESULT, THE REPORT FAILED TO INDENTIFY WIRES FROM ACCOUNTSFROM WHICH A FORMER EDWARD JONES FINANCIAL ADVISOR WASCONVERTING FUNDS, AND THE FINANCIAL ADVISOR ULTIMATELYCONVERTED OVER $3 MILLION IN CUSTOMER FUNDS.



Resolution:











Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, EDWARD JONES WASCENSURED AND FINED $200,000.

Disclosure 29 of 73

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Initiated By: FINRA

Allegations: MSRB RULES G-8(A)(XIII), G-17, G-27, G-32 - EDWARD D. JONES & CO.,L.P.FAILED TO TIMELY DELIVER OFFICIAL STATEMENTS FOR A SIGNIFICANTPORTION OF THE NEW ISSUE MUNICIPAL BONDS IT SOLD TO CUSTOMERSWHEN IT WAS NOT AN UNDERWRITER OR A MEMBER OF THE SYNDICATE.OFFICIAL STATEMENTS FOR MANY OF THE TRANSACTIONS HAD NOT BEENMAILED AT LEAST FOUR MONTHS AFTER SETTLEMENT DATE. THE FIRM'SSYSTEMIC LATE DELIVERIES HAD MULTIPLE CAUSES BUT THE FIRMFAILED TO HAVE ADEQUATE PROCEDURES ADDRESSING THE DELIVERYOF OFFICIAL STATEMENTS AND SHOULD HAVE BEEN ON NOTICE THAT ITSFAILURE TO TIMELY OBTAIN OFFICIAL STATEMENTS FROM SYNDICATEMEMBERS RESULTED IN DELIVERIES BEING DELAYED FOR SEVERALWEEKS BEYOND SETTLEMENT DATE. THE FIRM FAILED TO TAKESUFFICIENT STEPS TO SOLVE A PRINTING BACKLOG PROBLEM ANDRELEVANT EMPLOYEES WERE NOT INFORMED THAT OFFICIALSTATEMENTS WERE REQUIRED TO BE DELIVERED NO LATER THANSETTLEMENT DATE. MAIL ROOM EMPLOYEES WERE GIVEN INCORRECTINFORMATION ABOUT THE TIMING OF DELIVERY. A MEMORANDUMEXPRESSING MAIL SERVICES GOAL TO MAIL OFFICIAL STATEMENTSWITHIN A CERTAIN TIME AFTER SETTLEMENT DATE WAS SENT TO THECOMPLIANCE OFFICER AND OTHERS WHO FAILED TO NOTICE THAT THEPOLICY WAS INCONSISTENT WITH MSRB RULE G-32. THE FIRM DID NOTUPDATE ITS PROCEDURES AND FIRM TRADING DESK EMPLOYEES FAILED,ON SOME OCCASIONS, TO TIMELY REQUEST OFFICIAL STATEMENTS FROMISSUERS, UNDERWRITERS OR OTHER SOURCES. THE FIRM AMENDED ITSWRITTEN SUPERVISORY PROCEDURES IN 2006 REGARDING MSRB RULEG-32 BUT DID NOT INDICATE WHEN STATEMENTS WERE TO BE DELIVEREDTO CUSTOMERS. THE FIRM FAILED TO KEEP RECORDS OF ALL DELIVERIESTO PURCHASERS OF NEW ISSUE MUNICIPAL SECURITIES AND A RECORDOF ALL DELIVERIES OF OFFICIAL STATEMENTS REQUIRED UNDER MSRBRULE G-32. THE FIRM HAD NO WRITTEN SUPERVISORY PROCEDURESADDRESSING THE OFFICIAL STATEMENT DELIVERY REQUIREMENTS OFMSRB RULE G-32 AND RECORDKEEPING REQUIREMENTS OF RULE G-8.WHEN THE FIRM UPDATED ITS PROCEDURES, IT PROVIDED INCORRECTOR SUFFICIENT GUIDANCE.














Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $900,000 AND REQUIREDWITHIN 60 DAYS OF NOTICE OF ACCEPTANCE OF THIS AWC TO ADOPT ANDIMPLEMENT SYSTEMS AND PROCEDURES REASONABLY DESIGNED TOENSURE COMPLIANCE WITH MSRB RULES G-32 AND G-8, INCLUDINGSYSTEMS AND PROCEDURES TO PROVIDE ADEQUATE OVERSIGHT IFTHIRD PARTY VENDORS ARE UTILIZED; AND PROVIDE CERTIFICATION BYTHE PRINCIPAL FOR OPERATIONS THAT THE FIRM HAS ADOPTED ANDIMPLEMENTED SUPERVISORY SYSTEMS AND PROCEDURES TO ENSURECOMPLIANCE WITH MSRB RULE G-32 AND G-8.


No




Allegations: FINRA ALLEGED EDWARD JONES VIOLATED MSRB RULE G-32 BY FAILINGTO TIMELY DELIVER OFFICIAL STATEMENTS TO CERTAIN CUSTOMERS INVARIOUS TRANSACTIONS WHEN EDWARD JONES WAS NOT ANUNDERWRITER OR MEMBER OF THE SYNDICATE. FINRA ALLEGEDEDWARD JONES VIOLATED MSRB RULES G-8, G-27, AND G-17 IN REGARDSTO CERTAIN RECORD KEEPING REQUIREMENTS.








Initiated By: FINRA


Censure


MONETARY FINE.





FINRA ALLEGED EDWARD JONES VIOLATED MSRB RULE G-32 BY FAILINGTO TIMELY DELIVER OFFICIAL STATEMENTS TO CERTAIN CUSTOMERS INVARIOUS TRANSACTIONS WHEN EDWARD JONES WAS NOT ANUNDERWRITER OR MEMBER OF THE SYNDICATE. FINRA ALLEGEDEDWARD JONES VIOLATED MSRB RULES G-8, G-27, AND G-17 IN REGARDSTO CERTAIN RECORD KEEPING REQUIREMENTS.


Resolution:

Other Sanctions Ordered: UNDERTAKING.

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, EDWARD JONESCONSENTED TO THE DESCRIBED SANCTIONS AND ENTRY OF FINDINGSAND WAS CENSURED AND FINED $900,000.

Firm Statement EDWARD JONES IS ALSO REQUIRED WITHIN 60 DAYS OF NOTICE OFACCEPTANCE OF THIS AWC TO ADOPT AND IMPLEMENT SYSTEMS ANDPROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITHMSRB RULES G-32 AND G-8, INCLUDING SYSTEMS AND PROCEDURES TOPROVIDE ADEQUATE OVERSIGHT IF THIRD PARTY VENDORS AREUTILIZED, AND PROVIDE CERTIFICATION BY THE PRINCIPAL OFOPERATIONS THAT EDWARD JONES HAS ADOPTED AND IMPLEMENTEDSUPERVISORY SYSTEMS AND PROCEDURES TO ENSURE COMPLIANCEWITH MSRB RULES G-32 AND G-8.



Disclosure 30 of 73

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Allegations: IT IS ALLEGED THAT THE FIRM VIOLATED SECTION 13.1-502(3) OF THEVIRGINIA SECURITIES ACT, SECTION 13.1-501 ET. SEQ. OF THE CODE OFVIRGINIA, BY ENGAGING IN A TRANSACTION, PRACTICE OF COURSE OFBUSINESS WHICH OPERATES AS A FRAUD OR DECEIT UPON APURCHASER; VIOLATED SECURITIES RULE 21 VAC 5-20-240 BY FAILING TOMAKE AND KEEP TRUE, ACCURATE AND CURRENT, AND PRESERVE THEBOOKS AND RECORDS RELATING TO ITS BUSINESS, AS DESCRIBED INSEC RULE 17A-4(B); VIOLATED SECURITIES RULE 21 VAC 5-20-260 B BYFAILING TO EXERCISE DILIGENT SUPERVISION OVER THE ACTIVITIES OFAN AGENT; VIOLATED SECURITIES RULE 21 VAC 5-20-260 D BY FAILING TOESTABLISH, MAINTAIN AND ENFORCE WRITTEN PROCEDURES, WHICH SETFORTH PROCEDURES ADOPTED BY A BROKER-DEALER; VIOLATEDSECURITIES RULE 21 VAC 5-20-260 D(2) BY FAILING TO PERFORMFREQUENT EXAMINATIONS OF ALL CUSTOMER ACCOUNTS TO DETECTAND PREVENT IRREGULARITIES OR ABUSES; AND VIOLATED SECURITIESRULE 21 VAC 5-20-260 D(4) BY FAILING TO REVIEW AND RECEIVE WRITTENAPPROVAL BY THE DESIGNATED SUPERVISOR OF THE DELEGATION BYANY CUSTOMER OF DISCRETIONARY AUTHORITY WITH RESPECT TO THECUSTOMER'S ACCOUNT TO THE BROKER-DEALER OR TO A STATED AGENTOR AGENTS OF THE BROKER-DEALER AND THE PROMPT WRITTENAPPROVAL OR EACH DISCRETIONARY ORDER ENTERED ON BEHALF OFTHE ACCOUNT.








Initiated By: VIRGINIA - DIVISION OF SECURITIES


Restitution





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

Other Product Type(s): MUTUAL FUNDS

IT IS ALLEGED THAT THE FIRM VIOLATED SECTION 13.1-502(3) OF THEVIRGINIA SECURITIES ACT, SECTION 13.1-501 ET. SEQ. OF THE CODE OFVIRGINIA, BY ENGAGING IN A TRANSACTION, PRACTICE OF COURSE OFBUSINESS WHICH OPERATES AS A FRAUD OR DECEIT UPON APURCHASER; VIOLATED SECURITIES RULE 21 VAC 5-20-240 BY FAILING TOMAKE AND KEEP TRUE, ACCURATE AND CURRENT, AND PRESERVE THEBOOKS AND RECORDS RELATING TO ITS BUSINESS, AS DESCRIBED INSEC RULE 17A-4(B); VIOLATED SECURITIES RULE 21 VAC 5-20-260 B BYFAILING TO EXERCISE DILIGENT SUPERVISION OVER THE ACTIVITIES OFAN AGENT; VIOLATED SECURITIES RULE 21 VAC 5-20-260 D BY FAILING TOESTABLISH, MAINTAIN AND ENFORCE WRITTEN PROCEDURES, WHICH SETFORTH PROCEDURES ADOPTED BY A BROKER-DEALER; VIOLATEDSECURITIES RULE 21 VAC 5-20-260 D(2) BY FAILING TO PERFORMFREQUENT EXAMINATIONS OF ALL CUSTOMER ACCOUNTS TO DETECTAND PREVENT IRREGULARITIES OR ABUSES; AND VIOLATED SECURITIESRULE 21 VAC 5-20-260 D(4) BY FAILING TO REVIEW AND RECEIVE WRITTENAPPROVAL BY THE DESIGNATED SUPERVISOR OF THE DELEGATION BYANY CUSTOMER OF DISCRETIONARY AUTHORITY WITH RESPECT TO THECUSTOMER'S ACCOUNT TO THE BROKER-DEALER OR TO A STATED AGENTOR AGENTS OF THE BROKER-DEALER AND THE PROMPT WRITTENAPPROVAL OR EACH DISCRETIONARY ORDER ENTERED ON BEHALF OFTHE ACCOUNT.


Resolution:


Sanction Details: THE FIRM WAS TO PAY 50% OF THE EQUITY LOSSES INCURRED BY FOURVIRGINIA INVESTORS IDENTIFIED BY THE DIVISION. THE INVESTORS WERENOT REQUIRED TO DEMONSTRATE THAT THEIR INVESTMENTS WITHINTHEIR ACCOUNTS WERE UNSUITABLE, UNAUTHORIZED, OR THAT THEIRCLAIMS ARE NOT TIME-BARRED BUT WOULD BE REQUIRED TO EXECUTEAN APPROPRIATE LEASE. INVESTORS WITH WHOM THE FIRM HASPREVIOUSLY SETTLED ON THESE ISSUES WERE EXCLUDED FROMREPAYMENT UNDER THIS SETTLEMENT. THE FIRM OFFERED TO VIRGINIAINVESTORS IDENTIFIED TO THE DIVISION AND WHO HAD A MARGIN LOANBETWEEN JANUARY 1, 1998 AND JUNE 30, 2001, A REBATE OF 65% OF THEMARGIN INTEREST THAT THE VIRGINIA INVESTORS PAID. THE INVESTORSTHAT THE FIRM LOCATED WERE NOT REQUIRED TO DEMONSTRATE THEPURPOSE OF ANY MARGIN LOAN OR LOANS IN THEIR ACCOUNTS,ACKNOWLEDGE THAT THEY DID NOT UNDERSTAND THE NATURE ORPURPOSE OF ANY MARGIN LOAN, OR PROVE THAT THEIR CLAIMS ARE NOTTIME-BARRED BUT WOULD BE REQUIRED TO EXECUTE AN APPROPRIATERELEASE. INVESTORS WITH WHOM THE FIRM HAS PREVIOUSLY SETTLEDON THESE ISSUES WERE EXCLUDED FROM REPAYMENT UNDER THISSETTLEMENT.


No

Sanctions Ordered: Disgorgement/Restitution

Settled






Sanction Details: THE FIRM WAS TO PAY 50% OF THE EQUITY LOSSES INCURRED BY FOURVIRGINIA INVESTORS IDENTIFIED BY THE DIVISION. THE INVESTORS WERENOT REQUIRED TO DEMONSTRATE THAT THEIR INVESTMENTS WITHINTHEIR ACCOUNTS WERE UNSUITABLE, UNAUTHORIZED, OR THAT THEIRCLAIMS ARE NOT TIME-BARRED BUT WOULD BE REQUIRED TO EXECUTEAN APPROPRIATE LEASE. INVESTORS WITH WHOM THE FIRM HASPREVIOUSLY SETTLED ON THESE ISSUES WERE EXCLUDED FROMREPAYMENT UNDER THIS SETTLEMENT. THE FIRM OFFERED TO VIRGINIAINVESTORS IDENTIFIED TO THE DIVISION AND WHO HAD A MARGIN LOANBETWEEN JANUARY 1, 1998 AND JUNE 30, 2001, A REBATE OF 65% OF THEMARGIN INTEREST THAT THE VIRGINIA INVESTORS PAID. THE INVESTORSTHAT THE FIRM LOCATED WERE NOT REQUIRED TO DEMONSTRATE THEPURPOSE OF ANY MARGIN LOAN OR LOANS IN THEIR ACCOUNTS,ACKNOWLEDGE THAT THEY DID NOT UNDERSTAND THE NATURE ORPURPOSE OF ANY MARGIN LOAN, OR PROVE THAT THEIR CLAIMS ARE NOTTIME-BARRED BUT WOULD BE REQUIRED TO EXECUTE AN APPROPRIATERELEASE. INVESTORS WITH WHOM THE FIRM HAS PREVIOUSLY SETTLEDON THESE ISSUES WERE EXCLUDED FROM REPAYMENT UNDER THISSETTLEMENT.

Regulator Statement CONTACT GLORIA A. PULKOWSKI AT 804-371-9566 FOR FURTHERINFORMATION.


Allegations: IN APRIL 2002 THE VIRGINIA STATE CORPORATION COMMISSION, DIVISIONOF SECURITIES AND RETAIL FRANCHISING (THE "DIVISION") COMMENCEDAN INVESTIGATION INTO EDWARD JONES BASED ON ACTIONS OF AFORMER FINANCIAL ADVISOR AND HIS RECOMMENDATION FOR USE OFMARGIN DATING BACK TO 1998. AFTER INVESTIGATING THE MATTER, THEDIVISION ALLEGED THAT EDWARD JONES CONDUCTED ACTIVITY THATCONSTITUTED A VIOLATION OF THE VIRGINIA SECURITIES ACT ANDPROVISIONS OF THE CODE OF VIRGINIA: (I) BY ENGAGING IN ATRANSACTION, PRACTICE OR COURSE OF BUSINESS WHICH OPERATESAS A FRAUD OR DECEIT UPON A PURCHASER; (II) BY FAILING TO MAKEAND KEEP TRUE, ACCURATE AND CURRENT, AND PRESERVE THE BOOKSAND RECORDS RELATING TO ITS BUSINESS; (III) BY FAILING TOESTABLISH, MAINTAIN AND ENFORCE WRITTEN PROCEDURES; (IV) BYFAILING TO PERFORM FREQUENT EXAMINATIONS OF ALL CUSTOMERACCOUNTS TO DETECT AND PREVENT IRREGULARITIES OR ABUSES; AND(V) BY FAILING TO REVIEW AND RECEIVE WRITTEN APPROVAL BY THEDESIGNATED SUPERVISOR OF THE DELEGATION BY ANY CUSTOMER OFDISCRETIONARY AUTHORITY WITH RESPECT TO THE CUSTOMER'SACCOUNT.







Initiated By: VIRGINIA - DIVISION OF SECURITIES


Restitution






IN APRIL 2002 THE VIRGINIA STATE CORPORATION COMMISSION, DIVISIONOF SECURITIES AND RETAIL FRANCHISING (THE "DIVISION") COMMENCEDAN INVESTIGATION INTO EDWARD JONES BASED ON ACTIONS OF AFORMER FINANCIAL ADVISOR AND HIS RECOMMENDATION FOR USE OFMARGIN DATING BACK TO 1998. AFTER INVESTIGATING THE MATTER, THEDIVISION ALLEGED THAT EDWARD JONES CONDUCTED ACTIVITY THATCONSTITUTED A VIOLATION OF THE VIRGINIA SECURITIES ACT ANDPROVISIONS OF THE CODE OF VIRGINIA: (I) BY ENGAGING IN ATRANSACTION, PRACTICE OR COURSE OF BUSINESS WHICH OPERATESAS A FRAUD OR DECEIT UPON A PURCHASER; (II) BY FAILING TO MAKEAND KEEP TRUE, ACCURATE AND CURRENT, AND PRESERVE THE BOOKSAND RECORDS RELATING TO ITS BUSINESS; (III) BY FAILING TOESTABLISH, MAINTAIN AND ENFORCE WRITTEN PROCEDURES; (IV) BYFAILING TO PERFORM FREQUENT EXAMINATIONS OF ALL CUSTOMERACCOUNTS TO DETECT AND PREVENT IRREGULARITIES OR ABUSES; AND(V) BY FAILING TO REVIEW AND RECEIVE WRITTEN APPROVAL BY THEDESIGNATED SUPERVISOR OF THE DELEGATION BY ANY CUSTOMER OFDISCRETIONARY AUTHORITY WITH RESPECT TO THE CUSTOMER'SACCOUNT.


Resolution:


Sanction Details: EDWARD JONES WILL OFFER TO PAY 50% OF THE EQUITY LOSSESINCURRED BY FOUR VIRGINIA INVESTORS IDENTIFIED BY THE DIVISION.EDWARD JONES WILL OFFER A REBATE OF 65% OF THE MARGIN INTERESTPAID BY THE VIRGINIA INVESTORS IDENTIFIED TO THE DIVISION AND WHOHAD A MARGIN LOAN BETWEEN JANUARY 1, 1998 AND JUNE 30, 2001.


Settled

Disclosure 31 of 73

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Initiated By: FINRA





Other Product Type(s): TRACE-ELIGIBLE SECURITIES

Allegations: NASD RULE 6230(A) - EDWARD D. JONES & CO., L.P. FAILED TO REPORT TOTHE TRADE REPORTING AND COMPLIANCE ENGINE(TRACE)TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15MINUTES OF THE TIME OF EXECUTION.











Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $10,000.


No




Initiated By: FINRA


Censure


MONETARY FINE OF $10,000.




Other Product Type(s): TRACE-ELIGIBLE SECURITIES

Allegations: NASD RULE 6230(A) - EDWARD D. JONES & CO., L.P. FAILED TO REPORT TOTHE TRADE REPORTING AND COMPLIANCE ENGINE(TRACE)TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15MINUTES OF THE TIME OF EXECUTION.


Resolution: Acceptance, Waiver & Consent(AWC)90©2020 FINRA. All rights reserved. Report about EDWARD JONES







Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $10,000.



Disclosure 32 of 73

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Initiated By: NASD


Docket/Case Number: EAF0401100001


Allegations: NASD RULES 2110 AND 3010 - FROM JANUARY 1, 2002 THROUGHDECEMBER 31, 2004, EDWARD JONES FAILED TO PROVIDE CERTAININVESTORS THE OPPORTUNITY TO PURCHASE CLASS A SHARES OFCERTAIN MUTUAL FUNDS AT NET ASSET VALUE (NAV). CERTAIN MUTUALFUNDS OFFERED NAV TRANSFER PROGRAMS THAT ALLOWED INVESTORSTO PURCHASE CLASS A SHARES AT NAV AND NOT PAY ANY SALESCHARGES, IF THE CUSTOMER INVESTED PROCEEDS FROM THEREDEMPTION OF SHARES OF ANOTHER MUTUAL FUND WITHIN SPECIFIEDTIME FRAMES AND PREVIOUSLY HAD PAID EITHER A FRONT-END OR BACK-END SALES CHARGE. THE FIRM FAILED TO EXERCISE REASONABLE DUEDILIGENCE TO IDENTIFY THE ESSENTIAL TERMS AND CONDITIONS OF THENAV TRANSFER PROGRAMS OF CERTAIN MUTUAL FUNDS. THE FIRMFAILED TO ENSURE, AND FAILED TO ESTABLISH, MAINTAIN AND ENFORCEA SYSTEM AND PROCEDURES TO ENSURE, THAT ITS CUSTOMERSRECEIVED NAV PRICING WHEN APPROPRIATE. AS A RESULT, INVESTORSWHO WERE ELIGIBLE TO PURCHASE CLASS A SHARES UNDER NAVTRANSFER PROGRAMS (1) PURCHASED CLASS A SHARES AND INCURREDFRONT-END SALES CHARGES THAT THEY SHOULD NOT HAVE PAID,AND/OR (2) PURCHASED OTHER SHARE CLASSES OF THESE MUTUALFUNDS AND THEREBY BECAME SUBJECT TO BACK-END SALES CHARGES,ALSO KNOWN AS CONTINGENT DEFERRED SALES CHARGES AS WELL ASHIGHER ONGOING DISTRIBUTION AND SERVICE FEES, TYPICALLYASSOCIATED WITH SHARE CLASSES OTHER THAN CLASS A.






https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=EAF0401100001







Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE THE FIRM IS CENSURED, FINED $250,000 AND REQUIRED TOCOMPLY WITH THE FOLLOWING UNDERTAKINGS: THE FIRM WILL PROVIDEREMEDIATION TO CLIENTS WHO PURCHASED SHARES OF MUTUAL FUNDSDURING THE PERIOD JANUARY 1, 2002 THROUGH THE NOTICE OFACCEPTANCE OF THIS AWC, AND QUALIFIED FOR, BUT DID NOT RECEIVE,THE BENEFIT OF NAV TRANSFER PROGRAMS. THE FIRM WILL PROVIDEREMEDIATION IN ACCORDANCE WITH A METHODOLOGY NOTUNACCEPTABLE TO NASD. WITHIN 60 DAYS FROM THE NOTICE OFACCEPTANCE OF THIS AWC, THE FIRM SHALL RETAIN A THIRD PARTYEXAMINER, NOT UNACCEPTABLE TO NASD, TO ASSESS THE FIRM'SREMEDIATION AND PROVIDE A REPORT TO NASD. WITHIN 60 DAYS FROMTHE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALL SUBMIT TONASD FOR REVIEW A SAMPLE LETTER NOTIFYING CLIENTS OFREMEDIATION PAYMENTS. WITHIN 60 DAYS FROM THE NOTICE OFACCEPTANCE OF THIS AWC, THE FIRM WILL DESIGNATE AND TRAIN STAFFTO FIELD AND RESPOND TO CLIENT INQUIRIES IN CONNECTION WITH THISREMEDIATION PROCESS; WITHIN 210 DAYS FROM THE NOTICE OFACCEPTANCE OF THIS AWC, THE FIRM SHALL COMPLETE THEREMEDIATION PROCESS; WITHIN 240 DAYS FROM THE NOTICE OFACCEPTANCE OF THIS AWC, THE FIRM SHALL FILE A REPORT WITH NASD,AND SIMULTANEOUSLY PROVIDE A COPY TO THE THIRD PARTY EXAMINER,CERTIFIED TO, AND SIGNED BY, AN OFFICER OF THE FIRM WHO ISREGISTERED WITH NASD AT THE TIME OF CERTIFICATION. THE THIRDPARTY EXAMINER WILL UTILIZE HE REMEDIATION METHODOLOGY TOASSESS THE FIRM'S REMEDIATION PROCESS. NOT LATER THAN 300 DAYSAFTER THE DATE OF NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRMSHALL REQUIRE THE THIRD PARTY EXAMINER TO SUBMIT A FINAL REPORTTO THE FIRM AND TO NASD.


No








WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE THE FIRM IS CENSURED, FINED $250,000 AND REQUIRED TOCOMPLY WITH THE FOLLOWING UNDERTAKINGS: THE FIRM WILL PROVIDEREMEDIATION TO CLIENTS WHO PURCHASED SHARES OF MUTUAL FUNDSDURING THE PERIOD JANUARY 1, 2002 THROUGH THE NOTICE OFACCEPTANCE OF THIS AWC, AND QUALIFIED FOR, BUT DID NOT RECEIVE,THE BENEFIT OF NAV TRANSFER PROGRAMS. THE FIRM WILL PROVIDEREMEDIATION IN ACCORDANCE WITH A METHODOLOGY NOTUNACCEPTABLE TO NASD. WITHIN 60 DAYS FROM THE NOTICE OFACCEPTANCE OF THIS AWC, THE FIRM SHALL RETAIN A THIRD PARTYEXAMINER, NOT UNACCEPTABLE TO NASD, TO ASSESS THE FIRM'SREMEDIATION AND PROVIDE A REPORT TO NASD. WITHIN 60 DAYS FROMTHE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALL SUBMIT TONASD FOR REVIEW A SAMPLE LETTER NOTIFYING CLIENTS OFREMEDIATION PAYMENTS. WITHIN 60 DAYS FROM THE NOTICE OFACCEPTANCE OF THIS AWC, THE FIRM WILL DESIGNATE AND TRAIN STAFFTO FIELD AND RESPOND TO CLIENT INQUIRIES IN CONNECTION WITH THISREMEDIATION PROCESS; WITHIN 210 DAYS FROM THE NOTICE OFACCEPTANCE OF THIS AWC, THE FIRM SHALL COMPLETE THEREMEDIATION PROCESS; WITHIN 240 DAYS FROM THE NOTICE OFACCEPTANCE OF THIS AWC, THE FIRM SHALL FILE A REPORT WITH NASD,AND SIMULTANEOUSLY PROVIDE A COPY TO THE THIRD PARTY EXAMINER,CERTIFIED TO, AND SIGNED BY, AN OFFICER OF THE FIRM WHO ISREGISTERED WITH NASD AT THE TIME OF CERTIFICATION. THE THIRDPARTY EXAMINER WILL UTILIZE HE REMEDIATION METHODOLOGY TOASSESS THE FIRM'S REMEDIATION PROCESS. NOT LATER THAN 300 DAYSAFTER THE DATE OF NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRMSHALL REQUIRE THE THIRD PARTY EXAMINER TO SUBMIT A FINAL REPORTTO THE FIRM AND TO NASD.


Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.


Censure


Docket/Case Number: EAF0401100001



Allegations: PURSUANT TO NASD RULE 9216, EDWARD D. JONES & CO., L.P. ("EDWARDJONES"), ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER ANDCONSENT ("AWC") WHEREBY IT AGREED, WITHOUT ADMITTING ORDENYING THE FINDINGS OF THE NASD, TO THE ENTRY OF CERTAINFINDINGS AND SANCTIONS IN CONNECTION WITH ITS HANDLING OF NETASSET VALUE ("NAV") TRANSFER PROGRAMS OFFERED BY CERTAINMUTUAL FUNDS DURING THE PERIOD JANUARY 1, 2002, THROUGHDECEMBER 31, 2004. DURING THIS PERIOD, THE PROSPECTUSES OFSEVERAL MUTUAL FUND COMPANIES PROVIDED THAT UNDER CERTAINCIRCUMSTANCES INVESTORS WERE ELIGIBLE TO PURCHASE SHARES ATNET ASSET VALUE (I.E., WITHOUT ANY DEDUCTION FOR A SALES LOAD) IFTHEY WERE MAKING THE PURCHASE WITH PROCEEDS FROM THEREDEMPTION OF THE SHARES OF ANOTHER FUND FAMILY AND THATREDEMPTION HAD TAKEN PLACE WITHIN A SPECIFIED PERIOD OF TIME OFTHE PURCHASE, E.G., 30 OR 60 OR 90 DAYS. THE NASD ALLEGED THATEDWARD JONES FAILED TO PROVIDE ALL INVESTORS THE OPPORTUNITYTO PURCHASE CLASS A SHARES OF CERTAIN MUTUAL FUNDS AT NETASSET VALUE PURSUANT TO THE TERMS OF THEIR NAV TRANSFERPROGRAMS. THE NASD FURTHER ALLEGED THAT EDWARD JONES FAILEDTO EXERCISE REASONABLE DUE DILIGENCE TO IDENTIFY THE ESSENTIALTERMS AND CONDITIONS OF ALL NAV TRANSFER PROGRAMS OFFERED BYTHE MUTUAL FUNDS THAT IT SOLD AND FAILED TO ESTABLISH, MAINTAIN,AND ENFORCE A SYSTEM AND PROCEDURES TO ENSURE THAT ALL OF ITSCUSTOMERS RECEIVED NET ASSET VALUE PRICING WHEN APPROPRIATE.






https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=EAF0401100001



MONETARY FINE OF $250,000.00


Resolution:


Sanction Details: EDWARD JONES WAS CENSURED; FINED $250,000; AND AGREED TOPROVIDE REMEDIATION PAYMENTS TO INVESTORS IN AN AMOUNT TO BEDETERMINED BUT ESTIMATED TO BE APPROXIMATELY $25,000,000. SUCHREMEDIATION INCLUDED, IN APPROPRIATE CASES, 1) A REFUND OFAMOUNTS PAID AS A SALES CHARGE, 2) A CASH PAYMENT EQUAL TO ANAMOUNT NECESSARY TO PLACE THE CLIENT IN A FINANCIAL POSITIONEQUIVALENT TO WHAT HE OR SHE WOULD HAVE BEEN IN IF THERELEVANT TRANSACTIONS HAD TAKEN PLACE AT NET ASSET VALUE, AND3) INTEREST ON THOSE AMOUNTS.

Firm Statement SEE 12C.



Disclosure 33 of 73

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Initiated By: STATE OF MAINE OFFICE OF SECURITIES





Docket/Case Number: 05-053-CAG



Allegations: THE OFFICE OF SECURITIES ALLEGED THAT EDWARD JONES VIOLATEDTHE REVISED MAINE SECURITIES ACT SECTIONS 10201 AND 10313(1)(G),32M.R.S.A. PARAGRAPH 10101-10713, WHEN IT FAILED TO DISCLOSE TO ITSMAINE CLIENTS THAT IT RECEIVED REVENUE SHARING PAYMENTS FROMTHE SALE OF PREFERRED MUTUAL FUNDS.








Resolution:


Sanction Details: EDWARD JONES NEITHER ADMITTED NOR DENIED THAT IT VIOLATED THEREVISED MAINE SECURITIES ACT, SECTIONS 10201, 10313(1)(G). EDWARDJONES IS ENTERING INTO THIS CONSENT AGREEMENT FOR THE SOLEPURPOSE OF RESOLVING THIS MATTER.


Consent

Disclosure 34 of 73

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Initiated By: KANSAS SECURITIES COMMISSIONER


Restitution


CONSENT ORDER


Docket/Case Number: 06E018/KSC 2004-4808



Other Product Type(s): IRA

Allegations: FAILURE TO FOLLOW OFFICE PROCEDURES; FAILURE TO SUPERVISE.



Resolution:

Other Sanctions Ordered: THE FIRM MADE A $2,500 PAYMENT TO THE INVESTOR EDUCATION FUNDADMINISTERED BY THE OFFICE OF THE KANSAS SECURITIESCOMMISSIONER.


No


Consent






THE FIRM MADE A $2,500 PAYMENT TO THE INVESTOR EDUCATION FUNDADMINISTERED BY THE OFFICE OF THE KANSAS SECURITIESCOMMISSIONER.

Sanction Details: THE FIRM PAID $7,500 IN RESTITUTION TO THE FORMER CLIENT.

Regulator Statement LIEF NELSON, A REGISTERED REPRESENTATIVE FOR THE FIRM,PROCESSED THE TRANSFER OF MONEY FROM A CLIENT'S INDIVIDUAL IRAACCOUNT, BASED UPON THE IMPROPER REPRESENTATIONS OF THECLIENT'S HUSBAND, WITHOUT VERIFYING THE REQUEST WITH THECLIENT. THE MONEY WAS TRANSFERRED TO AN ACCOUNT AT ANOTHERFINANCIAL INSTITUTION, OF WHICH THE CLIENT HAD NO KNOWLEDGE ORCONTROL. THE FIRM FAILED TO PROPERLY SUPERVISE MR. NELSON ANDHIS OFFICE PROCEDURES.


Initiated By: OFFICE OF SECURITIES COMMISSIONER FOR THE STATE OF KANSAS


Restitution


MONETARY


Docket/Case Number: DOCKET NO. 06E018



Allegations: ALLEGATIONS: EDWARD JONES FAILED TO SUPERVISE INVESTMENTREPRESENTATIVE, LIEF E. NELSON CRD NO. 1335900, IN THEDISBURSEMENT OF CLIENT FUNDS FROM AN IRA ACCOUNT.



Resolution:


Sanction Details: EDWARD JONES NEITHER ADMITS NOR DENIES THE ALLEGATIONS BUTAGREES TO PAY RESTITUTION TO THE CLIENT OF $7,500.00. EDWARDJONES ALSO AGREES TO MAKE A PAYMENT TO THE INVESTOR EDUCATIONFUND PURSUANT TO K.S.A. 17-1271(D) AND L. 2004, CH. 154, 40(D), THEAMOUNT OF $2,500.00


Consent






Disclosure 35 of 73

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Initiated By: NASD




Docket/Case Number: E3B2004011101



Allegations: MSRB RULE G-15(A)(I)(A)(5) AND G-27(C); FAILURE TO DISCLOSE YIELD TOMATURITY ON TRANSACTION CONFIRMATIONS ISSUED TO CUSTOMERSWHO SOLD MUNICIPAL SECURITIES.EDWARD JONES INCLUDED YIELD INFORMATION IN CONFIRMATIONSISSUED TO CUSTOMERS WHEN THEY PURCHASED MUNICIPALSECURITIES, BUT BECAUSE OF A CHANGE IN IT'S AUTOMATED SYSTEMS,THAT INFORMATION WAS OMITTED FROM THE CONFIRMATIONS ISSUEDTO CUSTOMERS WHO SOLD MUNICIPAL BONDS.EDWARD JONES' SUPERVISORY SYSTEM AND ITS WRITTEN SUPERVISORYPROCEDURES WERE NOT ADEQUATE TO ENSURE THAT CONFIRMATIONSISSUED TO ITS CUSTOMERS IN MUNICIPAL SECURITIES TRANSACTIONSDISCLOSED THE INFORMATION REQUIRED BY THE MSRB RULE.



Resolution:

Other Sanctions Ordered: WITHIN 90 DAYS, THE FIRM SHALL TO NASD THAT IT HAS REVISED ANDIMPLEMENTED A POLICY AND PROCEDURES TO ENSURE THE FIRM'SCONFIRMATIONS ISSUED IN CONNECTION WITH TRANSACTIONS INMUNICIPAL SECURITIES IN OR FOR THE ACCOUNTS OF CUSTOMERSCONTAIN ALL DISCLOSURES REQUIRED BY MSRB RULE G-15; EVERY SIXMONTHS FOR PERIOD OF TWO YEARS, THE FIRM SHALL PROVIDE AWRITTEN CERTIFICATION THAT IT HAS REVIEWED ITS CONFIRMATION OFMUNICIPAL SECURITIES TRANSACTIONS AND HAS CONFIRMED THAT THEYCONTAIN ALL DISCLOSURES.


No








Other Sanctions Ordered: WITHIN 90 DAYS, THE FIRM SHALL TO NASD THAT IT HAS REVISED ANDIMPLEMENTED A POLICY AND PROCEDURES TO ENSURE THE FIRM'SCONFIRMATIONS ISSUED IN CONNECTION WITH TRANSACTIONS INMUNICIPAL SECURITIES IN OR FOR THE ACCOUNTS OF CUSTOMERSCONTAIN ALL DISCLOSURES REQUIRED BY MSRB RULE G-15; EVERY SIXMONTHS FOR PERIOD OF TWO YEARS, THE FIRM SHALL PROVIDE AWRITTEN CERTIFICATION THAT IT HAS REVIEWED ITS CONFIRMATION OFMUNICIPAL SECURITIES TRANSACTIONS AND HAS CONFIRMED THAT THEYCONTAIN ALL DISCLOSURES.

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE FIRM IS CENSURED AND FINED $300,000.


Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.DISTRICT NO.3 SEATTLE


Censure


MONETARY FINE OF $300,000


Docket/Case Number: ENF SEA #2005-22



Allegations: THE NASD ALLEGED THAT IN CONNECTION WITH TRANSACTIONS WHICHINVOLVED THE SALES OF MUNICIPAL SECURITIES BY CUSTOMERSDURING THE PERIOD FROM JANUARY 2003 UNTIL APRIL 2004, THE FIRMFAILED TO ENSURE THAT CONFIRMATIONS ISSUED INCLUDED YIELD TOMATURITY INFORMATION AS REQUIRED BY MSRB G-15(A)(I)(A)(5); THATDURING THE PERIOD FROM MAY 1995 UNTIL APRIL 2004, THE FIRM FAILEDTO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, DESIGNED TOENSURE THAT CONFIRMATIONS ISSUED FOR CUSTOMER TRANSACTIONSIN MUNICIPAL SECURITIES DISCLOSED INFORMATION REGARDING THOSETRANSACTIONS AS REQUIRED BY MSRB RULE G-15; AND THAT THESECONSTITUTED A VIOLATION OF MSRB RULE G-27(C).



