ALPINE SECURITIES CORPORATION · ALPINE SECURITIES CORPORATION CRD# 14952 SEC# 8-31464 Main Office...

BrokerCheck Report

ALPINE SECURITIES CORPORATION

Section Title

Report Summary

Firm History

CRD# 14952

1

6

Firm Profile 2 - 5

Page(s)

Firm Operations 7 - 13

Disclosure Events 14

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CRD# 14952

SEC# 8-31464

Main Office Location

39 EXCHANGE PLACESALT LAKE CITY, UT 84111Regulated by FINRA Denver Office

Mailing Address

39 EXCHANGE PLACESALT LAKE CITY, UT 84111

Business Telephone Number

801 320-1313

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 42

Civil Event 1

Arbitration 1

Firm Profile

This firm is classified as a corporation.

This firm was formed in Utah on 01/11/1984.

Its fiscal year ends in September.

Firm History

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

Firm Operations

Is this brokerage firm currently suspended with anyregulator? No

This firm conducts 8 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• 49 U.S. states and territories

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1©2020 FINRA. All rights reserved. Report about ALPINE SECURITIES CORPORATION


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This firm is classified as a corporation.

This firm was formed in Utah on 01/11/1984.

CRD#

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

Firm Profile

Firm Names and Locations

Its fiscal year ends in September.


SEC#

14952

8-31464

Main Office Location

Mailing Address

Business Telephone Number

Doing business as ALPINE SECURITIES CORPORATION

801 320-1313

Regulated by FINRA Denver 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?

SCA CLEARING LLC

SOLE SHAREHOLDER

75% or more

Domestic Entity

03/2011

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


BRANT, DAVID ROBERT

CFO/FINOP

Less than 5%

No

Individual

06/2017

Yes

2718478



Position


Position Start Date

DOUBEK, CHRISTOPHER ROBERT

CEO

Less than 5%

Individual

06/2020

1705718








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


MURPHY, CHRISTINE ALEXANDRIA

CCO AMLCO

Less than 5%

No

Individual

06/2020

Yes

1510853



Position



Position Start Date


WALSH, JOSEPH PATRICK

COO

Less than 5%

No

Individual

01/2019

Yes

1519958








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

Indirect Owners

Firm Profile

HURRY, JOHN JOSEPH

SOLE BENEFICIAL OWNER

SCA CLEARING LLC

75% or more

No

Individual

08/2019

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 49 U.S. states and territories.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

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

Yes

No

No

No

Federal Regulator Status Date Effective

SEC Approved 04/17/1984

Self-Regulatory Organization Status Date Effective

FINRA Approved 05/29/1984

Cboe BYX Exchange, Inc. Approved 11/15/2010

Cboe BZX Exchange, Inc. Approved 11/03/2008

NYSE Arca, Inc. Approved 04/05/2007

Nasdaq Stock Market Approved 07/12/2006






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alaska Approved 09/18/1995

Arizona Approved 11/17/1994

Arkansas Approved 06/11/2012

California Approved 07/09/1984

Colorado Approved 07/02/1984

Delaware Approved 05/19/2005

District of Columbia Approved 02/14/2014

Florida Approved 05/21/1985

Georgia Approved 01/28/1985

Hawaii Approved 01/07/1998

Idaho Approved 04/13/1989

Illinois Approved 06/30/1988

Indiana Approved 03/07/1997

Iowa Approved 01/13/1997

Kansas Approved 06/17/2005

Kentucky Approved 04/20/2010

Louisiana Approved 06/19/1997

Maine Approved 10/15/2012

Maryland Approved 01/11/2005

Massachusetts Approved 01/24/2005

Michigan Approved 01/29/1997

Minnesota Approved 05/24/1995

Mississippi Approved 02/28/2014

Missouri Approved 07/09/2002

Montana Approved 08/20/2001

Nebraska Approved 02/18/2009

Nevada Approved 06/15/1984

New Jersey Approved 05/15/1987

New Mexico Approved 02/05/1997

New York Approved 07/25/1984

North Carolina Approved 09/27/1996

North Dakota ConditionalRestricted

02/24/2010

Ohio Approved 10/13/1987

U.S. States &Territories

Status Date Effective

Oklahoma Approved 01/27/2005

Oregon Approved 06/02/1997

Pennsylvania Approved 11/28/1984

Puerto Rico Approved 01/15/2016

Rhode Island Approved 01/23/2014

South Carolina ConditionalRestricted

04/07/2010

South Dakota ConditionalRestricted

01/22/2010

Tennessee Approved 05/24/1995

Texas Approved 09/18/1986

Utah Approved 04/26/1984

Vermont Approved 07/19/2012

Virginia Approved 11/08/2013

Washington Approved 06/09/1995

West Virginia Approved 08/16/2010

Wisconsin Approved 04/22/1997

Wyoming Approved 07/31/1984






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 not engage in other non-securities business.

Non-Securities Business Description:

This firm currently conducts 8 types of businesses.

Types of Business

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

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

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

Mutual fund retailer

Put and call broker or dealer or option writer

Trading securities for own account

Private placements of securities

Other - MARGIN RETAILER ON A FULLY DISCLOSED BASISOFFER MARGIN ON A SELF-CLEARING BASISENGAGE IN THE CLEARING OF CORRESPONDENT FIRMS (I.E. OTHER INTRODUCING BROKER-DEALERS)






Firm Operations

Clearing Arrangements

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

Introducing Arrangements

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






Firm Operations

Industry Arrangements

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

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

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

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

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

Control Persons/Financing

Name: STATEMENT SOLUTIONS

Business Address: 3 UNIVERSITY PLAZA DRIVESUITE 500HACKENSACK, NJ 07601

Effective Date: 08/23/2018

Description: PRODUCES CLIENT STATEMENTS AND CONFIRMS

Name: FIS FINANCIAL SYSTEMS LLC

Business Address: 3 VAN DEGRAFF DRIVEBURLINGTON, MA 01803


Description: CLEARING FIRMS BACK OFFICE SERVICE PROVIDER. (FORMERLYKNOWN AS SUNGARD)

Name: DBCOM CONSULTING, INC.

Business Address: 2 RESEARCH WAWYPRINCETON, NJ 08540


Description: ALPINE ENGAGED DBCOM CONSULTING, ALSO KNOWN AS EQUBE TOHOST TRADE TRANSACTION AND EXCEPTION REPORTS DATA.

Name: SMARSH, INC.

Business Address: 921 SW WASHINGTON STREET, STE 540PORTLAND, OR 97205


Description: EMAIL ARCHIVING AND RETENTION VENDOR, RETAINS FIRM'S EMAILCOMMUNICATIONS






Firm Operations

Industry Arrangements (continued)

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






Firm Operations

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

This firm is, directly or indirectly:

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

Yes

Yes

No

03/03/2011

7170 E MCDONALD ROADSCOTTSDALE, AZ 85253

118786

SCOTTSDALE CAPITAL ADVISORS CORP is under common control with the firm.