Resolution:









Sanction Details: EDWARD JONES ACCEPTED AND CONSENTED TO, WITHOUT ADMITTINGOR DENYING GUILT, A SETTLEMENT WHICH INCLUDED CENSURE AND AFINE OF $300,000; AGREED TO DEVISE AND IMPLEMENT A POLICY AND SETOF PROCEDURES IN ENSURE THE FIRM'S CONFIRMATIONS ISSUED INCONNECTION WITH TRANSACTIONS IN MUNICIPAL SECURITIES CONTAINALL DISCLOSURES REQUIRED BY MSRB RULE G-15; AND AGREED THATFOR A PERIOD OF TWO YEARS THE FIRM WILL PROVIDE TO THE NASD'SSEATTLE DISTRICT OFFICE A WRITTEN CERTIFICATION THAT IT HASREVIEWED ITS CONFIRMATION DISCLOSURES AND THAT THEY CONFORMTO THE REQUIREMENTS OF MSRB RULE G-15.


Disclosure 36 of 73

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Initiated By: MISSOURI


Other


CONSENT ORDER






Allegations: FAILURE TO DISCLOSE INFORMATION



Resolution:


Yes

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

Consent






Other Sanctions Ordered: CONSENT ORDER

Sanction Details: CONSENT ORDER



Initiated By: STATE OF MISSOURI SECURITIES DIVISION


Other


FINE OF $1,500,000.00


Docket/Case Number: FILE NO. AP-05-31


Other Product Type(s): REVENUE SHARING ARRANGEMENTS

Allegations: THIS CONSENT ORDER REPRESENTS A SETTLEMENT BETWEEN THEPARTIES. THE MISSOURI SECURITIES DIVISION ALLEGES THAT EDWARD D.JONES & CO., L.P. D/B/A EDWARD JONES FAILED TO ADEQUATELYDISCLOSE TO INVESTORS INFORMATION ABOUT ITS REVENUE SHARINGARRANGEMENTS INVOLVING CERTAIN MUTUAL FUND COMPANIES.



Resolution:


Sanction Details: EDWARD JONES CONSENTS TO THE ENTRY OF AN ORDER, NECESSARYFOR THE PROTECTION OF PUBLIC INVESTORS AND CONSISTENT WITHTHE PROVISIONS OF CHAPTER 409,RSMO SUPP. 2004, WHICH PROVIDESTHAT;(1)EDWARD JONES SHALL MAKE AVAILABLE UPON REQUEST BY THEDIVISION ALL INFORMATION AND REPORTS SUBMITTED TO THE SELF-REGULATORY AND LAW ENFORCEMENT AUTHORITIES PERTAINING TO ITSPOLICIES AND PROCEDURES REGARDING REVENUE SHARING;(2)EDWARDJONES SHALL MAKE AVAILABLE UPON REQUEST BY THE SECURITIESDIVISION INFORMATION REGARDING THE IMPLEMENTATION OF ITSMUTUAL FUND RESEARCH PROGRAM; AND(3)EDWARD JONES ISORDERED TO PAY A CIVIL PENALTY OF $650,000.00 MADE PAYABLE TO THESTATE OF MISSOURI, AND IT IS ORDERED TO PAY $850,000.00 TOEDUCATION FUNDS. EDWARD JONES WILL PAY ITS OWN COSTS ANDATTORNEYS FEES.


Order






EDWARD JONES CONSENTS TO THE ENTRY OF AN ORDER, NECESSARYFOR THE PROTECTION OF PUBLIC INVESTORS AND CONSISTENT WITHTHE PROVISIONS OF CHAPTER 409,RSMO SUPP. 2004, WHICH PROVIDESTHAT;(1)EDWARD JONES SHALL MAKE AVAILABLE UPON REQUEST BY THEDIVISION ALL INFORMATION AND REPORTS SUBMITTED TO THE SELF-REGULATORY AND LAW ENFORCEMENT AUTHORITIES PERTAINING TO ITSPOLICIES AND PROCEDURES REGARDING REVENUE SHARING;(2)EDWARDJONES SHALL MAKE AVAILABLE UPON REQUEST BY THE SECURITIESDIVISION INFORMATION REGARDING THE IMPLEMENTATION OF ITSMUTUAL FUND RESEARCH PROGRAM; AND(3)EDWARD JONES ISORDERED TO PAY A CIVIL PENALTY OF $650,000.00 MADE PAYABLE TO THESTATE OF MISSOURI, AND IT IS ORDERED TO PAY $850,000.00 TOEDUCATION FUNDS. EDWARD JONES WILL PAY ITS OWN COSTS ANDATTORNEYS FEES.

Disclosure 37 of 73

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Initiated By: STATE OF VERMONT SECURITIES DIVISION





Docket/Case Number: NO. 05-101-S



Allegations: COMMISSIONER OF THE VERMONT DEPARTMENT OF BANKING,INSURANCE, SECURITIES AND HEALTH CARE ADMINISTRATION ALLEGESEDWARD JONES DID NOT ADEQUATELY SUPERVISE A FINANCIAL ADVISORIN THE DISBURSEMENT OF FUNDS IN A CLIENT'S IRA ACCOUNT.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS EDWARD JONESHAS AGREED TO PAY INTO AN EDWARD JONES MONEY MARKET IRA FORTHE CLIENT, THE DISTRIBUTION AMOUNT OF $3,781.97 PLUS THEESTIMATED TAX PENALTY OF $1,718.03 FOR A TOTAL OF $5,500.00, REVISESUPERVISORY POLICIES AND UPDATE FORM U-4 TO INCLUDE THEDIVISION'S LETTER OF ADMONITION TO THE FINANCIAL ADVISOR.

Firm Statement SEE ABOVE


Order

Disclosure 38 of 73

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Cease and Desist


CENSURE, DISGORGEMENT, PREJUDGMENT INTEREST, CIVIL MONETARYPENALTY, UNDERTAKINGS





Allegations: SEC ADMIN RELEASE NO. 33-8520A, SECURITIES EXCHANGE ACT 34-50910A, JULY 13, 2007; AMENDED ORDER: THE SECURITIES ANDEXCHANGE COMMISSION COMPLAINT ALLEGES THAT RESPONDENTVIOLATED THE FEDERAL SECURITIES LAWS BY FAILING TO DISCLOSE ITSRECEIPT OF REVENUE SHARING PAYMENTS FOR DISTRIBUTION OFSHARES OF MUTUAL FUNDS AND SECTION 529 COLLEGE SAVINGS PLANSFROM SEVEN "PREFERRED MUTUAL FUND FAMILIES." RESPONDENTWILFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT, RULE 10B-10 UNDER THE EXCHANGE ACT, SECTION 15B(C)(1) OF THE EXCHANGEACT, EDWARD JONES ALSO CONTRAVENED THE DICTATES OF MUNICIPALSECURITIES RULEMAKING BOARD ("MSRB") RULE G-15.



Resolution:

Other Sanctions Ordered: UNDERTAKING: (A) EDWARD JONES SHALL PLACE AND MAINTAIN ON THEMUTUAL FUND PORTION OF ITS PUBLIC WEBSITE WITHIN 15 DAYS OF THEDATE OF ENTRY OF THIS ORDER DISCLOSURES REGARDING ITSPREFERRED MUTUAL FUND FAMILY PROGRAM; (B)SHALL PLACE ANDMAINTAIN ON THE COLLEGE SAVINGS PROGRAM PORTION OF ITS PUBLICWEBSITE WITHIN 15 DAYS OF THE DATE OF ENTRY OF THIS ORDERDISCLOSURES REGARDING ITS PREFERRED MUTUAL FUND FAMILYPROGRAM; SHALL SEND THE INFORMATION CONTAINED IN PARAGRAPHSA. AND B. ABOVE: TO ITS CURRENT CUSTOMERS WITHIN 60 DAYSFOLLOWING THE DATE OF ENTRY OF THIS ORDER AND ANNUALLYTHEREAFTER; SHALL DEVISE AND IMPLEMENT WITHIN 60 DAYS OF THEDATE OF ENTRY OF THIS ORDER A POLICY AND SET OF PROCEDURES TOENSURE THAT EDWARD JONES IS COMPLYING WITH ITS DISCLOSUREOBLIGATIONS UNDER THIS ORDER, THE FEDERAL SECURITIES LAWS ANDTHE MSRB RULES; SHALL DEVISE AND IMPLEMENT WITHIN 60 DAYS OFTHE DATE OF ENTRY OF THIS ORDER A POLICY AND SET OF PROCEDURESTO CONDUCT COMPREHENSIVE REVIEWS OF ALL PROSPECTUSES ANDSAIS ISSUED BY THE PREFERRED FAMILIES ON A REGULAR BASIS; SHALLDEVISE AND IMPLEMENT WITHIN 60 DAYS OF THE DATE OF ENTRY OF THISORDER A POLICY AND SET OF PROCEDURES TO DOCUMENT THE BASISFOR ITS DECISIONS TO ADD OR REMOVE MUTUAL FUND FAMILIES FROMITS LIST OF PREFERRED FAMILIES; SHALL DEVISE AND IMPLEMENTWITHIN 60 DAYS OF THE DATE OF ENTRY OF THIS ORDER A POLICY ANDSET OF PROCEDURES FOR TRAINING ITS IRS REGARDING THEDISCLOSURE OF FINANCIAL INCENTIVES THAT EDWARD JONES, ITS IRS,GENERAL PARTNERS AND LIMITED PARTNERS RECEIVE FROM EACH OFTHE PREFERRED FAMILIES; SHALL RETAIN, WITHIN 60 DAYS OF THE DATEOF ENTRY OF THIS ORDER, THE SERVICES OF AN INDEPENDENTCONSULTANT NOT UNACCEPTABLE TO THE COMMISSION'S STAFF; RETAINTHE INDEPENDENT CONSULTANT TO, AT THE CONCLUSION OF THEREVIEW, WHICH IN NO EVENT SHALL BE MORE THAN 120 DAYS AFTER THEDATE OF ENTRY OF THIS ORDER, SUBMIT TO EDWARD JONES AND TO THECOMMISSION'S STAFF AN INITIAL REPORT.


No


Order





www.finra.org/brokercheck User GuidanceUNDERTAKING: (A) EDWARD JONES SHALL PLACE AND MAINTAIN ON THEMUTUAL FUND PORTION OF ITS PUBLIC WEBSITE WITHIN 15 DAYS OF THEDATE OF ENTRY OF THIS ORDER DISCLOSURES REGARDING ITSPREFERRED MUTUAL FUND FAMILY PROGRAM; (B)SHALL PLACE ANDMAINTAIN ON THE COLLEGE SAVINGS PROGRAM PORTION OF ITS PUBLICWEBSITE WITHIN 15 DAYS OF THE DATE OF ENTRY OF THIS ORDERDISCLOSURES REGARDING ITS PREFERRED MUTUAL FUND FAMILYPROGRAM; SHALL SEND THE INFORMATION CONTAINED IN PARAGRAPHSA. AND B. ABOVE: TO ITS CURRENT CUSTOMERS WITHIN 60 DAYSFOLLOWING THE DATE OF ENTRY OF THIS ORDER AND ANNUALLYTHEREAFTER; SHALL DEVISE AND IMPLEMENT WITHIN 60 DAYS OF THEDATE OF ENTRY OF THIS ORDER A POLICY AND SET OF PROCEDURES TOENSURE THAT EDWARD JONES IS COMPLYING WITH ITS DISCLOSUREOBLIGATIONS UNDER THIS ORDER, THE FEDERAL SECURITIES LAWS ANDTHE MSRB RULES; SHALL DEVISE AND IMPLEMENT WITHIN 60 DAYS OFTHE DATE OF ENTRY OF THIS ORDER A POLICY AND SET OF PROCEDURESTO CONDUCT COMPREHENSIVE REVIEWS OF ALL PROSPECTUSES ANDSAIS ISSUED BY THE PREFERRED FAMILIES ON A REGULAR BASIS; SHALLDEVISE AND IMPLEMENT WITHIN 60 DAYS OF THE DATE OF ENTRY OF THISORDER A POLICY AND SET OF PROCEDURES TO DOCUMENT THE BASISFOR ITS DECISIONS TO ADD OR REMOVE MUTUAL FUND FAMILIES FROMITS LIST OF PREFERRED FAMILIES; SHALL DEVISE AND IMPLEMENTWITHIN 60 DAYS OF THE DATE OF ENTRY OF THIS ORDER A POLICY ANDSET OF PROCEDURES FOR TRAINING ITS IRS REGARDING THEDISCLOSURE OF FINANCIAL INCENTIVES THAT EDWARD JONES, ITS IRS,GENERAL PARTNERS AND LIMITED PARTNERS RECEIVE FROM EACH OFTHE PREFERRED FAMILIES; SHALL RETAIN, WITHIN 60 DAYS OF THE DATEOF ENTRY OF THIS ORDER, THE SERVICES OF AN INDEPENDENTCONSULTANT NOT UNACCEPTABLE TO THE COMMISSION'S STAFF; RETAINTHE INDEPENDENT CONSULTANT TO, AT THE CONCLUSION OF THEREVIEW, WHICH IN NO EVENT SHALL BE MORE THAN 120 DAYS AFTER THEDATE OF ENTRY OF THIS ORDER, SUBMIT TO EDWARD JONES AND TO THECOMMISSION'S STAFF AN INITIAL REPORT.

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, RESPONDENTCONSENTED TO THE ENTRY OF THIS ORDER. ACORDINGLY, PURSUANT TOSECTION TO SECTION 8A OF THE SECURITIES ACT AND SECTIONS 15(B)AND 21C OF THE EXCHANGE ACT IS ORDERED THAT EDWARD JONES ISCENSURED; SHALL CEASE AND DESIST FROM COMMITTING OR CAUSINGANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OFTHE SECURITIES ACT, SECTION 15B(C)(1) OF THE EXCHANGE ACT ANDRULE 10B-10 THEREUNDER AND MSRB RULE G-15. SHALL PAYDISGORGEMENT PLUS PREJUDGMENT INTEREST IN THE TOTAL AMOUNTOF $37.5 MILLION ("DISGORGEMENT") AND A CIVIL MONETARY PENALTY INTHE AMOUNT OF $37.5 MILLION ("PENALTIES"), FOR A TOTAL PAYMENT OF$75 MILLION. SECURIES ACT OF 33-8632, SECURITIES EXCHANGE ACT OF34-52677, OCTOBER 26, 2005; IT IS ORDERED, PURSUANT TO SECTION27A(B) OF THE SECURITIES ACT AND SECTION 21E(B) OF THE EXCHANGEACT, THAT A WAIVER FROM THE DISQUALIFICATION PROVISIONS OFSECTION 27A(B)(1)(A)(II) OF THE SECURITIES ACT AND SECTION21E(B)(1)(A)(II) OF THE EXCHANGE ACT AS TO JONES FINANCIAL AND ITSAFFILIATES RESULTING FROM THE ENTRY OF THE ORDER IS HEREBYGRANTED.






WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, RESPONDENTCONSENTED TO THE ENTRY OF THIS ORDER. ACORDINGLY, PURSUANT TOSECTION TO SECTION 8A OF THE SECURITIES ACT AND SECTIONS 15(B)AND 21C OF THE EXCHANGE ACT IS ORDERED THAT EDWARD JONES ISCENSURED; SHALL CEASE AND DESIST FROM COMMITTING OR CAUSINGANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OFTHE SECURITIES ACT, SECTION 15B(C)(1) OF THE EXCHANGE ACT ANDRULE 10B-10 THEREUNDER AND MSRB RULE G-15. SHALL PAYDISGORGEMENT PLUS PREJUDGMENT INTEREST IN THE TOTAL AMOUNTOF $37.5 MILLION ("DISGORGEMENT") AND A CIVIL MONETARY PENALTY INTHE AMOUNT OF $37.5 MILLION ("PENALTIES"), FOR A TOTAL PAYMENT OF$75 MILLION. SECURIES ACT OF 33-8632, SECURITIES EXCHANGE ACT OF34-52677, OCTOBER 26, 2005; IT IS ORDERED, PURSUANT TO SECTION27A(B) OF THE SECURITIES ACT AND SECTION 21E(B) OF THE EXCHANGEACT, THAT A WAIVER FROM THE DISQUALIFICATION PROVISIONS OFSECTION 27A(B)(1)(A)(II) OF THE SECURITIES ACT AND SECTION21E(B)(1)(A)(II) OF THE EXCHANGE ACT AS TO JONES FINANCIAL AND ITSAFFILIATES RESULTING FROM THE ENTRY OF THE ORDER IS HEREBYGRANTED.

Regulator Statement UNDERTAKINGS: WITHIN 150 DAYS FROM SHALL IN WRITING ADVISE THEINDEPENDENT CONSULTANT AND THE COMMISSION'S STAFF OF THERECOMMENDATIONS FROM THE INITIAL REPORT THAT IT IS ADOPTINGAND THE RECOMMENDATIONS THAT IT CONSIDERS TO BE UNNECESSARYOR INAPPROPRIATE. WITH RESPECT TO ANY RECOMMENDATION WITHWHICH EDWARD JONES AND THE INDEPENDENT CONSULTANT DO NOTAGREE, EDWARD JONES SHALL ATTEMPT IN GOOD FAITH TO REACH ANAGREEMENT WITH THE INDEPENDENT CONSULTANT WITHIN 180 DAYSFROM THE DATE OF THE ENTRY OF THE ORDER. SHALL FURTHER RETAINTHE INDEPENDENT CONSULTANT TO CONDUCT A FOLLOW UP REVIEWAND SUBMIT A WRITTEN FINAL REPORT TO EDWARD JONES AND TO THECOMMISSION'S STAFF NO LATER THAN ONE YEAR AFTER THE DATE OFENTRY OF THIS ORDER. WITHIN 60 DAYS OF THE DATE OF THE ENTRY OFTHIS ORDER, SHALL SUBMIT TO THE INDEPENDENT CONSULTANT FORREVIEW A PLAN PURSUANT TO WHICH THE INDEPENDENT CONSULTANTSHALL ADMINISTER AND DISTRIBUTE THE MONETARY SUMS ORDERED TOBE PAID. SHALL COOPERATE FULLY WITH THE INDEPENDENTCONSULTANT AND SHALL PROVIDE WITH ACCESS TO EDWARD JONES'FILES, BOOKS, RECORDS AND PERSONNEL AS REASONABLY REQUESTED.SHALL NOT HAVE THE AUTHORITY TO TERMINATE THE INDEPENDENTCONSULTANT, WITHOUT THE PRIOR WRITTEN APPROVAL OF THECOMMISSION'S STAFF. SHALL REQUIRE THE INDEPENDENT CONSULTANTTO ENTER INTO AN AGREEMENT THAT PROVIDES THAT FOR THE PERIODOF THE ENGAGEMENT AND FOR A PERIOD OF TWO YEARS FROMCOMPLETION OF THE ENGAGEMENT, THE INDEPENDENT CONSULTANTSHALL NOT ENTER INTO ANY EMPLOYMENT, CONSULTANT, ATTORNEY-CLIENT, AUDITING OR OTHER PROFESSIONAL RELATIONSHIP WITH THEFIRM. EDWARD JONES SHALL NOT SEEK OR ACCEPT, DIRECTLY ORINDIRECTLY, REIMBURSEMENT OR INDEMNIFICATION FROM ANY SOURCEINCLUDING, BUT NOT LIMITED TO, PAYMENT MADE PURSUANT TO ANYINSURANCE POLICY, WITH REGARD TO ANY PENALTY AMOUNTS THATEDWARD JONES SHALL PAY PURSUANT TO THIS ORDER.


Allegations: 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 1993 ("SECURITIES ACT") AND SECTIONS 15(B) AND 21C OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINSTEDWARD D. JONES & CO., L.P., ("JONES.")

BASED ON JONES' CONDUCT THAT JONES DID NOT DISCLOSE ITSFINANCIAL INCENTIVES TO SELL MUTUAL FUNDS FROM THE PREFERREDFAMILIES ON ITS WEBSITE OR ON ANY OTHER WRITTEN DOCUMENT ORORALLY TO CUSTOMERS AND THAT JONES FAILED TO DISCLOSE ON ITSWEBSITE OR ON ANY OTHER WRITTEN DOCUMENT ANY INCENTIVES TOSELL 529 PLANS. JONES WILLFULLY VIOLATED:

A. SECTION 17(A)(2) OF THE SECURITIES ACT.B. RULE 10B-10 UNDER THE EXCHANGE ACT.C. SECTION 15B(C)(1) OF THE EXCHANGE ACT.D. CONTRAVENED THE DICTATES OF MSRB RULE G-15.







Initiated By: SECURITIES AND EXCHANGE COMMISSIONSECURITIES ACT OF 1933 -- RELEASE NO. 8520SECURITIES ACT OF 1934 -- RELEASE NO. 50910


Cease and Desist


CENSUREMONETARY FINE OF $75 MILLION DOLLARSDISGORGEMENT


Docket/Case Number: FILE NO. 3-11780


Other Product Type(s): VARIABLE ANNUITIES529 PLANS

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 1993 ("SECURITIES ACT") AND SECTIONS 15(B) AND 21C OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINSTEDWARD D. JONES & CO., L.P., ("JONES.")

BASED ON JONES' CONDUCT THAT JONES DID NOT DISCLOSE ITSFINANCIAL INCENTIVES TO SELL MUTUAL FUNDS FROM THE PREFERREDFAMILIES ON ITS WEBSITE OR ON ANY OTHER WRITTEN DOCUMENT ORORALLY TO CUSTOMERS AND THAT JONES FAILED TO DISCLOSE ON ITSWEBSITE OR ON ANY OTHER WRITTEN DOCUMENT ANY INCENTIVES TOSELL 529 PLANS. JONES WILLFULLY VIOLATED:

A. SECTION 17(A)(2) OF THE SECURITIES ACT.B. RULE 10B-10 UNDER THE EXCHANGE ACT.C. SECTION 15B(C)(1) OF THE EXCHANGE ACT.D. CONTRAVENED THE DICTATES OF MSRB RULE G-15.


Resolution:

Other Sanctions Ordered: IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATEAND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INJONES' OFFER.

ACCORDINGLY, PURSUANT TO SECTION 8A OF THE SECURITIES ACT ANDSECTIONS 15(B) AND 21C OF THE EXCHANGE ACT, IT IS HEREBY ORDEREDTHAT:

A. JONES IS CENSURED.B. JONES SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANYVIOLATIONS AND FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THESECURITIES ACT, SECTION 15B(C)(1) OF THE EXCHANGE ACT AND RULE10B-10 THEREUNDER AND MSRB RULE G-15.

C. IT IS FURTHER ORDERED THAT:

1. JONES SHALL PAY DISGORGEMENT PLUS PREJUDGMENT INTEREST INTHE TOTAL AMOUNT OF $37.5 MILLION ("DISGORGEMENT") AND A CIVILMONETARY PENALTY IN THE AMOUNT OF $37.5 MILLION ("PENALTIES"),FOR A TOTAL OF $75 MILLION.2. THERE SHALL BE, PURSUANT TO SECTION 308(A) OF THE SARBANES-OXLEY ACT OF 2002 A FAIR FUND ESTABLISHED FOR THE FUNDSDESCRIBED IN SECTION C1.3. PURSUANT TO AN ESCROW AGREEMENT NOT UNACCEPTABLE TO THESTAFF OF THE COMMISSION, JONES SHALL, WITHIN 90 DAYS OF THISORDER, PAY THE DISGORGEMENT AND PENALTIES INTO AN ESCROWACCOUNT. JONES SHALL BE RESPONSIBLE FOR ALL COSTS ASSOCIATEDWITH THE ESCROW AGREEMENT AND THE FAIR FUND DISTRIBUTION.


Order






IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATEAND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INJONES' OFFER.

ACCORDINGLY, PURSUANT TO SECTION 8A OF THE SECURITIES ACT ANDSECTIONS 15(B) AND 21C OF THE EXCHANGE ACT, IT IS HEREBY ORDEREDTHAT:

A. JONES IS CENSURED.B. JONES SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANYVIOLATIONS AND FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THESECURITIES ACT, SECTION 15B(C)(1) OF THE EXCHANGE ACT AND RULE10B-10 THEREUNDER AND MSRB RULE G-15.

C. IT IS FURTHER ORDERED THAT:

1. JONES SHALL PAY DISGORGEMENT PLUS PREJUDGMENT INTEREST INTHE TOTAL AMOUNT OF $37.5 MILLION ("DISGORGEMENT") AND A CIVILMONETARY PENALTY IN THE AMOUNT OF $37.5 MILLION ("PENALTIES"),FOR A TOTAL OF $75 MILLION.2. THERE SHALL BE, PURSUANT TO SECTION 308(A) OF THE SARBANES-OXLEY ACT OF 2002 A FAIR FUND ESTABLISHED FOR THE FUNDSDESCRIBED IN SECTION C1.3. PURSUANT TO AN ESCROW AGREEMENT NOT UNACCEPTABLE TO THESTAFF OF THE COMMISSION, JONES SHALL, WITHIN 90 DAYS OF THISORDER, PAY THE DISGORGEMENT AND PENALTIES INTO AN ESCROWACCOUNT. JONES SHALL BE RESPONSIBLE FOR ALL COSTS ASSOCIATEDWITH THE ESCROW AGREEMENT AND THE FAIR FUND DISTRIBUTION.

Sanction Details: (A) JONES SHALL PLACE AND MAINTAIN ON ITS MUTUAL FUND PORTIONOF ITS PUBLIC WEBSITE WITHIN 15 DAYS SPECIFIC DISCLOSURESREGARDING ITS PREFERRED MUTUAL FUND FAMILY PROGRAM.

(B) JONES SHALL PLACE AND MAINTAIN ON THE COLLEGE SAVINGSPROGRAM PORTION OF ITS PUBLIC WEBSITE WITHIN 15 DAYS SPECIFICDISCLOSURES REGARDING 529 PLANS OF ITS PREFERRED MUTUAL FUNDFAMILY PROGRAM.

(C) WITHIN 60 DAYS JONES WILL SEND INFORMATION REGARDING THESPECIFIED DISCLOSURES IN A AND B TO NEW ACCOUNT CUSTOMERS FOREACH MUTUAL FUND AND 529 PLAN TRANSACTION AND QUARTERLYPURSUANT TO COMPLIANCE WITH EXCHANGE ACT RULE 10B-10 ANDMSRB RULE G-15.

(D) JONES SHALL IMPLEMENT WITHIN 60 DAYS A POLICY AND PROCEDURETO CONDUCT REVIEWS OF ALL PROSPECTUSES AND SAIS, AS WELL ASTHE PUBLIC WEBSITE, TO ENSURE THAT JONES IS IN COMPLIANCE WITHTHE DISCLOSURE OBLIGATION UNDER THIS ORDER, THE FEDERALSECURITIES LAWS AND THE MSRB RULES.

(E)WITHIN 60 DAYS JONES SHALL ESTABLISH POLICIES AND PROCEDURESTO DOCUMENT ADDING OR REMOVING MUTUAL FUND FAMILIES FROM ITSPREFERRED LIST.

(F) WITHIN 60 DAYS POLICIES AND PROCEDURES SHALL BE ESTABLISHEDTO TRAIN IRS IN THE DISCLOSURE OF INCENTIVES THAT INDIVIDUALSWITH JONES RECEIVE FROM THE PREFERRED FUNDS.

(G) WITHIN 60 DAYS JONES SHALL RETAIN THE SERVICES OF AN ICACCEPTABLE TO COMMISSION'S STAFF TO CONDUCT A REVIEW OF THEPOLICIES AND PROCEDURES THAT JONES IS REQUIRED TO DEVISE ANDIMPLEMENT UNDER THIS ORDER.

(H) WITHIN 120 DAYS THE IC SHALL SUBMIT A REPORT TO THECOMMISSION'S STAFF AND JONES WHICH WILL INCLUDE THE ADEQUACYOF POLICIES AND PROCEDURES REQUIRED UNDER THIS ORDER,WHETHER THE DISCLOSURE OF REVENUE SHARING IS IN COMPLIANCEWITH THE ORDER, A DESCRIPTION OF THE REVIEW PERFORMED,CONCLUSIONS REACHED, RECOMMENDATIONS FOR MODIFICATIONS ANDADDITIONS TO THE POLICIES AND PROCEDURES DEVISED ANDIMPLEMENTED BY JONES.(CONT. IN 13)






(A) JONES SHALL PLACE AND MAINTAIN ON ITS MUTUAL FUND PORTIONOF ITS PUBLIC WEBSITE WITHIN 15 DAYS SPECIFIC DISCLOSURESREGARDING ITS PREFERRED MUTUAL FUND FAMILY PROGRAM.

(B) JONES SHALL PLACE AND MAINTAIN ON THE COLLEGE SAVINGSPROGRAM PORTION OF ITS PUBLIC WEBSITE WITHIN 15 DAYS SPECIFICDISCLOSURES REGARDING 529 PLANS OF ITS PREFERRED MUTUAL FUNDFAMILY PROGRAM.

(C) WITHIN 60 DAYS JONES WILL SEND INFORMATION REGARDING THESPECIFIED DISCLOSURES IN A AND B TO NEW ACCOUNT CUSTOMERS FOREACH MUTUAL FUND AND 529 PLAN TRANSACTION AND QUARTERLYPURSUANT TO COMPLIANCE WITH EXCHANGE ACT RULE 10B-10 ANDMSRB RULE G-15.

(D) JONES SHALL IMPLEMENT WITHIN 60 DAYS A POLICY AND PROCEDURETO CONDUCT REVIEWS OF ALL PROSPECTUSES AND SAIS, AS WELL ASTHE PUBLIC WEBSITE, TO ENSURE THAT JONES IS IN COMPLIANCE WITHTHE DISCLOSURE OBLIGATION UNDER THIS ORDER, THE FEDERALSECURITIES LAWS AND THE MSRB RULES.

(E)WITHIN 60 DAYS JONES SHALL ESTABLISH POLICIES AND PROCEDURESTO DOCUMENT ADDING OR REMOVING MUTUAL FUND FAMILIES FROM ITSPREFERRED LIST.

(F) WITHIN 60 DAYS POLICIES AND PROCEDURES SHALL BE ESTABLISHEDTO TRAIN IRS IN THE DISCLOSURE OF INCENTIVES THAT INDIVIDUALSWITH JONES RECEIVE FROM THE PREFERRED FUNDS.

(G) WITHIN 60 DAYS JONES SHALL RETAIN THE SERVICES OF AN ICACCEPTABLE TO COMMISSION'S STAFF TO CONDUCT A REVIEW OF THEPOLICIES AND PROCEDURES THAT JONES IS REQUIRED TO DEVISE ANDIMPLEMENT UNDER THIS ORDER.

(H) WITHIN 120 DAYS THE IC SHALL SUBMIT A REPORT TO THECOMMISSION'S STAFF AND JONES WHICH WILL INCLUDE THE ADEQUACYOF POLICIES AND PROCEDURES REQUIRED UNDER THIS ORDER,WHETHER THE DISCLOSURE OF REVENUE SHARING IS IN COMPLIANCEWITH THE ORDER, A DESCRIPTION OF THE REVIEW PERFORMED,CONCLUSIONS REACHED, RECOMMENDATIONS FOR MODIFICATIONS ANDADDITIONS TO THE POLICIES AND PROCEDURES DEVISED ANDIMPLEMENTED BY JONES.(CONT. IN 13)

Firm Statement (I) WITHIN 150 DAYS JONES SHALL IN WRITING ADVISE THE IC AND THECOMMISSION'S STAFF OF THE RECOMMENDATIONS FROM THE INITIALREPORT THAT IT IS ADOPTING AND THE RECOMMENDATIONS ITCONSIDERS INAPPROPRIATE WITH AN EXPLANATION OF WHY IT ISINAPPROPRIATE AND PROVIDE AN ALTERNATIVE TO ACHIEVE THE SAMEOBJECTIVE.

(J) IN THE EVENT THAT JONES AND THE IC DO NOT AGREE, JONES SHALLATTEMPT TO REACH AN AGREEMENT WITH THE IC. IF NO AGREEMENT ISREACHED JONES AND THE IC SHALL CONFER WITH THE COMMISSION'SSTAFF TO RESOLVE THE MATTER.

(K) WITHIN ONE YEAR THE IC WILL SUBMIT A FINAL REPORT TO JONES ANDTHE COMMISSION'S STAFF. THE FINAL REPORT WILL ADDRESS JONESCOMPLIANCE WITH THE ORDER, AND MAKE FURTHERRECOMMENDATIONS IF DEEMED NECESSARY.

(L) WITHIN 30 DAYS OF THE IC'S FINAL REPORT, JONES SHALL ADOPT THERECOMMENDATIONS CONTAINED IN THE FINAL REPORT.

(M) WITHIN 60 DAYS OF THIS ORDER JONES SHALL SUBMIT TO THE IC ADISTRIBUTION PLAN FOR REVIEW. THE IC SHALL ADMINISTER ANDDISTRIBUTE THE MONETARY SUMS ORDERED TO BE PAID PURSUANT TOIV.C OF THE SEC ORDER. THE DISTRIBUTION PLAN SHALL ADDRESS HOWTHE MONETARY SUMS SHALL BE DISTRIBUTED TO BENEFIT CUSTOMERSWHO PURCHASED PREFERRED FAMILY MUTUAL FUNDS BETWEENJANUARY 1, 1999 AND THE DATE OF THIS ORDER. IF THE IC FINDS THEDISTRIBUTION PLAN UNACCEPTABLE, JONES SHALL ATTEMPT TO REACHAN AGREEMENT WITH THE IC WITHIN 90 DAYS OF THE ENTRY OF THISORDER. IF BOTH PARTIES ARE UNABLE TO AGREE ON AN ALTERNATIVEPROPOSAL, JONES SHALL ABIDE BY THE RECOMMENDATION OF THE IC.THIS FINAL DISTRIBUTION PLAN MUST BE SUBMITTED TO AND ACCEPTEDBY THE COMMISSION'S STAFF.

(N) JONES SHALL COOPERATE FULLY WITH ANY REQUEST BY THE IC TOACCESS FILES, BOOKS, RECORDS AND PERSONNEL.

(O) UPON RECEIPT OF A TIMELY APPLICATION FROM THE IC OR JONES,COMMISSION'S STAFF MAY EXTEND ANY OF THE PROCEDURAL DATES SETFORTH ABOVE.






(I) WITHIN 150 DAYS JONES SHALL IN WRITING ADVISE THE IC AND THECOMMISSION'S STAFF OF THE RECOMMENDATIONS FROM THE INITIALREPORT THAT IT IS ADOPTING AND THE RECOMMENDATIONS ITCONSIDERS INAPPROPRIATE WITH AN EXPLANATION OF WHY IT ISINAPPROPRIATE AND PROVIDE AN ALTERNATIVE TO ACHIEVE THE SAMEOBJECTIVE.

(J) IN THE EVENT THAT JONES AND THE IC DO NOT AGREE, JONES SHALLATTEMPT TO REACH AN AGREEMENT WITH THE IC. IF NO AGREEMENT ISREACHED JONES AND THE IC SHALL CONFER WITH THE COMMISSION'SSTAFF TO RESOLVE THE MATTER.

(K) WITHIN ONE YEAR THE IC WILL SUBMIT A FINAL REPORT TO JONES ANDTHE COMMISSION'S STAFF. THE FINAL REPORT WILL ADDRESS JONESCOMPLIANCE WITH THE ORDER, AND MAKE FURTHERRECOMMENDATIONS IF DEEMED NECESSARY.

(L) WITHIN 30 DAYS OF THE IC'S FINAL REPORT, JONES SHALL ADOPT THERECOMMENDATIONS CONTAINED IN THE FINAL REPORT.

(M) WITHIN 60 DAYS OF THIS ORDER JONES SHALL SUBMIT TO THE IC ADISTRIBUTION PLAN FOR REVIEW. THE IC SHALL ADMINISTER ANDDISTRIBUTE THE MONETARY SUMS ORDERED TO BE PAID PURSUANT TOIV.C OF THE SEC ORDER. THE DISTRIBUTION PLAN SHALL ADDRESS HOWTHE MONETARY SUMS SHALL BE DISTRIBUTED TO BENEFIT CUSTOMERSWHO PURCHASED PREFERRED FAMILY MUTUAL FUNDS BETWEENJANUARY 1, 1999 AND THE DATE OF THIS ORDER. IF THE IC FINDS THEDISTRIBUTION PLAN UNACCEPTABLE, JONES SHALL ATTEMPT TO REACHAN AGREEMENT WITH THE IC WITHIN 90 DAYS OF THE ENTRY OF THISORDER. IF BOTH PARTIES ARE UNABLE TO AGREE ON AN ALTERNATIVEPROPOSAL, JONES SHALL ABIDE BY THE RECOMMENDATION OF THE IC.THIS FINAL DISTRIBUTION PLAN MUST BE SUBMITTED TO AND ACCEPTEDBY THE COMMISSION'S STAFF.

(N) JONES SHALL COOPERATE FULLY WITH ANY REQUEST BY THE IC TOACCESS FILES, BOOKS, RECORDS AND PERSONNEL.

(O) UPON RECEIPT OF A TIMELY APPLICATION FROM THE IC OR JONES,COMMISSION'S STAFF MAY EXTEND ANY OF THE PROCEDURAL DATES SETFORTH ABOVE.

Disclosure 39 of 73

i


Allegations: **12/22/04**ALLEGATIONS:1.VIOLATED SECTION 17(A)(2) OF THESECURITIES ACT [15 U.S.C. 77Q(A)(2)] IN THAT EDWARD JONES, IN THEOFFER OR SALE OF SECURITIES, BY THE USE OF MEANS ORINSTRUMENTS OF TRANSPORTATION OR COMMUNICATION IN INTERSTATECOMMERCE OR BY USE OF THE MAILS, DIRECTLY OR INDIRECTLYOBTAINED MONEY OR PROPERTY BY MEANS OF UNTRUE STATEMENTS OFMATERIAL FACT OR OMISSIONS TO STATE MATERIAL FACTS NECESSARYIN ORDER TO MAKE THE STATEMENTS MADE IN LIGHT OF THECIRCUMSTANCES UNDER WHICH THEY WERE MADE, NOTMISLEADING.2.VIOLATED SECTION 10B-10 OF THE EXCHANGE ACT [17C.F.R. 240.10B-10] IN THAT EDWARD JONES, EFFECTED PURCHASES ORSALES BY CUSTOMERS OF, SECURITIES WITHOUT, AT OR BEFORECOMPLETION OF SUCH TRANSACTIONS, GIVING OR SENDING THECUSTOMERS WRITTEN NOTIFICATION DISCLOSING THE SOURCES ANDAMOUNTS OF ANY OTHER REMUNERATION IT RECEIVED OR WAS TORECEIVE IN CONNECTION WITH THE TRANSACTIONS.3.ENGAGED IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLEPRINCIPLES OF TRADE IN VIOLATION OF EXCHANGE RULE 476(A)(6) INTHAT:A.THE FIRM ENCOURAGED INVESTMENT REPRESENTATIVES TO SELLMUTUAL FUND SHARES BASED IN PART ON THE AMOUNT OF REVENUETHE FIRM RECEIVED FROM CERTAIN MUTUAL FUND COMPANIES;B.THEFIRM FAILED TO ADEQUATELY DISCLOSE THE SOURCE AND AMOUNT OFREMUNERATION RECEIVED OR TO BE RECEIVED IN CONNECTION WITHTHE SALES OF COLLEGE SAVINGS 529 PLANS;C.THE FIRM FAILED TOSEND OR GIVE WRITTEN CONFIRMATIONS TO CUSTOMERS, AT ORBEFORE THE COMPLETION OF MUNICIPAL SECURITIES TRANSACTIONS,THAT DISCLOSED EITHER THE SOURCE AND AMOUNT OF ANYREMUNERATION IT RECEIVED OR WAS TO RECEIVE IN CONNECTION WITHTHE TRANSACTION FROM PERSONS OTHER THAN THE CUSTOMERS, OR ASTATEMENT INDICATING WHETHER IT RECEIVED OR WILL RECEIVE ANYSUCH REMUNERATION AND THAT THE SOURCE AND AMOUNT OF SUCHOTHER REMUNERATION WILL BE FURNISHED UPON WRITTEN REQUESTOF THE CUSTOMERS IN VIOLATION OF THE DICTATES OF MUNICIPALSECURITIES RULEMAKING BOARD (MSRB) RULE G-15.**CONTINUED AT#14**







Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCMENT




Docket/Case Number: HPD#: 04-194



**12/22/04**ALLEGATIONS:1.VIOLATED SECTION 17(A)(2) OF THESECURITIES ACT [15 U.S.C. 77Q(A)(2)] IN THAT EDWARD JONES, IN THEOFFER OR SALE OF SECURITIES, BY THE USE OF MEANS ORINSTRUMENTS OF TRANSPORTATION OR COMMUNICATION IN INTERSTATECOMMERCE OR BY USE OF THE MAILS, DIRECTLY OR INDIRECTLYOBTAINED MONEY OR PROPERTY BY MEANS OF UNTRUE STATEMENTS OFMATERIAL FACT OR OMISSIONS TO STATE MATERIAL FACTS NECESSARYIN ORDER TO MAKE THE STATEMENTS MADE IN LIGHT OF THECIRCUMSTANCES UNDER WHICH THEY WERE MADE, NOTMISLEADING.2.VIOLATED SECTION 10B-10 OF THE EXCHANGE ACT [17C.F.R. 240.10B-10] IN THAT EDWARD JONES, EFFECTED PURCHASES ORSALES BY CUSTOMERS OF, SECURITIES WITHOUT, AT OR BEFORECOMPLETION OF SUCH TRANSACTIONS, GIVING OR SENDING THECUSTOMERS WRITTEN NOTIFICATION DISCLOSING THE SOURCES ANDAMOUNTS OF ANY OTHER REMUNERATION IT RECEIVED OR WAS TORECEIVE IN CONNECTION WITH THE TRANSACTIONS.3.ENGAGED IN CONDUCT INCONSISTENT WITH JUST AND EQUITABLEPRINCIPLES OF TRADE IN VIOLATION OF EXCHANGE RULE 476(A)(6) INTHAT:A.THE FIRM ENCOURAGED INVESTMENT REPRESENTATIVES TO SELLMUTUAL FUND SHARES BASED IN PART ON THE AMOUNT OF REVENUETHE FIRM RECEIVED FROM CERTAIN MUTUAL FUND COMPANIES;B.THEFIRM FAILED TO ADEQUATELY DISCLOSE THE SOURCE AND AMOUNT OFREMUNERATION RECEIVED OR TO BE RECEIVED IN CONNECTION WITHTHE SALES OF COLLEGE SAVINGS 529 PLANS;C.THE FIRM FAILED TOSEND OR GIVE WRITTEN CONFIRMATIONS TO CUSTOMERS, AT ORBEFORE THE COMPLETION OF MUNICIPAL SECURITIES TRANSACTIONS,THAT DISCLOSED EITHER THE SOURCE AND AMOUNT OF ANYREMUNERATION IT RECEIVED OR WAS TO RECEIVE IN CONNECTION WITHTHE TRANSACTION FROM PERSONS OTHER THAN THE CUSTOMERS, OR ASTATEMENT INDICATING WHETHER IT RECEIVED OR WILL RECEIVE ANYSUCH REMUNERATION AND THAT THE SOURCE AND AMOUNT OF SUCHOTHER REMUNERATION WILL BE FURNISHED UPON WRITTEN REQUESTOF THE CUSTOMERS IN VIOLATION OF THE DICTATES OF MUNICIPALSECURITIES RULEMAKING BOARD (MSRB) RULE G-15.**CONTINUED AT#14**


Resolution:


Sanction Details: **12/22/04**DECISION - 04-194 ISSUED BY THE NYSE HEARING PANELSANCTION: CONSENT TO CENSURE AND $37.5 MILLION PENALTY AND$37.5 MILLION FINE AND UNDERTAKING.1.VIOLATED SECTION 17(A)(2) OFTHE SECURITIES ACT [15 U.S.C. 77Q(A)(2)] IN THAT EDWARD JONES, INTHE OFFER OR SALE OF SECURITIES, BY THE USE OF MEANS ORINSTRUMENTS OF TRANSPORTATION OR COMMUNICATION IN INTERSTATECOMMERCE OR BY USE OF THE MAILS, DIRECTLY OR INDIRECTLYOBTAINED MONEY OR PROPERTY BY MEANS OF UNTRUE STATEMENTS OFMATERIAL FACT OR OMISSIONS TO STATE MATERIAL FACTS NECESSARYIN ORDER TO MAKE THE STATEMENTS MADE IN LIGHT OF THECIRCUMSTANCES UNDER WHICH THEY WERE MADE, NOTMISLEADING.2.VIOLATED SECTION 10B-10 OF THE EXCHANGE ACT [17C.F.R. 240.10B-10] IN THAT EDWARD JONES, EFFECTED PURCHASES ORSALES BY CUSTOMERS OF, SECURITIES WITHOUT, AT OR BEFORECOMPLETION OF SUCH TRANSACTIONS, GIVING OR SENDING THECUSTOMERS WRITTEN NOTIFICATION DISCLOSING THE SOURCES ANDAMOUNTS OF ANY OTHER REMUNERATION IT RECEIVED OR WAS TORECEIVE IN CONNECTION WITH THE TRANSACTIONS.3.ENGAGED INCONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OFTRADE IN VIOLATION OF EXCHANGE RULE 476(A)(6) IN THAT:A. THEFIRM ENCOURAGED INVESTMENT REPRESENTATIVES TO SELL MUTUALFUND SHARES BASED IN PART ON THE AMOUNT OF REVENUE THE FIRMRECEIVED FROM CERTAIN MUTUAL FUND COMPANIES;B.THE FIRM FAILEDTO ADEQUATELY DISCLOSE THE SOURCE AND AMOUNT OFREMUNERATION RECEIVED OR TO BE RECEIVED IN CONNECTION WITHTHE SALES OF COLLEGE SAVINGS 529 PLANS;C.THE FIRM FAILED TOSEND OR GIVE WRITTEN CONFIRMATIONS TO CUSTOMERS, AT ORBEFORE THE COMPLETION OF MUNICIPAL SECURITIES TRANSACTIONS,**CONTINUED AT #14**

Sanctions Ordered: CensureMonetary/Fine $75,000,000.00

Decision






**12/22/04**DECISION - 04-194 ISSUED BY THE NYSE HEARING PANELSANCTION: CONSENT TO CENSURE AND $37.5 MILLION PENALTY AND$37.5 MILLION FINE AND UNDERTAKING.1.VIOLATED SECTION 17(A)(2) OFTHE SECURITIES ACT [15 U.S.C. 77Q(A)(2)] IN THAT EDWARD JONES, INTHE OFFER OR SALE OF SECURITIES, BY THE USE OF MEANS ORINSTRUMENTS OF TRANSPORTATION OR COMMUNICATION IN INTERSTATECOMMERCE OR BY USE OF THE MAILS, DIRECTLY OR INDIRECTLYOBTAINED MONEY OR PROPERTY BY MEANS OF UNTRUE STATEMENTS OFMATERIAL FACT OR OMISSIONS TO STATE MATERIAL FACTS NECESSARYIN ORDER TO MAKE THE STATEMENTS MADE IN LIGHT OF THECIRCUMSTANCES UNDER WHICH THEY WERE MADE, NOTMISLEADING.2.VIOLATED SECTION 10B-10 OF THE EXCHANGE ACT [17C.F.R. 240.10B-10] IN THAT EDWARD JONES, EFFECTED PURCHASES ORSALES BY CUSTOMERS OF, SECURITIES WITHOUT, AT OR BEFORECOMPLETION OF SUCH TRANSACTIONS, GIVING OR SENDING THECUSTOMERS WRITTEN NOTIFICATION DISCLOSING THE SOURCES ANDAMOUNTS OF ANY OTHER REMUNERATION IT RECEIVED OR WAS TORECEIVE IN CONNECTION WITH THE TRANSACTIONS.3.ENGAGED INCONDUCT INCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OFTRADE IN VIOLATION OF EXCHANGE RULE 476(A)(6) IN THAT:A. THEFIRM ENCOURAGED INVESTMENT REPRESENTATIVES TO SELL MUTUALFUND SHARES BASED IN PART ON THE AMOUNT OF REVENUE THE FIRMRECEIVED FROM CERTAIN MUTUAL FUND COMPANIES;B.THE FIRM FAILEDTO ADEQUATELY DISCLOSE THE SOURCE AND AMOUNT OFREMUNERATION RECEIVED OR TO BE RECEIVED IN CONNECTION WITHTHE SALES OF COLLEGE SAVINGS 529 PLANS;C.THE FIRM FAILED TOSEND OR GIVE WRITTEN CONFIRMATIONS TO CUSTOMERS, AT ORBEFORE THE COMPLETION OF MUNICIPAL SECURITIES TRANSACTIONS,**CONTINUED AT #14**

Regulator Statement **8/9/07**VIOLATIONS AS PER HEARING PANEL DECISION 04-194, FINE INTHE AMOUNT OF $75,000,000 AND AN UNDERTAKING REMAIN THE SAME.ON AUGUST 9, 2007, THE NYSE REGULATION, INC. HEARING BOARD,PURSUANT TO A REQUEST BY THE PARTIES, SUBSTITUTED THE WORDS "PURCHASE OF" FOR THE WORD "TRANSACTION" IN SECTION III ON PAGE15 OF THE DECISION. THE MODIFICATION IS CONTAINED IN A FOOTNOTEAS AN ADDENDUM ON PAGE 15 OF THE DECISION.CONTACT: PEGGY GERMINO 212-656-8450


Allegations: AN EXCHANGE PANEL MET TO CONSIDER A STIPULATION OF FACTS ANDCONSENT TO PENALTY ENTERED INTO BETWEEN THE EXCHANGE'SDIVISION OF ENFORCEMENT AND EDWARD JONES ("THE FIRM"). WITHOUTADMITTING OR DENYING GUILT, THE FIRM CONSENTED TO A FINDING BYTHE HEARING PANEL THAT IT:

I. VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT [15 U.S.C. §§77Q(A)(2)]II. VIOLATED SECTION 10B-10 OF THE EXCHANGE ACT [17 C.F.R.§ 240.10B-10]III. ENGAGED IN CONDUCT INCONSISTENT WITH PRINCIPLES OF TRADE INVIOLATION OF EXCHANGE RULE 476(A)(6) IN THAT:

A. THE FIRM ENCOURAGED IRS TO SELL MUTUAL FUND SHARES BASED INPART ON REVENUE THE FIRM RECEIVED FROM CERTAIN MUTUAL FUNDCOMPANIES;B. THE FIRM FAILED TO ADEQUATELY DISCLOSE THE SOURCE ANDAMOUNT OF REMUNERATION TO BE RECEIVED IN CONNECTION WITH THESALES OF 529 COLLEGE SAVINGS PLANS.C. THE FIRM FAILED TO GIVE WRITTEN CONFIRMATIONS TO CUSTOMERSTHAT DISCLOSED THE SOURCE AND AMOUNT OF REMUNERATIONRECEIVED IN VIOLATION OF THE MSRB RULE G-15.

IV. VIOLATED EXCHANGE RULE 401 IN FAILING TO USE THE PRINCIPLES OFGOOD BUSINESS PRACTICE IN THE CONDUCT OFITS BUSINESS AFFAIRSIN THAT:

A. THE FIRM ENCOURAGED IRS TO SELL MUTUAL FUND SHARES BASED INPART ON THE AMOUNT OF REVENUE RECEIVED FROM CERTAIN MUTUALFUND COMPANIES;B. THE FIRM FAILED TO ADEQUATELY DISCLOSE THE SOURCE ANDAMOUNT OF REMUNERATION WITH THE SALES OF 529 PLANS;

V. VIOLATED EXCHANGE RULE 342 BY FAILING TO:

A. REVIEW PROSPECTUSES AND SAIS OFFERED BY CERTAIN MUTUALFUND FAMILIES TO DETERMINE IF ADEQUATE DISCLOSURES OF REVENUESHARING, DIRECTED BROKERAGE PAYMENTS OR OTHER INCENTIVESWERE MADE.B. REASONABLY SUPERVISE ITS BUSINESS ACTIVITIES, AND ESTABLISHAND MAINTAIN APPROPRIATE PROCEDURES FOR SUPERVISION WITHRESPECT TO LATE TRADING OF MUTUAL FUNDS.

VI. VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND SEC RULES 17A-4 AND EXCHANGE RULE 440 BY FAILING TO PRESERVE FOR 3 YEARSAND/OR PRESERVE IN AN EASILY ACCESSIBLE PLACE FOR 2 YEARS,RECORDS OF ELECTRONIC COMMUNICATION







Initiated By: THE NEW YORK STOCK EXCHANGE


Censure


MONETARY FINE OF $75 MILLION DOLLARS


Docket/Case Number: HPD#: 04-194


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

AN EXCHANGE PANEL MET TO CONSIDER A STIPULATION OF FACTS ANDCONSENT TO PENALTY ENTERED INTO BETWEEN THE EXCHANGE'SDIVISION OF ENFORCEMENT AND EDWARD JONES ("THE FIRM"). WITHOUTADMITTING OR DENYING GUILT, THE FIRM CONSENTED TO A FINDING BYTHE HEARING PANEL THAT IT:

I. VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT [15 U.S.C. §§77Q(A)(2)]II. VIOLATED SECTION 10B-10 OF THE EXCHANGE ACT [17 C.F.R.§ 240.10B-10]III. ENGAGED IN CONDUCT INCONSISTENT WITH PRINCIPLES OF TRADE INVIOLATION OF EXCHANGE RULE 476(A)(6) IN THAT:

A. THE FIRM ENCOURAGED IRS TO SELL MUTUAL FUND SHARES BASED INPART ON REVENUE THE FIRM RECEIVED FROM CERTAIN MUTUAL FUNDCOMPANIES;B. THE FIRM FAILED TO ADEQUATELY DISCLOSE THE SOURCE ANDAMOUNT OF REMUNERATION TO BE RECEIVED IN CONNECTION WITH THESALES OF 529 COLLEGE SAVINGS PLANS.C. THE FIRM FAILED TO GIVE WRITTEN CONFIRMATIONS TO CUSTOMERSTHAT DISCLOSED THE SOURCE AND AMOUNT OF REMUNERATIONRECEIVED IN VIOLATION OF THE MSRB RULE G-15.

IV. VIOLATED EXCHANGE RULE 401 IN FAILING TO USE THE PRINCIPLES OFGOOD BUSINESS PRACTICE IN THE CONDUCT OFITS BUSINESS AFFAIRSIN THAT:

A. THE FIRM ENCOURAGED IRS TO SELL MUTUAL FUND SHARES BASED INPART ON THE AMOUNT OF REVENUE RECEIVED FROM CERTAIN MUTUALFUND COMPANIES;B. THE FIRM FAILED TO ADEQUATELY DISCLOSE THE SOURCE ANDAMOUNT OF REMUNERATION WITH THE SALES OF 529 PLANS;

V. VIOLATED EXCHANGE RULE 342 BY FAILING TO:

A. REVIEW PROSPECTUSES AND SAIS OFFERED BY CERTAIN MUTUALFUND FAMILIES TO DETERMINE IF ADEQUATE DISCLOSURES OF REVENUESHARING, DIRECTED BROKERAGE PAYMENTS OR OTHER INCENTIVESWERE MADE.B. REASONABLY SUPERVISE ITS BUSINESS ACTIVITIES, AND ESTABLISHAND MAINTAIN APPROPRIATE PROCEDURES FOR SUPERVISION WITHRESPECT TO LATE TRADING OF MUTUAL FUNDS.

VI. VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND SEC RULES 17A-4 AND EXCHANGE RULE 440 BY FAILING TO PRESERVE FOR 3 YEARSAND/OR PRESERVE IN AN EASILY ACCESSIBLE PLACE FOR 2 YEARS,RECORDS OF ELECTRONIC COMMUNICATION

Resolution: Decision & Order of Offer of Settlement 111©2020 FINRA. All rights reserved. Report about EDWARD JONES






Resolution:

Other Sanctions Ordered: IN VIEW OF THE ABOVE FINDINGS, THE HEARING PANEL, BY UNANIMOUSVOTE, IMPOSED THE PENALTY CONSENTED TO BY THE FIRM AS SETFORTH BELOW:THE IMPOSITION BY THE EXCHANGE, THE SECURITIES EXCHANGECOMMISSION ("SEC") AND NATIONAL ASSOCIATION OF SECURITIESDEALERS ("NASD") OF A SANCTION OF A CENSURE AND A TOTAL PAYMENTIN THE AMOUNT OF $75 MILLION, AS FOLLOWS1. $37.5 MILLION AS A PENALTY; AND2. $37.5 MILLION AS DISGORGEMENT THAT WILL BE PLACED INTO ACUSTOMER REIMBURSEMENT FUND TO COMPENSATE CUSTOMERSHARMED BY THE FIRM'S VIOLATIVE CONDUCT.3. PURSUANT TO SECTION 308(A) OF THE SARBANES-OXLEY ACT OF 2002,A FAIR FUND WILL BE ESTABLISHED FOR THE FUNDS DESCRIBED.4. PURSUANT TO AN ESCROW AGREEMENT ACCEPTED BY THEEXCHANGE, THE FIRM SHALL, WITHIN 90 DAYS OF THIS ORDER, PAY THEDISGORGEMENT AND PENALTIES INTO AN ESCROW ACCOUNT ASSPECIFIED BY THE COMMISSION'S ORDER.5. THE FIRM SHALL NOT ASSERT ANY REIMBURSEMENT ORINDEMNIFICATION FROM ANY SOURCE INCLUDING INSURANCECOMPANIES OR CLAIM, ASSERT, OR APPLY FOR A TAX DEDUCTION OR TAXCREDIT FOR ANY PENALTY AMOUNTS THAT IT PAYS PURSUANT TO THISORDER.6. WITHIN 60 DAYS OF THE DATE OF THE FINAL DECISION IN THIS MATTER,THE FIRM SHALL SUBMIT A DISTRIBUTION PLAN TO THE INDEPENDENTCONSULTANT ("IC") AND TO THE EXCHANGE STAFF ADDRESSING HOW THEMONETARY SUMS SHALL BE DISTRIBUTED. WITHIN AN ADDITIONAL 30DAYS THE FIRM SHALL SUBMIT A PLAN APPROVED BY THE IC OR ABIDE BYTHE RECOMMENDATION OF THE IC.7. THE FIRM SHALL PLACE AND MAINTAIN ON ITS MUTUAL FUND PORTIONOF ITS PUBLIC WEBSITE WITHIN 15 DAYS SPECIFIC DISCLOSURESREGARDING ITS PREFERRED MUTUAL FUND FAMILY PROGRAM.8. THE FIRM SHALL PLACE AND MAINTAIN ON THE COLLEGE SAVINGSPROGRAM PORTION OF ITS PUBLIC WEBSITE WITHIN 15 DAYS SPECIFICDISCLOSURES REGARDING 529 PLANS OF ITS PREFERRED MUTUAL FUNDFAMILY PROGRAM. (CONT. IN C.)

Sanction Details: 9. WITHIN 60 DAYS THE FIRM WILL SEND INFORMATION REGARDING THEDISCLOSURES IN 7 AND 8 TO NEW ACCOUNT CUSTOMERS BEFORE ANDAFTER EACH MUTUAL FUND AND 529 PLAN TRANSACTION ANDQUARTERLY PURSUANT TO PERIODIC PLANS IN COMPLIANCE WITHEXCHANGE ACT RULE 10B-10 AND MSRB RULE G-15.10. THE FIRM SHALL IMPLEMENT WITHIN 60 DAYS A POLICY ANDPROCEDURE TO CONDUCT REVIEWS OF ALL PROSPECTUSES AND SAIS,AS WELL AS THE PUBLIC WEBSITE, ON A REGULAR BASIS TO ENSURETHAT THE FIRM IS IN COMPLIANCE WITH THE DISCLOSURE OBLIGATIONUNDER THIS ORDER, THE FEDERAL SECURITIES LAWS AND THE MSRBRULES.11. WITHIN 60 DAYS THE FIRM SHALL ESTABLISH POLICIES ANDPROCEDURES FOR ADDING OR REMOVING MUTUAL FUND FAMILIES FROMITS PREFERRED LIST.12. WITHIN 60 DAYS POLICIES AND PROCEDURES SHALL BE ESTABLISHEDTO TRAIN IRS IN THE DISCLOSURE OF INCENTIVES THAT INDIVIDUALSWITH JONES RECEIVE FROM THE PREFERRED FUNDS.13. WITHIN 60 DAYS THE FIRM SHALL RETAIN THE SERVICES OF ANINDEPENDENT CONSULTANT ("IC") ACCEPTABLE TO COMMISSION'S STAFFTO CONDUCT A REVIEW OF THE POLICIES AND PROCEDURES THAT THEFIRM IS TO DEVISE AND IMPLEMENT UNDER THIS ORDER.14. WITHIN 120 DAYS THE IC SHALL SUBMIT AN INITIAL REPORT TO THECOMMISSION'S STAFF AND THE FIRM WHICH WILL INCLUDE THE POLICIESAND PROCEDURES REQUIRED TO BE IMPLEMENTED UNDER THIS ORDER,WHETHER THE DISCLOSURE OF REVENUE SHARING IS IN COMPLIANCEWITH THE ORDER, A DESCRIPTION OF THE REVIEW PERFORMED,CONCLUSIONS REACHED, RECOMMENDATIONS FOR MODIFICATIONS ANDADDITIONS TO THE POLICIES AND PROCEDURES DEVISED ANDIMPLEMENTED BY THE FIRM.15. WITHIN 150 DAYS THE FIRM SHALL IN WRITING ADVISE THE IC AND THECOMMISSION'S STAFF OF THE RECOMMENDATIONS FROM THE INITIALREPORT THAT IT IS ADOPTING AND THE RECOMMENDATIONS ITCONSIDERS INAPPROPRIATE WITH AN EXPLANATION OF WHY IT ISINAPPROPRIATE AND PROVIDE AN ALTERNATIVE TO ACHIEVE THE SAMEOBJECTIVE. (CONT. IN 13)

Sanctions Ordered: CensureMonetary/Fine $75,000,000.00Disgorgement/Restitution

Decision & Order of Offer of Settlement






9. WITHIN 60 DAYS THE FIRM WILL SEND INFORMATION REGARDING THEDISCLOSURES IN 7 AND 8 TO NEW ACCOUNT CUSTOMERS BEFORE ANDAFTER EACH MUTUAL FUND AND 529 PLAN TRANSACTION ANDQUARTERLY PURSUANT TO PERIODIC PLANS IN COMPLIANCE WITHEXCHANGE ACT RULE 10B-10 AND MSRB RULE G-15.10. THE FIRM SHALL IMPLEMENT WITHIN 60 DAYS A POLICY ANDPROCEDURE TO CONDUCT REVIEWS OF ALL PROSPECTUSES AND SAIS,AS WELL AS THE PUBLIC WEBSITE, ON A REGULAR BASIS TO ENSURETHAT THE FIRM IS IN COMPLIANCE WITH THE DISCLOSURE OBLIGATIONUNDER THIS ORDER, THE FEDERAL SECURITIES LAWS AND THE MSRBRULES.11. WITHIN 60 DAYS THE FIRM SHALL ESTABLISH POLICIES ANDPROCEDURES FOR ADDING OR REMOVING MUTUAL FUND FAMILIES FROMITS PREFERRED LIST.12. WITHIN 60 DAYS POLICIES AND PROCEDURES SHALL BE ESTABLISHEDTO TRAIN IRS IN THE DISCLOSURE OF INCENTIVES THAT INDIVIDUALSWITH JONES RECEIVE FROM THE PREFERRED FUNDS.13. WITHIN 60 DAYS THE FIRM SHALL RETAIN THE SERVICES OF ANINDEPENDENT CONSULTANT ("IC") ACCEPTABLE TO COMMISSION'S STAFFTO CONDUCT A REVIEW OF THE POLICIES AND PROCEDURES THAT THEFIRM IS TO DEVISE AND IMPLEMENT UNDER THIS ORDER.14. WITHIN 120 DAYS THE IC SHALL SUBMIT AN INITIAL REPORT TO THECOMMISSION'S STAFF AND THE FIRM WHICH WILL INCLUDE THE POLICIESAND PROCEDURES REQUIRED TO BE IMPLEMENTED UNDER THIS ORDER,WHETHER THE DISCLOSURE OF REVENUE SHARING IS IN COMPLIANCEWITH THE ORDER, A DESCRIPTION OF THE REVIEW PERFORMED,CONCLUSIONS REACHED, RECOMMENDATIONS FOR MODIFICATIONS ANDADDITIONS TO THE POLICIES AND PROCEDURES DEVISED ANDIMPLEMENTED BY THE FIRM.15. WITHIN 150 DAYS THE FIRM SHALL IN WRITING ADVISE THE IC AND THECOMMISSION'S STAFF OF THE RECOMMENDATIONS FROM THE INITIALREPORT THAT IT IS ADOPTING AND THE RECOMMENDATIONS ITCONSIDERS INAPPROPRIATE WITH AN EXPLANATION OF WHY IT ISINAPPROPRIATE AND PROVIDE AN ALTERNATIVE TO ACHIEVE THE SAMEOBJECTIVE. (CONT. IN 13)

Firm Statement 16. IN THE EVENT THAT THE FIRM AND THE IC DO NOT AGREE, THE FIRMSHALL ATTEMPT TO REACH AN AGREEMENT WITH THE IC. IF NOAGREEMENT IS REACHED THE FIRM AND THE IC SHALL JOINTLY CONFERWITH THE COMMISSION'S STAFF TO RESOLVE THE MATTER.17. WITHIN ONE YEAR THE IC WILL SUBMIT A FINAL REPORT TO THE FIRMAND THE COMMISSION'S STAFF. THE FINAL REPORT WILL ADDRESS THEFIRM'S COMPLIANCE WITH THE ORDER, ITS IMPLEMENTATION OFPOLICIES AND PROCEDURES AND MAKE FURTHER RECOMMENDATIONS IFDEEMED NECESSARY.18. WITHIN 30 DAYS OF THE IC'S FINAL REPORT, THE FIRM SHALL ADOPTTHE RECOMMENDATIONS CONTAINED IN THE FINAL REPORT.19. WITHIN 60 DAYS OF THIS ORDER THE FIRM SHALL SUBMIT TO THE IC ADISTRIBUTION PLAN FOR REVIEW. THE IC SHALL ADMINISTER ANDDISTRIBUTE THE SUMS ORDERED TO BE PAID PURSUANT TO THE SECORDER. THE DISTRIBUTION PLAN SHALL ADDRESS HOW THE SUMS SHALLBE DISTRIBUTED TO BENEFIT CUSTOMERS WHO PURCHASEDPREFERRED FAMILY MUTUAL FUNDS BETWEEN JANUARY 1, 1999 AND THEDATE OF THIS ORDER. IF THE IC FINDS THE DISTRIBUTION PLANUNACCEPTABLE, THE FIRM SHALL ATTEMPT TO REACH AN AGREEMENTWITH THE IC WITHIN 90 DAYS OF THE ENTRY OF THIS ORDER. IF BOTHPARTIES ARE UNABLE TO AGREE ON AN ALTERNATIVE PROPOSAL, THEFIRM SHALL ABIDE BY THE RECOMMENDATION OF THE IC. THIS FINALDISTRIBUTION PLAN MUST BE SUBMITTED TO AND ACCEPTED BY THECOMMISSION'S STAFF.20. THE FIRM SHALL COOPERATE FULLY WITH ANY REASONABLEREQUEST BY THE IC TO ACCESS FILES, BOOKS, RECORDS ANDPERSONNEL.21. UPON RECEIPT OF A TIMELY APPLICATION FROM THE IC OR THE FIRM,COMMISSION'S STAFF MAY EXTEND ANY OF THE PROCEDURAL DATES SETFORTH ABOVE.22. THE FIRM: (1) SHALL NOT TERMINATE THE IC, WITHOUT PRIORAPPROVAL OF THE COMMISSION'S STAFF; (2) SHALL COMPENSATE THE IC,AND PERSONS ENGAGED TO ASSIST THE IC AT THEIR CUSTOMARY RATES;(3) SHALL NOT HAVE AN ATTORNEY CLIENT RELATIONSHIP OR SEEK TOINVOKE THE ATTORNEY-CLIENT PRIVILEGE OR ANY OTHER DOCTRINE ORPRIVILEGE.






16. IN THE EVENT THAT THE FIRM AND THE IC DO NOT AGREE, THE FIRMSHALL ATTEMPT TO REACH AN AGREEMENT WITH THE IC. IF NOAGREEMENT IS REACHED THE FIRM AND THE IC SHALL JOINTLY CONFERWITH THE COMMISSION'S STAFF TO RESOLVE THE MATTER.17. WITHIN ONE YEAR THE IC WILL SUBMIT A FINAL REPORT TO THE FIRMAND THE COMMISSION'S STAFF. THE FINAL REPORT WILL ADDRESS THEFIRM'S COMPLIANCE WITH THE ORDER, ITS IMPLEMENTATION OFPOLICIES AND PROCEDURES AND MAKE FURTHER RECOMMENDATIONS IFDEEMED NECESSARY.18. WITHIN 30 DAYS OF THE IC'S FINAL REPORT, THE FIRM SHALL ADOPTTHE RECOMMENDATIONS CONTAINED IN THE FINAL REPORT.19. WITHIN 60 DAYS OF THIS ORDER THE FIRM SHALL SUBMIT TO THE IC ADISTRIBUTION PLAN FOR REVIEW. THE IC SHALL ADMINISTER ANDDISTRIBUTE THE SUMS ORDERED TO BE PAID PURSUANT TO THE SECORDER. THE DISTRIBUTION PLAN SHALL ADDRESS HOW THE SUMS SHALLBE DISTRIBUTED TO BENEFIT CUSTOMERS WHO PURCHASEDPREFERRED FAMILY MUTUAL FUNDS BETWEEN JANUARY 1, 1999 AND THEDATE OF THIS ORDER. IF THE IC FINDS THE DISTRIBUTION PLANUNACCEPTABLE, THE FIRM SHALL ATTEMPT TO REACH AN AGREEMENTWITH THE IC WITHIN 90 DAYS OF THE ENTRY OF THIS ORDER. IF BOTHPARTIES ARE UNABLE TO AGREE ON AN ALTERNATIVE PROPOSAL, THEFIRM SHALL ABIDE BY THE RECOMMENDATION OF THE IC. THIS FINALDISTRIBUTION PLAN MUST BE SUBMITTED TO AND ACCEPTED BY THECOMMISSION'S STAFF.20. THE FIRM SHALL COOPERATE FULLY WITH ANY REASONABLEREQUEST BY THE IC TO ACCESS FILES, BOOKS, RECORDS ANDPERSONNEL.21. UPON RECEIPT OF A TIMELY APPLICATION FROM THE IC OR THE FIRM,COMMISSION'S STAFF MAY EXTEND ANY OF THE PROCEDURAL DATES SETFORTH ABOVE.22. THE FIRM: (1) SHALL NOT TERMINATE THE IC, WITHOUT PRIORAPPROVAL OF THE COMMISSION'S STAFF; (2) SHALL COMPENSATE THE IC,AND PERSONS ENGAGED TO ASSIST THE IC AT THEIR CUSTOMARY RATES;(3) SHALL NOT HAVE AN ATTORNEY CLIENT RELATIONSHIP OR SEEK TOINVOKE THE ATTORNEY-CLIENT PRIVILEGE OR ANY OTHER DOCTRINE ORPRIVILEGE.

Disclosure 40 of 73

i


Allegations: SECTIONS 17(A), 17(A)(1), 17(A)(2) OF THE SECURITIES ACT AND RULES17A-4, 17A-4(B)(4) THEREUNDER SECTION 15B(C)(1) OF THE EXCHANGEACT, RULE 10B-10 UNDER THE EXCHANGE ACT, MUNICIPAL SECURITIESRULEMAKING BOARD RULE G-15, NASD CONDUCT RULES 2110, 2210,2830(K), 2830(I), 2820(G), 3110, 3010 – EDWARD JONES (THE "FIRM") AND ITSPARTNERS HAD A FINANCIAL INCENTIVE TO INTERNALLY PROMOTE THESALES OF MUTUAL FUNDS FROM THE PREFERRED FAMILIES OVER OTHERMUTUAL FUNDS THAT IS REGISTERED REPRESENTATIVES ("RRS") COULDSELL. IN ADDITION, THE FIRM PROMOTED TO ITS RRS THE EXISTENCE OFREVENUE SHARING BY PREFERRED FAMILIES AND ENCOURAGED RRS ONA CASE-BY-CASE BASIS TO CONSIDER REVENUE SHARING IN MAKINGRECOMMENDATIONS TO THEIR CUSTOMERS TO PURCHASE CERTAINMUTUAL FUNDS. THE FIRM TOLD THE PUBLIC AND ITS CLIENTS THAT ITWAS PROMOTING THE SALE OF THE PREFERRED FAMILIES' MUTUALFUNDS BECAUSE OF THE FUNDS' LONG-TERM INVESTMENT OBJECTIVESAND PERFORMANCE. AT THE SAME TIME, EDWARD JONES FAILED TODISCLOSE THAT IT RECEIVED TENS OF MILLIONS OF DOLLARS FROM THEPREFERRED FAMILIES EACH YEAR, ON TOP OF COMMISSIONS AND OTHERFEES, FOR SELLING THEIR MUTUAL FUNDS. THE FIRM DID NOT HAVESUFFICIENT PROCEDURES IN PLACE TO ENSURE THAT SOMEONE WITHAPPROPRIATE KNOWLEDGE, EXPERIENCE, AND AUTHORITY REVIEW THEPROSPECTUSES AND STATEMENTS OF ADDITIONAL INFORMATION ("SAIS")OF THE MUTUAL FUNDS OFFERED BY THE PREFERRED FAMILIES TODETERMINE IF THEY ADEQUATELY DISCLOSED REVENUE SHARING ANDDIRECTED BROKERAGE PAYMENTS MADE TO THE FIRM OR THE OTHERINCENTIVES OFFERED BY THE PREFERRED FAMILIES. MOREOVER,EDWARD JONES FAILED TO DISCLOSE THE MATERIAL FINANCIALINCENTIVES TO THE FIRM, ITS PARTNERS AND ITS RRS TO SELL 529PLANS FROM CERTAIN OF THE PREFERRED FAMILIES OVER THE OTHER529 PLANS THAT THE FIRM COULD SELL. EDWARD JONES RECEIVEDALMOST $18 MILLION IN DIRECTED BROKERAGE FROM THREE OF THEPREFERRED FAMILIES.