SCA CLEARING, LLC OWNS ALPINE SECURITIES CORPORATION. ALPINE'SAFFILIATE, SCOTTSDALE CAPITAL ADVISORS CORPORATION IS OWNED BYSCOTTSDALE CAPITAL ADVISORS HOLDINGS LLC. SCA CLEARING, LLCAND SCOTTSDALE CAPITAL ADVISORS HOLDINGS LLC SHARE A COMMONBENEFICIAL OWNERSHIP.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

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 1 41 0

Civil Event 0 0 1

Arbitration N/A 1 N/A






Disclosure Event Details

What you should know about reported disclosure events:

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

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

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§ 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.

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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 41

Reporting Source: Regulator

Allegations: RESPONDENT ALPINE SECURITIES CORPORATION FAILED TO FILE ITSCONTINUING MEMBERSHIP APPLICATIONS ("CMAS") UNDER NASD RULE1017. ON APRIL 9, 2019, RESPONDENT TIMELY FILED REQUESTS FORHEARING UNDER FINRA RULES 9552 AND 9559. ON JUNE 18, 2019 THEPARTIES PARTICIPATED BY TELEPHONE IN A HEARING BEFORE A FINRAHEARING PANEL. THE HEARING PANEL'S DECISION IN THIS EXPEDITEDPROCEEDING DATED AUGUST 15, 2019: THIS DECISION WAS NOT CALLEDFOR REVIEW BY THE NATIONAL ADJUDICATORY COUNCIL ("NAC"),PURSUANT TO RULE 9559(Q), AND THEREFORE IT SHALL BE EFFECTIVEUPON SERVICE AND SHALL CONSTITUTE THE FINAL ACTION OF FINRA INTHIS PROCEEDING. ACCORDINGLY, RESPONDENT IS SUSPENDED FROMFINRA MEMBERSHIP FOR FAILURE TO FILE CMAS.

Current Status: Final






Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Suspension

Other Sanction(s)/ReliefSought:

Date Initiated: 03/19/2019

Docket/Case Number: 2019062263301

Principal Product Type: No Product

Other Product Type(s):

Allegations: RESPONDENT ALPINE SECURITIES CORPORATION FAILED TO FILE ITSCONTINUING MEMBERSHIP APPLICATIONS ("CMAS") UNDER NASD RULE1017. ON APRIL 9, 2019, RESPONDENT TIMELY FILED REQUESTS FORHEARING UNDER FINRA RULES 9552 AND 9559. ON JUNE 18, 2019 THEPARTIES PARTICIPATED BY TELEPHONE IN A HEARING BEFORE A FINRAHEARING PANEL. THE HEARING PANEL'S DECISION IN THIS EXPEDITEDPROCEEDING DATED AUGUST 15, 2019: THIS DECISION WAS NOT CALLEDFOR REVIEW BY THE NATIONAL ADJUDICATORY COUNCIL ("NAC"),PURSUANT TO RULE 9559(Q), AND THEREFORE IT SHALL BE EFFECTIVEUPON SERVICE AND SHALL CONSTITUTE THE FINAL ACTION OF FINRA INTHIS PROCEEDING. ACCORDINGLY, RESPONDENT IS SUSPENDED FROMFINRA MEMBERSHIP FOR FAILURE TO FILE CMAS.

Resolution Date: 08/15/2019

Resolution:

Other Sanctions Ordered:

Sanction Details: PURSUANT TO FINRA RULE 9552, RESPONDENT'S FINRA MEMBERSHIP ISSUSPENDED ON AUGUST 15, 2019. RESPONDENT IS ALSO ASSESSEDCOSTS JOINTLY AND SEVERALLY OF $3,625.66.

SEC APPEAL: ON AUGUST 16, 2019, FINRA RECEIVED FROM THERESPONDENT AN APPLICATION FOR REVIEW TO THE SECURITIESEXCHANGE COMMISSION OF THE AUGUST 15, 2019 EXTENDED HEARINGPANEL DECISION.

THE SUSPENSION IS STILL IN EFFECT PENDING THE OUTCOME OF THEAPPEAL.

SUSPENSION LIFTED ON AUGUST 20, 2019. THE SEC RENDERED ANORDER GRANTING INTERIM STAY.

ON AUGUST 28, 2019, THE FIRM DETERMINED TO UNWIND THEIR CHANGEIN OWNERSHIP RETURNING TO THE PREVIOUS OWNERSHIP STRUCTUREAND SUBMITTED A REQUEST FOR TERMINATION OF THE SUSPENSION,WHICH WAS APPROVED BY ENFORCEMENT.THE SUSPENSION IS LIFTED.

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

No

Sanctions Ordered: Suspension

Other






PURSUANT TO FINRA RULE 9552, RESPONDENT'S FINRA MEMBERSHIP ISSUSPENDED ON AUGUST 15, 2019. RESPONDENT IS ALSO ASSESSEDCOSTS JOINTLY AND SEVERALLY OF $3,625.66.

SEC APPEAL: ON AUGUST 16, 2019, FINRA RECEIVED FROM THERESPONDENT AN APPLICATION FOR REVIEW TO THE SECURITIESEXCHANGE COMMISSION OF THE AUGUST 15, 2019 EXTENDED HEARINGPANEL DECISION.

THE SUSPENSION IS STILL IN EFFECT PENDING THE OUTCOME OF THEAPPEAL.

SUSPENSION LIFTED ON AUGUST 20, 2019. THE SEC RENDERED ANORDER GRANTING INTERIM STAY.

ON AUGUST 28, 2019, THE FIRM DETERMINED TO UNWIND THEIR CHANGEIN OWNERSHIP RETURNING TO THE PREVIOUS OWNERSHIP STRUCTUREAND SUBMITTED A REQUEST FOR TERMINATION OF THE SUSPENSION,WHICH WAS APPROVED BY ENFORCEMENT.THE SUSPENSION IS LIFTED.