Initiated By: NASD




Docket/Case Number: CAF040115



SECTIONS 17(A), 17(A)(1), 17(A)(2) OF THE SECURITIES ACT AND RULES17A-4, 17A-4(B)(4) THEREUNDER SECTION 15B(C)(1) OF THE EXCHANGEACT, RULE 10B-10 UNDER THE EXCHANGE ACT, MUNICIPAL SECURITIESRULEMAKING BOARD RULE G-15, NASD CONDUCT RULES 2110, 2210,2830(K), 2830(I), 2820(G), 3110, 3010 – EDWARD JONES (THE "FIRM") AND ITSPARTNERS HAD A FINANCIAL INCENTIVE TO INTERNALLY PROMOTE THESALES OF MUTUAL FUNDS FROM THE PREFERRED FAMILIES OVER OTHERMUTUAL FUNDS THAT IS REGISTERED REPRESENTATIVES ("RRS") COULDSELL. IN ADDITION, THE FIRM PROMOTED TO ITS RRS THE EXISTENCE OFREVENUE SHARING BY PREFERRED FAMILIES AND ENCOURAGED RRS ONA CASE-BY-CASE BASIS TO CONSIDER REVENUE SHARING IN MAKINGRECOMMENDATIONS TO THEIR CUSTOMERS TO PURCHASE CERTAINMUTUAL FUNDS. THE FIRM TOLD THE PUBLIC AND ITS CLIENTS THAT ITWAS PROMOTING THE SALE OF THE PREFERRED FAMILIES' MUTUALFUNDS BECAUSE OF THE FUNDS' LONG-TERM INVESTMENT OBJECTIVESAND PERFORMANCE. AT THE SAME TIME, EDWARD JONES FAILED TODISCLOSE THAT IT RECEIVED TENS OF MILLIONS OF DOLLARS FROM THEPREFERRED FAMILIES EACH YEAR, ON TOP OF COMMISSIONS AND OTHERFEES, FOR SELLING THEIR MUTUAL FUNDS. THE FIRM DID NOT HAVESUFFICIENT PROCEDURES IN PLACE TO ENSURE THAT SOMEONE WITHAPPROPRIATE KNOWLEDGE, EXPERIENCE, AND AUTHORITY REVIEW THEPROSPECTUSES AND STATEMENTS OF ADDITIONAL INFORMATION ("SAIS")OF THE MUTUAL FUNDS OFFERED BY THE PREFERRED FAMILIES TODETERMINE IF THEY ADEQUATELY DISCLOSED REVENUE SHARING ANDDIRECTED BROKERAGE PAYMENTS MADE TO THE FIRM OR THE OTHERINCENTIVES OFFERED BY THE PREFERRED FAMILIES. MOREOVER,EDWARD JONES FAILED TO DISCLOSE THE MATERIAL FINANCIALINCENTIVES TO THE FIRM, ITS PARTNERS AND ITS RRS TO SELL 529PLANS FROM CERTAIN OF THE PREFERRED FAMILIES OVER THE OTHER529 PLANS THAT THE FIRM COULD SELL. EDWARD JONES RECEIVEDALMOST $18 MILLION IN DIRECTED BROKERAGE FROM THREE OF THEPREFERRED FAMILIES.


Resolution:

Other Sanctions Ordered: SIMULTANEOUSLY WITH THIS PROCEEDING, OTHER REGULATORS HAVEINSTITUTED REGULATORY PROCEEDINGS AGAINST EDWARD JONES. THEFIRM HAS AGREED TO PAY DISGORGEMENT PLUS INTEREST OF $37.5MILLION AND A CIVIL MONETARY PENALTY IN THE AMOUNT OF $37.5MILLION TO RESOLVE THIS NASD PROCEEDING AND OTHER REGULATORYPROCEEDINGS.


No

Sanctions Ordered: Censure






www.finra.org/brokercheck User GuidanceSIMULTANEOUSLY WITH THIS PROCEEDING, OTHER REGULATORS HAVEINSTITUTED REGULATORY PROCEEDINGS AGAINST EDWARD JONES. THEFIRM HAS AGREED TO PAY DISGORGEMENT PLUS INTEREST OF $37.5MILLION AND A CIVIL MONETARY PENALTY IN THE AMOUNT OF $37.5MILLION TO RESOLVE THIS NASD PROCEEDING AND OTHER REGULATORYPROCEEDINGS.

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, EDWARD JONESCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, FIRM IS CENSURED AND HAS AGREED TO THEFOLLOWING UNDERTAKINGS: MAINTAIN ON THE MUTUAL FUND AND 529PORTION OF ITS PUBLIC WEBSITE, WITHIN 15 DAYS OF ACCEPTANCE OFTHIS AWC, DISCLOSURES REGARDING PREFERRED MUTUAL FUND FAMILYPROGRAM TO INCLUDE: THE EXISTENCE OF THE PROGRAM AND THESALES OF 529 PLANS; THE MUTUAL FUND FAMILIES IN THE PROGRAM THEAMOUNT OF REVENUE SHARING PAYMENTS THAT THE FIRM RECEIVESFROM EACH PREFERRED FAMILIES EXPRESSED IN POINTS OR DOLLARS;THE TOTAL AMOUNT OF REVENUE SHARING PAYMENTS EXPRESSED INDOLLARS RECEIVED ANNUALLY STARING WITH THE AMOUNT RECEIVED IN2004; THE SOURCE OF SUCH PAYMENTS; THAT ITS RRS AND THE EQUITYOWNERS OF THE FIRM MAY BENEFIT FINANCIALLY FROM THE REVENUESHARING PAYMENTS THE FIRM RECEIVES; THE EDWARD JONES DOESNOT RECEIVE REVENUE SHARING PAYMENTS FROM ANY NON-PREFERRED MUTUAL FUND FAMILIES. THE FIRM SHALL SEND THE ABOVEINFORMATION TO ITS CURRENT CUSTOMERS WITHIN 60 DAYSACCEPTANCE OF THIS AWC AND NEW CUSTOMERS UPON OPENING OF ANACCOUNT. THE FIRM SHALL DEVISE AND IMPLEMENT A POLICY AND SETOF PROCEDURES TO ENSURE THAT THE FIRM IS COMPLYING WITH ITSDISCLOSURE OBLIGATIONS AND ENSURE STATEMENT MADE IN ITS PUBLICWEBSITE COMPLY WITH THIS AWC, FEDERAL LAWS AND MSRB RULES ANDARE OTHERWISE NOT MISLEADING; THE FIRM SHALL DEVISE ANDIMPLEMENT A POLICY AND SET OF PROCEDURES TO CONDUCTCOMPREHENSIVE REVIEWS OF ALL PROSPECTUSES AND SAIS ISSUED BYTHE PREFERRED FAMILIES ON A REGULAR BASIS AND DOCUMENT THEBASIS FOR ITS DECISIONS TO ADD OR REMOVE MUTUAL FUND FAMILIESFROM ITS LIST OF PREFERRED FAMILIES; THE FIRM SHALL DEVISE ANDIMPLEMENT A POLICY AND SET OF PROCEDURES FOR TRAINING RRSREGARDING THE DISCLOSURE OF FINANCIAL INCENTIVES THE FIRM, ITSRRS, GENERAL PARTNERS AND LIMITED PARTNERS RECEIVE FROM EACHOF THE PREFERRED FAMILIES.

Regulator Statement EACH OF THESE THREE PREFERRED FAMILIES ROUTED PORTFOLIOTRADES TO A CLEARING FIRM, AND AS PART OF THE TRADE SETTLEMENT,INCLUDED A COMMISSION PAYMENT TO THE CLEARING FIRM. THECLEARING FIRM, IN TURN, RETAINED A FEE FOR ITS EXECUTION ANDCLEARANCE SERVICES AND CREDITED THE REMAINDER OF THECOMMISSION PAYMENTS TO EDWARD JONES. THESE "STEP-OUT"ARRANGEMENTS WERE PART OF THE FIRM'S OVERALL REVENUESHARING PROGRAM THOUGH WHICH IT FAVORED THE SALE OFPREFERRED FAMILY MUTUAL FUNDS TO ITS CUSTOMERS BY, AMONGOTHER THINGS, INCLUDING FUNDS FROM THESE FUND FAMILIES ON ITSPREFERRED FUND LIST. IN ADDITION, EDWARD JONES HELD ANUNLAWFUL SALES CONTEST. DURING OCTOBER 2002, THE FIRM CHANGEDTHE CONTEST RULES AND ONLY CREDITED SALES OF FUNDS THAT WEREON THE PREFERRED FUNDS LIST. THE FIRM, BY EXCLUDING MUTUALFUNDS AND VARIABLE ANNUITIES THAT WERE NOT ON THE PREFERREDFUNDS LIST, CREATED A PRODUCT SPECIFIC CONTEST IN WHICH SALESWERE NOT EQUALLY WEIGHED FOR AT LEAST THE FIRST HALF OF THECONTEST PERIOD. FURTHERMORE, EDWARD JONES FAILED TOPRESERVE HOME OFFICE AND WIRE E-MAILS FOR AN EIGHT-MONTHPERIOD AND FAILED TO PRESERVE INTERNET EMAILS FOR ONE YEAR.FURTHER, THE FIRM FAILED TO RETAIN HOME OFFICE EMAILS SENT ANDRECEIVED DURING A NINE-MONTH PERIOD IN A READILY ACCESSIBLEPLACE. MOREOVER, THE FIRM DID NOT HAVE ADEQUATE POLICIES ANDPROCEDURES IN PLACE TO APPROVE RELEASED TRADES OR TODETERMINE WHETHER TRADES WERE LEGITIMATELY ALLOCATED THESAME DAY'S NET ASSET VALUE ("NAV") UNTIL NOVEMBER 2003. EDWARDJONES ALSO DID NOT HAVE POLICIES AND/OR PROCEDURES FORSUPERVISORY REVIEW OF DECISIONS TO GRANT REQUEST FORRELEASED TRADES. FINALLY, THE FIRM DID NOT REASONABLY SUPERVISETHE ACTIVITIES RELATED TO THE SALE OF PREFERRED FAMILY MUTUALFUNDS AND 529 PLANS, REVENUE SHARING, DIRECTED BROKERAGE,SALES CONTEST, THE PRESERVATION OF EMAILS, AND LATE TRADING.






EACH OF THESE THREE PREFERRED FAMILIES ROUTED PORTFOLIOTRADES TO A CLEARING FIRM, AND AS PART OF THE TRADE SETTLEMENT,INCLUDED A COMMISSION PAYMENT TO THE CLEARING FIRM. THECLEARING FIRM, IN TURN, RETAINED A FEE FOR ITS EXECUTION ANDCLEARANCE SERVICES AND CREDITED THE REMAINDER OF THECOMMISSION PAYMENTS TO EDWARD JONES. THESE "STEP-OUT"ARRANGEMENTS WERE PART OF THE FIRM'S OVERALL REVENUESHARING PROGRAM THOUGH WHICH IT FAVORED THE SALE OFPREFERRED FAMILY MUTUAL FUNDS TO ITS CUSTOMERS BY, AMONGOTHER THINGS, INCLUDING FUNDS FROM THESE FUND FAMILIES ON ITSPREFERRED FUND LIST. IN ADDITION, EDWARD JONES HELD ANUNLAWFUL SALES CONTEST. DURING OCTOBER 2002, THE FIRM CHANGEDTHE CONTEST RULES AND ONLY CREDITED SALES OF FUNDS THAT WEREON THE PREFERRED FUNDS LIST. THE FIRM, BY EXCLUDING MUTUALFUNDS AND VARIABLE ANNUITIES THAT WERE NOT ON THE PREFERREDFUNDS LIST, CREATED A PRODUCT SPECIFIC CONTEST IN WHICH SALESWERE NOT EQUALLY WEIGHED FOR AT LEAST THE FIRST HALF OF THECONTEST PERIOD. FURTHERMORE, EDWARD JONES FAILED TOPRESERVE HOME OFFICE AND WIRE E-MAILS FOR AN EIGHT-MONTHPERIOD AND FAILED TO PRESERVE INTERNET EMAILS FOR ONE YEAR.FURTHER, THE FIRM FAILED TO RETAIN HOME OFFICE EMAILS SENT ANDRECEIVED DURING A NINE-MONTH PERIOD IN A READILY ACCESSIBLEPLACE. MOREOVER, THE FIRM DID NOT HAVE ADEQUATE POLICIES ANDPROCEDURES IN PLACE TO APPROVE RELEASED TRADES OR TODETERMINE WHETHER TRADES WERE LEGITIMATELY ALLOCATED THESAME DAY'S NET ASSET VALUE ("NAV") UNTIL NOVEMBER 2003. EDWARDJONES ALSO DID NOT HAVE POLICIES AND/OR PROCEDURES FORSUPERVISORY REVIEW OF DECISIONS TO GRANT REQUEST FORRELEASED TRADES. FINALLY, THE FIRM DID NOT REASONABLY SUPERVISETHE ACTIVITIES RELATED TO THE SALE OF PREFERRED FAMILY MUTUALFUNDS AND 529 PLANS, REVENUE SHARING, DIRECTED BROKERAGE,SALES CONTEST, THE PRESERVATION OF EMAILS, AND LATE TRADING.


Allegations: IN THE EARLY 1990S EDWARD JONES ("THE FIRM") NEGOTIATED REVENUESHARING PLANS WITH 7 FUND FAMILIES WHICH HAD BEEN DESIGNATEDAS "PREFERRED FUNDS".

THE FIRM DID NOT ADEQUATELY DISCLOSE ITS INCENTIVES TO SELLMUTUAL FUNDS FROM THE 7 PREFERRED FAMILIES BUT RELIED ONLANGUAGE PERTAINING TO REVENUE SHARING FOUND IN THEPROSPECTUSES AND STATEMENTS OF ADDITIONAL INFORMATION (SAIS)PROVIDED AT THE POINT OF SALE. DURING THE RELEVANT PERIODPROCEDURES WERE NOT IN PLACE BY THE FIRM TO ENSURE THAT THEPROSPECTUSES AND SAIS ADEQUATELY DISCLOSED REVENUE SHARING,DIRECTED BROKERAGE PAYMENTS OR OTHER INCENTIVES OFFERED TOTHE FIRM.

SINCE 2000 THE FIRM HAS SOLD 529 COLLEGE SAVINGS PLANS TO ITSCUSTOMERS AND ALTHOUGH IT HAS SELLING AGREEMENTS WITH 14MUTUAL FUND COMPANIES, THE FIRM PROMOTES ONLY THE 529 PLANSFROM CERTAIN PREFERRED FAMILIES. BASED ON THE CONDUCTDESCRIBED ABOVE, THE FIRM WILLFULLY VIOLATED SEC. 17(A)(2) OF THESECURITIES ACT, NASD RULE 2110, RULE 10B-10 UNDER THE EXCHANGEACT, §15B(C)(1) OF THE EXCHANGE ACT AND NASD RULE 2210 AND 2110.

WITH REGARD TO 529 SAVINGS PLANS, THE FIRM CONTRAVENED THEDICTATES OF MSRB RULE G-15 AND §15B(C)(1) OF THE EXCHANGE ACT.

ADDITIONAL ALLEGATIONS:THE FIRM IMPROPERLY FAVORED THE SALE OF MUTUAL FUNDS ON THEBASIS OF BROKERAGE COMMISSIONS IN VIOLATION OF NASD RULES2830(K) AND 2110.THE FIRM USED UNLAWFUL SALES CONDUCT IN HOLDING SALES TRIPINCENTIVE PROGRAMS AND ALLOWED IRS TO "WIN" VACATIONS INVIOLATION OF NASD RULES 2830(L), 2820(G) AND 2110.THE FIRM FAILED TO PRESERVE AND RETAIN EMAILS IN A READILYACCESSIBLE PLACE FOR 2 YEARS VIOLATING §17(A) OF THE EXCHANGEACT AND RULE 17A-4 AND NASD RULES 3110 AND 2110.THE FIRM FAILED TO SUPERVISE LATE TRADING VIOLATING NASD RULES3010 AND 2110.THE FIRM FAILED TO SUPERVISE, ESTABLISH, MAINTAIN AND ENFORCEADEQUATE WRITTEN SUPERVISORY PROCEDURES AND SYSTEMSRELATED TO SALES OF PREFERRED FAMILY MUTUAL FUNDS AND 529SAVINGS PLANS, VIOLATING NASD RULES 3010 AND 2110.









Censure


MONETARY FINE OF $75 MILLION DOLLARS





IN THE EARLY 1990S EDWARD JONES ("THE FIRM") NEGOTIATED REVENUESHARING PLANS WITH 7 FUND FAMILIES WHICH HAD BEEN DESIGNATEDAS "PREFERRED FUNDS".

THE FIRM DID NOT ADEQUATELY DISCLOSE ITS INCENTIVES TO SELLMUTUAL FUNDS FROM THE 7 PREFERRED FAMILIES BUT RELIED ONLANGUAGE PERTAINING TO REVENUE SHARING FOUND IN THEPROSPECTUSES AND STATEMENTS OF ADDITIONAL INFORMATION (SAIS)PROVIDED AT THE POINT OF SALE. DURING THE RELEVANT PERIODPROCEDURES WERE NOT IN PLACE BY THE FIRM TO ENSURE THAT THEPROSPECTUSES AND SAIS ADEQUATELY DISCLOSED REVENUE SHARING,DIRECTED BROKERAGE PAYMENTS OR OTHER INCENTIVES OFFERED TOTHE FIRM.

SINCE 2000 THE FIRM HAS SOLD 529 COLLEGE SAVINGS PLANS TO ITSCUSTOMERS AND ALTHOUGH IT HAS SELLING AGREEMENTS WITH 14MUTUAL FUND COMPANIES, THE FIRM PROMOTES ONLY THE 529 PLANSFROM CERTAIN PREFERRED FAMILIES. BASED ON THE CONDUCTDESCRIBED ABOVE, THE FIRM WILLFULLY VIOLATED SEC. 17(A)(2) OF THESECURITIES ACT, NASD RULE 2110, RULE 10B-10 UNDER THE EXCHANGEACT, §15B(C)(1) OF THE EXCHANGE ACT AND NASD RULE 2210 AND 2110.

WITH REGARD TO 529 SAVINGS PLANS, THE FIRM CONTRAVENED THEDICTATES OF MSRB RULE G-15 AND §15B(C)(1) OF THE EXCHANGE ACT.

ADDITIONAL ALLEGATIONS:THE FIRM IMPROPERLY FAVORED THE SALE OF MUTUAL FUNDS ON THEBASIS OF BROKERAGE COMMISSIONS IN VIOLATION OF NASD RULES2830(K) AND 2110.THE FIRM USED UNLAWFUL SALES CONDUCT IN HOLDING SALES TRIPINCENTIVE PROGRAMS AND ALLOWED IRS TO "WIN" VACATIONS INVIOLATION OF NASD RULES 2830(L), 2820(G) AND 2110.THE FIRM FAILED TO PRESERVE AND RETAIN EMAILS IN A READILYACCESSIBLE PLACE FOR 2 YEARS VIOLATING §17(A) OF THE EXCHANGEACT AND RULE 17A-4 AND NASD RULES 3110 AND 2110.THE FIRM FAILED TO SUPERVISE LATE TRADING VIOLATING NASD RULES3010 AND 2110.THE FIRM FAILED TO SUPERVISE, ESTABLISH, MAINTAIN AND ENFORCEADEQUATE WRITTEN SUPERVISORY PROCEDURES AND SYSTEMSRELATED TO SALES OF PREFERRED FAMILY MUTUAL FUNDS AND 529SAVINGS PLANS, VIOLATING NASD RULES 3010 AND 2110.


Resolution:

Other Sanctions Ordered: SIMULTANEOUSLY WITH THIS PROCEEDING, THE SEC AND THE NYSE HAVEINSTITUTED PROCEEDINGS AGAINST THE FIRM. THE FIRM HAS AGREEDTO PAY DISGORGEMENT PLUS PREJUDGMENT INTEREST OF $37.5 MILLION("DISGORGEMENT") AND A CIVIL MONETARY PENALTY IN THE AMOUNT OF$37.5 MILLION ("PENALTIES") TO RESOLVE THE NASD, SEC AND NYSEPROCEEDINGS AND SUCH TOTAL PAYMENT OF $75 MILLION WILL BE MADEAS DESCRIBED IN THE SEC PROCEEDING. THE FIRM HAS FURTHERCONSENTED TO A CENSURE AND HAS AGREED TO THE FOLLOWINGUNDERTAKINGS:

(A) THE FIRM SHALL PLACE AND MAINTAIN ON ITS PUBLIC WEBSITEWITHIN 15 DAYS SPECIFIC DISCLOSURES REGARDING ITS PREFERREDMUTUAL FUND FAMILY PROGRAM.

(B) THE FIRM SHALL PLACE AND MAINTAIN ON ITS PUBLIC WEBSITEWITHIN 15 DAYS SPECIFIC DISCLOSURES REGARDING 529 PLANS OF ITSPREFERRED MUTUAL FUND FAMILY PROGRAM.

(C) WITHIN 60 DAYS THE FIRM WILL SEND INFORMATION REGARDING THESPECIFIED DISCLOSURES IN A AND B TO NEW ACCOUNT CUSTOMERSBEFORE AND AFTER THE COMPLETION OF EACH MUTUAL FUND AND 529PLAN TRANSACTION AND QUARTERLY PURSUANT TO PERIODIC PLANS INCOMPLIANCE WITH EXCHANGE ACT RULE 10B-10 AND MSRB RULE G-15.

(D) THE FIRM SHALL IMPLEMENT WITHIN 60 DAYS A POLICY ANDPROCEDURE TO CONDUCT REVIEWS OF ALL PROSPECTUSES AND SAIS,AS WELL AS THE PUBLIC WEBSITE, ON A REGULAR BASIS TO ENSURETHAT THE FIRM IS IN COMPLIANCE WITH THE DISCLOSURE OBLIGATIONUNDER THIS AWC, THE FEDERAL SECURITIES LAWS AND THE MSRBRULES.

(E) WITHIN 60 DAYS THE FIRM SHALL ESTABLISH POLICIES ANDPROCEDURES TO DOCUMENT ITS BASIS FOR ADDING OR REMOVINGMUTUAL FUND FAMILIES FROM ITS PREFERRED LIST.

(F) WITHIN 60 DAYS POLICIES AND PROCEDURES SHALL BE ESTABLISHEDTO TRAIN IRS IN THE DISCLOSURE OF INCENTIVES THAT INDIVIDUALSWITH THE FIRM RECEIVE FROM THE PREFERRED FUNDS.

(G) WITHIN 60 DAYS THE FIRM SHALL RETAIN THE SERVICES OF ANINDEPENDENT CONSULTANT ("IC") ACCEPTABLE TO NASD STAFF TOCONDUCT A REVIEW OF THE POLICIES AND PROCEDURES THAT THE FIRMIS REQUIRED TO DEVISE UNDER THIS AWC.

Sanctions Ordered: CensureMonetary/Fine $75,000,000.00Disgorgement/Restitution







SIMULTANEOUSLY WITH THIS PROCEEDING, THE SEC AND THE NYSE HAVEINSTITUTED PROCEEDINGS AGAINST THE FIRM. THE FIRM HAS AGREEDTO PAY DISGORGEMENT PLUS PREJUDGMENT INTEREST OF $37.5 MILLION("DISGORGEMENT") AND A CIVIL MONETARY PENALTY IN THE AMOUNT OF$37.5 MILLION ("PENALTIES") TO RESOLVE THE NASD, SEC AND NYSEPROCEEDINGS AND SUCH TOTAL PAYMENT OF $75 MILLION WILL BE MADEAS DESCRIBED IN THE SEC PROCEEDING. THE FIRM HAS FURTHERCONSENTED TO A CENSURE AND HAS AGREED TO THE FOLLOWINGUNDERTAKINGS:

(A) THE FIRM SHALL PLACE AND MAINTAIN ON ITS PUBLIC WEBSITEWITHIN 15 DAYS SPECIFIC DISCLOSURES REGARDING ITS PREFERREDMUTUAL FUND FAMILY PROGRAM.

(B) THE FIRM SHALL PLACE AND MAINTAIN ON ITS PUBLIC WEBSITEWITHIN 15 DAYS SPECIFIC DISCLOSURES REGARDING 529 PLANS OF ITSPREFERRED MUTUAL FUND FAMILY PROGRAM.

(C) WITHIN 60 DAYS THE FIRM WILL SEND INFORMATION REGARDING THESPECIFIED DISCLOSURES IN A AND B TO NEW ACCOUNT CUSTOMERSBEFORE AND AFTER THE COMPLETION OF EACH MUTUAL FUND AND 529PLAN TRANSACTION AND QUARTERLY PURSUANT TO PERIODIC PLANS INCOMPLIANCE WITH EXCHANGE ACT RULE 10B-10 AND MSRB RULE G-15.

(D) THE FIRM SHALL IMPLEMENT WITHIN 60 DAYS A POLICY ANDPROCEDURE TO CONDUCT REVIEWS OF ALL PROSPECTUSES AND SAIS,AS WELL AS THE PUBLIC WEBSITE, ON A REGULAR BASIS TO ENSURETHAT THE FIRM IS IN COMPLIANCE WITH THE DISCLOSURE OBLIGATIONUNDER THIS AWC, THE FEDERAL SECURITIES LAWS AND THE MSRBRULES.

(E) WITHIN 60 DAYS THE FIRM SHALL ESTABLISH POLICIES ANDPROCEDURES TO DOCUMENT ITS BASIS FOR ADDING OR REMOVINGMUTUAL FUND FAMILIES FROM ITS PREFERRED LIST.

(F) WITHIN 60 DAYS POLICIES AND PROCEDURES SHALL BE ESTABLISHEDTO TRAIN IRS IN THE DISCLOSURE OF INCENTIVES THAT INDIVIDUALSWITH THE FIRM RECEIVE FROM THE PREFERRED FUNDS.

(G) WITHIN 60 DAYS THE FIRM SHALL RETAIN THE SERVICES OF ANINDEPENDENT CONSULTANT ("IC") ACCEPTABLE TO NASD STAFF TOCONDUCT A REVIEW OF THE POLICIES AND PROCEDURES THAT THE FIRMIS REQUIRED TO DEVISE UNDER THIS AWC.

Sanction Details: (H) WITHIN 120 DAYS THE IC SHALL SUBMIT AN INITIAL REPORT TO THENASD STAFF AND THE FIRM WHICH WILL INCLUDE THE ADEQUACY OFPOLICIES AND PROCEDURES REQUIRED TO BE IMPLEMENTED UNDERTHIS AWC, WHETHER THE DISCLOSURE OF REVENUE SHARING IS INCOMPLETE COMPLIANCE WITH THE AWC, A DESCRIPTION OF THE REVIEWPERFORMED, CONCLUSIONS REACHED, RECOMMENDATIONS FORMODIFICATIONS AND ADDITIONS TO THE POLICIES AND PROCEDURESDEVISED AND IMPLEMENTED BY THE FIRM.

(I) WITHIN 150 DAYS THE FIRM SHALL IN WRITING ADVISE THE IC AND THENASD STAFF OF THE RECOMMENDATIONS FROM THE INITIAL REPORTTHAT IT IS ADOPTING AND THE RECOMMENDATIONS IT CONSIDERSINAPPROPRIATE WITH AN EXPLANATION OF WHY IT IS INAPPROPRIATEAND PROVIDE AN ALTERNATIVE TO ACHIEVE THE SAME OBJECTIVE.

(J) IN THE EVENT THAT THE FIRM AND THE IC DO NOT AGREE, THE FIRMSHALL ATTEMPT IN GOOD FAITH TO REACH AN AGREEMENT WITH THE IC.IF NO AGREEMENT IS REACHED THE FIRM AND THE IC SHALL JOINTLYCONFER WITH THE NASD STAFF TO RESOLVE THE MATTER.

(K) WITHIN ONE YEAR THE IC WILL SUBMIT A FINAL REPORT TO THE FIRMAND THE NASD STAFF. THE FINAL REPORT WILL ADDRESS THE FIRMCOMPLIANCE WITH THE AWC, ITS IMPLEMENTATION OF POLICIES ANDPROCEDURES AND MAKE FURTHER RECOMMENDATIONS IF DEEMEDNECESSARY.

(L) WITHIN 30 DAYS OF THE IC'S FINAL REPORT, THE FIRM SHALL ADOPTTHE RECOMMENDATIONS CONTAINED IN THE FINAL REPORT.

(M) WITHIN 60 DAYS OF THIS AWC THE FIRM SHALL SUBMIT TO THE IC ADISTRIBUTION PLAN FOR REVIEW. THE IC SHALL ADMINISTER ANDDISTRIBUTE THE SUMS ORDERED TO BE PAID PURSUANT TO §IV.C OF THESEC ORDER. THE DISTRIBUTION PLAN SHALL ADDRESS HOW THE SUMSSHALL BE DISTRIBUTED TO BENEFIT CUSTOMERS WHO PURCHASEDPREFERRED FAMILY MUTUAL FUNDS BETWEEN JANUARY 1, 1999 AND THE(CONT. IN 13.)





www.finra.org/brokercheck User Guidance(H) WITHIN 120 DAYS THE IC SHALL SUBMIT AN INITIAL REPORT TO THENASD STAFF AND THE FIRM WHICH WILL INCLUDE THE ADEQUACY OFPOLICIES AND PROCEDURES REQUIRED TO BE IMPLEMENTED UNDERTHIS AWC, WHETHER THE DISCLOSURE OF REVENUE SHARING IS INCOMPLETE COMPLIANCE WITH THE AWC, A DESCRIPTION OF THE REVIEWPERFORMED, CONCLUSIONS REACHED, RECOMMENDATIONS FORMODIFICATIONS AND ADDITIONS TO THE POLICIES AND PROCEDURESDEVISED AND IMPLEMENTED BY THE FIRM.

(I) WITHIN 150 DAYS THE FIRM SHALL IN WRITING ADVISE THE IC AND THENASD STAFF OF THE RECOMMENDATIONS FROM THE INITIAL REPORTTHAT IT IS ADOPTING AND THE RECOMMENDATIONS IT CONSIDERSINAPPROPRIATE WITH AN EXPLANATION OF WHY IT IS INAPPROPRIATEAND PROVIDE AN ALTERNATIVE TO ACHIEVE THE SAME OBJECTIVE.

(J) IN THE EVENT THAT THE FIRM AND THE IC DO NOT AGREE, THE FIRMSHALL ATTEMPT IN GOOD FAITH TO REACH AN AGREEMENT WITH THE IC.IF NO AGREEMENT IS REACHED THE FIRM AND THE IC SHALL JOINTLYCONFER WITH THE NASD STAFF TO RESOLVE THE MATTER.

(K) WITHIN ONE YEAR THE IC WILL SUBMIT A FINAL REPORT TO THE FIRMAND THE NASD STAFF. THE FINAL REPORT WILL ADDRESS THE FIRMCOMPLIANCE WITH THE AWC, ITS IMPLEMENTATION OF POLICIES ANDPROCEDURES AND MAKE FURTHER RECOMMENDATIONS IF DEEMEDNECESSARY.

(L) WITHIN 30 DAYS OF THE IC'S FINAL REPORT, THE FIRM SHALL ADOPTTHE RECOMMENDATIONS CONTAINED IN THE FINAL REPORT.

(M) WITHIN 60 DAYS OF THIS AWC THE FIRM SHALL SUBMIT TO THE IC ADISTRIBUTION PLAN FOR REVIEW. THE IC SHALL ADMINISTER ANDDISTRIBUTE THE SUMS ORDERED TO BE PAID PURSUANT TO §IV.C OF THESEC ORDER. THE DISTRIBUTION PLAN SHALL ADDRESS HOW THE SUMSSHALL BE DISTRIBUTED TO BENEFIT CUSTOMERS WHO PURCHASEDPREFERRED FAMILY MUTUAL FUNDS BETWEEN JANUARY 1, 1999 AND THE(CONT. IN 13.)

Firm Statement (DATE OF THIS ORDER. IF THE IC FINDS THE DISTRIBUTION PLANUNACCEPTABLE, THE FIRM SHALL ATTEMPT IN GOOD FAITH TO REACH ANAGREEMENT WITH THE IC WITHIN 90 DAYS OF THE ENTRY OF THISORDER. IF BOTH PARTIES ARE UNABLE TO AGREE ON AN ALTERNATIVEPROPOSAL, THE FIRM SHALL ABIDE BY THE RECOMMENDATION OF THE IC.THIS FINAL DISTRIBUTION PLAN MUST BE SUBMITTED TO AND ACCEPTEDBY THE NASD STAFF.

(N) THE FIRM SHALL COOPERATE FULLY WITH ANY REASONABLEREQUEST BY THE IC TO ACCESS FILES, BOOKS, RECORDS ANDPERSONNEL.

(O) FOR GOOD CAUSE SHOWN, AND UPON RECEIPT OF A TIMELYAPPLICATION FROM THE IC OR THE FIRM, NASD STAFF MAY EXTEND ANYOF THE PROCEDURAL DATES SET FORTH ABOVE.

(P) TO ENSURE THE INDEPENDENCE OF THE IC, THE FIRM: (1) SHALL NOTHAVE THE AUTHORITY TO TERMINATE THE IC, WITHOUT PRIOR APPROVALOF THE NASD STAFF; (2) SHALL COMPENSATE THE IC, AND PERSONSENGAGED TO ASSIST THE IC AT THEIR REASONABLE AND CUSTOMARYRATES; (3) SHALL NOT HAVE AN ATTORNEY CLIENT RELATIONSHIP ORSEEK TO INVOKE THE ATTORNEY-CLIENT PRIVILEGE OR ANY OTHERDOCTRINE OR PRIVILEGE IN PREVENTING THE IC FROM TRANSMITTINGINFORMATION, REPORTS OR DOCUMENTS TO NASD STAFF.

(Q) THE FIRM SHALL REQUIRE THE IC TO ENTER INTO AN AGREEMENTTHAT PROVIDES THAT FOR THE PERIOD OF ENGAGEMENT AND TWOYEARS FROM COMPLETION OF THE ENGAGEMENT, THE IC SHALL NOTENTER INTO ANY EMPLOYMENT, CONSULTANT, ATTORNEY-CLIENT,AUDITING OR OTHER PROFESSIONAL RELATIONSHIP WITH THE FIRM ORANY OF ITS PRESENT OR FORMER AFFILIATES, DIRECTORS, OFFICERS,EMPLOYEES, OR AGENTS ACTING IN THEIR CAPACITY. ANY FIRM USED BYTHE IC OR AFFILIATED IN PERFORMANCE OF HIS OR HER DUTIES UNDERTHIS AWC SHALL NOT, WITHOUT PRIOR WRITTEN CONSENT OF NASDSTAFF, ENTER INTO ANY EMPLOYMENT, CONSULTANT, ATTORNEY-CLIENT,AUDITING OR OTHER PROFESSIONAL RELATIONSHIP WITH THE FIRM, ORANY OF ITS PRESENT OR FORMER AFFILIATES, DIRECTORS, OFFICERS,EMPLOYEES OR AGENTS ACTING IN THEIR CAPACITY FOR THE PERIOD OFENGAGEMENT AND TWO YEARS AFTER THE ENGAGEMENT.






(DATE OF THIS ORDER. IF THE IC FINDS THE DISTRIBUTION PLANUNACCEPTABLE, THE FIRM SHALL ATTEMPT IN GOOD FAITH TO REACH ANAGREEMENT WITH THE IC WITHIN 90 DAYS OF THE ENTRY OF THISORDER. IF BOTH PARTIES ARE UNABLE TO AGREE ON AN ALTERNATIVEPROPOSAL, THE FIRM SHALL ABIDE BY THE RECOMMENDATION OF THE IC.THIS FINAL DISTRIBUTION PLAN MUST BE SUBMITTED TO AND ACCEPTEDBY THE NASD STAFF.

(N) THE FIRM SHALL COOPERATE FULLY WITH ANY REASONABLEREQUEST BY THE IC TO ACCESS FILES, BOOKS, RECORDS ANDPERSONNEL.

(O) FOR GOOD CAUSE SHOWN, AND UPON RECEIPT OF A TIMELYAPPLICATION FROM THE IC OR THE FIRM, NASD STAFF MAY EXTEND ANYOF THE PROCEDURAL DATES SET FORTH ABOVE.

(P) TO ENSURE THE INDEPENDENCE OF THE IC, THE FIRM: (1) SHALL NOTHAVE THE AUTHORITY TO TERMINATE THE IC, WITHOUT PRIOR APPROVALOF THE NASD STAFF; (2) SHALL COMPENSATE THE IC, AND PERSONSENGAGED TO ASSIST THE IC AT THEIR REASONABLE AND CUSTOMARYRATES; (3) SHALL NOT HAVE AN ATTORNEY CLIENT RELATIONSHIP ORSEEK TO INVOKE THE ATTORNEY-CLIENT PRIVILEGE OR ANY OTHERDOCTRINE OR PRIVILEGE IN PREVENTING THE IC FROM TRANSMITTINGINFORMATION, REPORTS OR DOCUMENTS TO NASD STAFF.

(Q) THE FIRM SHALL REQUIRE THE IC TO ENTER INTO AN AGREEMENTTHAT PROVIDES THAT FOR THE PERIOD OF ENGAGEMENT AND TWOYEARS FROM COMPLETION OF THE ENGAGEMENT, THE IC SHALL NOTENTER INTO ANY EMPLOYMENT, CONSULTANT, ATTORNEY-CLIENT,AUDITING OR OTHER PROFESSIONAL RELATIONSHIP WITH THE FIRM ORANY OF ITS PRESENT OR FORMER AFFILIATES, DIRECTORS, OFFICERS,EMPLOYEES, OR AGENTS ACTING IN THEIR CAPACITY. ANY FIRM USED BYTHE IC OR AFFILIATED IN PERFORMANCE OF HIS OR HER DUTIES UNDERTHIS AWC SHALL NOT, WITHOUT PRIOR WRITTEN CONSENT OF NASDSTAFF, ENTER INTO ANY EMPLOYMENT, CONSULTANT, ATTORNEY-CLIENT,AUDITING OR OTHER PROFESSIONAL RELATIONSHIP WITH THE FIRM, ORANY OF ITS PRESENT OR FORMER AFFILIATES, DIRECTORS, OFFICERS,EMPLOYEES OR AGENTS ACTING IN THEIR CAPACITY FOR THE PERIOD OFENGAGEMENT AND TWO YEARS AFTER THE ENGAGEMENT.

Disclosure 41 of 73

i


Initiated By: NASD



Allegations: ARTICLE V, SECTIONS 2(C) AND 3(B) OF NASD'S BY-LAWS, AND NASDRULES 2110 AND 3010 - EDWARD JONES ("RESPONDENT FIRM") FILED ATLEAST 280 LATE AMENDMENTS TO FORMS U4 AND U5, WHICHREPRESENTED APPROXIMATELY 27% OF THE REQUIRED AMENDMENTSRELATING TO REPORTABLE CUSTOMER COMPLAINTS, TERMINATIONS,REGULATORY ACTIONS, AND CRIMINAL DISCLOSURES. DURING THERELEVANT PERIOD, THE RESPONDENT FIRM'S SUPERVISORY SYSTEMAND PROCEDURES WERE NOT REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH ITS ARTICLE V REPORTING OBLIGATIONS.













Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, IT IS CENSURED AND FINED $300,000, WHICHSHALL BE PAID WITHIN 10 DAYS OF NOTICE OF ACCEPTANCE OF THISAWC. IN ADDITION RESPONDENT FIRM SHALL COMPLY WITH THEFOLLOWING UNDERTAKINGS: (1) PROMPTLY FOLLOWING NOTICE OFACCEPTANCE OF THIS AWC, THE FIRM'S INTERNAL AUDIT DEPARTMENTOR PERSONNEL NOT DIRECTLY RESPONSIBLE FOR THE FIRM'S ARTICLE VREPORTING OBLIGATIONS AND THEIR IMMEDIATE SUPERVISORS SHALLCONDUCT AN AUDIT TO ASSESS THE EFFECTIVENESS OF ITS SYSTEM ANDPROCEDURES FOR ENSURING TIMELY FILING OF FORM U4 AND U5AMENDMENTS SUMMARIZING FINDINGS AND RECOMMENDATIONS ANDSHALL FOR THE NEXT FOUR CALENDAR QUARTERS BEGINNING FOURTHQUARTER 2004, CONDUCT A SIMILAR AUDIT AND PREPARE A SIMILARWRITTEN AUDIT REPORT. (2) NO LATER THAN 90 DAYS AFTER NOTICE OFACCEPTANCE OF THIS AWC, AN OFFICER OF THE FIRM SHALL CERTIFY INWRITING TO NASD THAT AN AUDIT WAS CONDUCTED AND THE OFFICERHAS REVIEWED THE CURRENT AUDIT REPORT. (3) NO LATER THAN 60DAYS AFTER THE DATE OF THE CURRENT AUDIT REPORT, AN OFFICERSHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HAS IMPLEMENTED,OR HAS BEGUN TO IMPLEMENT, ANY RECOMMENDATIONS WITHIN ASPECIFIED TIME PERIOD. (4) NO LATER THAN 60 DAYS AFTER THE LASTDAY OF THE NEXT FOUR QUARTERS, AN OFFICER SHALL CERTIFY INWRITING TO NASD THAT AN AUDIT WAS CONDUCTED, THE CURRENT AUDITREPORT WAS REVIEWED, AND RECOMMENDATIONS IMPLEMENTED, ORBEGUN TO BE IMPLEMENTED. (5) NO LATER THAN SIX MONTHS AFTERNOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICER SHALL CERTIFY INWRITING TO NASD THAT THE FIRM HAS REVIEWED ITS SYSTEM ANDPROCEDURES FOR COMPLYING WITH ITS ARTICLE V REPORTINGOBLIGATIONS AND HAS ESTABLISHED A SYSTEM AND PROCEDURESREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REPORTINGREQUIREMENTS SET FORTH THEREIN.


No








WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, IT IS CENSURED AND FINED $300,000, WHICHSHALL BE PAID WITHIN 10 DAYS OF NOTICE OF ACCEPTANCE OF THISAWC. IN ADDITION RESPONDENT FIRM SHALL COMPLY WITH THEFOLLOWING UNDERTAKINGS: (1) PROMPTLY FOLLOWING NOTICE OFACCEPTANCE OF THIS AWC, THE FIRM'S INTERNAL AUDIT DEPARTMENTOR PERSONNEL NOT DIRECTLY RESPONSIBLE FOR THE FIRM'S ARTICLE VREPORTING OBLIGATIONS AND THEIR IMMEDIATE SUPERVISORS SHALLCONDUCT AN AUDIT TO ASSESS THE EFFECTIVENESS OF ITS SYSTEM ANDPROCEDURES FOR ENSURING TIMELY FILING OF FORM U4 AND U5AMENDMENTS SUMMARIZING FINDINGS AND RECOMMENDATIONS ANDSHALL FOR THE NEXT FOUR CALENDAR QUARTERS BEGINNING FOURTHQUARTER 2004, CONDUCT A SIMILAR AUDIT AND PREPARE A SIMILARWRITTEN AUDIT REPORT. (2) NO LATER THAN 90 DAYS AFTER NOTICE OFACCEPTANCE OF THIS AWC, AN OFFICER OF THE FIRM SHALL CERTIFY INWRITING TO NASD THAT AN AUDIT WAS CONDUCTED AND THE OFFICERHAS REVIEWED THE CURRENT AUDIT REPORT. (3) NO LATER THAN 60DAYS AFTER THE DATE OF THE CURRENT AUDIT REPORT, AN OFFICERSHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HAS IMPLEMENTED,OR HAS BEGUN TO IMPLEMENT, ANY RECOMMENDATIONS WITHIN ASPECIFIED TIME PERIOD. (4) NO LATER THAN 60 DAYS AFTER THE LASTDAY OF THE NEXT FOUR QUARTERS, AN OFFICER SHALL CERTIFY INWRITING TO NASD THAT AN AUDIT WAS CONDUCTED, THE CURRENT AUDITREPORT WAS REVIEWED, AND RECOMMENDATIONS IMPLEMENTED, ORBEGUN TO BE IMPLEMENTED. (5) NO LATER THAN SIX MONTHS AFTERNOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICER SHALL CERTIFY INWRITING TO NASD THAT THE FIRM HAS REVIEWED ITS SYSTEM ANDPROCEDURES FOR COMPLYING WITH ITS ARTICLE V REPORTINGOBLIGATIONS AND HAS ESTABLISHED A SYSTEM AND PROCEDURESREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REPORTINGREQUIREMENTS SET FORTH THEREIN.


Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS INC.


Censure


MONETARY FINE OF $300,000.





Allegations: ARTICLE V, SECTIONS 2(C) AND 3(B)OF NASD'S BY-LAWS, AND NASD RULES2110 AND 3010 - IT IS ALLEDGED THAT EDWARD JONES FILED AT LEAST 280LATE AMENDMENTS TO FORMS U4 AND U5, WHICH REPRESENTEDAPPROXIMATELY 27% OF THE REQUIRED AMEMDMENTS RELATING TOREPORTABLE CUSTOMER COMPLAINTS, TERMINATIONS, REGULATORYACTIONS, AND CRIMINAL DISCLOSURES. DURING THE RELEVANT PERIOD,EDWARD JONES' SUPERVISORY SYSTEM AND PROCEDURES WERE NOTREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS ARTICLE VREPORTING OBLIGATIONS.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, EDWARD JONESCONSENTS TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, IT HAS ACCEPTED THE CENSURE AND FINE OF$300,000, WHICH SHALL BE PAID WITHIN 10 DAYS OF NOTICE OF THIS AWC.IN ADDITION EDWARD JONES SHALL COMPLY WITH THE FOLLOWINGUNDERTAKINGS: (1)PROMPTLY,THE FIRM'S INTERNAL AUDIT DEPARTMENTOR PERSONNEL NOT DIRECTLY RESPONSIBLE FOR THE FIRM'S ARTICLE VREPORTING OBLIGATIONS AND THEIR IMMEDIATE SUPERVISORS SHALLCONDUCT AN AUDIT TO ACCESS THE EFFECTIVENESS OF ITS SYSTEMAND PROCEDURES FOR ENSURING TIMELY FILING OF FORM U4 AND U5AMENDMENTS SUMMARIZING FINDINGS AND RECOMMENDATIONS ANDSHALL FOR THE NEXT FOUR CALENDAR QUARTERS BEGINNING FOURTHQUARTER 2004, CONDUCT A SIMILAR AUDIT AND PREPARE A SIMILARWRITTEN AUDIT REPORT. (2) NO LATER THAN 90 DAYS AFTER NOTICE OFACCEPTANCE OF THIS AWC, AN OFFICER OF THE FIRM SHALL CERTIFY TOTHE NASD THAT AN AUDIT WAS CONDUCTED AND THE OFFICER HASREVIEWED THE CURRENT AUDIT REPORT. (3) NO LATER THAN 60 DAYSAFTER THE DATE OF THE CURRENT AUDIT REPORT, AN OFFICER SHALLCERTIFY IN WRITING TO THE NASD THAT THE FIRM HAS IMPLEMENTED,OR HAS BEGUN TO IMPLEMENT, ANY RECOMMENDATIONS WITHIN ASPECIFIED TIME PERIOD. (4) NO LATER THAN 60 DAYS AFTER THE LASTDAY OF THE NEXT FOUR QUARTERS, AN OFFICER SHALL CERTIFY INWRITING TO THE NASD THAT AN AUDIT WAS CONDUCTED, THE CURRENTAUDIT REPORT WAS REVIEWED, AND RECOMMENDATIONS IMPLEMENTED,OR BEGUN TO BE IMPLEMENTED. (5) NO LATER THAT SIX MONTHS AFTERNOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICER SHALL CERTIFY INWRITING TO THE NASD THAT THE FIRM HAS REVIEWED ITS SYSTEM ANDPROCEDURES FOR COMPLYING WITH ITS ARTICLE V REPORTINGOBLIGATIONS AND HAS ESTABLISHED A SYSTEM AND PROCEDURESREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REPORTINGREQUIREMENTS SET FORTH THEREIN.








Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, EDWARD JONESCONSENTS TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, IT HAS ACCEPTED THE CENSURE AND FINE OF$300,000, WHICH SHALL BE PAID WITHIN 10 DAYS OF NOTICE OF THIS AWC.IN ADDITION EDWARD JONES SHALL COMPLY WITH THE FOLLOWINGUNDERTAKINGS: (1)PROMPTLY,THE FIRM'S INTERNAL AUDIT DEPARTMENTOR PERSONNEL NOT DIRECTLY RESPONSIBLE FOR THE FIRM'S ARTICLE VREPORTING OBLIGATIONS AND THEIR IMMEDIATE SUPERVISORS SHALLCONDUCT AN AUDIT TO ACCESS THE EFFECTIVENESS OF ITS SYSTEMAND PROCEDURES FOR ENSURING TIMELY FILING OF FORM U4 AND U5AMENDMENTS SUMMARIZING FINDINGS AND RECOMMENDATIONS ANDSHALL FOR THE NEXT FOUR CALENDAR QUARTERS BEGINNING FOURTHQUARTER 2004, CONDUCT A SIMILAR AUDIT AND PREPARE A SIMILARWRITTEN AUDIT REPORT. (2) NO LATER THAN 90 DAYS AFTER NOTICE OFACCEPTANCE OF THIS AWC, AN OFFICER OF THE FIRM SHALL CERTIFY TOTHE NASD THAT AN AUDIT WAS CONDUCTED AND THE OFFICER HASREVIEWED THE CURRENT AUDIT REPORT. (3) NO LATER THAN 60 DAYSAFTER THE DATE OF THE CURRENT AUDIT REPORT, AN OFFICER SHALLCERTIFY IN WRITING TO THE NASD THAT THE FIRM HAS IMPLEMENTED,OR HAS BEGUN TO IMPLEMENT, ANY RECOMMENDATIONS WITHIN ASPECIFIED TIME PERIOD. (4) NO LATER THAN 60 DAYS AFTER THE LASTDAY OF THE NEXT FOUR QUARTERS, AN OFFICER SHALL CERTIFY INWRITING TO THE NASD THAT AN AUDIT WAS CONDUCTED, THE CURRENTAUDIT REPORT WAS REVIEWED, AND RECOMMENDATIONS IMPLEMENTED,OR BEGUN TO BE IMPLEMENTED. (5) NO LATER THAT SIX MONTHS AFTERNOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICER SHALL CERTIFY INWRITING TO THE NASD THAT THE FIRM HAS REVIEWED ITS SYSTEM ANDPROCEDURES FOR COMPLYING WITH ITS ARTICLE V REPORTINGOBLIGATIONS AND HAS ESTABLISHED A SYSTEM AND PROCEDURESREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REPORTINGREQUIREMENTS SET FORTH THEREIN.


Disclosure 42 of 73

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Allegations: NASD RULES 2110, 3010 - EDWARD JONES HAD A BONUS PLAN FOR ITSREPRESENTATIVES WHEREBY THE REPRESENTATIVES COULD RECEIVEBONUS PAYMENTS BASED ON THE PROFITABILITY OF THEIR BRANCHOFFICES; THE BONUS PLAN INDIRECTLY ENCOURAGED ITSREPRESENTATIVES TO RECOMMEND USE OF MARGIN LOANS TO PUBLICCUSTOMERS. THE FIRM FAILED TO ESTABLISH AND MAINTAIN ASUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORYPROCEDURES, REASONABLY DESIGNED TO DETER AND PREVENT ITSREPRESENTATIVES FROM MAKING UNSUITABLE RECOMMENDATIONSINVOLVING THE USE OF MARGIN LOANS IN CLIENT ACCOUNTS AS ARESULT OF ITS BONUS PLAN.







Initiated By: NASD




Docket/Case Number: C07040079



NASD RULES 2110, 3010 - EDWARD JONES HAD A BONUS PLAN FOR ITSREPRESENTATIVES WHEREBY THE REPRESENTATIVES COULD RECEIVEBONUS PAYMENTS BASED ON THE PROFITABILITY OF THEIR BRANCHOFFICES; THE BONUS PLAN INDIRECTLY ENCOURAGED ITSREPRESENTATIVES TO RECOMMEND USE OF MARGIN LOANS TO PUBLICCUSTOMERS. THE FIRM FAILED TO ESTABLISH AND MAINTAIN ASUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORYPROCEDURES, REASONABLY DESIGNED TO DETER AND PREVENT ITSREPRESENTATIVES FROM MAKING UNSUITABLE RECOMMENDATIONSINVOLVING THE USE OF MARGIN LOANS IN CLIENT ACCOUNTS AS ARESULT OF ITS BONUS PLAN.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, EDWARD JONESCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $200,000.


No




Allegations: ALLEGATIONS THAT EDWARD JONES VIOLATED NASD CONDUCT RULES3010 AND 2110, BY FAILING TO ESTABLISH AND MAINTAIN A SUPERVISORYSYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES,REASONABLY DESIGNED TO DETER AND PREVENT ITS REPRESENTATIVESFROM MAKING UNSUITABLE RECOMMENDATIONS INVOLVING THE USE OFMARGIN LOANS IN CLIENT ACCOUNTS AS A RESULT OF ITS BONUS PLAN.









Censure


MONETARY FINE OF $200,000.00


Docket/Case Number: C07040079-AWC



ALLEGATIONS THAT EDWARD JONES VIOLATED NASD CONDUCT RULES3010 AND 2110, BY FAILING TO ESTABLISH AND MAINTAIN A SUPERVISORYSYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES,REASONABLY DESIGNED TO DETER AND PREVENT ITS REPRESENTATIVESFROM MAKING UNSUITABLE RECOMMENDATIONS INVOLVING THE USE OFMARGIN LOANS IN CLIENT ACCOUNTS AS A RESULT OF ITS BONUS PLAN.


Resolution:

Other Sanctions Ordered: SEE ABOVE

Sanction Details: SEE ABOVE

Firm Statement THE FIRM ACCEPTED AND CONSENTED, WITHOUT ADMITTING ORDENYING THE ALLEGATIONS OR FINDINGS BY THE HEARING PANEL THATIT VIOLATED NASD CONDUCT RULES 3010 AND 2110 AND CONSENT TO ACENSURE AND A FINE OF $200,000.



Disclosure 43 of 73

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Initiated By: IOWA


Docket/Case Number: C00-06-540



Allegations: ALLEGED EDWARD D. JONES & CO., LP FAILED TO REASONABLYSUPERVISE ITS AGENT, WAYNE D. BELNER.


Appealed To and Date AppealFiled:

N/A







Cease and Desist


CIVIL PENALTY AND COSTS OF $9,500


Other Product Type(s): ACTION INVOLVED SALE OF UNREGISTERED STOCK IN TWO COMPANIES -IOWA RURAL HOUSING AND MISSOURI RURAL HOUSING.


Resolution:

Other Sanctions Ordered: CEASE AND DESIST FAILING TO REASONABLY SUPERVISE ITS AGENT INTHE STATE OF IOWA WHO IDENTIFIED OUTSIDE ACTIVITY, PAY A CIVILPENALTY AND COSTS OF $9,500.

Sanction Details: N/A

Regulator Statement N/A


Yes


Order


Initiated By: IOWA INSURANCE COMMISSIONERIOWA INSURANCE DIVISION


Cease and Desist


Docket/Case Number: C00-06-540


Other Product Type(s): ACTION INVOLVED UNAUTHORIZED SALE BY AGENT OF UNREGISTEREDSTOCK IN TWO COMPANIES - IOWA RURAL HOUSING AND MISSOURIRURAL HOUSING.

Allegations: ALLEGATIONS THAT EDWARD D. JONES & CO., FAILED TO REASONABLYSUPERVISE ITS AGENT, WAYNE D. BELNER.








Cease and Desist


CIVIL PENALTY AND COSTS OF $9,500


Resolution:

Other Sanctions Ordered: CEASE AND DESIST FAILING TO REASONABLY SUPERVISE ITS AGENT INTHE STATE OF IOWA WHO IDENTIFIED OUTSIDE ACTIVITY, PAY A CIVILPENALTY AND COSTS OF $9,500.

Sanction Details: N/A



Order

Disclosure 44 of 73

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Initiated By: NASD




Docket/Case Number: CMS040143



Allegations: NASD CONDUCTS 2110 AND 3010 AND NASD MARKETPLACE RULE6230(D)(1) - RESPONDENT MEMBER REPORTED A PTIE THAT INCLUDED ITSMARKUP/MARKDOWN, AND IMPROPERLY REPORTED THEMARKUP/MARKDOWN AS A COMMISSION FOR TRANSACTIONS REPORTEDTO TRACE; THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHRESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, ANDTHE RULES OF NASD CONCERNING THE REPORTING OF TRANSACTIONSTO TRACE; AND, THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDEFOR SUPERVISION REASONABLY DESIGNED TO ENSURE THAT THE FIRM'SAUOTMATED TRACE REPORTING SYSTEM REPORTED TRADES INCOMPLIANCE WITH NASD MARKETPLACE RULE 6230(D)(1).









Resolution:

Other Sanctions Ordered: UNDERTAKE TO REVISE THE FIRM'S SUPERVISORY PROCEDURES WITHRESPECT TO TRACE

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENTMEMBER CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED, FINED$15,000, AND UNDERTAKE TO REVISE THE FIRM'S SUPERVISORYPROCEDURES WITH RESPECT TO TRACE WITHIN 30 BUSINESS DAYS.


No






Censure


$15,000.00 FINE ($7,500 FOR THE PATTERN OF INACCURATE REPORTINGAND $7,500 FOR THE SUPERVISION VIOLATIONS).


Docket/Case Number: CMS040143-AWC



Allegations: THE FIRM ACCEPTS AND CONSENTS, WITHOUT ADMITTING OR DENYINGTHE ALLEGATIONS OR FINDINGS, THAT IN 8,319 TRANSACTIONSREPORTED TO TRACE, THE FIRM IMPROPERLY INCLUDED ITSMARKUP/MARKDOWN.


Resolution: Acceptance, Waiver & Consent(AWC)129©2020 FINRA. All rights reserved. Report about EDWARD JONES






Resolution:






Disclosure 45 of 73

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Initiated By: NASD







Allegations: MSRB RULES G-17, G-30(A) - EDWARD JONES RECEIVED REQUESTS FROMPUBLIC CUSTOMERS TO LIQUIDATE EIGHT DIFFERENT MUNICIPALSECURITY POSITIONS AND CONTACTED A BROKER'S BROKER ANDOBTAINED BIDS FOR THE CUSTOMERS' SECURITIES. BASED ON THE BIDSPROVIDED BY THE BROKER'S BROKER, EDWARD JONES 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 9.04% TO 36.00%. BY RELYING SOLELY ONTHE BIDS PROVIDED BY THE BROKER'S BROKER TO DETERMINE THE FAIRMARKET VALUE OF THE SECURITY, EDWARD JONES FAILED TO ENSURETHAT THE TRANSACTIONS WERE EXECUTED AT AGGREGATE PRICES THATWERE FAIR AND REASONABLE.











Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, EDWARD JONESCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, THE FIRM WAS CENSURED, FINED $15,000, ANDREQUIRED TO PAY $10,181.50, PLUS INTEREST, IN RESTITUTION TO THECUSTOMER. SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTIONSHALL BE PROVIDED TO NASD NO LATER THAN 90 DAYS AFTERACCEPTANCE 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.


No





Allegations: MSRB RULES G-17, G-30(A) - EDWARD JONES RECEIVED REQUESTS FROMPUBLIC CUSTOMERS TO LIQUIDATE EIGHT DIFFERENT MUNICIPALSECURITY POSITIONS. IN TURN, IT CONTACTED A BROKER'S BROKEROBTAINING BIDS FOR THE CUSTOMERS' SECURITIES. BASED ON THE BIDSPROVIDED, EDWARD JONES PURCHASED THE SECURITIES FROM THECUSTOMERS FOR ITS OWN ACCOUNT AND SOLD THE SECURITIES TO THEBROKER'S BROKER AT A NOMINAL GAIN. IN ALL EIGHT INSTANCES, THEPRICES PAID TO THE CUSTOMERS AND RECIEVED BY THE FIRM BASED ONTHESE BIDS WERE LATER DETERMINED TO BE BELOW THE ACTUAL FAIRMARKET VALUE FOR THE SECURITES IN AMOUNTS RANGING FROM 9.04%TO 36%. BY RELYING SOLELY ON THE BIDS PROVIDED, EDWARD JONESFAILED TO ENSURE THAT THE TRANSACTIONS WERE EXECUTED ATAGGREGATE PRICES THAT WERE FAIR AND REASONABLE.








Censure


FINED $15,000 AND REQUIRED TO PAY $10,181.50 PLUS INTEREST INRESTITUTION TO THE CUSTOMER.





Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, EDWARD JONESCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, THE FIRM WAS CENSURED, FINED $15,000, ANDREQUIRED TO PAY $10,181.50, PLUS INTEREST IN RESTITUTION TO THECUSTOMER. SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTIONSHALL BE PROVIDED TO NASD NO LATER THAN 90 DAYS AFTERACCEPTANCE 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.




Disclosure 46 of 73

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Allegations: **12/30/2003** EXECUTED STIPULATION OF FACTS AND CONSENT TOPENALTY CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYINGGUILT, THE FIRM CONSENTS TO FINDINGS BY THE HEARING PANEL THAT ITVIOLATED: 1. EXCHANGE RULE 346(F), BY EMPLOYING INDIVIDUALS,WHOM THE FIRM KNEW, OR IN THE EXERCISE OF REASONABLE CARE,SHOULD HAVE KNOWN, WERE SUBJECT TO STATUTORYDISQUALIFICATION. 2. EXCHANGE RULE 351(A)(9), BY FAILING TOPROMPTLY REPORT ITS ASSOCIATION WITH PERSONS SUBJECT TOSTATUTORY DISQUALIFICATION. 3. EXCHANGE RULE 351(A)(5), BY FAILINGTO PROMPTLY REPORT AN EMPLOYEE'S ARREST OR CONVICTION TO THEEXCHANGE. 4. EXCHANGE RULE 342, BY FAILING TO PROVIDE FOR,ESTABLISH, AND MAINTAIN ADEQUATE PROCEDURES AND CONTROLS,INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW OF ITS BUSINESSACTIVITIES, TO ENSURE COMPLIANCE WITH EXCHANGE RULES ANDFEDERAL SECURITIES LAWS RELATING TO EMPLOYMENT OF STATUTORYDISQUALIFIED INDIVIDUALS.STIPULATED SANCTION: THE IMPOSITION BY THE EXCHANGE OF ACENSURE AND A $100,000 FINE.







Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT




Docket/Case Number: HPD# 04-32



**12/30/2003** EXECUTED STIPULATION OF FACTS AND CONSENT TOPENALTY CONSENTED TO FINDINGS: WITHOUT ADMITTING OR DENYINGGUILT, THE FIRM CONSENTS TO FINDINGS BY THE HEARING PANEL THAT ITVIOLATED: 1. EXCHANGE RULE 346(F), BY EMPLOYING INDIVIDUALS,WHOM THE FIRM KNEW, OR IN THE EXERCISE OF REASONABLE CARE,SHOULD HAVE KNOWN, WERE SUBJECT TO STATUTORYDISQUALIFICATION. 2. EXCHANGE RULE 351(A)(9), BY FAILING TOPROMPTLY REPORT ITS ASSOCIATION WITH PERSONS SUBJECT TOSTATUTORY DISQUALIFICATION. 3. EXCHANGE RULE 351(A)(5), BY FAILINGTO PROMPTLY REPORT AN EMPLOYEE'S ARREST OR CONVICTION TO THEEXCHANGE. 4. EXCHANGE RULE 342, BY FAILING TO PROVIDE FOR,ESTABLISH, AND MAINTAIN ADEQUATE PROCEDURES AND CONTROLS,INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW OF ITS BUSINESSACTIVITIES, TO ENSURE COMPLIANCE WITH EXCHANGE RULES ANDFEDERAL SECURITIES LAWS RELATING TO EMPLOYMENT OF STATUTORYDISQUALIFIED INDIVIDUALS.STIPULATED SANCTION: THE IMPOSITION BY THE EXCHANGE OF ACENSURE AND A $100,000 FINE.


Resolution:


Sanction Details: **03/11/2004** DECISION HPD 04-32 ISSUED BY NYSE HEARING PANELDECISION: 1. VIOLATED EXCHANGE RULE 346(F) IN THAT THE FIRMEMPLOYED INDIVIDUALS WHOM THE FIRM KNEW, OR IN EXERCISE OFREASONABLE CARE, SHOULD HAVE KNOWN WERE SUBJECT TOSTATUTORY DISQUALIFICATION. 2. VIOLATED EXCHANGE RULE 351(A)(9) INTHAT THE FIRM FAILED TO PROMPTLY REPORT ITS ASSOCIATION WITHPERSONS SUBJECT TO STATUTORY DISQUALIFICATION. 3. VIOLATEDEXCHANGE RULE 351(A)(5) IN THAT THE FIRM FAILED TO PROMPTLYREPORT AN EMPLOYEE'S ARREST OR CONVICTION TO THE EXCHANGE. 4.VIOLATED EXCHANGE 342 IN THAT THE FIRM FAILED TO PROVIDE FOR,ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES AND CONTROLS,INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW OF ITSBUSINESS ACTIVITIES, TO ENSURE COMPLIANCE WITH EXCHANGE RULESAND THE FEDERAL SECURITIES LAWS RELATING TO EMPLOYMENT OFSTATUTORILY DISQUALIFIED INDIVIDUALS. PENALTY: THE IMPOSITION BYTHE EXCHANGE OF THE PENALTY OF A CENSURE AND A FINE OF $100,000.


No


Decision






**03/11/2004** DECISION HPD 04-32 ISSUED BY NYSE HEARING PANELDECISION: 1. VIOLATED EXCHANGE RULE 346(F) IN THAT THE FIRMEMPLOYED INDIVIDUALS WHOM THE FIRM KNEW, OR IN EXERCISE OFREASONABLE CARE, SHOULD HAVE KNOWN WERE SUBJECT TOSTATUTORY DISQUALIFICATION. 2. VIOLATED EXCHANGE RULE 351(A)(9) INTHAT THE FIRM FAILED TO PROMPTLY REPORT ITS ASSOCIATION WITHPERSONS SUBJECT TO STATUTORY DISQUALIFICATION. 3. VIOLATEDEXCHANGE RULE 351(A)(5) IN THAT THE FIRM FAILED TO PROMPTLYREPORT AN EMPLOYEE'S ARREST OR CONVICTION TO THE EXCHANGE. 4.VIOLATED EXCHANGE 342 IN THAT THE FIRM FAILED TO PROVIDE FOR,ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES AND CONTROLS,INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW OF ITSBUSINESS ACTIVITIES, TO ENSURE COMPLIANCE WITH EXCHANGE RULESAND THE FEDERAL SECURITIES LAWS RELATING TO EMPLOYMENT OFSTATUTORILY DISQUALIFIED INDIVIDUALS. PENALTY: THE IMPOSITION BYTHE EXCHANGE OF THE PENALTY OF A CENSURE AND A FINE OF $100,000.

Regulator Statement **04/8/2004** THE DECISION IS NOW FINAL AND IS EFFECTIVEIMMEDIATELY. CONTACT: MICHELE VAN TASSEL (212) 656-5340.


Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCMENT


Censure


MONETARY FINE


Docket/Case Number: HPD # 04-32



Allegations: ALLEGATIONS THAT IT VIOLATED: EXCHANGE RULE 346(F), BY EMPLOYINGINDIVIDUALS WHOM THE FIRM KNEW, OR IN THE EXERCISE OFREASONABLE CARE, SHOULD HAVE KNOWN, WERE SUBJECT TOSTATUTORY DISQUALIFICATION. 2. EXCHANGE RULE 351(A)(9), BY FAILINGTO PROMPTLY REPORT ITS ASSOCIATION WITH PERSONS SUBJECT TOSTATUTORY DISQUALIFICATION. 3. EXCHANGE RULE 351 (A)(5), BY FAILINGTO PROMPTLY REPORT AN EMPLOYEE'S ARREST OR CONVICTION TO THEEXCHANGE. 4. EXCHANGE RULE 342, BY FAILING TO PROVIDE FOR,ESTABLISH, AND MAINTAIN ADEQUATE PROCEDURES AND CONTROLS,INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW OF ITS BUSINESSACTIVITIES, TO ENSURE COMPLIANCE WITH EXCHANGE RULES ANDFEDERAL SECURITIES LAWS RELATING TO EMPLOYMENT OF STATUTORYDISQUALIFIED INDIVIDUALS.



Resolution:


Stipulation and Consent








Firm Statement WITHOUT ADMITTING OR DENYING GUILT, THE FIRM CONSENTS TO THEFINDINGS BY THE HEARING PANEL THAT IT VIOLATED: 1. EXCHANGE RULE346(F) BY EMPLOYING INDIVIDUALS, WHOM THE FIRM KNEW, OR IN THEEXERCISE OF REASONABLE CARE, SHOULD HAVE KNOWN, WERESUBJECT TO STATUTORY DISQUALIFICATION. 2. EXHANGE RULE 351(A)(9),BY FAILING TO PROMPTLY REPORT ITS ASSOCIATION WITH PERSONSSUBJECT TO STATUTORY DISQUALIFICATION. 3. EXCHANGE RULE 351(A)(5)BY FAILING TO PROMPTLY REPORT AN EMPLOYEE'S ARREST ORCONVICTION TO THE EXCHANGE. 4. EXCHANGE RULE 342, BY FAILING TOPROVIDE FOR, ESTABLISH, AND MAINTAIN ADEQUATE PROCEDURES ANDCONTROLS, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW OF ITSBUSINESS ACTIVITIES, TO ENSURE COMPLAINCE WITH EXCHANGE RULESAND FEDERAL SECURITIES LAWS RELATING TO THE EMPLOYMENT OFSTATUTORY DISQUALIFIED INDIVIDUALS. THE PANEL APPROVED THEEXECUTED STIPULATION OF FACTS AND CONSENT TO PENALTY OF THEIMPOSITION OF A CENSURE BY THE EXCHANGE AND A $100,000 FINE.


Disclosure 47 of 73

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Initiated By: STATE OF ALASKA, DIVISION OF BANKING, SECURITIES ANDCORPORATIONS.


Other


CONSENT ORDER AND MONETARY FINE OF $11,000.


Docket/Case Number: ALASKA ORDER NO. 03-04 S



Allegations: ALLEGED FAILURE TO PROPERLY CLASSIFY AND MAINTAIN A RECORD OFSPECIFIED CORRESPONDENCE AS A COMPLAINT.


Resolution: Consent







Resolution:

Other Sanctions Ordered: 1. REVIEW, WITHIN 90 DAYS OF THE EXECUTION OF THIS ORDER, ALLINCOMING CORRESPONDENCE RECEIVED AT ALASKA BRANCHES ORRELATED TO ALASKA AGENTS FOR THE THREE YEAR PERIOD ENDINGOCTOBER 1, 2003 TO DETERMINE WHETHER OTHER COMPLAINTS HAVEBEEN MISCLASSIFIED. 2. PROVIDE ADDITIONAL TRAINING IN CORRECTLYIDENTIFYING CORRESPONDENCE AS COMPLAINTS.

Sanction Details: RESPONDENT EDWARD JONES PAID THE ENTIRE FINE. SEE 12 B ABOVEFOR ADDITIONAL DETAILS.

Firm Statement CONSENT ORDER WAS ENTERED. RESPONDENTS CONSENT TO FINDINGTHAT THEY MISCLASSIFIED THE CARROLL LETTER BY NOT TREATING IT ASA COMPLAINT. RESPONDENTS AGREE TO TAKE THE CORRECTIVE ACTIONSAS REQUIRED BY THE STATE OF ALASKA IN CONNECTION WITH THISCONSENT ORDER.


Consent

Disclosure 48 of 73

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Initiated By: HAWAII





Docket/Case Number: SEU-98-079


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


Allegations: UNREGISTERED SALESPERSON TRANSACTING WITHIN THE STATE.



Resolution:



Order






Sanction Details: UNDER CONSENT ORDER AGREED TO BY THE FIRM, PAYMENT OF $3,000.CIVIL PENALTY FOR THE UNREGISTERED ACTIVITY OF A SALESPERSONWITH THE FIRM.


Initiated By: STATE OF HAWAII - DEPARTMENT OF COMMERCE AND CONSUMERAFFAIRS


Other


CONSENT ORDER





Allegations: STATE OF HAWAII ALLEGED THAT EDWARD JONES AND JEFFREYMORRISON EFFECTED THREE TRANSACTIONS WITHOUT THE PROPERREGISTRATION PURSUANT TO SECTION 485-14 OF THE ACT.



Resolution:

Other Sanctions Ordered: CONSENT ORDER

Sanction Details: UNDER CONSENT ORDER AGREED TO BY THE FIRM, PAYMENT OF $3,000CIVIL PENALTY FOR THE UNREGISTERED ACTIVITY OF A SALESPERSONWITH THE FIRM.

Firm Statement EDWARD JONES VOLUNTARILY STIPULATED TO THE CONSENT ORDER INTHAT IT AND MR. MORRISON HAD INADVERTENTLY ENTERED THREETRADES IN THE STATE OF HAWAII APPROXIMATELY 20 DAYS PRIOR TO HISLICENSING APPROVAL.


Consent

Disclosure 49 of 73

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Docket/Case Number: N-VS-218

Principal Product Type:


Allegations:



Resolution:


Sanction Details:

Regulator Statement NASDAQ COMPLAINT N-VS-218FILED 8-10-76

Sanctions Ordered: Monetary/Fine $25.00

Decision






Docket/Case Number: N-VS-218



Allegations: ALLEGATIONS OF VIOLATION OF SECTION IC3(D)(I) OF SCHEDULE D OFTHE ASSOCIATION'S BYLAWS (NASDAQ VOLUME REPORTING).









Resolution:


Sanction Details: FINE PAID.

Firm Statement EDWARD JONES WAS FINED $25 BY THE NASDAQ COMMITTEE OF THENASD PURSUANT TO A SUMMARY COMPLAINT PROCEDURE.


Decision

Disclosure 50 of 73

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Docket/Case Number:



Allegations:



Resolution:


Sanction Details:

Regulator Statement MAY 19, 1969; CENSURED AND FINED $1000.00.ASSESSED $64.65 - FINAL 06/18/69.FINAL: 06/18/69; FINES & COSTS PAID.


Decision











Docket/Case Number:


Other Product Type(s): HOT ISSUES

Allegations: ALLEGATIONS OF FAILURE TO MAKE BONA FIDE PUBLIC OFFERINGS INTHE DISTRIBUTION OF 17 "HOT ISSUES" IN VIOLATION OF ARTICLE III,SECTION 1 "FREE-RIDING".



Resolution:


Sanction Details: FINE AND COSTS PAID.

Firm Statement THE NASD DISTRICT BUSINESS COMMITTEE CENSURED AND FINEDEDWARD JONES $1000 AND ASSESSED COSTS OF $64.65.


Decision

Disclosure 51 of 73

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Docket/Case Number: SC-30


Allegations:












Resolution:


Sanction Details:

Regulator Statement COMPLAINT SC-30 FILED 05/19/81DIST 4DECISION 07/10/81: CENSURED; FINED $250 J&S.07/10/81: ALL RIGHTS WAIVED.07/10/81: FINAL.FINES & COSTS 06/05/81 #FC SC 30; PAID J&S.

Sanctions Ordered: CensureMonetary/Fine $250.00

Decision






Docket/Case Number: SC:KC-30, DISTRICT # 4



Allegations: ALLEGATIONS OF VIOLATION OF ITS RULE CONCERNING FREE-RIDINGAND WITHHOLDING.



Resolution: Decision









Firm Statement EDWARD JONES AND WILLIAM BORAH, A FORMER REGISTEREDREPRESENTATIVE, WERE CENSURED AND FINED $250 BY THE NASDPURSUANT TO A SUMMARY COMPLAINT PROCEDURE.


Disclosure 52 of 73

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Docket/Case Number: C07000041-AWC



Allegations: NASD RULE 3010 - RESPONDENT MEMBER FAILED TO MAINTAINADEQUATE WRITTEN SUPERVISORY PROCEDURES PERTAINING TO THEREVIEW AND MONITORING OF CUSTOMER ACCOUNT ACTIVITY INVIOLATION OF NASD RULE 3010 WHEREBY A FORMER REGISTEREDREPRESENTATIVE OF RESPONDENT MEMBER FIRM MADERECOMMENDATIONS TO A PUBLIC CUSTOMER INVOLVING THE PURCHASEOF CORPORATE AND MUNICPAL BONDS ON MARGIN, ALTHOUGH THEMARGIN INTEREST CHARGED BY RESPONDENT MEMBER EXCEEDED THEBOND YIELD. THE RECOMMENDATION WAS UNSUITABLE FOR THECUSTOMER BASED ON HER AGE, INVESTMENT EXPERIENCE, FINANCIALCONDITION AND INVESTMENT OBJECTIVES, BUT RESPONDENT MEMBER'SWRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE TO DETECTAND PREVENT SUCH UNSUITABLE RECOMMENDATIONS BY ISREGISTERED REPRESENTATIVE.











Sanction Details: PURSUANT TO IM-8310-2(F), A BAR OR EXPULSION SHALL BECOMEEFFECTIVE UPON APPROVAL OR ACCEPTANCE OF THIS AWC BY THE NAC.