Regulator Statement ASSOCIATED CASE NUMBER EXPEDITED PROCEEDING FPI190001-

SEC RELEASE 34-86719 / AUGUST 20, 2019, ADMIN. PROC. FILE NO. 3-19360:ON AUGUST 16, 2019, THE FIRM FILED AN APPLICATION FOR REVIEW OF ANAUGUST 15, 2019 FINRA DECISION FINDING THAT THEY HAD VIOLATEDNASD RULE 1017 BY FAILING TO FILE CONTINUING MEMBERSHIPAPPLICATIONS ("CMAS"). FINRA FOUND THAT APPLICANTS WEREREQUIRED TO FILE CMAS TO OBTAIN ITS APPROVAL OF THE TRANSFER OFINDIRECT OWNERSHIP OF THE APPLICANTS FROM TWO TRUSTS TO SIXTRUSTS. FINRA SUSPENDED APPLICANTS FROM FINRA MEMBERSHIPUNTIL THEY FILED COMPLIANT CMAS.ON AUGUST 20, 2019, THE SEC RENDERED AN ORDER GRANTING INTERIMSTAY. ACCORDINGLY, IT IS ORDERED THAT APPLICANT'S MOTION FOR ANINTERIM STAY OF FINRA'S DECISION SUSPENDING THE FIRM FROM FINRAMEMBERSHIP IS GRANTED, AND THAT SUCH INTERIM STAY SHALLCONTINUE UNTIL IT IS DETERMINED WHETHER A STAY PENDING THERESOLUTION OF THE MERITS OF THIS PROCEEDING SHOULD BEGRANTED. IT IS FURTHER ORDERED THAT APPLICANT SHALL FILE BYAUGUST 30, 2019, A BRIEF AND ANY SUPPORTING PAPERS IN SUPPORT OFA STAY PENDING THE RESOLUTION OF THE PROCEEDING ON THE MERITS.FINRA SHALL FILE BY SEPTEMBER 9, 2019, ANY OPPOSITION BRIEF; ANDAPPLICANT SHALL FILE BY SEPTEMBER 16, 2019, ANY REPLY BRIEF.THEREFORE, THE SUSPENSION IS LIFTED ON AUGUST 20, 2019 WITH ASEC ORDER GRANTING INTERIM STAY.

ON AUGUST 28, 2019, THE FIRM DETERMINED TO UNWIND THEIR CHANGEIN OWNERSHIP RETURNING TO THE PREVIOUS OWNERSHIP STRUCTUREAND SUBMITTED A REQUEST FOR TERMINATION OF THE SUSPENSION,WHICH WAS APPROVED BY ENFORCEMENT.

THE SUSPENSION IS LIFTED.

SEC ADMIN RELEASE 34-87146 / SEPTEMBER 27, 2019, FILED NO. 3-19360:ORDER GRANTING MOTION TO WITHDRAW REQUEST FOR STAY ANDTERMINATING INTERIM STAY. ON AUGUST 29, 2019, THE APPLICANT FILED ANOTICE STATING THAT THE PARTIES HAD AGREED THAT THE CHALLENGEDSUSPENSION WAS "NO LONGER OPERATIVE" AND THAT APPLICANT "MAYCONTINUE TO CONDUCT ITS BUSINESS." FINRA ALSO PUBLISHED NOTICEON ITS BROKERCHECK WEBSITE THAT THE CHALLENGED SUSPENSIONHAD BEEN LIFTED. IN ITS NOTICE TO THE COMMISSION, APPLICANTSTATED THAT IT WAS WITHDRAWING ITS STAY MOTION BECAUSE IT HADBECOME MOOT. UNDER THE CIRCUMSTANCES, IT IS APPROPRIATE TOGRANT APPLICANT'S REQUEST TO WITHDRAW THE MOTION AND TOTERMINATE THE INTERIM STAY. ACCORDINGLY, IT IS ORDERED THAT THEREQUEST OF THE FIRM TO WITHDRAW ITS STAY MOTION IS GRANTED;AND THAT THE INTERIM STAY ORDERED ON AUGUST 20, 2019 ISTERMINATED.






ASSOCIATED CASE NUMBER EXPEDITED PROCEEDING FPI190001-

SEC RELEASE 34-86719 / AUGUST 20, 2019, ADMIN. PROC. FILE NO. 3-19360:ON AUGUST 16, 2019, THE FIRM FILED AN APPLICATION FOR REVIEW OF ANAUGUST 15, 2019 FINRA DECISION FINDING THAT THEY HAD VIOLATEDNASD RULE 1017 BY FAILING TO FILE CONTINUING MEMBERSHIPAPPLICATIONS ("CMAS"). FINRA FOUND THAT APPLICANTS WEREREQUIRED TO FILE CMAS TO OBTAIN ITS APPROVAL OF THE TRANSFER OFINDIRECT OWNERSHIP OF THE APPLICANTS FROM TWO TRUSTS TO SIXTRUSTS. FINRA SUSPENDED APPLICANTS FROM FINRA MEMBERSHIPUNTIL THEY FILED COMPLIANT CMAS.ON AUGUST 20, 2019, THE SEC RENDERED AN ORDER GRANTING INTERIMSTAY. ACCORDINGLY, IT IS ORDERED THAT APPLICANT'S MOTION FOR ANINTERIM STAY OF FINRA'S DECISION SUSPENDING THE FIRM FROM FINRAMEMBERSHIP IS GRANTED, AND THAT SUCH INTERIM STAY SHALLCONTINUE UNTIL IT IS DETERMINED WHETHER A STAY PENDING THERESOLUTION OF THE MERITS OF THIS PROCEEDING SHOULD BEGRANTED. IT IS FURTHER ORDERED THAT APPLICANT SHALL FILE BYAUGUST 30, 2019, A BRIEF AND ANY SUPPORTING PAPERS IN SUPPORT OFA STAY PENDING THE RESOLUTION OF THE PROCEEDING ON THE MERITS.FINRA SHALL FILE BY SEPTEMBER 9, 2019, ANY OPPOSITION BRIEF; ANDAPPLICANT SHALL FILE BY SEPTEMBER 16, 2019, ANY REPLY BRIEF.THEREFORE, THE SUSPENSION IS LIFTED ON AUGUST 20, 2019 WITH ASEC ORDER GRANTING INTERIM STAY.

ON AUGUST 28, 2019, THE FIRM DETERMINED TO UNWIND THEIR CHANGEIN OWNERSHIP RETURNING TO THE PREVIOUS OWNERSHIP STRUCTUREAND SUBMITTED A REQUEST FOR TERMINATION OF THE SUSPENSION,WHICH WAS APPROVED BY ENFORCEMENT.

THE SUSPENSION IS LIFTED.

SEC ADMIN RELEASE 34-87146 / SEPTEMBER 27, 2019, FILED NO. 3-19360:ORDER GRANTING MOTION TO WITHDRAW REQUEST FOR STAY ANDTERMINATING INTERIM STAY. ON AUGUST 29, 2019, THE APPLICANT FILED ANOTICE STATING THAT THE PARTIES HAD AGREED THAT THE CHALLENGEDSUSPENSION WAS "NO LONGER OPERATIVE" AND THAT APPLICANT "MAYCONTINUE TO CONDUCT ITS BUSINESS." FINRA ALSO PUBLISHED NOTICEON ITS BROKERCHECK WEBSITE THAT THE CHALLENGED SUSPENSIONHAD BEEN LIFTED. IN ITS NOTICE TO THE COMMISSION, APPLICANTSTATED THAT IT WAS WITHDRAWING ITS STAY MOTION BECAUSE IT HADBECOME MOOT. UNDER THE CIRCUMSTANCES, IT IS APPROPRIATE TOGRANT APPLICANT'S REQUEST TO WITHDRAW THE MOTION AND TOTERMINATE THE INTERIM STAY. ACCORDINGLY, IT IS ORDERED THAT THEREQUEST OF THE FIRM TO WITHDRAW ITS STAY MOTION IS GRANTED;AND THAT THE INTERIM STAY ORDERED ON AUGUST 20, 2019 ISTERMINATED.

iReporting Source: Firm

Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY


Suspension






Allegations: THE INDIRECT OWNERS OF ALPINE CHANGED THE OWNERSHIPSTRUCTURE FROM TWO TRUSTS TO SIX TRUSTS. ACCORDING TO FINRATHIS CONSTITUTED A CHANGE OF OWNERSHIP AND THUS TRIGGERED AREQUIREMENT TO FILE A CONTINUING MEMBERSHIP APPLICATION (CMA).FURTHER, FINRA FOUND THAT ALPINE'S CMA WAS "SUBSTANTIALLYINCOMPLETE" BECAUSE THE ENTIRE TRUST DOCUMENTS WERE NOTPROVIDED.