Other


PRELIMINARY DETERMINATION TO RECOMMEND THAT DISCIPLINARYACTION BE BROUGHT AGAINST EDWARD JONES AND THOMAS W. JACK


Docket/Case Number: E07980030 TC


Other Product Type(s): BOND TRADING ON MARGIN

Allegations: ALLEGATIONS OF INADEQUATE WRITTEN SUPERVISORY PROCEDURESPERTAINING TO THE REVIEW AND MONITORING OF A CUSTOMER'SACCOUNT ACTIVITY IN VIOLATION OF NASD CONDUCT RULE 3010THEREBY PREVENTING UNSUITABLE RECOMMENDATIONS AND BONDTRADING ON MARGIN.



Resolution:


Sanction Details: WITHOUT ADMITTING TO OR DENYING ALLEGATIONS, EDWARD JONESAGREES TO PAY THE $5,000. THOMAS JACK WAS DISMISSED FROM THEPROCEEDINGS.

Firm Statement WITHOUT ADMITTING TO OR DENYING ALLEGATIONS, EDWARD JONESAGREES TO PAY THE $5,000. THOMAS JACK WAS DISMISSED FROM THEPROCEEDINGS.



Disclosure 53 of 73

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Disclosure 53 of 73


Initiated By: SECURITIES DIVISION OF THE NEW MEXICO SECRETARY OF STATE





Docket/Case Number: 2000-99-038



Allegations: NEW MEXICO SECRETARY OF STATE ALLEGED VIOLATIONS OF CERTAINLICENSING PROVISIONS OF THE NEW MEXICO SECURITIES ACT OF 1986.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, EDWARD JONESAGREED TO PAY A $5,000 CIVIL PENALTY FINE AND $500 IN INVESTIGATIONCOSTS. MR. GRUBB AGREED TO PAY A $2,500 CIVIL PENALTY FINE.

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, EDWARD JONESAGREED TO PAY A $5,000 CIVIL PENALTY FINE AND $500 IN INVESTIGATIONCOSTS. MR. GRUBB AGREED TO PAY A $2,500 CIVIL PENALTY FINE.


Settled

Disclosure 54 of 73

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Allegations: **09/19/2000** STIPULATION AND CONSENT TO PENALTY FILED BY NYSEDIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS:WITHOUT ADMITTING OR DENYING GUILT, THE FIRM CONSENTS TO: A.

FINDINGS BY THE HEARING PANEL THAT IT: 1. VIOLATEDEXCHANGE RULE 342(A) AND (B) IN THAT IT FAILED REASONABLY TOSUPERVISE AND CONTROL THE BUSINESS ACTIVITIES OF THE FIRM ANDITS EMPLOYEES, TO PROVIDE FOR APPROPRIATE PROCEDURES OFSUPERVISION AND CONTROL OF THE BUSINESS ACTIVITIES OF THE FIRMAND ITS EMPLOYEES, AND TO ESTABLISH A SEPARATE SYSTEM OFFOLLOW-UP AND REVIEW TO ASSURE COMPLIANCE WITH APPLICABLEEXCHANGE RULES AND FEDERAL SECURITIES LAWS AND REGULATIONSWITH RESPECT TO THE SALE OF CALLABLE CDS AND THE PUBLICDISSEMINATION OF RESEARCH REPORTS; 2. ENGAGED IN CONDUCTINCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE INTHAT, ON ONE OR MORE OCCASIONS, IT: (I) RECOMMENDED AND SOLD ASECURITY TO ONE OR MORE CUSTOMERS WHICH WAS UNSUITABLE INVIEW OF THE CUSTOMER?S AGE, INVESTMENT OBJECTIVES AND/ORFINANCIAL RESOURCES, AND II) MADE MISREPRESENTATIONS TO ONE ORMORE CUSTOMERS, AND/OR OMITTED TO DISCLOSE FACTS NECESSARYIN ORDER TO MAKE THE STATEMENTS MADE NOT MISLEADING TO ONE ORMORE CUSTOMERS, IN CONNECTION WITH THE SOLICITATION AND/ORSALE OF A SECURITY TO THE CUSTOMER; 3. VIOLATED EXCHANGE RULE472.30 IN THAT, ON ONE OR MORE OCCASIONS, IT UTILIZEDCOMMUNICATIONS WHICH CONTAINED MISSTATEMENTS AND/OROMISSIONS OF MATERIAL FACTS, AND 4. VIOLATED EXCHANGE RULE472.40 IN THAT, ON ONE OR MORE OCCASIONS, IT UTILIZED RESEARCHREPORTS RECOMMENDING THE PURCHASE OR SALE OF A SPECIFICSECURITY WHICH FAILED TO DISCLOSE OR INACCURATELY DISCLOSED: (I)THAT THE FIRM MADE A MARKET IN THE SECURITY BEINGRECOMMENDED; (II) THAT THE FIRM WAS MANAGER OR CO-MANAGER OFTHE MOST RECENT PUBLIC OFFERING OF A SECURITY OF THERECOMMENDED ISSUER; (III) THE DATE OF THE COMMUNICATION; AND (IV)THAT A FIRM EMPLOYEE SERVED ON THE BOARDS OF DIRECTORS OFTWO CORPORATIONS WHOSE SECURITIES **CONINTUED IN #13**







Initiated By: NYSE DIVISION OF ENFORCEMENT




Docket/Case Number: HPD# 00-187



**09/19/2000** STIPULATION AND CONSENT TO PENALTY FILED BY NYSEDIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS:WITHOUT ADMITTING OR DENYING GUILT, THE FIRM CONSENTS TO: A.

FINDINGS BY THE HEARING PANEL THAT IT: 1. VIOLATEDEXCHANGE RULE 342(A) AND (B) IN THAT IT FAILED REASONABLY TOSUPERVISE AND CONTROL THE BUSINESS ACTIVITIES OF THE FIRM ANDITS EMPLOYEES, TO PROVIDE FOR APPROPRIATE PROCEDURES OFSUPERVISION AND CONTROL OF THE BUSINESS ACTIVITIES OF THE FIRMAND ITS EMPLOYEES, AND TO ESTABLISH A SEPARATE SYSTEM OFFOLLOW-UP AND REVIEW TO ASSURE COMPLIANCE WITH APPLICABLEEXCHANGE RULES AND FEDERAL SECURITIES LAWS AND REGULATIONSWITH RESPECT TO THE SALE OF CALLABLE CDS AND THE PUBLICDISSEMINATION OF RESEARCH REPORTS; 2. ENGAGED IN CONDUCTINCONSISTENT WITH JUST AND EQUITABLE PRINCIPLES OF TRADE INTHAT, ON ONE OR MORE OCCASIONS, IT: (I) RECOMMENDED AND SOLD ASECURITY TO ONE OR MORE CUSTOMERS WHICH WAS UNSUITABLE INVIEW OF THE CUSTOMER?S AGE, INVESTMENT OBJECTIVES AND/ORFINANCIAL RESOURCES, AND II) MADE MISREPRESENTATIONS TO ONE ORMORE CUSTOMERS, AND/OR OMITTED TO DISCLOSE FACTS NECESSARYIN ORDER TO MAKE THE STATEMENTS MADE NOT MISLEADING TO ONE ORMORE CUSTOMERS, IN CONNECTION WITH THE SOLICITATION AND/ORSALE OF A SECURITY TO THE CUSTOMER; 3. VIOLATED EXCHANGE RULE472.30 IN THAT, ON ONE OR MORE OCCASIONS, IT UTILIZEDCOMMUNICATIONS WHICH CONTAINED MISSTATEMENTS AND/OROMISSIONS OF MATERIAL FACTS, AND 4. VIOLATED EXCHANGE RULE472.40 IN THAT, ON ONE OR MORE OCCASIONS, IT UTILIZED RESEARCHREPORTS RECOMMENDING THE PURCHASE OR SALE OF A SPECIFICSECURITY WHICH FAILED TO DISCLOSE OR INACCURATELY DISCLOSED: (I)THAT THE FIRM MADE A MARKET IN THE SECURITY BEINGRECOMMENDED; (II) THAT THE FIRM WAS MANAGER OR CO-MANAGER OFTHE MOST RECENT PUBLIC OFFERING OF A SECURITY OF THERECOMMENDED ISSUER; (III) THE DATE OF THE COMMUNICATION; AND (IV)THAT A FIRM EMPLOYEE SERVED ON THE BOARDS OF DIRECTORS OFTWO CORPORATIONS WHOSE SECURITIES **CONINTUED IN #13**


Resolution:


Decision







Sanction Details: **11/06/2000** DECISION 00-187 ISSUED BY NYSE HEARING PANELDECISION: VIOLATED EXCHANGE RULE 342(A) AND (B) IN THAT IT FAILEDREASONABLY TO SUPERVISE AND CONTROL AND PROVIDE APPROPRIATEPROCEDURES OF SUPERVISION AND CONTROL AND PROVIDEAPPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL ANDESTABLISH A SYSTEM OF FOLLOW-UP AND REVIEW WITH RESPECT TOTHE SALE OF CALLABLE CDS AND PUBLIC DISSEMINATION OF RESEARCHREPORTS, RECOMMENDED AND SOLD A SECURITY TO CUSTOMERSWHICH WAS UNSUITABLE, MADE MISREPRESENTATIONS TO OR OMITTEDTO DISCLOSE FACTS TO CUSTOMERS, VIOLATED EXCHANGE RULE 472.30IN THAT IT USED COMMUNICATIONS WHICH CONTAINED MISSTATEMENTSOR OMISSIONS OF MATERIAL FACTS, AND VIOLATED ECHANGE RULE472.40 IN THAT IT UTILIZED RESEARCH REPORTS WHICH FAILED TODISCLOSE OR INACCURATELY DISCLOSED CERTAIN INFORMATION --CONSENT TO CENSURE, $200,000 FINE AND A REQUIREMENT THAT THEFIRM REVIEW AT LEAST ANNUALLY FOR A PERIOD OF FIVE YEARS ITSMARKETING AND SALE OF CALLABLE CDS, DEPOSIT NOTES AND OTHERSIMILAR PRODUCTS HOWEVER LABELED, INCLUDING RELATEDDISCLOSURE DOCUMENTS AND TRAINING AND EDUCATION OF ITS SALESFORCE, FOR APPROPRIATE PRESENTATION OF THE PRODUCT(S),SPECIFICALLY TO DETECT AND PREVENT UNSUITABLE SALES ANDMISREPRESENTATIONS RELATED TO THE IMPORTANT FEATURES OF THEPRODUCT(S) INCLUDING, BUT NOT LIMITED TO, THE CALL FEATURE,LENGTH OF MATURITY, REINVESTMENT RISK AND MARKET-VALUEFLUCTUATION OF THE PRODUCT(S). A REPORT OF EACH SUCH REVIEWSHALL BE WRITTEN UNDER THE AUSPICES OF THE FIRM?S DIRECTOR OFCOMPLIANCE AND SUBMITTED TO THE FIRM?S CHIEF EXECUTIVEOFFICER.

Regulator Statement WERE COVERED BY THE COMMUNICATION.B. THE IMPOSITION BY THEEXCHANGE OF THE PENALTY OF:(1) A CENSURE; (2) A FINE OF $200,000AND (3) A REQUIREMENT THAT THE FIRM REVIEW AT LEAST ANNUALLYFOR A PERIOD OF FIVE YEARS ITS MARKETING AND SALE OF CALLABLECDS, DEPOSIT NOTES AND OTHER SIMILAR PRODUCTS HOWEVERLABELED, INCLUDING RELATED DISCLOSURE DOCUMENTS AND TRAININGAND EDUCATION OF ITS SALES FORCE, FOR APPROPRIATEPRESENTATION OF THE PRODUCT(S), SPECIFICALLY TO DETECT ANDPREVENT UNSUITABLE SALES AND MISREPRESENTATIONS RELATED TOTHE IMPORTANT FEATURES OF THE PRODUCT(S) INCLUDING, BUT NOTLIMITED TO, THE CALL FEATURE, LENGTH OF MATURITY, REINVESTMENTRISK AND MARKET-VALUE FLUCTUATION OF THE PRODUCT(S). A REPORTOF EACH SUCH REVIEW SHALL BE WRITTEN UNDER THE AUSPICES OFTHE FIRM?S DIRECTOR OF COMPLIANCE AND SUBMITTED TO THE FIRM?SCHIEF EXECUTIVE OFFICER. **12/08/2000** THE DECISION IS NOW FINALAND IS EFFECTIVE IMMEDIATELY. CONTACT: PEGGY GERMINO (212) 656-8450.







WERE COVERED BY THE COMMUNICATION.B. THE IMPOSITION BY THEEXCHANGE OF THE PENALTY OF:(1) A CENSURE; (2) A FINE OF $200,000AND (3) A REQUIREMENT THAT THE FIRM REVIEW AT LEAST ANNUALLYFOR A PERIOD OF FIVE YEARS ITS MARKETING AND SALE OF CALLABLECDS, DEPOSIT NOTES AND OTHER SIMILAR PRODUCTS HOWEVERLABELED, INCLUDING RELATED DISCLOSURE DOCUMENTS AND TRAININGAND EDUCATION OF ITS SALES FORCE, FOR APPROPRIATEPRESENTATION OF THE PRODUCT(S), SPECIFICALLY TO DETECT ANDPREVENT UNSUITABLE SALES AND MISREPRESENTATIONS RELATED TOTHE IMPORTANT FEATURES OF THE PRODUCT(S) INCLUDING, BUT NOTLIMITED TO, THE CALL FEATURE, LENGTH OF MATURITY, REINVESTMENTRISK AND MARKET-VALUE FLUCTUATION OF THE PRODUCT(S). A REPORTOF EACH SUCH REVIEW SHALL BE WRITTEN UNDER THE AUSPICES OFTHE FIRM?S DIRECTOR OF COMPLIANCE AND SUBMITTED TO THE FIRM?SCHIEF EXECUTIVE OFFICER. **12/08/2000** THE DECISION IS NOW FINALAND IS EFFECTIVE IMMEDIATELY. CONTACT: PEGGY GERMINO (212) 656-8450.


Initiated By: NEW YORK STOCK EXCHANGE, INC.


Censure


$200,000 FINE AND THE REQUIREMENT THAT APPLICANT CONDUCT ANANNUAL REVIEW FOR THE NEXT FIVE YEARS OF MARKETING, TRAINING,AND DISCLOSURE MATERIALS RELATED TO LONG TERM CALLABLECERTIFICATE OF DEPOSIT INVESTMENTS.


Docket/Case Number: HEARING PANEL DECISION 00-187



Allegations: ALLEGED FAILURE TO REASONABLY SUPERVISE, CONDUCTINCONSISTENT WITH JUST AND EQUITABLE PRINCIPALS OF TRADE INDISTRIBUTION OF CALLABLE CDS, AND VIOLATION OF NYSE RULE 472.40RELATING TO INACCURATE CAPACITY DISCLOSURES IN RESEARCHREPORTS.



Resolution:

Other Sanctions Ordered: APPLICANT MUST CONDUCT AN ANNUAL REVIEW FOR THE NEXT FIVEYEARS OF MARKETING, TRAINING, AND DISCLOSURE MATERIALS RELATEDTO LONG TERM CALLABLE CERTIFICATE OF DEPOSIT INVESTMENTS.


Firm Statement DRP WAS INCORRECTLY REPORTED UNDER 11D4 INSTEAD OF 11E2.



Disclosure 55 of 73

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Initiated By: SECURITIES AND EXCHANGE COMMISSION


Injunction






Allegations: ALLEGATIONS THAT APPLICANT VIOLATED THE SECURITIES ACT OF 1933IN AN UNDERWRITING PURSUANT TO A SHELF REGISTRATION OFDEBENTURES OF D.H. BALDWIN CO. IN 1982, BY CONTINUING TO SELL THESECURITIES PURSUANT TO A FALSE AND MISLEADING REG. STATEMENTAFTER ADVERSE INFORMATION APPEARED IN THE PRESS ABOUT THEISSUER.



Resolution:


Sanction Details: A FINAL JUDGMENT OF PERMANENT INJUNCTION ENJOINING &RESTRAINING APPLICANT FROM VIOLATING SECTION 17(A)(1) &(3) OF THESECURITIES ACT WAS ENTERED. APPLICANT CONSENTED TO THE ENTRYOF THE JUDGMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS.JUDGMENT REQUIRES APPLICANT TO CREATE A "DUE DILIGENCE REVIEW(CONTINUED BELOW)

Firm Statement COMMITTEE" TO REVIEW & SUPERVISE ITS DUE DILIGENCE REVIEWPROCEDURES. ALTHOUGH APPLICANT WAS NOT CHARGED WITH ANYKNOWLEDGE OR ACTIVE DECEIT IN CONNECTION WITH ANY ALLEGEDDEFICIENCIES IN THE REG. STATEMENT, THE SEC ALLEGED THATAPPLICANT RECKLESSLY FAILED TO VERIFY STATEMENTS CONTAINEDTHEREIN AFTER THE APPEARANCE OF THE NEWS ARTICLES.

Sanctions Ordered: Cease and Desist/Injunction

Consent

Disclosure 56 of 73

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Other


CHARGE MEMORANDUM




Other Product Type(s): PRODUCT TYPE NOT GIVEN

Allegations: A CHARGE MEMORANDUM WAS FILED AGAINST MR. ISAAC FRANKLINSTEVENS CRD#827523 AND APPLICANT ALLEGING UNSUITABILITY, LACK OFDIVERSIFICATION, MISSTATEMENTS, LACK OF DUE DILIGENCE,FALSIFYING NEW ACCOUNT FORMS, AND DISTRIBUTION OF UNAPPROVEDINFORMATION ON THE SALE OF SECURITIES TO 8 CUSTOMERS. NOSPECIFIC ACTION REQUESTED.



Resolution:


Sanction Details: WITHOUT ACCEPTING OR DENYING THE ALLEGATIONS THE FIRM HASACCPEPTED THE CENSURE AND PAID THE FINE OF $5000.


Consent

Disclosure 57 of 73

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Initiated By: SECRETARY OF STATE, INDIANA SECURITIES DIVISION


Allegations: ALLEGATIONS OF MISREPRESENTATIONS RESPECTING COMPLAINTSRECEIVED FROM CLIENTS OF ITS MARION, INDIANA BRANCH OFFICECONCERNING SALES PRESENTATIONS FOR MUTUAL FUNDS REGARDINGTHE RISK OF LOSS.








Other


CONSENT AGREEMENT


Docket/Case Number: 91-0004CD




Resolution:


Sanction Details: OTHER; APPLICANT ENTERED INTO A CONSENT AGREEMENT WITHINDIANA. WITHOUT ADMITTING OR DENYING THE COMPLAINTALLEGATIONS OR THAT VIOLATIONS OF THE INDIANA SEC. ACTOCCURRED, APPLICANT AGREED: TO HAVE A COMPLIANCE SEMINAR FORINDIANA BROKERS; TO DISCLOSE TO THE INDIANA SEC. DIVISION ANYINDIANA INVESTOR (CONTINUED BELOW)

Firm Statement COMPLAINTS; TO OFFER TO SETTLE WITH COMPLAINING CLIENTS UP TO72% OF THEIR PRINCIPAL LOSSES; AND TO REIMBURSE THE DIVISION FORITS UNSPECIFIED COSTS OF INVESTIGATIONS.

Sanctions Ordered:

Settled

Disclosure 58 of 73

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





Allegations: ALLEGATIONS IN REGARD TO THE SALE OF D.H. BALDWIN DEBENTURESINCLUDE: UNTRUE STATEMENTS IN VIOLATION OF IL SEC. LAW OF 1953,FRAUD, INEQUITABLE BUSINESS PRACTICE, AND OMISSION TO STATEMATERIAL FACTS. STATE FILED NOTICE OF HEARING TO DETERMINEWHETHER APPLICANT AND 9 IR'S SHOULD HAVE IL REGISTRATIONSREVOKED OR SUSPENDED.








Other


STIPULATION AND CONSENT



Resolution:


Sanction Details: APPLICANT ENTERED INTO A STIPULATION & CONSENT TO ENTER ORDERWITH THE SEC. OF STATE OF IL. WITHOUT ADMITTING OR DENYING ANY OFTHE ALLEGATIONS, APPLICANT AGREED TO REVIEW THE OFFICEPROCEDURES OF 12 IL OFFICES EVERY 6 MONTHS FOR A ONE YEARPERIOD; PREPARE A FORM U-4 FOR EACH OF THE 12 IRS WHOSE OFFICESHAVE (CONTINUED BELOW)

Firm Statement ADDITIONAL AUDIT PROCEDURES; PROVIDE IL WITH A REPORT FROMINDEPENDENT COUNSEL ON ITS DUE DILIGENCE PROCEDURES;PAY ILSTATE $10,000; & SUBMIT TO ARBITRATION WITH 22 D.H. BALDWINHOLDERS LISTED ON AN EXHIBIT ATTACHED TO THE CONSENT. INRETURN, THE STATE AGREED TO DISMISS WITH PREJUDICE AS TOAPPLICANT AND SEVEN OF ITS IRS ANY FURTHER ACTION.



Disclosure 59 of 73

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Initiated By: SECURITIES ENFORCEMENT UNIT, DEPT. OFCOMMERCE & CO*See FAQ #1*





Allegations: HI ENTERED INTO SETTLEMENT AGREEMENT WITHJONES REGARDING CEASE AND DESIST ORDER ISSUED ON 09/18/98.SETTLEMENT AGMT REQUIRES JONES TO RESCIND AND PAY $43,000.00 TOCUSTOMER AND PAY $12,500.00 TO HI FOR REIMBURSEMENT OFADMINISTRATIVE COSTS.











Resolution:


Sanction Details: JONES RESCIND AND PAY CUSTOMER $43,000.00 AND PAY$12,500.00 TO HI FOR REIMBURSEMENT OF ADMIN COSTS.

Regulator Statement CONTACT: MICHAEL MORIYAMA (808) 586-2740

Sanctions Ordered: Disgorgement/RestitutionCease and Desist/Injunction

Settled


Initiated By: STATE OF HAWAII - COMMISSIONER OF SECURITIES


Cease and Desist






Allegations: PRELIMINARY CEASE AND DESIST ORDER WAS FILED ALLEGING THATREGISTERED REPRESENTATIVE, ALFRED T. PATTEN VIOLATED VARIOUSPROVISIONS OF HAWAII REVISED STATUTES, INCLUDING WRONGFULLYOBTAINING FUNDS. APPLICANT WAS CHARGED WITH FAILURE TOSUPERVISE.



Resolution:


Settled







Sanction Details: PAYMENT OF CLIENT'S PRINCIPAL LOSS OF $43,000 AND REIMBURSEMENTTO THE STATE FOR ADMINISTRATIVE COSTS OF $12,500.

Firm Statement FOLLOWING THE HEARING OFFICER'S GRANTING OF APPLICANT'SMOTION FOR SUMMARY JUDGMENT AGAINST THE CLAIM OF VICARIOUSLIABILITY, THE PARTIES ENTERED A SETTLEMENT AGREEMENT WHEREINAPPLICANT AGREED TO PAY CLIENT'S PRINCIPAL LOSS OF $43,000 ANDREIMBURSE THE STATE'S ADMINISTRATIVE COSTS OF $12,500.


Disclosure 60 of 73

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Docket/Case Number: CMS960137AWC



Allegations:



Resolution:


Sanction Details:

Regulator Statement LETTER OF ACCEPTANCE, WAIVER & CONSENT NO. CMS960137 AWC.

ON APRIL 23, 1997, EDWARD D. JONES & COMPANY (EDJO) WASNOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT(AWC) IT SUBMITTED WAS ACCEPTED BY THE MARKET REGULATION ANDTHE NATIONAL BUSINESS CONDUCT COMMITTEES. THE AWC ALLEGESTHATEDJO VIOLATED NASD CONDUCT RULE 3350 FOR EXECUTING FIVESEPARATE SHORT SALE TRANSACTIONS IN A NASDAQ NATIONAL MARKETSYSTEM SECURITY AT OR BELOW THE CURRENT INSIDE BID WHEN THECURRENT INSIDE BID WAS BELOW THE PRECEDING INSIDE BID IN THESECURITY.

SANCTIONS INCLUDE A $1,000 FINE AND REMITTAL OF $7,307.77 OFREALIZED AND UNREALIZED FIRM AND CUSTOMER PROFITS RELATING TOTHE TRANSACTIONS.

***$8,307.77 PAID ON 6/2/97, INVOICE #97-MS-410***







www.finra.org/brokercheck User GuidanceLETTER OF ACCEPTANCE, WAIVER & CONSENT NO. CMS960137 AWC.

ON APRIL 23, 1997, EDWARD D. JONES & COMPANY (EDJO) WASNOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT(AWC) IT SUBMITTED WAS ACCEPTED BY THE MARKET REGULATION ANDTHE NATIONAL BUSINESS CONDUCT COMMITTEES. THE AWC ALLEGESTHATEDJO VIOLATED NASD CONDUCT RULE 3350 FOR EXECUTING FIVESEPARATE SHORT SALE TRANSACTIONS IN A NASDAQ NATIONAL MARKETSYSTEM SECURITY AT OR BELOW THE CURRENT INSIDE BID WHEN THECURRENT INSIDE BID WAS BELOW THE PRECEDING INSIDE BID IN THESECURITY.

SANCTIONS INCLUDE A $1,000 FINE AND REMITTAL OF $7,307.77 OFREALIZED AND UNREALIZED FIRM AND CUSTOMER PROFITS RELATING TOTHE TRANSACTIONS.

***$8,307.77 PAID ON 6/2/97, INVOICE #97-MS-410***




Other


ACCEPTANCE, WAIVER AND CONSENT


Docket/Case Number: CMS960137 AWC



Allegations: ALLEGATIONS THAT APPLICANT MISTAKENLY EXECUTED SHORT SALES OFA COMMON STOCK WHEN THE PREVIOUS INSIDE QUOTES HAPPENED TOBE DOWNTICKS IN VIOLATION OF NASD CONDUCT RULE 3350.



Resolution:


Sanction Details: FINE OF $1,000 AND REMITTANCE OF $7,307.77 OF PROFITS RELATING TOTHE TRANSACTION.

Firm Statement PURSUANT TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENTWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, APPLICANTAGREED TO A $1,000 FINE AND REMITTAL OF $7,307.77 OF PROFITSRELATING TO THE TRANSACTIONS.








Firm Statement PURSUANT TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENTWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, APPLICANTAGREED TO A $1,000 FINE AND REMITTAL OF $7,307.77 OF PROFITSRELATING TO THE TRANSACTIONS.

Disclosure 61 of 73

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Cease and Desist


CENSURE AND CIVIL PENALTY


Docket/Case Number: RELS. 34-38880; IC-22767; FILE #3-9181

Principal Product Type: Unit Investment Trust(s)


Allegations: +04/20/2001+ ** 11-08-96, SEC NEWS DIGEST ISSUE #96-213, DATED11/07/1996, ENFORCEMENT PROCEEDINGS AND ADMINISTRATIVEPROCEEDING REL. #34-37926, DATED 11/06/1996, DISCLOSES: THECOMMISSION ANNOUNCED TODAY THE INSTITUTION OF PUBLICADMINISTRATIVE CEASE-AND-DESIST PROCEEDINGS, PURSUANT TOSECTIONS 15(B), 19(H) AND 21C OF THE SECURITIES EXCHANGE ACT OF1934 AND SECTIONS 9(B) AND 9(F) OF THE INVESTMENT COMPANY ACT OF1940, AGAINST EDWARD D. JONES & CO., (JONES & CO.), A REGISTEREDBROKER-DEALER. THE ORDER INSTITUTING PROCEEDINGS ALLEGESTHAT JONES & CO. UNLAWFULLY CHARGED COMMISSIONS INREPURCHASING INTERESTS IN THREE UNIT INVESTMENT TRUSTS FROMJONES & CO. CUSTOMERS, PROFITING BY APPROXIMATELY $120,000. AS ARESULT, THE ORDER ALLEGES THAT JONES & CO. VIOLATED RULE 22C-1PROMULGATED UNDER THE INVESTMENT COMPANY ACT IN THAT JONES &CO. REPURCHASED THE INTERESTS AT A PRICE WHICH WAS NOT BASEDON THE CURRENT NET ASSET VALUE OF THE UIT INTERESTS. A HEARINGWILL BE HELD TO DETERMINE WHETHER THE ALLEGATIONS IN THEORDER ARE TRUE AND TO DETERMINE WHAT REMEDIAL SANCTIONS, IFANY, ARE APPROPRIATE AND IN THE PUBLIC INTEREST. (REL. 34-37926; IC-22316)



Resolution: Order







Sanction Details: IT IS ORDERED: (1) THAT JONES & CO. BE, AND HEREBY IS, CENSURED. (2)THAT, PURSUANT TO SECTION 9(F) OF THE INVESTMENT COMPANY ACT,JONES & CO. CEASE AND DESIST FROM COMMITTING OR CAUSING ANYVIOLATION, AND COMMITTING OR CAUSING ANY FUTURE VIOLATION, OFRULE 22C-1 PROMULGATED UNDER SECTION 22(C) OF THE INVESTMENTCOMPANY ACT. (3) THAT, PURSUANT TO SECTION 9(D) OF THEINVESTMENT COMPANY ACT, JONES & CO. PAY A CIVIL PENALTY OF $50,000TO THE UNITED STATES TREASURY WITHIN 30 DAYS OF THIS ORDER.

Regulator Statement +04/21/2001+ SEC ADMINISTRATIVE PROC. REL. #34-38880, DATED07/28/1997, DISCLOSES: JONES & CO. HAS SUBMITTED AN OFFER OFSETTLEMENT WITHOUT ADMITTING OR DENYING THE FINDINGS ANDCONSENTED TO THE ENTRY OF THIS CEASE-AND-DESIST ORDER. THESEC FINDS THAT: (1) SINCE 1989, JONES & CO. HAS MAINTAINED ASECONDARY MARKET FOR THE UNITS OF THREE UNIT INVESTMENTTRUSTS ("UITS"). (2) AS PART OF ITS ACTIVITIES IN MAINTAINING ASECONDARY MARKET IN THE UIT UNITS, JONES & CO. OFFERED TOREPURCHASE THE UNITS FROM THEINVESTING PUBLIC AT THE UIT UNIT'S NET ASSET VALUE. (3) INVESTORSWERE INFORMED THAT JONES & CO. COULD PROFIT IN THE SECONDARYMARKET" IN THE AMOUNT OF ANY DIFFERENCE BETWEEN THE PRICE ATWHICH SUCH UNITS WERE PURCHASED AND THEPRICE AT WHICH SUCH UNITS WERE RESOLD" OR REDEEMED.INVESTORS WERE NOT INFORMED THAT JONES & CO. COULD CHARGE ACOMMISSION IN PURCHASING THE UNITS FROM THE INVESTORS. (4)BEGINNING IN JANUARY 1990, JONES & CO. BEGAN ALLOWING ITSREGISTERED REPRESENTATIVES TO CHARGE A COMMISSION FORPURCHASING THE UIT UNITS FROM CUSTOMERS IN CERTAINCIRCUMSTANCES. FROM JANUARY 1990 UNTIL MARCH 1993, INAPPROXIMATELY 50% OF THE TRANSACTIONS INVOLVING A REPURCHASEOF THE UIT UNITS, JONES & CO. CHARGED A COMMISSION. ON AVERAGE,THE COMMISSION WAS APPROXIMATELY SIX-TENTHS OF ONE PERCENTOF THE BID PRICE FOR THE UIT. (5) AS A RESULT OF CHARGING THESECOMMISSIONS, JONES & CO. RECEIVED APPROX. $120,000. (6) FROMJANUARY 1990 UNTIL MARCH 1993, JONES & CO. WILLFULLY VIOLATEDRULE 22C-1, PROMULGATED PURSUANT TO SEC. 22(C) OF THEINVESTMENT COMPANY ACT. (7) IN SEPTEMBER 1996, JONES & CO. BEGANTHE PROCESS OF REFUNDING THE COMMISSION, PLUS INTEREST, TO ALLINVESTORS WHO WERE CHARGED SUCH A COMMISSION IN THEREPURCHASE TRANSACTIONS AT ISSUE. JONES & CO. PAID OUT$198,111.26, INCLUSIVE OF INTEREST, IN REPAYMENT TO THE AFFECTEDINVESTORS. IN VIEW OF THE FOREGOING, THE SEC ISSUED CEASE-AND-DESIST ORDER.

Sanctions Ordered: CensureMonetary/Fine $50,000.00Cease and Desist/Injunction






+04/21/2001+ SEC ADMINISTRATIVE PROC. REL. #34-38880, DATED07/28/1997, DISCLOSES: JONES & CO. HAS SUBMITTED AN OFFER OFSETTLEMENT WITHOUT ADMITTING OR DENYING THE FINDINGS ANDCONSENTED TO THE ENTRY OF THIS CEASE-AND-DESIST ORDER. THESEC FINDS THAT: (1) SINCE 1989, JONES & CO. HAS MAINTAINED ASECONDARY MARKET FOR THE UNITS OF THREE UNIT INVESTMENTTRUSTS ("UITS"). (2) AS PART OF ITS ACTIVITIES IN MAINTAINING ASECONDARY MARKET IN THE UIT UNITS, JONES & CO. OFFERED TOREPURCHASE THE UNITS FROM THEINVESTING PUBLIC AT THE UIT UNIT'S NET ASSET VALUE. (3) INVESTORSWERE INFORMED THAT JONES & CO. COULD PROFIT IN THE SECONDARYMARKET" IN THE AMOUNT OF ANY DIFFERENCE BETWEEN THE PRICE ATWHICH SUCH UNITS WERE PURCHASED AND THEPRICE AT WHICH SUCH UNITS WERE RESOLD" OR REDEEMED.INVESTORS WERE NOT INFORMED THAT JONES & CO. COULD CHARGE ACOMMISSION IN PURCHASING THE UNITS FROM THE INVESTORS. (4)BEGINNING IN JANUARY 1990, JONES & CO. BEGAN ALLOWING ITSREGISTERED REPRESENTATIVES TO CHARGE A COMMISSION FORPURCHASING THE UIT UNITS FROM CUSTOMERS IN CERTAINCIRCUMSTANCES. FROM JANUARY 1990 UNTIL MARCH 1993, INAPPROXIMATELY 50% OF THE TRANSACTIONS INVOLVING A REPURCHASEOF THE UIT UNITS, JONES & CO. CHARGED A COMMISSION. ON AVERAGE,THE COMMISSION WAS APPROXIMATELY SIX-TENTHS OF ONE PERCENTOF THE BID PRICE FOR THE UIT. (5) AS A RESULT OF CHARGING THESECOMMISSIONS, JONES & CO. RECEIVED APPROX. $120,000. (6) FROMJANUARY 1990 UNTIL MARCH 1993, JONES & CO. WILLFULLY VIOLATEDRULE 22C-1, PROMULGATED PURSUANT TO SEC. 22(C) OF THEINVESTMENT COMPANY ACT. (7) IN SEPTEMBER 1996, JONES & CO. BEGANTHE PROCESS OF REFUNDING THE COMMISSION, PLUS INTEREST, TO ALLINVESTORS WHO WERE CHARGED SUCH A COMMISSION IN THEREPURCHASE TRANSACTIONS AT ISSUE. JONES & CO. PAID OUT$198,111.26, INCLUSIVE OF INTEREST, IN REPAYMENT TO THE AFFECTEDINVESTORS. IN VIEW OF THE FOREGOING, THE SEC ISSUED CEASE-AND-DESIST ORDER.




Cease and Desist



Docket/Case Number: SEC ADMIN. PROCEEDING FILE NO. 3-9181

Principal Product Type: Unit Investment Trust(s)


Allegations: ALLEGATIONS OF VIOLATION OF SECTION 22 OF THE INVESTMENTCOMPANY ACT OF 1940 FOR IMPROPERLY PERMITTING THE CHARGE OFCOMMISSIONS ON REPURCHASES OF CERTAIN UNIT INVESTMENTTRUSTS.



Resolution:


Sanction Details: MR. WALTER EXECUTED AN OFFER OF SETTLEMENT WITHOUT ADMITTINGOR DENYING THE FINDINGS IN THE COMMISSION'S ORDER THAT HE HADPERMITTED SOME COMMISSIONS TO BE CHARGED ON CERTAIN UNITTRUST REPURCHASES IN VIOLATION OF RULE 22 C-1 OF THE INVESTMENTCOMPANY ACT. MR. WALTER AGREED TO CEASE & DESIST FROM CAUSING(CONTINUED BELOW)

Firm Statement ANY FUTURE VIOLATIONS OF SECTION 22 AND RULE 22 C-1 UNDER THEINVESTMENT COMPANY ACT. APPLICANT ALSO EXECUTED AN OFFER OFSETTLEMENT WITH AN AGREEMENT TO CEASE AND DESIST FROM FUTUREVIOLATIONS OF RULE 22 C-1, A CENSURE, AND A PAYMENT OF A $50,000CIVIL PENALTY.

Sanctions Ordered: CensureMonetary/Fine $50,000.00Cease and Desist/Injunction

Settled





www.finra.org/brokercheck User GuidanceANY FUTURE VIOLATIONS OF SECTION 22 AND RULE 22 C-1 UNDER THEINVESTMENT COMPANY ACT. APPLICANT ALSO EXECUTED AN OFFER OFSETTLEMENT WITH AN AGREEMENT TO CEASE AND DESIST FROM FUTUREVIOLATIONS OF RULE 22 C-1, A CENSURE, AND A PAYMENT OF A $50,000CIVIL PENALTY.

Disclosure 62 of 73

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Initiated By: ILLINOIS







Other Product Type(s): UNSPECIFIED TYPE OF FINANCIAL PRODUCT.

Allegations: RESPONDENTS EDWARD D. JONES & COMPANY, INC. AND OTHERSOFFERED AND SOLD SECURITIES TO ILLINOIS RESIDENTS BY MEANS OFMISREPRESENTATIONS, OMISSIONS, FRAUD OR ARTIFICE UNDER THEILLINOIS SECURITIES LAW OF 1953, AS AMENDED THE "LAW"), SUBJECTINGRESPONDENTS TO REGISTRATION REVOCATION IN ILLINOIS. AUTHORITY:SECTIONS 8.E(1)(F), 12.B, 12.F, 12.G, AND 12.J OF THE LAW.



Resolution:


Sanction Details: BY MEANS OF A SETTLEMENT AGREEMENT THE ABOVE REFERENCEDACTION HAS BEEN RESOLVED. RESPONDENTS (SAME AS ORIGINALCOMPLAINT) HAVE AGREED TO EITHER MAKE A MONETARY OFFER OFSETTLEMENT TO INVESTORS OR PROCEED TO BINDING ARBITRATION.RESPONDENTS HAVE AGREED TO PAY FOR ARBITRATION COSTS. THEHEARING ON THIS MATTER HAS BEEN DISMISSED.

Sanctions Ordered:

Settled


Allegations: NOTICE OF HEARING WAS ISSUED TO RESPONDENTS WHEREIN IT WASALLEGED THAT CERTAIN ACTIVITIES OR BUSINESS AND SALES PRACTICESCONDUCTED BY DEFENDANTS INVOLVING THE SALE OF LIMITEDPARTNERSHIP INTERESTS ISSUED BY NATURAL RESOURCE MANAGEMENTPROVIDED SUFFICIENT GROUNDS TO REQUIRE A PUBLIC HEARING.







Initiated By: SECRETARY OF STATE, ILLINOIS SECURITIES DEPARTMENT


Other




Principal Product Type: Direct Investment(s) - DPP & LP Interest(s)


Allegations: NOTICE OF HEARING WAS ISSUED TO RESPONDENTS WHEREIN IT WASALLEGED THAT CERTAIN ACTIVITIES OR BUSINESS AND SALES PRACTICESCONDUCTED BY DEFENDANTS INVOLVING THE SALE OF LIMITEDPARTNERSHIP INTERESTS ISSUED BY NATURAL RESOURCE MANAGEMENTPROVIDED SUFFICIENT GROUNDS TO REQUIRE A PUBLIC HEARING.


Resolution:

Firm Statement RESPONDENTS ENTERED INTO A SETTLEMENT AGREEMENT WITHILLINOIS. WITHOUT ADMITTING OR DENYING ANY OF THE ALLEGATIONSBROUGHT BY THE STATE, APPLICANT AGREED TO GIVE THE COMPLAININGCUSTOMERS THE OPTIONS OF ARBITRATING THEIR NRM COMPLAINTS ORBEING PAID A SETTLEMENT AMOUNT PREDETERMINED BY EDWARDJONES AND ILLINOIS.

Settled

Disclosure 63 of 73

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Allegations: EVENT: STIPULATION AND CONSENT TO PENALTYFILED BY NYSE DIVISION OF ENFORCMENT AND PENDING. WITHOUTADMITTING OR DENYING GUIL, THE FIRMS CONSENTS TO: A) AFINDING BY THE HEARING PANEL THAT IT: 1. VIOLATED EXCHANGE351(a) IN THAT ON ONE OR MORE OCCASIONS IT DID NOT PROMPTLYREPORT TO THE EXCHANGE A MATTER AS REQUIRED BY THE RULE. 2.VIOLATED EXCHANGE RULE 345.17(b) IN THAT ON ONE MORE OCCASIONSIT FAILED TO TIMELY FILE WITH THE EXCHANGE AMENDMENTS TO FORMSU-5. 3. VIOLATED EXCHANGE RULE 342(a) AND (b) IN THAT ITFAILED TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATEPROCEDURES OF SUPERVISION AND CONTROL, INCLUDING A SEPARATESYSTEM OF FOLLOW-UP AND REVIEW, WITH RESPECT TO ITS OBLIGATIONTO PROMPTLY REPORT OT THE EXCHANGE MATTERS AS REQUIRED BYEXCHANGE RULES. B) THE IMPOSITION BY THE EXCHANGE OF THEPENALTY OF A CENSURE, A FINE OF $40,0000 AND A REQUIREMENT TOCOMPLY WITH ITS UNDERTAKING TO (i) ADOPT AND IMPLEMENT POLICIESAND APPROPRIATED PROCEDURES THAT WOULD REASONABLY ENSURETHATTHE FIRM PROMPLTLY REPORTS TO THE EXCHANGE MATTERS ASREQUIREDBY RULES 351 AND 345 ON FORMS RE-3 AND FORMS U-5, (ii) CONDUCTAN INTERNAL REVIEW TO BE CONCLUDED WITHIN A PERIORD OF THREEMONTHS AFTER THE DECISION ISSUED IN THIS MATTER BECOMES FINALUNDER EXCHANGE RULE 476(e), TO DETERMINE IF ALL MATTERSREPORTABLE PURSUANT TO RULES 351 AND 345 ON FORMS RE-3 ANDFORMS U-5 HAVE BEEN REPORTED, AND TO THE EXTENT NECESSARYMAKESUCH ADDITIONAL FINDINGS, AND (iii) REPORT TO THE EXCHANGE ATTHE END OF THE THREE MONTH PERIOD ON THE RESULTS OF SUCHREVIEWAND TO AFFIRMS THT ALL REQUIRED REPORTS HAVE BEEN MADE.







Initiated By: NYSE DIVISION OF ENFORCEMENT ' NYSEHPD#94-166 NYSE*See FAQ #1*




Docket/Case Number: HPD 94-166



EVENT: STIPULATION AND CONSENT TO PENALTYFILED BY NYSE DIVISION OF ENFORCMENT AND PENDING. WITHOUTADMITTING OR DENYING GUIL, THE FIRMS CONSENTS TO: A) AFINDING BY THE HEARING PANEL THAT IT: 1. VIOLATED EXCHANGE351(a) IN THAT ON ONE OR MORE OCCASIONS IT DID NOT PROMPTLYREPORT TO THE EXCHANGE A MATTER AS REQUIRED BY THE RULE. 2.VIOLATED EXCHANGE RULE 345.17(b) IN THAT ON ONE MORE OCCASIONSIT FAILED TO TIMELY FILE WITH THE EXCHANGE AMENDMENTS TO FORMSU-5. 3. VIOLATED EXCHANGE RULE 342(a) AND (b) IN THAT ITFAILED TO PROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATEPROCEDURES OF SUPERVISION AND CONTROL, INCLUDING A SEPARATESYSTEM OF FOLLOW-UP AND REVIEW, WITH RESPECT TO ITS OBLIGATIONTO PROMPTLY REPORT OT THE EXCHANGE MATTERS AS REQUIRED BYEXCHANGE RULES. B) THE IMPOSITION BY THE EXCHANGE OF THEPENALTY OF A CENSURE, A FINE OF $40,0000 AND A REQUIREMENT TOCOMPLY WITH ITS UNDERTAKING TO (i) ADOPT AND IMPLEMENT POLICIESAND APPROPRIATED PROCEDURES THAT WOULD REASONABLY ENSURETHATTHE FIRM PROMPLTLY REPORTS TO THE EXCHANGE MATTERS ASREQUIREDBY RULES 351 AND 345 ON FORMS RE-3 AND FORMS U-5, (ii) CONDUCTAN INTERNAL REVIEW TO BE CONCLUDED WITHIN A PERIORD OF THREEMONTHS AFTER THE DECISION ISSUED IN THIS MATTER BECOMES FINALUNDER EXCHANGE RULE 476(e), TO DETERMINE IF ALL MATTERSREPORTABLE PURSUANT TO RULES 351 AND 345 ON FORMS RE-3 ANDFORMS U-5 HAVE BEEN REPORTED, AND TO THE EXTENT NECESSARYMAKESUCH ADDITIONAL FINDINGS, AND (iii) REPORT TO THE EXCHANGE ATTHE END OF THE THREE MONTH PERIOD ON THE RESULTS OF SUCHREVIEWAND TO AFFIRMS THT ALL REQUIRED REPORTS HAVE BEEN MADE.


Resolution:


Sanction Details: HEARING PANEL DECISION 94-166 ISSUED BY NYSEHEARING PANEL VIOLATED EXCHANGE RULE 351(a) BY NOT PROMPLYREPORTING MATTERS AS REQUIRED; RULE 345.17(b) BY FAILING TOTIMELY FILE FROMS U-5 AMENDMENTS; RULE 342 BY FAILING TOPROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURESFORSUPERVISION AND CONTROL WITH RESPECT TO PROMPT REPORTING--CONSENT TO CENSURE, $40,000 FINE AND SPECIAL UNDERTAKING TO:(i) ADOPT AND IMPLEMENT POLICIES AND APPROPRIATE PROCEDURESTHAT WOULD REASONABLY ENSURE THAT THE FIRM PROMPTLY REPORTSTOTHE EXCHANGE MATTERS AS REQUIRED BY RULES 351 AND 345 ONFORMSRE-3 AND FORMS U-5, (ii) CONDUCT AN INTERNAL REVIEW TO BECONCLUDED WITHIN A PERIOD OF THREE MONTHS AFTER THE DECISIONISSUED IN THIS MATTER BECOMES FINAL UNDER EXCHANGE RULE 476,TODETERMINE IF ALL MATTERS REPORTABLE PURSUANT TO RULES 351 AND345 ON FORMS RE-3 AND FORM U-5 HAVE BEEN REPORTED, AND TO THEEXTENT NECESSARY MAKE SUCH ADDITIONAL FILINGS, AND (iii) REPORTTO THE EXCHANGE AT THE END OF THE THREE MONTH PERIOD ON THERESULTS OF SUCH REVIEW AND TO AFFIRM THAT ALL REQUIREDREPORTSHAVE BEEN MADE.







www.finra.org/brokercheck User GuidanceHEARING PANEL DECISION 94-166 ISSUED BY NYSEHEARING PANEL VIOLATED EXCHANGE RULE 351(a) BY NOT PROMPLYREPORTING MATTERS AS REQUIRED; RULE 345.17(b) BY FAILING TOTIMELY FILE FROMS U-5 AMENDMENTS; RULE 342 BY FAILING TOPROVIDE FOR, ESTABLISH AND MAINTAIN APPROPRIATE PROCEDURESFORSUPERVISION AND CONTROL WITH RESPECT TO PROMPT REPORTING--CONSENT TO CENSURE, $40,000 FINE AND SPECIAL UNDERTAKING TO:(i) ADOPT AND IMPLEMENT POLICIES AND APPROPRIATE PROCEDURESTHAT WOULD REASONABLY ENSURE THAT THE FIRM PROMPTLY REPORTSTOTHE EXCHANGE MATTERS AS REQUIRED BY RULES 351 AND 345 ONFORMSRE-3 AND FORMS U-5, (ii) CONDUCT AN INTERNAL REVIEW TO BECONCLUDED WITHIN A PERIOD OF THREE MONTHS AFTER THE DECISIONISSUED IN THIS MATTER BECOMES FINAL UNDER EXCHANGE RULE 476,TODETERMINE IF ALL MATTERS REPORTABLE PURSUANT TO RULES 351 AND345 ON FORMS RE-3 AND FORM U-5 HAVE BEEN REPORTED, AND TO THEEXTENT NECESSARY MAKE SUCH ADDITIONAL FILINGS, AND (iii) REPORTTO THE EXCHANGE AT THE END OF THE THREE MONTH PERIOD ON THERESULTS OF SUCH REVIEW AND TO AFFIRM THAT ALL REQUIREDREPORTSHAVE BEEN MADE.

Regulator Statement CONTACT: MS. PEGGY L. GERMINO AT (212) 656-8450 U-6 ELECTRONICALLY ENTERED BY NYSE4; TRANS #400003-01895UNLESS A REVIEW BY THE NYSE BOARD OF DIRECTORS IS REQUESTED,THIS DECISION WILL BECOME FINAL 25 CALENDER DAYS AFTER NOTICEOF THE HEARING PANEL'S DETERMINATION HAS BEEN SERVED UPONRESPONDENT. CONTACT: MS. PEGGY L. GERMINO AT (212) 656-8450 U-6 ELECTRONICALLY ENTERED BY NYSE1; TRANS #400041-04095**FEBRUARY 3, 1995** THE DECISION IS NOW FINAL AND IS EFFECTIVEIMMEDIATELY -- IMPOSED PENALTY CONSENTED TO BY THE FIRM OF ACENSURE, A FINE OF $40,000.00 AND A REQUIREMENT TO COMPLY WITHITS UNDERTAKING TO (i) ADOPT AND IMPLEMENT POLICIES ANDAPPROPRIATE PROCEDURES THAT WOULD REASONABLY **ENSURE THATTHEFIRM PROMPLY REPORTS TO THE EXCHANGE MATTERS AS REQURIED BYRULE 351 AND 345 ON FORMS RE-3 AND FORMS U-5, (ii) CONDUCT ANINTERNAL REVIEW TO BE CONCLUDED WITHIN A PERIOD OF THREEMONTHSAFTER THE DECISION ISSUED IN THIS MATTER BECOMES FINAL UNDEREXCHANGE RULE 476, TO DETERMINE IF ALL MATTERS REPORTABLEPURSUANT TO RULES 351 AND 345 ON FORMS RE-3 AND FORMS U-5 HAVEBEEN REPORTED, AND TO THE EXTENT NECESSARY MAKE SUCHADDTIONALFILINGS, AND (iii) REPORT TO THE EXCHANGE AT THE END OF THETHREE MONTH PERIOD ON THE RESULTS OF SUCH REVIEW AND TOAFFIRMTHAT ALL REQUIRED REPORTS HAVE BEEN MADE. --- CONTACT MS. PEGGYL. GERMINO AT (212) 656-8450.






CONTACT: MS. PEGGY L. GERMINO AT (212) 656-8450 U-6 ELECTRONICALLY ENTERED BY NYSE4; TRANS #400003-01895UNLESS A REVIEW BY THE NYSE BOARD OF DIRECTORS IS REQUESTED,THIS DECISION WILL BECOME FINAL 25 CALENDER DAYS AFTER NOTICEOF THE HEARING PANEL'S DETERMINATION HAS BEEN SERVED UPONRESPONDENT. CONTACT: MS. PEGGY L. GERMINO AT (212) 656-8450 U-6 ELECTRONICALLY ENTERED BY NYSE1; TRANS #400041-04095**FEBRUARY 3, 1995** THE DECISION IS NOW FINAL AND IS EFFECTIVEIMMEDIATELY -- IMPOSED PENALTY CONSENTED TO BY THE FIRM OF ACENSURE, A FINE OF $40,000.00 AND A REQUIREMENT TO COMPLY WITHITS UNDERTAKING TO (i) ADOPT AND IMPLEMENT POLICIES ANDAPPROPRIATE PROCEDURES THAT WOULD REASONABLY **ENSURE THATTHEFIRM PROMPLY REPORTS TO THE EXCHANGE MATTERS AS REQURIED BYRULE 351 AND 345 ON FORMS RE-3 AND FORMS U-5, (ii) CONDUCT ANINTERNAL REVIEW TO BE CONCLUDED WITHIN A PERIOD OF THREEMONTHSAFTER THE DECISION ISSUED IN THIS MATTER BECOMES FINAL UNDEREXCHANGE RULE 476, TO DETERMINE IF ALL MATTERS REPORTABLEPURSUANT TO RULES 351 AND 345 ON FORMS RE-3 AND FORMS U-5 HAVEBEEN REPORTED, AND TO THE EXTENT NECESSARY MAKE SUCHADDTIONALFILINGS, AND (iii) REPORT TO THE EXCHANGE AT THE END OF THETHREE MONTH PERIOD ON THE RESULTS OF SUCH REVIEW AND TOAFFIRMTHAT ALL REQUIRED REPORTS HAVE BEEN MADE. --- CONTACT MS. PEGGYL. GERMINO AT (212) 656-8450.




Other


STIPULATION OF FACTS AND CONSENT TO PENALTY


Docket/Case Number: EXCHANGE HEARING PANEL DECISION 94-166



Allegations: ALLEGATIONS OF VIOLATION OF NYSE RULE 351(A)(FAILURE TOPROMPTLY REPORT CERTAIN EVENTS); NYSE RULE 345.17(B) (FAILURE TOTIMELY AMEND CERTAIN FORMS U-5); AND NYSE RULE 342(A) & (B)(FAILURE TO ESTABLISH APPROPRIATE PROCEDURES FOR CONTROL OFTHESE REPORTING REQUIREMENTS),



Resolution:


Sanction Details: SETTLED BY STIPULATION OF FACTS AND CONSENT TO PENALTY.APPLICANT WAS FINED $40,000 AND AGREED TO: (I) ADOPT POLICIES TOREASONABLY ENSURE PROMPT REPORTING REQUIRED BY RULES 345 &351; (II) CONDUCT AN INTERNAL REVIEW TO DETERMINE IF ANY OTHERFILINGS NEED TO BE MADE, AND, IFNECESSARY, MAKE SUCH FILINGS;AND(III)(CONTINUED BELOW)

Firm Statement REPORT TO THE NYSE AT THE END OF 3 MONTHS THE RESULTS OF THEREVIEW AS SPECIFIED IN (II) AND TO AFFIRM THAT ALL REQUIREDREPORTS HAVE BEEN MADE. THE LATE FILINGS WHICH ARE THE SUBJECTOF THIS ACTION WERE PREDOMINANTLY DISCOVERED BY THE APPLICANTITSELF IN CONDUCTING AN INTERNAL REVIEW AND WERE VOLUNTARILYDISCLOSED & FILED UPON DISCOVERY OF THE ERRORS.








Disclosure 64 of 73

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Initiated By: VERMONT SECURITIES DIVISION




Docket/Case Number: 93-058-S




Allegations: TRANSACTED BUSINESS THROUGH AN UNREGISTEREDBRANCH OFFICE AND FAILURE TO PROVIDE NOTIFICATION RELATIVE TOBRANCH OFFICE CHANGES. RE: 9 VSA 4214 AND POLICY 92-3-S.



Resolution:


Sanction Details: RESPONDENT ENTERED INTO A CONSENT ORDER WHEREINRESPONDENT NEITHER ADMITTED NOR DENIED THE DIVISION'SALLEGATIONS. RESPONDENT AGREED TO A FINE OF $3,500 AND COSTS OF$500.

Regulator Statement CONTACT: ENFORCEMENT ATTORNEY 802-828-3420


Consent



Allegations: ALLEGED THAT EDWARD JONES TRANSACTED BUSINESS THROUGH ANUNREGISTERED BRANCH OFFICE AND FAILED TO PROVIDE NOTIFICATIONRELATIVE TO BRANCH OFFICE CHANGES.











Docket/Case Number: 93-058-S




Resolution:


Sanction Details: RESPONDENT ENTERED INTO A CONSENT ORDER WHEREINRESPONDENT NEITHER ADMITTED NOR DENIED THE DIVISION'SALLEGATIONS. RESPONDENT AGREED TO A FINE OF $3,500 AND COSTSOF $500.


Consent

Disclosure 65 of 73

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Initiated By: FLORIDA DIVISION OF SECURITIES AND INVESTORPROTECTION




Docket/Case Number: 92.133.DOS




Allegations: Not Provided









Resolution:


Sanction Details: RELIEF GRANTED FROM ALL RESTRICTIONS IMPOSED ONTHE FIRMS OPERATION IN FLORIDA PER STIPULATION & CONSENTAGREEMENT DATED 4/24/92 (DOCKET #92.133.DOS)

Regulator Statement CONTACT: NANCY WOOD (904) 488-9805

Sanctions Ordered: Cease and Desist/Injunction



Initiated By: STATE OF FLORIDA DEPARTMENT OF BANKING AND FINANCE


Other


STIPULATION AND CONSENT AGREEMENT


Docket/Case Number: 92.133.DOS



Allegations: ALLEGATION OF VIOLATION OF THE FLORIDA SEC. & INVESTORPROTECTION ACT, WITH REGARDS TO THE TEMPORARY OPERATION OF 6BRANCH OFFICE LOCATIONS FOR WHICH IT HAD ASSIGNED FLORIDALICENSED REPRESENTATIVES AND HAD SUBMITTED PENDINGAPPLICATIONS TO THE DEPARTMENT, BUT FOR WHICH IT HAD NOT YETRECEIVED APPROVAL FROM FLORIDA.



Resolution:

Other Sanctions Ordered: STIPULATION AND CONSENT AGREEMENT

Sanction Details: APPLICANT ENTERED INTO A STIPULATION AND CONSENT AGREEMENTWITH FLORIDA. WITHOUT ADMITTING OR DENYING THAT THESEACTIVITIES CONSTITUTED VIOLAITONS OF THE FLORIDA SEC. & INVESTORPROTECTION ACT, APPLICANT AGREED: TO MAKE A $15,000CONTRIBUTION TO FLORIDA'S ANTIFRAUD TRUST FUND,& TO MAKE(CONTINUED BELOW)








Sanction Details: APPLICANT ENTERED INTO A STIPULATION AND CONSENT AGREEMENTWITH FLORIDA. WITHOUT ADMITTING OR DENYING THAT THESEACTIVITIES CONSTITUTED VIOLAITONS OF THE FLORIDA SEC. & INVESTORPROTECTION ACT, APPLICANT AGREED: TO MAKE A $15,000CONTRIBUTION TO FLORIDA'S ANTIFRAUD TRUST FUND,& TO MAKE(CONTINUED BELOW)

Firm Statement CERTAIN ONGOING CHANGES IN ITS SUPERVISION OF ITS FLORIDAOFFICES. EFFECTIVE APRIL 12, 1996, APPLICANT WAS RELIEVED OF ANYONGOING SPECIAL COMPLIANCE REQUIREMENTS GOVERNING ITSFLORIDA OFFICES FORMERLY IMPOSED BY THE AGREEMENT.

Disclosure 66 of 73

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Docket/Case Number: MS-1104-AWC



Allegations:



Resolution:


Sanction Details:

Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-1104-AWC (A)LETTEROF ACCEPTANCE, WAIVER AND CONSENT FILED MAY 31, 1991 AGAINSTRESPONDENT MEMBER EDWARD D. JONES & COMPANY ALLEGINGVIOLATIONSOF PART VI, SECTION 5(a) OF SCHEDULE D IN THAT RESPONDENTSFAILED TO REPORT THEIR NASDAQ VOLUME. THE LETTER OFACCEPTANCE,WAIVER AND CONSENT WAS ACCEPTED BY THE MARKET SURVEILLANCECOMMITTEE ON JULY 1, 1991 AND BY THE NATIONAL BUSINESS CONDUCTCOMMITTEE ON AUGUST 19, 1991. $1,000 FINE. ***$1,000.00 PAID ON 9/4/91 INVOICE #91-MS-1014***


Consent






MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-1104-AWC (A)LETTEROF ACCEPTANCE, WAIVER AND CONSENT FILED MAY 31, 1991 AGAINSTRESPONDENT MEMBER EDWARD D. JONES & COMPANY ALLEGINGVIOLATIONSOF PART VI, SECTION 5(a) OF SCHEDULE D IN THAT RESPONDENTSFAILED TO REPORT THEIR NASDAQ VOLUME. THE LETTER OFACCEPTANCE,WAIVER AND CONSENT WAS ACCEPTED BY THE MARKET SURVEILLANCECOMMITTEE ON JULY 1, 1991 AND BY THE NATIONAL BUSINESS CONDUCTCOMMITTEE ON AUGUST 19, 1991. $1,000 FINE. ***$1,000.00 PAID ON 9/4/91 INVOICE #91-MS-1014***




Other


ACCEPTANCE, WAIVER AND CONSENT PROCEDURE


Docket/Case Number: MS-1104-AWC



Allegations: ALLEGATIONS OF VIOLATION OF PART VI, SECTION 5(A) OF SCHEDULE DFOR FAILURE TO GIVE TIMELY VOLUME REPORTING IN CONNECTION WITHCERTAIN ACTIVITIES AS A NASDAQ MARKET MAKER.



Resolution:


Sanction Details: FINE OF $1,000.

Firm Statement APPLICANT WAS FINED $1,000 BY THE NATIONAL ASSOCIATION OFSECURITIES DEALERS, INC. PURSUANT TO ITS ACCEPTANCE, WAIVER ANDCONSENT PROCEDURE.



Disclosure 67 of 73

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Allegations:











Docket/Case Number: MS-973(A)-AWC



Allegations:


Resolution:


Sanction Details:

Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-973(A)-AWC: (A)LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED OOCTOBER 4,1990AGAINST RESPONDENT MEMBER EDWARD D. JONES & CO.; ALLEGINGVIOLATIONS OF PART VI, SECTIONS 5(a) OF SCHEDULED D IN THATRESPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME.

THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BYTHE MARKET SURVEILLANCE COMMITTEE ON NOVEMBER 27, 1990 AND BYTHE BUSINESS CONDUCT COMMITTEE ON DECEMBER 24, 1990. $1,500FINE. ***$1,7500.00 PAID ON 3/19/91 INVOICE #91-MS-288***






Allegations: ALLEGATION OF VIOLATION OF PART VI, SECTION 5(A) OF SCHEDULE DFOR FAILURE TO GIVE TIMELY VOLUME REPORTING IN CONNECTION WITHCERTAIN ACTIVITIES AS A NASDAQ MARKET MAKER.








Other


ACCEPTANCE, WAIVER AND CONSENT PROCEDURE.


Docket/Case Number: MS-973 AWC




Resolution:


Sanction Details: FINE OF $1,750.

Firm Statement APPLICANT WAS FINED $1,750 BY THE NATIONAL ASSOCIATION OFSECURITIES DEALERS, INC. PURSUANT TO ITS ACCEPTANCE, WAIVER ANDCONSENT PROCEDURE.



Disclosure 68 of 73

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Initiated By: IDAHO


Other


FINE






Allegations: COMPLAINANT ALLEGED VIOLATIONS OF THE IDAHO SECURITIES ACT INTHAT RESPONDENT EDWARD D. JONES & CO. ALLOWED UNREGISTEREDPERSONNEL TO EFFECT OR ATTEMPT TO EFFECT SECURITIESTRANSACTIONS FOR WHICH THEY ARE REQUIRED TO BE REGISTERED.








FINE


Resolution:


Sanction Details: COMPLAINT FOUND THAT RESPONDENT DID NOT PROPERLY SUPERVISETHE ACTIVITIES OF PERSONNEL. WITHOUT ADMITTING OR DENYING THEALLEGATIONS AND FINDINGS, RESPONDENT AGREED: TO PAY A FINE OF$5,000 AND INVESTIGATIVE EXPENSES OF $2,000; TO DEVELOP AND ABIDEBY A WRITTEN POLICY SUPERVISING THE SECURITIES RELATEDACTIVITIES OF ITS UNREGISTERED BRANCHOFFICE PERSONNEL; AND, TO CONDUCT ADEQUATE SUPERVISION IN THEFUTURE.


Consent


Initiated By: IDAHO DEPARTMENT OF FINANCE


Other


CONSENSUAL AGREEMENT





Allegations: ALLEGATIONS OF VIOLATIONS IN SUPERVISING SECURITIES-RELATEDACTIVITIES OF NON-REGISTERED BRANCH PERSONNEL.



Resolution:


Sanction Details: APPLICANT ENTERED A CONSENSUAL AGREEMENT WITH THE IDAHODEPARTMENT OF FINANCE. WITHOUT ADMITTING OR DENYING THEFINDINGS OF THE STATE, APPLICANT AGREED TO DEVELOP AND ABIDE BYWRITTEN POLICIES SUPERVISING THE SECURITIES -RELATED ACTIVITIESOF NON-REGISTERED BRANCH PERSONNEL, TO CONDUCT ADEQUATESUPERVISION (CONTINUED BELOW)


Settled






Sanction Details: APPLICANT ENTERED A CONSENSUAL AGREEMENT WITH THE IDAHODEPARTMENT OF FINANCE. WITHOUT ADMITTING OR DENYING THEFINDINGS OF THE STATE, APPLICANT AGREED TO DEVELOP AND ABIDE BYWRITTEN POLICIES SUPERVISING THE SECURITIES -RELATED ACTIVITIESOF NON-REGISTERED BRANCH PERSONNEL, TO CONDUCT ADEQUATESUPERVISION (CONTINUED BELOW)

Firm Statement THEREOF, TO PAY A FINE OF $5,000 AND TO REIMBURSE THE STATE $2,000FOR ITS COSTS OF INVESTIGATION.

Disclosure 69 of 73

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Docket/Case Number: KC-444



Allegations:



Resolution:


Sanction Details:

Regulator Statement COMPLAINT NO. KC-444 FILED FEBRUARY 8, 1989 BY DISTRICT NO. 4AGAINST RESPONDENTS EDWARD D. JONES & CO. AND JAMESTHEODOREMORRIS, JR. ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1 AND35 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENT MEMBER,ACTING THROUGH RESPONDENT MORRIS, APPROVED THE PUBLICATIONOF ANADVERTISEMENT WHICH CONTAINED MATERIAL MISSTATEMENTS OROMISSIONS WHICH CAUSED THIS ADVERTISEMENT TO BE MISLEADING.

DECISION RENDERED JUNE 20, 1989, WHEREIN THE OFFER OFSETTLEMENTSUBMITTED BY RESPONDENTS WAS ACCEPTED; THEREFORE, THEY ARECENSURED AND FINED $1,000.00, JOINTLY AND SEVERALLY. ***$1,000.00 PAID J&S 7/17/89***


Consent






COMPLAINT NO. KC-444 FILED FEBRUARY 8, 1989 BY DISTRICT NO. 4AGAINST RESPONDENTS EDWARD D. JONES & CO. AND JAMESTHEODOREMORRIS, JR. ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1 AND35 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENT MEMBER,ACTING THROUGH RESPONDENT MORRIS, APPROVED THE PUBLICATIONOF ANADVERTISEMENT WHICH CONTAINED MATERIAL MISSTATEMENTS OROMISSIONS WHICH CAUSED THIS ADVERTISEMENT TO BE MISLEADING.

DECISION RENDERED JUNE 20, 1989, WHEREIN THE OFFER OFSETTLEMENTSUBMITTED BY RESPONDENTS WAS ACCEPTED; THEREFORE, THEY ARECENSURED AND FINED $1,000.00, JOINTLY AND SEVERALLY. ***$1,000.00 PAID J&S 7/17/89***






Docket/Case Number: KC-444, DISTRICT # 4



Allegations: ALLEGATIONS OF VIOLATION OF ARTICLE III, SECTIONS 1 AND 35 OF THERULES OF FAIR PRACTICE FOR APPROVING AN ADVERTISEMENT FOUNDTO BE MISLEADING.



Resolution:



Firm Statement PURSUANT TO AN OFFER OF SETTLEMENT, WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, EDWARD JONES AND JAMES T. MORRIS, JR.,WERE CENSURED AND FINED $1000 BY THE NASD.


Decision & Order of Offer of Settlement

Disclosure 70 of 73

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Docket/Case Number: KC-292-SC



Allegations:



Resolution:


Sanction Details:

Regulator Statement COMPLAINT KC-292-SC FILED 08/31/83 DIST. #4 DECISION 09/14/83:CENSURED AND FINED $900, J&S. ****9/23/83, SUMMARY COMPLAINT #KC-292-SC, PAID IN FULL.


Decision





Docket/Case Number: KC-292-SC



Allegations: ALLEGATIONS OF VIOLATION OF ITS RULE CONCERNING FREE-RIDINGAND WITHHOLDING.










Resolution:



Firm Statement EDWARD JONES AND JAMES W. HARROD, A FORMER REGISTEREDREPRESENTATIVE, WERE CENSURED AND FINED $900 BY THE NASDPURSUANT TO A SUMMARY COMPLAINT PROCEDURE.


Decision

Disclosure 71 of 73

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Initiated By: CHICAGO STOCK EXCHANGE




Docket/Case Number: D-MSE-80-76



Allegations:



Resolution:


Sanction Details:


Decision






Regulator Statement MSE - FILE NUMBER D-MSE-80-7608/22/80 - FINED IN THE AMOUNT OF $50.00 AGAINST RESPONDENT'SMSTC PARTICIPANTACCOUNT ON AUGUST 22, 1980.


Initiated By: MIDWEST STOCK EXCHANGE, INC. (CHICAGO STOCK EXCHANGE)




Docket/Case Number: D-MSE-80-76



Allegations: ALLEGATIONS OF VIOLATION OF A REQUIREMENT THAT SETTLEMENTOBLIGATIONS BY PAID IN CLEARING HOUSE FUNDS ON SETTLEMENT DATEOR IN FEDERAL FUNDS ON THE NEXT BUSINESS DAY FOLLOWINGSETTLEMENT DATE.



Resolution:



Firm Statement MIDWEST STOCK EXCHANGE, INC. FINED EDWARD JONES $50.


Decision

Disclosure 72 of 73

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Initiated By: PENNSYLVANIA

Allegations: RESPONDENT MEMBER FIRM ENGAGED IN UNLICENSEDSALES ACTIVITY OVER THE PAST THREE (3) YEARS.







Initiated By: PENNSYLVANIA


Censure


COSTS AND FEES







Resolution:

Other Sanctions Ordered: THE ORDER ALLOWS THE COMPANY TO WITHDRAW ITS APPLICATION FORREGISTRATION, PROHIBITS THE COMPANY FROM REAPPLYING FORREGISTRATION FOR 18 MONTHS

Sanction Details: ORDER OF CENSURE ISSUED TO EDWARD D. JONES & COMPANY, INC..AND ASSESES COSTS, FEES AND OTHER SANCTIONS TOTALING $18,369.

Sanctions Ordered: Censure

Decision


Initiated By: PENNSYLVANIA SECURITIES COMMISSION


Prohibition






Allegations: ALLEGATION OF VIOLATIONS OF CERTAIN PROVISIONS OF THEPENNSYLVANIA SECURITIES ACT OF 1972 AS HAVING ENGAGED INTRANSACTIONS IN PENNSYLVANIA WITHOUT HAVING REGISTERED AS ABROKER/DEALER IN PENNSYLVANIA.









Resolution:


Sanction Details: CENSURE AND PROHIBITION FROM ENGAGING IN ANY FURTHERTRANSACTIONS IN PENNSYLVANIA AND FROM REAPPLYING FORREGISTRATION FOR A PERIOD OF 18 MONTHS; AND FINE OF $18,369.

Firm Statement APPLICANT ENTERED INTO A CONSENSUAL SETTLEMENT WITHOUTADMISSION OR DENIAL OF GUILT, PENNSYLVANIA ISSUED ITS ORDERINCLUDING FINDINGS OF FACT AND CONCLUSIONS OF LAW, AND THEAPPLICANT WAS CENSURED, PROHIBITED FROM ENGAGING IN ANYFURTHER TRANSACTIONS IN PENNSYLVANIA AND FROM REAPPLYING FORREGISTRATION FOR A PERIOD OF 18 MONTHS, AND FINED $18,369.


Settled

Disclosure 73 of 73

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Allegations:



Resolution:


Decision







Sanction Details:

Regulator Statement COMP# #KC-291, FILED 8/31/83, DIST. #4, ALLEGING VIOLATIONS OFARTICLE III, SECTION 1 OF THE RULES OF FAIR PRACTICE IN THATRESPONDENT MEMBER, JONES (EDWARD D.) & CO., ACTING THRUJOHN D. BEUERLEIN, FAILED TO MAKE A BONA FIDE PUBLICDISTRIBUTION OF AN OFFERING THAT WENT TO AN IMMEDIATEPREMIUM IN THE SECONDARY MARKET IN THAT SHARES WERE HELDIN THE RESPONDENT MEMBER'S ACCOUNT AND SOLD AT A LATER DATE,IN CONTRAVENTION OF THE B/G'S INTERPRETATION WITH RESPECTTO FREE-RIDING AND WITHHOLDING. ****DECISION RENDERED2/23/84, WHEREIN RESPONDENTS ARE CENSURED AND RESPONDENTMEMBER IS FINED $3,230 AND ASSESSED COSTS OF $276.90. IF NOFURTHER ACTION, DECISION IS FINAL 4/7/84. ****3/6/84, APPEALEDTO B/G. *****3/15/84, B/G REVIEW. ****B/G'S RENDERED 8/28/84,WHEREIN THE FINDINGS MADE AND THE SANCTIONS IMPOSED AREAFFIRMED. IF NO FURTHER ACTION, DECISION IS FINAL 9/26/84.****9/25/84, APPEALED TO SEC. ****SEC NEWS DIGEST, ISSUE 85-192,OCTOBER 3, 1985: THE COMMISSION AFFIRMED SANCTIONS IMPOSED BYTHE NASD ON EDWARD D. JONES & CO. AND JOHN D. BEUERLEIN. THENASD CENSURED APPLICANTS AND FINED THE FIRM $3,230. THECOMMISSION FOUND, AS HAD THE NASD, THAT APPLICANTS VIOLATEDTHE NASD'S INTERPRETATION RESPECTING FREE-RIDING ANDWITHHOLDING. THE INTERPRETATION REQUIRES MEMBERS TODISTRIBUTEAT THE PUBLIC OFFERING PRICE ALL SHARES OF PUBLIC OFFERINGSTHATRISE TO AN IMMEDIATE AFTERMARKET PREMIUM (HOT ISSUES). ITPROHIBITS MEMBERS FROM CONTINUING TO HOLD ANY OF SUCHSECURITIES IN ANY OF THEIR ACCOUNTS. IN FEBRUARY 1983,APPLICANTS RECEIVED AN ALLOTMENT OF 2,200 SHARES OF A HOTISSUE, VSLI TECHNOLOGY, INC., FROM THE MANAGING UNDERWRITER,AND IMPROPERLY RETAINED 1,000 SHARES OF VLSI STOCK WHENTHE STOCK ROSE TO AN IMMEDIATE AFTERMARKET PREMIUM.THE FIRM THEN SOLD THE 1,000 SHARES OF VLSI TO ANOTHER DEALERAT A PROFIT. (REL. 34-22449)



Allegations: ALLEGATIONS OF VIOLATIONS OF NASD RULE CONCERNING FREE-RIDINGAND WITHHOLDING.









Censure






Allegations: ALLEGATIONS OF VIOLATIONS OF NASD RULE CONCERNING FREE-RIDINGAND WITHHOLDING.


Resolution:


Sanction Details: CENSURE AND FINE OF $3,230.