Resolution:


Sanctions Ordered: Suspension

Dismissed







Sanction Details: UNDER EXPEDITED HEARING PANEL DECISION, DATED 8/15/2019 (THE "DECISION"), FINRA SUSPENDED APPLICANT'S MEMBERSHIP UNTIL ITFILES A CMA.

Firm Statement ON 8/21/2019, SEC GRANTED THE INTERIM STAY OF THE FINRAMEMBERSHIP SUSPENSION OF APPLICANT. PRIOR TO SUCH ACTION BYTHE SEC, ON 8/20/2019 THE INDIRECT OWNERS OF APPLICANT TOOKSTEPS TO UNWIND COMPLETELY THE TRUST OWNERSHIP STRUCTURE OFTHE HURRY FAMILY TRUSTS. AFTER DISCUSSION WITH FINRA STAFF, ITWAS AGREED THAT THE STAY MOTION BECAME MOOT AS A RESULT OFTHE REVERSION TO THE LAST OWNERSHIP STRUCTURE APPROVED BYTHE FINRA MAP GROUP. APPLICANT FILED WITH THE COMMISSION ANOTIFICATION THAT IT'S NOT GOING FORWARD WITH THE EXPEDITEDMOTION FOR A STAY BECAUSE FINRA AGREED THAT THE SUSPENSION ISNO LONGER OPERATIVE.

Disclosure 2 of 41

i


Initiated By: FINRA


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITERRONEOUSLY DISCLOSED ON CUSTOMER CONFIRMATIONS THATTRANSACTIONS WERE EXECUTED AT AVERAGE PRICES. THE FINDINGSSTATED THAT THE FIRM TRANSMITTED REPORTS TO THE ORDER AUDITTRAIL SYSTEM (OATS) THAT CONTAINED INACCURATE, INCOMPLETE, ORIMPROPERLY FORMATTED DATA. THE REPORTS CONTAINED ANINACCURATE SPECIAL HANDLING CODE OF "DIR" INDICATING THAT THEORDERS WERE DIRECTED TO MARKET CENTERS BY THE CUSTOMERS.THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM DIDNOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO CERTAIN APPLICABLE SECURITIES LAWSAND REGULATIONS, AND/OR FINRA RULES AND THE SEC. THE FIRM'SWRITTEN SUPERVISORY PROCEDURES (WSPS) FAILED TO PROVIDE FORONE OR MORE OF THE FOUR MINIMAL REQUIREMENTS FOR ADEQUATEWSPS IN THE FOLLOWING SUBJECT AREAS: LIMIT ORDER DISPLAY, THREEQUOTE RULE, ORDER MARKING, LOCATE RULE, CLOSE OUT AND PRE-BORROW RULE, NAKED SHORT SELLING ANTIFRAUD RULE, MONITORINGACTIVITY DURING A TRADING HALT, ENTERING MULTIPLE QUOTATIONSFOR OVER-THE-COUNTER SECURITIES, GENERAL RECORDKEEPING ANDACCURACY, AND SUB-PENNY QUOTES.














Resolution:

Other Sanctions Ordered: UNDERTAKING: REVISE THE FIRM'S WSPS

Sanction Details: THE FIRM WAS CENSURED, FINED AND UNDERTAKES TO REVISE ITSWSPS.FINE PAID IN FULL ON OCTOBER 14, 2014.


No

Sanctions Ordered: CensureMonetary/Fine $20,000.00

Acceptance, Waiver & Consent(AWC)


Allegations: FINRA'S TRADING AND MARKET MAKING SURVEILLANCE STAFF REVIEWEDTHE FIRM'S TRADING AND MARKET MAKING ACTIVITIES FOR TRADE DATESFEBRUARY 6 THROUGH 17, 2012. FINRA FOUND THAT THE FIRMERRONEOUSLY DISCLOSED THAT TRANSACTIONS WERE EXECUTED ATAVERAGE PRICES ON CUSTOMER CONFIRMATIONS IN SEVEN (7)INSTANCES. ADDITIONALLY, THE FIRM TRANSMITTED INACCURATE,INCOMPLETE AND IMPROPERLY FORMATTED DATA IN THE ORDER AUDITTRAIL SYSTEM IN FORTY-FIVE (45) INSTANCES. FINRA ALSO CITEDDEFICIENCIES IN THE FIRM'S WRITTEN SUPERVISORY PROCEDURES INTHE AREAS OF TRADING AND MARKET MAKING. WITHOUT ADMITTING ORDENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS ANDTO THE ENTRY OF FINDINGS ENUMERATED ABOVE.






https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2012031507401


Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)


Censure


FINE AND ORDER TO REVISE FIRM'S WRITTEN SUPERVISORYPROCEDURES



Principal Product Type: Equity - OTC



Resolution:

Other Sanctions Ordered: THE FIRM IS REQUIRED TO REVISE ITS WRITTEN SUPERVISORYPROCEDURES.

Sanction Details: SEE ABOVETHE FIRM ENTERED INTO AN ELECTION OF PAYMENT FORM. PAYMENTAUTHORIZATION FORM RETURNED TO FINRA ON 10/6/2014.

Firm Statement SEE ABOVE



Disclosure 3 of 41

i


Allegations: SEC RULES 17A-3, 17A-4, NASD RULES 2110, 2460, 3010, 3110, 3310,INTERPRETATIVE MATERIAL(IM) 3310 - A FIRM TRADER AND MARKETMAKER, ON BEHALF OF ALPINE SECURITIES CORPORATION, FILED FORM211 APPLICATIONS TO QUOTE THE SECURITIES OF TWO ISSUERS ON THEOVER-THE-COUNTER BULLETIN BOARD (OTCBB) AND PREPARED A FORMFOR ONE OF THE ISSUERS AND SIGNED THE APPLICATION AS THEPERSON FINRA SHOULD CONTACT FOR ADDITIONAL INFORMATIONREGARDING THE APPLICATION. SHARES OF ONE STOCK WEREDELIVERED TO A FORMER FIRM PRINCIPAL IN CERTIFICATE FORM. THEINDIVIDUAL AND THE FORMER FIRM PRINCIPAL TRANSFERRED SOME OFTHE SHARES TO THE INDIVIDUAL'S RELATIVE AND THE REMAINDER TOENTITIES AFFILIATED WITH HIS FAMILY AND THE FIRM. NEITHER THEINDIVIDUAL NOR THE FIRM PROVIDED BONA FIDE SERVICES, INCLUDINGINVESTMENT BANKING SERVICES TO EITHER ISSUER, OR TO ANY OTHERPERSON OR ENTITY AFFILIATED WITH OR RELATED TO THEM. THESHARES CONSTITUTED CONSIDERATION TO THE INDIVIDUAL AND THEFIRM FOR FILING THE FORM 211 APPLICATIONS, ENTERING QUOTATIONSAND ACTING AS A MARKET MAKER IN THE SECURITIES. THE FIRM, ACTINGTHROUGH THE INDIVIDUAL, WAS THE ONLY MARKET MAKER ENTERINGQUOTATIONS IN THE SECURITY. THE FIRM, ACTING THROUGH THEINDIVIDUAL, ENTERED NON-BONA FIDE QUOTATIONS IN THE SECURITYAND SOLD SHARES FROM HIS RELATIVES' ACCOUNTS FOR A TOTAL OF$70,454. THE INDIVIDUAL ARRANGED FOR A RELATIVE TO TRANSFERSHARES TO AN AUTOMOBILE DEALERSHIP IN EXCHANGE FOR THEPURCHASE OF A CAR AND HE AGREED THAT HE WOULD BUY BACK THESHARES FOR AN AMOUNT EQUAL TO THE PRICE HE AND HIS RELATIVEAGREED THEY OWED TO PAY FOR THE VEHICLE. TO FACILITATE THEPURCHASE, HE ARRANGED FOR THE DEALERSHIP TO OPEN A SECURITIESACCOUNT AT THE FIRM FOR THE SOLE PURPOSE OF DEPOSITING THESHARES AND PROMPTLY SELLING THEM TO THE INDIVIDUAL OR THE FIRM;THE DEALERSHIP TRANSACTED NO OTHER TRADES IN ANY OTHERSECURITIES IN ITS FIRM ACCOUNT. OVER THE COURSE OF TRADES IN THESECURITY ONE DAY, THE FIRM, THROUGH THE INDIVIDUAL,PURPOSEFULLY SELECTED A SHARE PRICE FOR THE TRANSACTION THATWHEN MULTIPLIED BY THE NUMBER OF SHARES WOULD TOTAL THEVEHICLE'S PURCHASE PRICE. ACCORDINGLY, THE FIRM, ACTINGTHROUGH ITS TRADER AND MARKET MAKER, PUBLISHED ORCIRCULATED, OR CAUSED TO BE PUBLISHED OR CIRCULATED, ACOMMUNICATION REPORTING A TRANSACTION WITHOUT BELIEVING THATTHE TRANSACTION WAS A BONA FIDE PURCHASE OR SALE, AND QUOTEDTHE BID PRICE AND ASK PRICE IN THE SECURITY, WITHOUT BELIEVINGTHAT SUCH QUOTATIONS REPRESENTED A BONA FIDE BID FOR, OF OFFEROF, THE SECURITY. THE FIRM FAILED TO INCLUDE AS REVENUES ORASSET AMONG ITS BOOKS AND RECORDS ITS RECEIPT OF NUMEROUSSHARES IN SECURITIES OF FIVE ISSUERS AND NUMEROUS WARRANTS INFOUR ISSUERS; THEREBY FAILING TO ACCURATELY MAKE AND KEEPCURRENT ITS LEDGERS, OR OTHER RECORDS, REFLECTING ALL ASSETS,LIABILITIES, INCOME AND EXPENSE AND CAPITAL ACCOUNTS. DESPITETHE FACT THAT THE FIRM'S MARKET MAKER RECEIVED PAYMENT FORFILING FORMS 211, MAKING MARKETS IN TWO SECURITIES AND ENTERINGQUOTATIONS IN THE SECURITIES, NO FIRM SUPERVISORY PERSONNELMADE ANY EFFORT TO REASONABLY SUPERVISE HIS ACTIVITIES. NO ONEAT THE FIRM TOOK ADEQUATE MEASURES TO ENSURE HE DID NOTRECEIVE PAYMENT FOR MARKET MAKING AND THAT HE DID NOT ENTERNON-BONA FIDE QUOTATIONS IN A SECURITY OR ENGAGE IN A NON-BONAFIDE TRANSACTION IN THE SECURITY. THE FIRM'S SUPERVISORY SYSTEMDID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS AND NASD RULES CONCERNING NASD RULES 2460, 3310AND IM 3310.