Firm Statement APPLICANT AND BEUERLEIN WERE CENSURED; APPLICANT WASADDITIONALLY FINED $3,230.


Other






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


Initiated By: ATTORNEY GENERAL'S OFFICE STATE OF CALIFORNIA

Relief Sought: Injunction

Other Relief Sought: MONETARY

Date Court Action Filed: 12/20/2004


Other Product Types:

Court Details: SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OFSACRAMENTO, CASE NO. 04AS05097.

THE STATE ALLEGES EDWARD JONES VIOLATED CORPORATIONS CODESECTION 25401 BY FAILING TO ADEQUATELY DISCLOSE ITS REVENUESHARING ARRANGEMENTS WITH CERTAIN DESIGNATED PREFERREDMUTUAL FUND FAMILIES; AND SECTION 25216(A) BY OMITTING TODISCLOSE A MATERIAL FACT OR FACTS WITH RESPECT TO ITS REVENUESHARING ARRANGEMENTS WITH CERTAIN DESIGNATED PREFERREDMUTUAL FUND FAMILIES WHICH MAY HAVE BEEN MISLEADING.

Allegations:


Resolution: Settled


Other Sanctions:

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, EDWARD JONESAGREED TO PAY $2.7 MILLION TO THE ATTORNEY GENERAL AS FEES ANDCOSTS AND $4.8 MILLION TO THE STATE OF CALIFORNIA AS CIVILPENALTIES.

Firm Statement ON 5/12/2006, THE COURT GRANTED THE PARTNERSHIP'S MOTION TODISMISS AND DISMISSED THE LAWSUIT, AND FURTHER DENIED THEATTORNEY GENERAL'S REQUEST FOR RECONSIDERATION. THECALIFORNIA ATTORNEY GENERAL FILED AN APPEAL. ON 8/24/2007, THECALIFORNIA COURT OF APPEAL ISSUED ITS OPINION, REMANDING THECASE TO THE TRIAL COURT WITH INSTRUCTIONS TO VACATE THEPREVIOUS ORDER SUSTAINING THE DEMURRER WITHOUT LEAVE TOAMEND, AND ENTERED A NEW ORDER OVERRULING THE DEMURRER. ON10/3/2007, EDWARD JONES TIMELY FILED A PETITION FOR REVIEW WITHTHE CALIFORNIA SUPREME COURT. ON 11/28/2007, THE CALIFORNIASUPREME COURT DENIED THE PETITION. ON 12/6/2007, THE CASE WASREMITTED BACK TO TRIAL COURT. UNDER A SETTLEMENT AGREEMENT,THE CASE WAS DISMISSED WITH PREJUDICE.

Monetary/Fine $4,800,000.00Sanctions Ordered or ReliefGranted:





www.finra.org/brokercheck User GuidanceON 5/12/2006, THE COURT GRANTED THE PARTNERSHIP'S MOTION TODISMISS AND DISMISSED THE LAWSUIT, AND FURTHER DENIED THEATTORNEY GENERAL'S REQUEST FOR RECONSIDERATION. THECALIFORNIA ATTORNEY GENERAL FILED AN APPEAL. ON 8/24/2007, THECALIFORNIA COURT OF APPEAL ISSUED ITS OPINION, REMANDING THECASE TO THE TRIAL COURT WITH INSTRUCTIONS TO VACATE THEPREVIOUS ORDER SUSTAINING THE DEMURRER WITHOUT LEAVE TOAMEND, AND ENTERED A NEW ORDER OVERRULING THE DEMURRER. ON10/3/2007, EDWARD JONES TIMELY FILED A PETITION FOR REVIEW WITHTHE CALIFORNIA SUPREME COURT. ON 11/28/2007, THE CALIFORNIASUPREME COURT DENIED THE PETITION. ON 12/6/2007, THE CASE WASREMITTED BACK TO TRIAL COURT. UNDER A SETTLEMENT AGREEMENT,THE CASE WAS DISMISSED WITH PREJUDICE.

Disclosure 2 of 2

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Relief Sought:

Other Relief Sought:



Other Product Types:

Court Details:

Allegations:


Resolution: Consent


Other Sanctions:

Sanction Details:

Regulator Statement SEC NEWS DIGEST, ISSUE 85-188, SEPTEMBER 27, 1985: THECOMMISSION ANNOUNCED THAT ON SEPTEMBER 26, 1985 THE USDC FORTHEDISTRICT OF COLUMBIA ENTERED A FINAL JUDGEMENT OF PERMANENTINJUNCTION ENJOINING EDWARD D. JONES & CO. (EDJ) FROM VIOLATIONSOF THE ANTIFRAUD PROVISIONS OF THE SECURITIES ACT OF 1933. EDJCONSENTED TO THE JUDGEMENT WITHOUT ADMITTING OR DENYING THECOMPLAINT'S ALLEGATONS, WHICH WAS ALSO FILED SEPTEMBER 26,1985.THE COMPLAINT ALLEGED THAT EDJ CONTINUED TO SELL DEBENTURESISSUED BY D.H. BALDWIN COMPANY (DHB), A SUBSIDIARY OFBALDWIN-UNITED CORPORATION (BALDWIN), AS AN UNDERWRITER AFTERMATERIAL ADVERSE INFORMATION ABOUT BALDWIN APPEARED IN THEPRESS. THE PRESS ARTICLE DESCRIBED CAPITAL SHORTAGES IN DHB'SPRIMARY SUBSIDIARIES AS A RESULT OF INCREASING SALES OFINSURANCE PRODUCTS AND REDUCTIONS IN VALUATIONS OF AFFILIATEDCOMPANY SECURITIES. EDJ FAILED TO REASONABLY INVESTIGATE AFTERTHIS PRESS STATEMENT OCCURRED AND RECKLESSLY CONTINUED TOSELLDHB DEBENTURES. BALDWIN AND DHB DEFAULTED ON A MAJOR SHORT-TERMDEBT APPROXIMATELY THREE MONTHS AFTER EDJ COMPLETED ITSUNDERWRITING OF THE DEBENTURES AND ENTERED BANKRUPTCYPROCEEDINGS SIX MONTHS LATER. THE JUDGEMENT ENJOINS EDJ FROMVIOLATIONS OF SECTION 17(a) OF THE SECURITIES ACT AND REQUIRESEDJ TO CREATE A "DUE DILIGENCE REVIEW COMMITTEE" TO REVIEW ANDSUPERVISE ITS DUE DILIGENCE INVESTIGATION PROCEDURES. (SEC V.EDWARD D. JONES & CO., CIVIL ACTION NO. 85-3078, USDC DC)(LR-10879)

Cease and Desist/InjunctionSanctions Ordered or ReliefGranted:






SEC NEWS DIGEST, ISSUE 85-188, SEPTEMBER 27, 1985: THECOMMISSION ANNOUNCED THAT ON SEPTEMBER 26, 1985 THE USDC FORTHEDISTRICT OF COLUMBIA ENTERED A FINAL JUDGEMENT OF PERMANENTINJUNCTION ENJOINING EDWARD D. JONES & CO. (EDJ) FROM VIOLATIONSOF THE ANTIFRAUD PROVISIONS OF THE SECURITIES ACT OF 1933. EDJCONSENTED TO THE JUDGEMENT WITHOUT ADMITTING OR DENYING THECOMPLAINT'S ALLEGATONS, WHICH WAS ALSO FILED SEPTEMBER 26,1985.THE COMPLAINT ALLEGED THAT EDJ CONTINUED TO SELL DEBENTURESISSUED BY D.H. BALDWIN COMPANY (DHB), A SUBSIDIARY OFBALDWIN-UNITED CORPORATION (BALDWIN), AS AN UNDERWRITER AFTERMATERIAL ADVERSE INFORMATION ABOUT BALDWIN APPEARED IN THEPRESS. THE PRESS ARTICLE DESCRIBED CAPITAL SHORTAGES IN DHB'SPRIMARY SUBSIDIARIES AS A RESULT OF INCREASING SALES OFINSURANCE PRODUCTS AND REDUCTIONS IN VALUATIONS OF AFFILIATEDCOMPANY SECURITIES. EDJ FAILED TO REASONABLY INVESTIGATE AFTERTHIS PRESS STATEMENT OCCURRED AND RECKLESSLY CONTINUED TOSELLDHB DEBENTURES. BALDWIN AND DHB DEFAULTED ON A MAJOR SHORT-TERMDEBT APPROXIMATELY THREE MONTHS AFTER EDJ COMPLETED ITSUNDERWRITING OF THE DEBENTURES AND ENTERED BANKRUPTCYPROCEEDINGS SIX MONTHS LATER. THE JUDGEMENT ENJOINS EDJ FROMVIOLATIONS OF SECTION 17(a) OF THE SECURITIES ACT AND REQUIRESEDJ TO CREATE A "DUE DILIGENCE REVIEW COMMITTEE" TO REVIEW ANDSUPERVISE ITS DUE DILIGENCE INVESTIGATION PROCEDURES. (SEC V.EDWARD D. JONES & CO., CIVIL ACTION NO. 85-3078, USDC DC)(LR-10879)



Relief Sought:

Other Relief Sought:



Other Product Types: DEBENTURES

Court Details: UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA, CIVILACTION NO. 85-3078

VIOLATIONS OF SECTION 17(A) OF THE SECURITIES ACT IN CONNECTIONWITH THE UNDERWRITING OF D.H. BALDWIN DEBENTURES.

Allegations:


Resolution: Consent


Other Sanctions:

Cease and Desist/InjunctionSanctions Ordered or ReliefGranted:






Sanction Details: PERMANENT INJUNCTION ENJOINING EDWARD JONES FROM VIOLATIONSOF SECTION 17(A) OF THE SECURITIES ACT AND REQUIREMENT THATEDWARD JONES CREATE A "DUE DILIGENCE REVIEW COMMITTEE" TOREVIEW AND SUPERVISE ITS DUE DILIGENCE INVESTIGATIONPROCEDURES.

Firm Statement ON 09/25/1985, THE UNITED STATES DISTRICT COURT FOR THE DISTRICTOF COLUMBIA ENTERED A FINAL JUDGMENT OF PERMANENT INJUNCTIONENJOINING EDWARD JONES FROM VIOLATIONS OF SECTION 17(A) OF THESECURITIES ACT AND REQUIRES THAT EDWARD JONES CREATE A "DUEDILIGENCE REVIEW COMMITTEE" TO REVIEW AND SUPERVISE ITS DUEDILIGENCE INVESTIGATION PROCEDURES. EDWARD JONES CONSENTEDTO THE JUDGMENT WITHOUT ADMITTING OR DENYING THE COMPLAINT'SALLEGATIONS CONCERNING THE UNDERWRITING OF D.H. BALDWINDEBENTURES.






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 148


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

06/29/2000

00-02685

ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

ANNUITIES; COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SECINVOLVE

$1,400,000.00

AWARD AGAINST PARTY

06/07/2001

$44,828.78

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 148

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

10/09/2000

00-04272

DO NOT USE-NO OTHER CONTROVERSY INVOLVED; EMPLOYMENT-LIBELOR SLANDER ON FORM U-5

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES 184©2020 FINRA. All rights reserved. Report about EDWARD JONES




www.finra.org/awardsonline

https://www.finra.org/arbitration-mediation/arbitration-awards-online?search=00-02685





Disposition:

Disposition Date:


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

$500,000.00

AWARD AGAINST PARTY

12/21/2001

$75,000.00


Disclosure 3 of 148

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/21/2001

01-01136

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$48,000.00

AWARD AGAINST PARTY

04/24/2002

$68,504.83


Disclosure 4 of 148

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Arbitration Forum:

Case Initiated:

Allegations:

NASD

03/13/2001

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







Case Initiated:

Case Number:



Disposition:

Disposition Date:


03/13/2001

01-01159


$837,000.00

AWARD AGAINST PARTY

03/12/2002

$50,000.00


Disclosure 5 of 148

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

05/10/2001

01-02351

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE


$46,066.00

AWARD AGAINST PARTY

08/20/2002

$8,861.75


Disclosure 6 of 148

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Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING








Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

07/02/2001

01-03281

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING


$117,648.72

AWARD AGAINST PARTY

07/15/2002

$103,594.71


Disclosure 7 of 148

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

08/14/2001

01-03612

ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOTUSE-NO OTHER CONTROVERSY INVOLVED


Unspecified Damages

AWARD AGAINST PARTY

03/01/2002

$125.00


Disclosure 8 of 148

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

08/13/2001

01-04237



$4,700,000.00

AWARD AGAINST PARTY

11/05/2002

$90,600.00


Disclosure 9 of 148

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/08/2002

02-00005

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; OPTIONS

$750,000.00

AWARD AGAINST PARTY

09/03/2003

$90,367.00

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 148

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/09/2002

02-00061



$4,961,018.00

AWARD AGAINST PARTY

09/25/2003

$2,687,558.69



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:

NASD

02/06/2002

02-00131

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

$1,262,874.00

AWARD AGAINST PARTY

03/24/2003189©2020 FINRA. All rights reserved. Report about EDWARD JONES







Disposition Date:


03/24/2003

$14,250.01



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/24/2002

02-00229

ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

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

$172,050.38

AWARD AGAINST PARTY

11/01/2002

$229,343.16



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

04/11/2002

02-01504

ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-UNAUTHORIZEDTRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NOOTHER CONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS190©2020 FINRA. All rights reserved. Report about EDWARD JONES









Disposition:

Disposition Date:



$450,000.00

AWARD AGAINST PARTY

01/15/2003

$75,745.01



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/22/2002

02-01529



$366,785.00

AWARD AGAINST PARTY

03/24/2003

$10,000.00



i



Arbitration Forum:

Allegations:

NASD

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY







Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


NASD

04/04/2002

02-01683


$250,000.00

AWARD AGAINST PARTY

06/05/2003

$104,000.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

05/24/2002

02-02194

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-UNAUTHORIZED TRADING


$497,931.00

AWARD AGAINST PARTY

12/05/2003

$100,000.00



i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

06/13/2002

02-02381

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING;ACCOUNT RELATED-FAILURE TO SUPERVISE

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

$400,000.00

AWARD AGAINST PARTY

02/06/2004

$55,000.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

06/24/2002

02-02483


COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHERTYPES OF SECURITIES

$235,334.10

AWARD AGAINST PARTY

05/22/2003

$67,700.00











i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

05/28/2002

02-02557



$900,000.00

AWARD AGAINST PARTY

08/07/2003

$333,533.01



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:

NASD

05/25/2002

02-02626

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-MARGINCALLS

COMMON STOCK; CORPORATE BONDS; MUNICIPAL BONDS; MUTUALFUNDS

$11,600,000.00

AWARD AGAINST PARTY

12/11/2003194©2020 FINRA. All rights reserved. Report about EDWARD JONES







Disposition Date:


12/11/2003

$1,033,233.01



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

09/24/2002

02-05038

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURETO SUPERVISE


$440,000.00

AWARD AGAINST PARTY

08/08/2003

$10,000.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

09/19/2002

02-05051

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-FAILURE TO SUPERVISE











Disposition:

Disposition Date:



$750,000.00

AWARD AGAINST PARTY

12/19/2003

$2,700.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

10/29/2002

02-06265



Unspecified Damages

AWARD AGAINST PARTY

10/22/2004

$186,758.43



i



Arbitration Forum:

Case Initiated:

Allegations:

NASD

12/10/2002

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-NEGLIGENCE







Case Initiated:

Case Number:



Disposition:

Disposition Date:


12/10/2002

02-06536


$50,000.00

AWARD AGAINST PARTY

12/22/2003

$28,907.48



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/11/2003

02-06722



$460,000.00

AWARD AGAINST PARTY

03/12/2004

$78,676.00



i



Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE 197©2020 FINRA. All rights reserved. Report about EDWARD JONES







Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


NASD

12/02/2002

02-06979



$360,000.00

AWARD AGAINST PARTY

01/08/2004

$92,000.01



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/15/2003

03-00075

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE


$87,000.00

AWARD AGAINST PARTY

02/26/2004

$20,810.00



i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/21/2003

03-00186



$290,000.00

AWARD AGAINST PARTY

03/12/2004

$100,000.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/22/2003

03-00417

DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$135,802.80

AWARD AGAINST PARTY

03/09/2004

$68,126.41


i199©2020 FINRA. All rights reserved. Report about EDWARD JONES








i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

02/18/2003

03-01034

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING;ACCOUNT RELATED-NEGLIGENCE


$139,975.00

AWARD AGAINST PARTY

04/15/2004

$139,975.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/07/2003

03-01454

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NOOTHER CONTROVERSY INVOLVED


$5,000,000.00

AWARD AGAINST PARTY

04/30/2004

$600.00








Sum of All Relief Awarded: $600.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

04/16/2003

03-01732

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-NEGLIGENCE

ANNUITIES; COMMON STOCK; MUTUAL FUNDS; PREFERRED STOCK

$400,000.00

AWARD AGAINST PARTY

06/02/2004

$35,000.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

NASD

04/08/2003

03-02445

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY

UNKNOWN TYPE OF SECURITIES

$154,842.05

AWARD AGAINST PARTY 201©2020 FINRA. All rights reserved. Report about EDWARD JONES







Disposition:

Disposition Date:


AWARD AGAINST PARTY

04/21/2005

$23,556.22



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

05/06/2003

03-02618

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; DO NOTUSE-NO OTHER CONTROVERSY INVOLVED


$38,104.28

AWARD AGAINST PARTY

02/03/2004

$38,104.29



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

NASD

05/12/2003

03-02658

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING;ACCOUNT RELATED-NEGLIGENCE








Case Number:



Disposition:

Disposition Date:


03-02658


$56,319.55

AWARD AGAINST PARTY

11/23/2004

$69,489.55



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

07/16/2003

03-04335

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-OTHER

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUNICIPAL BOND FUNDS; MUTUAL FUNDS

$6,000,000.00

AWARD AGAINST PARTY

05/19/2004

$74,338.11



i



Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE 203©2020 FINRA. All rights reserved. Report about EDWARD JONES







Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

07/02/2003

03-04689

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

ANNUITIES; COMMON STOCK; CORPORATE BONDS; DO NOT USE-NOOTHER TYPE OF SEC INVOLVE

$350,000.00

AWARD AGAINST PARTY

11/30/2004

$105,001.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

07/17/2003

03-05125

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NOOTHER CONTROVERSY INVOLVED


$623,730.00

AWARD AGAINST PARTY

10/21/2004

$67,175.00



i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

07/31/2003

03-05558

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-FAILURE TO SUPERVISE


$236,000.00

AWARD AGAINST PARTY

01/25/2005

$130,300.01



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

08/04/2003

03-05587

ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE


$227,800.00

AWARD AGAINST PARTY

09/09/2004

$124,928.01










i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

08/13/2003

03-05690

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUTUAL FUNDS

$98,943.00

AWARD AGAINST PARTY

05/24/2004

$28,004.98



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

NASD

08/19/2003

03-05851

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE


$173,500.00








Disposition:

Disposition Date:


AWARD AGAINST PARTY

12/16/2004

$208,032.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

10/24/2003

03-07018

ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BOND FUNDS;MUTUAL FUNDS

$15,913.00

AWARD AGAINST PARTY

06/02/2004

$8,261.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

NASD

12/08/2003

03-07249









Case Number:



Disposition:

Disposition Date:


03-07249


Unspecified Damages

AWARD AGAINST PARTY

02/08/2005

$54,336.34



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

10/28/2003

03-07517

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE


$60,058.72

AWARD AGAINST PARTY

08/18/2004

$41,625.01



i



Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-NEGLIGENCE








Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


NASD

12/12/2003

03-08648

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-NEGLIGENCE


$190,000.00

AWARD AGAINST PARTY

06/07/2005

$46,700.01



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/09/2004

03-08904

ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-INCORRECT QUANTITY; DO NOTUSE-NO OTHER CONTROVERSY INVOLVED


$4,550,000.00

AWARD AGAINST PARTY

03/07/2005

$165,738.00



i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/31/2004

04-00523



$48,938.56

AWARD AGAINST PARTY

03/31/2005

$19,397.86



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/24/2004

04-01936

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED


$252,351.26

AWARD AGAINST PARTY

12/06/2004

$22,357.90










i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/29/2004

04-02035



$3,000,000.00

AWARD AGAINST PARTY

01/03/2006

$654,168.01



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:

NASD

04/29/2004

04-03058

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-FAILURE TO SUPERVISE


$40,000.00

AWARD AGAINST PARTY

06/30/2005








Sum of All Relief Awarded: $26,000.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

05/10/2004

04-03332

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURETO SUPERVISE

CERTIFICATE OF DEPOSIT; COMMON STOCK; DO NOT USE-NO OTHERTYPE OF SEC INVOLVE; MUTUAL FUNDS

$755,000.00

AWARD AGAINST PARTY

05/27/2005

$45,000.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



NASD

05/17/2004

04-03528

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-SUITABILITY

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

$100,000.00212©2020 FINRA. All rights reserved. Report about EDWARD JONES








Disposition:

Disposition Date:


$100,000.00

AWARD AGAINST PARTY

03/24/2005

$44,497.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

07/07/2004

04-04739

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NOOTHER CONTROVERSY INVOLVED


Unspecified Damages

AWARD AGAINST PARTY

05/18/2005

$8,291.01



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

NASD

07/26/2004

04-05277









Case Number:



Disposition:

Disposition Date:


04-05277

COMMON STOCK; CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OFSEC INVOLVE; MUTUAL FUNDS

$25,900.00

AWARD AGAINST PARTY

02/15/2005

$5,325.02



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

08/05/2004

04-05525



$971,067.00

AWARD AGAINST PARTY

07/12/2005

$55,000.00



i



Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE 214©2020 FINRA. All rights reserved. Report about EDWARD JONES







Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

10/06/2004

04-07014



$299,255.50

AWARD AGAINST PARTY

03/21/2006

$40,000.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

10/13/2004

04-07080



$50,000.00

AWARD AGAINST PARTY

11/22/2005

$40,148.68



i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

10/20/2004

04-07305



$308,000.00

AWARD AGAINST PARTY

12/13/2005

$90,225.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

11/05/2004

04-07648



$500,000.00

AWARD AGAINST PARTY

06/06/2006

$457,914.00










i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

12/02/2004

04-08106


ANNUITIES; CERTIFICATE OF DEPOSIT; DO NOT USE-NO OTHER TYPE OFSEC INVOLVE

Unspecified Damages

AWARD AGAINST PARTY

12/12/2005

$65,000.03



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

NASD

12/09/2004

04-08280

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-ERRORS-CHARGES;ACCOUNT RELATED-FAILURE TO SUPERVISE


$53,977.46

AWARD AGAINST PARTY217©2020 FINRA. All rights reserved. Report about EDWARD JONES







Disposition:

Disposition Date:


AWARD AGAINST PARTY

02/02/2006

$6,518.67



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

12/09/2004

04-08291

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-NEGLIGENCE


$35,000.00

AWARD AGAINST PARTY

03/16/2006

$63,675.01



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

12/29/2004

04-08682

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED











Disposition:

Disposition Date:



$25,000.00

AWARD AGAINST PARTY

11/02/2005

$25,830.95



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/10/2005

05-00089



$722,598.00

AWARD AGAINST PARTY

02/28/2006

$225,000.03



i



Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-NEGLIGENCE







Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


NASD

01/20/2005

05-00266


$328,517.00

AWARD AGAINST PARTY

12/14/2005

$160,800.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

02/15/2005

05-00334

ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSYINVOLVED


$48,864.82

AWARD AGAINST PARTY

03/30/2006

$6,108.10



i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/14/2005

05-00740

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY


$25,000.00

AWARD AGAINST PARTY

08/25/2005

$15,127.50



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/24/2005

05-01481

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


$500,000.00

AWARD AGAINST PARTY

04/12/2006

$222,271.43










i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/29/2005

05-01570

ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED


$300,000.00

AWARD AGAINST PARTY

07/06/2006

$143,457.01



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

04/20/2005

05-02005

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; DO NOT USE-NO OTHER CONTROVERSY INVOLVED


$240,000.00

AWARD AGAINST PARTY

08/11/2006

$110,916.00










i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

06/09/2005

05-02604

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE


$21,510.75

AWARD AGAINST PARTY

12/01/2005

$956.31



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

NASD

07/05/2005

05-03338

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING;ACCOUNT RELATED-FAILURE TO SUPERVISE


$82,193.00








Disposition:

Disposition Date:


AWARD AGAINST PARTY

08/17/2006

$23,127.73



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

08/05/2005

05-03983

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACHOF CONTRACT


$500,000.00

AWARD AGAINST PARTY

11/21/2006

$470,100.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

NASD

09/19/2005

05-04845

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-NEGLIGENCE








Case Number:



Disposition:

Disposition Date:


05-04845

ANNUITIES; COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SECINVOLVE; MUNICIPAL BOND FUNDS

$788,000.00

AWARD AGAINST PARTY

08/28/2006

$61,954.41



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

09/20/2005

05-04901



$25,000.00

AWARD AGAINST PARTY

02/17/2006

$7,927.02



i



Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; DO NOTUSE-NO OTHER CONTROVERSY INVOLVED








Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


NASD

09/22/2005

05-04943

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; DO NOTUSE-NO OTHER CONTROVERSY INVOLVED


$500,000.00

AWARD AGAINST PARTY

02/06/2007

$495,014.05



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

12/06/2005

05-05068



$180,000.00

AWARD AGAINST PARTY

01/19/2007

$35,000.00



i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

12/15/2005

05-05396

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


Unspecified Damages

AWARD AGAINST PARTY

01/12/2007

$54,207.30



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

02/08/2006

05-06203

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED


$23,316.70

AWARD AGAINST PARTY

05/23/2007

$6,650.07










i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

12/13/2005

05-06306



$500,000.00

AWARD AGAINST PARTY

11/21/2006

$435,000.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:

NASD

03/30/2006

06-01608

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

CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$8,883.00

AWARD AGAINST PARTY

07/17/2006











i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

04/28/2006

06-02110

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY


$4,000.00

AWARD AGAINST PARTY

10/04/2006

$1,037.52



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



NASD

09/20/2006

06-04052



$330,000.00








Disposition:

Disposition Date:


AWARD AGAINST PARTY

11/16/2007

$85,000.01



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

04/18/2007

07-01211

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER


$13,368.56

AWARD AGAINST PARTY

10/31/2007

$13,306.57



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


FINRA

11/01/2007

07-02835

ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-NEGLIGENCE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS; OTHERTYPES OF SECURITIES










Disposition:

Disposition Date:



$3,818.00

AWARD AGAINST PARTY

08/06/2008

$3,993.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

03/05/2008

08-00578

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-NEGLIGENCE


$315,000.00

AWARD AGAINST PARTY

10/02/2009

$50,000.00



i



Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE







Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


FINRA

04/28/2008

08-01106

COMMON STOCK; CORPORATE BONDS; MUNICIPAL BOND FUNDS; MUTUALFUNDS

$138,945.33

AWARD AGAINST PARTY

09/01/2009

$8,748.30



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

10/10/2008

08-02808

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT RELATED-ERRORS-CHARGES; DO NOT USE-EXECUTIONS-OTHER


$8,500.00

AWARD AGAINST PARTY

03/27/2009

$5,485.00



i











Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

10/29/2008

08-03718

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHERCONTROVERSY INVOLVED

FREDDIE MACS; MUNICIPAL BONDS; MUTUAL FUNDS; PREFERRED STOCK

$26,194.62

AWARD AGAINST PARTY

04/01/2009

$3,869.06



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

03/19/2009

09-01388

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

$300,000.00

AWARD AGAINST PARTY

05/24/2010

$131,000.00










i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

03/25/2009

09-01583


MUTUAL FUNDS; OTHER TYPES OF SECURITIES

$7,942.72

AWARD AGAINST PARTY

08/18/2009

$3,525.01



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

04/24/2009

09-02203


MUTUAL FUNDS

$31,375.00

AWARD AGAINST PARTY

03/17/2010

$500.00234©2020 FINRA. All rights reserved. Report about EDWARD JONES







Sum of All Relief Awarded: $500.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

06/22/2009

09-02992

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

OTHER TYPES OF SECURITIES

$152,866.05

AWARD AGAINST PARTY

05/28/2010

$15,300.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

FINRA

07/21/2009

09-04250

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-FAILURE TO SUPERVISE

MUNICIPAL BOND FUNDS

$25,000.00

AWARD AGAINST PARTY








Disposition:

Disposition Date:


AWARD AGAINST PARTY

03/23/2010

$19,029.44



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

09/18/2009

09-05363

ACCOUNT ACTIVITY-SUITABILITY

$10,381.00

AWARD AGAINST PARTY

03/03/2010

$425.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

FINRA

10/30/2009

09-06124

DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE

$12,834.00








Disposition:

Disposition Date:


AWARD AGAINST PARTY

04/26/2010

$7,506.28



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

11/15/2010

10-03605

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

LIMITED PARTNERSHIPS

$48,500.00

AWARD AGAINST PARTY

01/09/2012

$10,000.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



FINRA

09/13/2010

10-03985

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

CORPORATE BONDS









Disposition:

Disposition Date:


$20,005.83

AWARD AGAINST PARTY

04/26/2011

$15,324.58



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

09/24/2010

10-04120

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-NEGLIGENCE

EXCHANGE-TRADED FUNDS

$24,410.64

AWARD AGAINST PARTY

09/09/2011

$32,670.98



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


FINRA

12/29/2010

10-05057

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT

ANNUITIES238©2020 FINRA. All rights reserved. Report about EDWARD JONES









Disposition:

Disposition Date:


ANNUITIES

$9,510.00

AWARD AGAINST PARTY

06/17/2011

$1,162.50



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

01/10/2011

10-05428

ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-OTHER-OTHER

COMMON STOCK

$626.17

AWARD AGAINST PARTY

06/21/2011

$600.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

FINRA

01/31/2011

11-00210

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TOSUPERVISE








Case Number:



Disposition:

Disposition Date:


11-00210

ANNUITIES; MUTUAL FUNDS; VARIABLE ANNUITIES

$45,462.27

AWARD AGAINST PARTY

02/08/2012

$38,300.50



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

05/18/2012

12-00535

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

$400,000.00

AWARD AGAINST PARTY

01/06/2014

$200,300.00



i



Allegations: 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








Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


FINRA

04/10/2012

12-01135

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

ANNUITIES

$22,075.00

AWARD AGAINST PARTY

12/10/2012

$13,228.01



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

05/15/2012

12-01708

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

$371,000.00

AWARD AGAINST PARTY

02/04/2013

$20,000.00



i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

08/30/2012

12-02772

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNTRELATED-TRANSFER

ANNUITIES; OTHER TYPES OF SECURITIES; VARIABLE ANNUITIES

$658,587.00

AWARD AGAINST PARTY

10/10/2013

$263,947.21



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

04/04/2013

13-00939

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

VARIABLE ANNUITIES

$43,756.00

AWARD AGAINST PARTY

09/25/2013

$19,600.00










i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

11/19/2013

13-03198

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; MUNICIPAL BONDS

$10,050.00

AWARD AGAINST PARTY

07/02/2014

$175.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

FINRA

04/08/2014

14-00200

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-OTHER-OTHER

ANNUITIES; COMMON STOCK

$1,000,000.01








Disposition:

Disposition Date:


AWARD AGAINST PARTY

07/29/2015

$519,511.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

02/25/2015

14-03167

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNTRELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

$974,682.00

AWARD AGAINST PARTY

04/01/2016

$2,600.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


FINRA

04/29/2015

15-00038

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-FRAUD; ACCOUNTACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING

COMMON STOCK










Disposition:

Disposition Date:


COMMON STOCK

Unspecified Damages

AWARD AGAINST PARTY

06/20/2019

$513,715.63



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

08/31/2015

15-02131

ACCOUNT ACTIVITY-MISREPRESENTATION

$33,476.00

AWARD AGAINST PARTY

03/14/2016

$14,305.79



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

FINRA

05/02/2016

16-01036

ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY;ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER








Case Number:



Disposition:

Disposition Date:


16-01036

COMMON STOCK; PREFERRED STOCK

$27,357.00

AWARD AGAINST PARTY

04/10/2017

$10,119.01



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

08/19/2016

16-02115

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT

$1,190.94

AWARD AGAINST PARTY

12/12/2016

$535.06



i



Arbitration Forum:

Case Initiated:

Allegations:

FINRA

11/15/2016

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-OTHER








Case Initiated:

Case Number:



Disposition:

Disposition Date:


11/15/2016

16-03301

COMMON STOCK; MUNICIPAL BONDS; MUTUAL FUNDS; OTHER TYPES OFSECURITIES

$28,700.00

AWARD AGAINST PARTY

10/20/2017

$34,011.19



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

02/23/2018

18-00725

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

VARIABLE ANNUITIES

$25,915.00

AWARD AGAINST PARTY

08/13/2018

$23,799.91



i



Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS








Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

08/24/2018

18-02976

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS

CERTIFICATE OF DEPOSIT

$5,000.00

AWARD AGAINST PARTY

03/08/2019

$4,522.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

87-01829

ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DONOT USE-NO OTHER CONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS

$5,000.00

AWARD AGAINST PARTY

07/06/1989

$2,977.00



i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/01/1988

88-00540

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOTUSE-NO OTHER CONTROVERSY INVOLVED


$104,000.00

AWARD AGAINST PARTY

08/21/1989

$3,375.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

04/19/1988

88-00762

DO NOT USE-NO OTHER CONTROVERSY INVOLVED


$61,951.00

AWARD AGAINST PARTY

04/26/1991

$0.00



i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/01/1988

88-01032

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NOOTHER CONTROVERSY INVOLVED


$94,274.62

AWARD AGAINST PARTY

07/31/1989

$11,000.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/01/1988

88-01418



$102,314.00

AWARD AGAINST PARTY

10/25/1989

$30,000.00










i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

88-02733

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURETO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED


$100,000.00

AWARD AGAINST PARTY

08/22/1989

$118,000.79



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/01/1988

88-03445



$185,709.00

AWARD AGAINST PARTY

08/25/1989











i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/01/1989

89-01277

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NOOTHER CONTROVERSY INVOLVED


$20,000.00

AWARD AGAINST PARTY

12/29/1989

$4,250.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

NASD

01/01/1989

89-01587

DO NOT USE-EXECUTIONS-EXECUTION PRICE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED; TRADING DISPUTES-MARK-UPS


$1,387.00








Disposition:

Disposition Date:


AWARD AGAINST PARTY

10/27/1989

$582.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

07/28/1989

89-01790

ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHERCONTROVERSY INVOLVED; TRADING DISPUTES-OTHER


$45,695.53

AWARD AGAINST PARTY

04/24/1991

$6,650.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

01/01/1989

89-02034

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED










Disposition:

Disposition Date:


$800.00

AWARD AGAINST PARTY

11/13/1989

$800.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/01/1989

89-02862



$29,000.00

AWARD AGAINST PARTY

07/16/1990

$1,188.48



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

12/20/1989

89-02955


DO NOT USE-NO OTHER TYPE OF SEC INVOLVE









Disposition:

Disposition Date:


$150,000.00

AWARD AGAINST PARTY

01/29/1991

$57,500.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

05/22/1990

90-01258


DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$40,000.00

AWARD AGAINST PARTY

03/26/1991

$1,000.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

02/01/1991

90-03018












Disposition:

Disposition Date:



$10,353.78

AWARD AGAINST PARTY

06/21/1991

$10,150.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/12/1994

93-04990

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-OTHER;DO NOT USE-NO OTHER CONTROVERSY INVOLVED


$607,430.25

AWARD AGAINST PARTY

10/03/1994

$123,000.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

NASD

05/16/1994

94-01336

DO NOT USE-NO OTHER CONTROVERSY INVOLVED; TRADING DISPUTES-OTHER








Case Number:



Disposition:

Disposition Date:


94-01336


$1,990.15

AWARD AGAINST PARTY

04/17/1995

$239.42



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

08/22/1994

94-02258

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-FAILURE TO SUPERVISE


$4,623.75

AWARD AGAINST PARTY

03/17/1995

$4,773.75



i



Arbitration Forum:

Allegations:

NASD

ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED








Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


NASD

01/30/1995

94-02849


$820.00

AWARD AGAINST PARTY

07/07/1995

$805.53



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

11/07/1994

94-03500

ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSYINVOLVED


$5,000.00

AWARD AGAINST PARTY

08/22/1995

$1,000.00



i



Allegations: ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSYINVOLVED








Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

01/30/1995

95-00260



$5,454.00

AWARD AGAINST PARTY

07/25/1995

$5,604.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

12/05/1995

95-05102

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE


$69,634.62

AWARD AGAINST PARTY

12/12/1996

$9,500.00



i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/14/1996

96-00173

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NOOTHER CONTROVERSY INVOLVED


$8,939.13

AWARD AGAINST PARTY

07/22/1996

$9,209.13



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

06/27/1996

96-02698

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;GOVERNMENT SECURITIES

$19,905.40

AWARD AGAINST PARTY

03/21/1997

$26,000.00











i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

06/24/1997

97-02233

DO NOT USE-EXECUTIONS-EXECUTION PRICE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$9,375.00

AWARD AGAINST PARTY

10/24/1997

$9,525.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

06/18/1998

98-01881

ACCOUNT RELATED-OTHER; DO NOT USE-EXECUTIONS-FAILURE TOEXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED


$15,750.00

AWARD AGAINST PARTY

12/30/1998

$100.00










i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

04/06/1999

99-01199

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-FAILURE TO SUPERVISE


Unspecified Damages

AWARD AGAINST PARTY

06/30/2000

$158,850.30



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

NASD

05/21/1999

99-02215

ACCOUNT RELATED-ERRORS-CHARGES; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$15,285.04








Disposition:

Disposition Date:


AWARD AGAINST PARTY

03/23/2000

$15,907.30



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

07/22/1999

99-03270

DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$9,678.22

AWARD AGAINST PARTY

03/17/2000

$2,268.00



i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

11/29/1999

99-04475

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES 263©2020 FINRA. All rights reserved. Report about EDWARD JONES









Disposition:

Disposition Date:



$133,280.00

AWARD AGAINST PARTY

01/04/2001

$64,850.00







End of Report

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EDWARD JONES - FINRA · EDWARD JONES CRD# 250 SEC# 8-759 Main Office Location 12555 MANCHESTER ROAD...

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