SEC RULES 17A-3, 17A-4, NASD RULES 2110, 2460, 3010, 3110, 3310,INTERPRETATIVE MATERIAL(IM) 3310 - A FIRM TRADER AND MARKETMAKER, ON BEHALF OF ALPINE SECURITIES CORPORATION, FILED FORM211 APPLICATIONS TO QUOTE THE SECURITIES OF TWO ISSUERS ON THEOVER-THE-COUNTER BULLETIN BOARD (OTCBB) AND PREPARED A FORMFOR ONE OF THE ISSUERS AND SIGNED THE APPLICATION AS THEPERSON FINRA SHOULD CONTACT FOR ADDITIONAL INFORMATIONREGARDING THE APPLICATION. SHARES OF ONE STOCK WEREDELIVERED TO A FORMER FIRM PRINCIPAL IN CERTIFICATE FORM. THEINDIVIDUAL AND THE FORMER FIRM PRINCIPAL TRANSFERRED SOME OFTHE SHARES TO THE INDIVIDUAL'S RELATIVE AND THE REMAINDER TOENTITIES AFFILIATED WITH HIS FAMILY AND THE FIRM. NEITHER THEINDIVIDUAL NOR THE FIRM PROVIDED BONA FIDE SERVICES, INCLUDINGINVESTMENT BANKING SERVICES TO EITHER ISSUER, OR TO ANY OTHERPERSON OR ENTITY AFFILIATED WITH OR RELATED TO THEM. THESHARES CONSTITUTED CONSIDERATION TO THE INDIVIDUAL AND THEFIRM FOR FILING THE FORM 211 APPLICATIONS, ENTERING QUOTATIONSAND ACTING AS A MARKET MAKER IN THE SECURITIES. THE FIRM, ACTINGTHROUGH THE INDIVIDUAL, WAS THE ONLY MARKET MAKER ENTERINGQUOTATIONS IN THE SECURITY. THE FIRM, ACTING THROUGH THEINDIVIDUAL, ENTERED NON-BONA FIDE QUOTATIONS IN THE SECURITYAND SOLD SHARES FROM HIS RELATIVES' ACCOUNTS FOR A TOTAL OF$70,454. THE INDIVIDUAL ARRANGED FOR A RELATIVE TO TRANSFERSHARES TO AN AUTOMOBILE DEALERSHIP IN EXCHANGE FOR THEPURCHASE OF A CAR AND HE AGREED THAT HE WOULD BUY BACK THESHARES FOR AN AMOUNT EQUAL TO THE PRICE HE AND HIS RELATIVEAGREED THEY OWED TO PAY FOR THE VEHICLE. TO FACILITATE THEPURCHASE, HE ARRANGED FOR THE DEALERSHIP TO OPEN A SECURITIESACCOUNT AT THE FIRM FOR THE SOLE PURPOSE OF DEPOSITING THESHARES AND PROMPTLY SELLING THEM TO THE INDIVIDUAL OR THE FIRM;THE DEALERSHIP TRANSACTED NO OTHER TRADES IN ANY OTHERSECURITIES IN ITS FIRM ACCOUNT. OVER THE COURSE OF TRADES IN THESECURITY ONE DAY, THE FIRM, THROUGH THE INDIVIDUAL,PURPOSEFULLY SELECTED A SHARE PRICE FOR THE TRANSACTION THATWHEN MULTIPLIED BY THE NUMBER OF SHARES WOULD TOTAL THEVEHICLE'S PURCHASE PRICE. ACCORDINGLY, THE FIRM, ACTINGTHROUGH ITS TRADER AND MARKET MAKER, PUBLISHED ORCIRCULATED, OR CAUSED TO BE PUBLISHED OR CIRCULATED, ACOMMUNICATION REPORTING A TRANSACTION WITHOUT BELIEVING THATTHE TRANSACTION WAS A BONA FIDE PURCHASE OR SALE, AND QUOTEDTHE BID PRICE AND ASK PRICE IN THE SECURITY, WITHOUT BELIEVINGTHAT SUCH QUOTATIONS REPRESENTED A BONA FIDE BID FOR, OF OFFEROF, THE SECURITY. THE FIRM FAILED TO INCLUDE AS REVENUES ORASSET AMONG ITS BOOKS AND RECORDS ITS RECEIPT OF NUMEROUSSHARES IN SECURITIES OF FIVE ISSUERS AND NUMEROUS WARRANTS INFOUR ISSUERS; THEREBY FAILING TO ACCURATELY MAKE AND KEEPCURRENT ITS LEDGERS, OR OTHER RECORDS, REFLECTING ALL ASSETS,LIABILITIES, INCOME AND EXPENSE AND CAPITAL ACCOUNTS. DESPITETHE FACT THAT THE FIRM'S MARKET MAKER RECEIVED PAYMENT FORFILING FORMS 211, MAKING MARKETS IN TWO SECURITIES AND ENTERINGQUOTATIONS IN THE SECURITIES, NO FIRM SUPERVISORY PERSONNELMADE ANY EFFORT TO REASONABLY SUPERVISE HIS ACTIVITIES. NO ONEAT THE FIRM TOOK ADEQUATE MEASURES TO ENSURE HE DID NOTRECEIVE PAYMENT FOR MARKET MAKING AND THAT HE DID NOT ENTERNON-BONA FIDE QUOTATIONS IN A SECURITY OR ENGAGE IN A NON-BONAFIDE TRANSACTION IN THE SECURITY. THE FIRM'S SUPERVISORY SYSTEMDID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS AND NASD RULES CONCERNING NASD RULES 2460, 3310AND IM 3310. 22©2020 FINRA. All rights reserved. Report about ALPINE SECURITIES CORPORATION





Initiated By: FINRA







SEC RULES 17A-3, 17A-4, NASD RULES 2110, 2460, 3010, 3110, 3310,INTERPRETATIVE MATERIAL(IM) 3310 - A FIRM TRADER AND MARKETMAKER, ON BEHALF OF ALPINE SECURITIES CORPORATION, FILED FORM211 APPLICATIONS TO QUOTE THE SECURITIES OF TWO ISSUERS ON THEOVER-THE-COUNTER BULLETIN BOARD (OTCBB) AND PREPARED A FORMFOR ONE OF THE ISSUERS AND SIGNED THE APPLICATION AS THEPERSON FINRA SHOULD CONTACT FOR ADDITIONAL INFORMATIONREGARDING THE APPLICATION. SHARES OF ONE STOCK WEREDELIVERED TO A FORMER FIRM PRINCIPAL IN CERTIFICATE FORM. THEINDIVIDUAL AND THE FORMER FIRM PRINCIPAL TRANSFERRED SOME OFTHE SHARES TO THE INDIVIDUAL'S RELATIVE AND THE REMAINDER TOENTITIES AFFILIATED WITH HIS FAMILY AND THE FIRM. NEITHER THEINDIVIDUAL NOR THE FIRM PROVIDED BONA FIDE SERVICES, INCLUDINGINVESTMENT BANKING SERVICES TO EITHER ISSUER, OR TO ANY OTHERPERSON OR ENTITY AFFILIATED WITH OR RELATED TO THEM. THESHARES CONSTITUTED CONSIDERATION TO THE INDIVIDUAL AND THEFIRM FOR FILING THE FORM 211 APPLICATIONS, ENTERING QUOTATIONSAND ACTING AS A MARKET MAKER IN THE SECURITIES. THE FIRM, ACTINGTHROUGH THE INDIVIDUAL, WAS THE ONLY MARKET MAKER ENTERINGQUOTATIONS IN THE SECURITY. THE FIRM, ACTING THROUGH THEINDIVIDUAL, ENTERED NON-BONA FIDE QUOTATIONS IN THE SECURITYAND SOLD SHARES FROM HIS RELATIVES' ACCOUNTS FOR A TOTAL OF$70,454. THE INDIVIDUAL ARRANGED FOR A RELATIVE TO TRANSFERSHARES TO AN AUTOMOBILE DEALERSHIP IN EXCHANGE FOR THEPURCHASE OF A CAR AND HE AGREED THAT HE WOULD BUY BACK THESHARES FOR AN AMOUNT EQUAL TO THE PRICE HE AND HIS RELATIVEAGREED THEY OWED TO PAY FOR THE VEHICLE. TO FACILITATE THEPURCHASE, HE ARRANGED FOR THE DEALERSHIP TO OPEN A SECURITIESACCOUNT AT THE FIRM FOR THE SOLE PURPOSE OF DEPOSITING THESHARES AND PROMPTLY SELLING THEM TO THE INDIVIDUAL OR THE FIRM;THE DEALERSHIP TRANSACTED NO OTHER TRADES IN ANY OTHERSECURITIES IN ITS FIRM ACCOUNT. OVER THE COURSE OF TRADES IN THESECURITY ONE DAY, THE FIRM, THROUGH THE INDIVIDUAL,PURPOSEFULLY SELECTED A SHARE PRICE FOR THE TRANSACTION THATWHEN MULTIPLIED BY THE NUMBER OF SHARES WOULD TOTAL THEVEHICLE'S PURCHASE PRICE. ACCORDINGLY, THE FIRM, ACTINGTHROUGH ITS TRADER AND MARKET MAKER, PUBLISHED ORCIRCULATED, OR CAUSED TO BE PUBLISHED OR CIRCULATED, ACOMMUNICATION REPORTING A TRANSACTION WITHOUT BELIEVING THATTHE TRANSACTION WAS A BONA FIDE PURCHASE OR SALE, AND QUOTEDTHE BID PRICE AND ASK PRICE IN THE SECURITY, WITHOUT BELIEVINGTHAT SUCH QUOTATIONS REPRESENTED A BONA FIDE BID FOR, OF OFFEROF, THE SECURITY. THE FIRM FAILED TO INCLUDE AS REVENUES ORASSET AMONG ITS BOOKS AND RECORDS ITS RECEIPT OF NUMEROUSSHARES IN SECURITIES OF FIVE ISSUERS AND NUMEROUS WARRANTS INFOUR ISSUERS; THEREBY FAILING TO ACCURATELY MAKE AND KEEPCURRENT ITS LEDGERS, OR OTHER RECORDS, REFLECTING ALL ASSETS,LIABILITIES, INCOME AND EXPENSE AND CAPITAL ACCOUNTS. DESPITETHE FACT THAT THE FIRM'S MARKET MAKER RECEIVED PAYMENT FORFILING FORMS 211, MAKING MARKETS IN TWO SECURITIES AND ENTERINGQUOTATIONS IN THE SECURITIES, NO FIRM SUPERVISORY PERSONNELMADE ANY EFFORT TO REASONABLY SUPERVISE HIS ACTIVITIES. NO ONEAT THE FIRM TOOK ADEQUATE MEASURES TO ENSURE HE DID NOTRECEIVE PAYMENT FOR MARKET MAKING AND THAT HE DID NOT ENTERNON-BONA FIDE QUOTATIONS IN A SECURITY OR ENGAGE IN A NON-BONAFIDE TRANSACTION IN THE SECURITY. THE FIRM'S SUPERVISORY SYSTEMDID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS AND NASD RULES CONCERNING NASD RULES 2460, 3310AND IM 3310.


Resolution:

Other Sanctions Ordered: UNDERTAKING

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $82,500 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDINGPAYMENTS FOR MARKET MAKING, NON-BONA FIDEQUOTATIONS/TRANSACTIONS AND NASD RULES 2460, 3310,INTERPRETATIVE MATERIAL 3310 WITHIN 30 BUSINESS DAYS OFACCEPTANCE OF THIS AWC BY THE NAC. FINE PAID IN FULL DECEMBER 13,2011.


No




Allegations: FINRA ALLEGED ACTIONS DURING 2006 OF A FORMER PRINCIPAL, WHOPASSED AWAY IN FEBRUARY 2008, AND A FORMER TRADER FORVIOLATIONS OF NASD RULES 2110,2460 AND 3110 AS WELL AS SEC RULES17A-3 AND 17A-4. SEC RULES 17A-3, 17A-4, NASD RULES 2110, 2460, 3010,3110, 3310, INTERPRETATIVE MATERIAL(IM) 3310 - A FIRM TRADER ANDMARKET MAKER, ON BEHALF OF ALPINE SECURITIES CORPORATION,FILED FORM 211 APPLICATIONS TO QUOTE THE SECURITIES OF TWOISSUERS ON THE OVER-THE-COUNTER BULLETIN BOARD (OTCBB) ANDPREPARED A FORM FOR ONE OF THE ISSUERS AND SIGNED THEAPPLICATION AS THE PERSON FINRA SHOULD CONTACT FOR ADDITIONALINFORMATION REGARDING THE APPLICATION. SHARES OF ONE STOCKWERE DELIVERED TO A FORMER FIRM PRINCIPAL IN CERTIFICATE FORM.THE INDIVIDUAL AND THE FORMER FIRM PRINCIPAL TRANSFERRED SOMEOF THE SHARES TO THE INDIVIDUAL'S RELATIVE AND THE REMAINDER TOENTITIES AFFILIATED WITH HIS FAMILY AND THE FIRM. NEITHER THEINDIVIDUAL NOR THE FIRM PROVIDED BONA FIDE SERVICES, INCLUDINGINVESTMENT BANKING SERVICES TO EITHER ISSUER, OR TO ANY OTHERPERSON OR ENTITY AFFILIATED WITH OR RELATED TO THEM. THESHARES CONSTITUTED CONSIDERATION TO THE INDIVIDUAL AND THEFIRM FOR FILING THE FORM 211 APPLICATIONS, ENTERING QUOTATIONSAND ACTING AS A MARKET MAKER IN THE SECURITIES. THE FIRM, ACTINGTHROUGH THE INDIVIDUAL, WAS THE ONLY MARKET MAKER ENTERINGQUOTATIONS IN THE SECURITY. THE FIRM, ACTING THROUGH THEINDIVIDUAL, ENTERED NON-BONA FIDE QUOTATIONS IN THE SECURITYAND SOLD SHARES FROM HIS RELATIVES' ACCOUNTS FOR A TOTAL OF$70,454. THE INDIVIDUAL ARRANGED FOR A RELATIVE TO TRANSFERSHARES TO AN AUTOMOBILE DEALERSHIP IN EXCHANGE FOR THEPURCHASE OF A CAR AND HE AGREED THAT HE WOULD BUY BACK THESHARES FOR AN AMOUNT EQUAL TO THE PRICE HE AND HIS RELATIVEAGREED THEY OWED TO PAY FOR THE VEHICLE. TO FACILITATE THEPURCHASE, HE ARRANGED FOR THE DEALERSHIP TO OPEN A SECURITIESACCOUNT AT THE FIRM FOR THE PURPOSE OF DEPOSITING THE SHARESAND PROMPTLY SELLING THEM TO THE INDIVIDUAL OR THE FIRM; THEDEALERSHIP TRANSACTED NO OTHER TRADES IN ANY OTHERSECURITIES IN ITS FIRM ACCOUNT. THE FIRM, ACTING THROUGH ITSTRADER AND MARKET MAKER, PUBLISHED OR CIRCULATED, OR CAUSEDTO BE PUBLISHED OR CIRCULATED, A COMMUNICATION REPORTING ATRANSACTION WITHOUT BELIEVING THAT THE TRANSACTION WAS A BONAFIDE PURCHASE OR SALE, AND QUOTED THE BID PRICE AND ASK PRICE INTHE SECURITY, WITHOUT BELIEVING THAT SUCH QUOTATIONSREPRESENTED A BONA FIDE BID FOR, OF OFFER OF, THE SECURITY. THEFIRM FAILED TO INCLUDE AS REVENUES OR ASSET AMONG ITS BOOKSAND RECORDS ITS RECEIPT OF NUMEROUS SHARES IN SECURITIES OFFIVE ISSUERS AND NUMEROUS WARRANTS IN FOUR ISSUERS; THEREBYFAILING TO ACCURATELY MAKE AND KEEP CURRENT ITS LEDGERS, OROTHER RECORDS, REFLECTING ALL ASSETS, LIABILITIES, INCOME ANDEXPENSE AND CAPITAL ACCOUNTS. DESPITE THE FACT THAT THE FIRM'SMARKET MAKER RECEIVED PAYMENT FOR FILING FORMS 211, MAKINGMARKETS IN TWO SECURITIES AND ENTERING QUOTATIONS IN THESECURITIES, NO FIRM SUPERVISORY PERSONNEL MADE ANY EFFORT TOREASONABLY SUPERVISE HIS ACTIVITIES. NO ONE AT THE FIRM TOOKADEQUATE MEASURES TO ENSURE HE DID NOT RECEIVE PAYMENT FORMARKET MAKING AND THAT HE DID NOT ENTER NON-BONA FIDEQUOTATIONS IN A SECURITY OR ENGAGE IN A NON-BONA FIDETRANSACTION IN THE SECURITY. THE FIRM'S SUPERVISORY SYSTEM DIDNOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDNASD RULES CONCERNING NASD RULES 2460, 3310 AND IM 3310.








FINRA ALLEGED ACTIONS DURING 2006 OF A FORMER PRINCIPAL, WHOPASSED AWAY IN FEBRUARY 2008, AND A FORMER TRADER FORVIOLATIONS OF NASD RULES 2110,2460 AND 3110 AS WELL AS SEC RULES17A-3 AND 17A-4. SEC RULES 17A-3, 17A-4, NASD RULES 2110, 2460, 3010,3110, 3310, INTERPRETATIVE MATERIAL(IM) 3310 - A FIRM TRADER ANDMARKET MAKER, ON BEHALF OF ALPINE SECURITIES CORPORATION,FILED FORM 211 APPLICATIONS TO QUOTE THE SECURITIES OF TWOISSUERS ON THE OVER-THE-COUNTER BULLETIN BOARD (OTCBB) ANDPREPARED A FORM FOR ONE OF THE ISSUERS AND SIGNED THEAPPLICATION AS THE PERSON FINRA SHOULD CONTACT FOR ADDITIONALINFORMATION REGARDING THE APPLICATION. SHARES OF ONE STOCKWERE DELIVERED TO A FORMER FIRM PRINCIPAL IN CERTIFICATE FORM.THE INDIVIDUAL AND THE FORMER FIRM PRINCIPAL TRANSFERRED SOMEOF THE SHARES TO THE INDIVIDUAL'S RELATIVE AND THE REMAINDER TOENTITIES AFFILIATED WITH HIS FAMILY AND THE FIRM. NEITHER THEINDIVIDUAL NOR THE FIRM PROVIDED BONA FIDE SERVICES, INCLUDINGINVESTMENT BANKING SERVICES TO EITHER ISSUER, OR TO ANY OTHERPERSON OR ENTITY AFFILIATED WITH OR RELATED TO THEM. THESHARES CONSTITUTED CONSIDERATION TO THE INDIVIDUAL AND THEFIRM FOR FILING THE FORM 211 APPLICATIONS, ENTERING QUOTATIONSAND ACTING AS A MARKET MAKER IN THE SECURITIES. THE FIRM, ACTINGTHROUGH THE INDIVIDUAL, WAS THE ONLY MARKET MAKER ENTERINGQUOTATIONS IN THE SECURITY. THE FIRM, ACTING THROUGH THEINDIVIDUAL, ENTERED NON-BONA FIDE QUOTATIONS IN THE SECURITYAND SOLD SHARES FROM HIS RELATIVES' ACCOUNTS FOR A TOTAL OF$70,454. THE INDIVIDUAL ARRANGED FOR A RELATIVE TO TRANSFERSHARES TO AN AUTOMOBILE DEALERSHIP IN EXCHANGE FOR THEPURCHASE OF A CAR AND HE AGREED THAT HE WOULD BUY BACK THESHARES FOR AN AMOUNT EQUAL TO THE PRICE HE AND HIS RELATIVEAGREED THEY OWED TO PAY FOR THE VEHICLE. TO FACILITATE THEPURCHASE, HE ARRANGED FOR THE DEALERSHIP TO OPEN A SECURITIESACCOUNT AT THE FIRM FOR THE PURPOSE OF DEPOSITING THE SHARESAND PROMPTLY SELLING THEM TO THE INDIVIDUAL OR THE FIRM; THEDEALERSHIP TRANSACTED NO OTHER TRADES IN ANY OTHERSECURITIES IN ITS FIRM ACCOUNT. THE FIRM, ACTING THROUGH ITSTRADER AND MARKET MAKER, PUBLISHED OR CIRCULATED, OR CAUSEDTO BE PUBLISHED OR CIRCULATED, A COMMUNICATION REPORTING ATRANSACTION WITHOUT BELIEVING THAT THE TRANSACTION WAS A BONAFIDE PURCHASE OR SALE, AND QUOTED THE BID PRICE AND ASK PRICE INTHE SECURITY, WITHOUT BELIEVING THAT SUCH QUOTATIONSREPRESENTED A BONA FIDE BID FOR, OF OFFER OF, THE SECURITY. THEFIRM FAILED TO INCLUDE AS REVENUES OR ASSET AMONG ITS BOOKSAND RECORDS ITS RECEIPT OF NUMEROUS SHARES IN SECURITIES OFFIVE ISSUERS AND NUMEROUS WARRANTS IN FOUR ISSUERS; THEREBYFAILING TO ACCURATELY MAKE AND KEEP CURRENT ITS LEDGERS, OROTHER RECORDS, REFLECTING ALL ASSETS, LIABILITIES, INCOME ANDEXPENSE AND CAPITAL ACCOUNTS. DESPITE THE FACT THAT THE FIRM'SMARKET MAKER RECEIVED PAYMENT FOR FILING FORMS 211, MAKINGMARKETS IN TWO SECURITIES AND ENTERING QUOTATIONS IN THESECURITIES, NO FIRM SUPERVISORY PERSONNEL MADE ANY EFFORT TOREASONABLY SUPERVISE HIS ACTIVITIES. NO ONE AT THE FIRM TOOKADEQUATE MEASURES TO ENSURE HE DID NOT RECEIVE PAYMENT FORMARKET MAKING AND THAT HE DID NOT ENTER NON-BONA FIDEQUOTATIONS IN A SECURITY OR ENGAGE IN A NON-BONA FIDETRANSACTION IN THE SECURITY. THE FIRM'S SUPERVISORY SYSTEM DIDNOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDNASD RULES CONCERNING NASD RULES 2460, 3310 AND IM 3310.






Initiated By: FINRA


Censure



Docket/Case Number: 20070080318-01



FINRA ALLEGED ACTIONS DURING 2006 OF A FORMER PRINCIPAL, WHOPASSED AWAY IN FEBRUARY 2008, AND A FORMER TRADER FORVIOLATIONS OF NASD RULES 2110,2460 AND 3110 AS WELL AS SEC RULES17A-3 AND 17A-4. SEC RULES 17A-3, 17A-4, NASD RULES 2110, 2460, 3010,3110, 3310, INTERPRETATIVE MATERIAL(IM) 3310 - A FIRM TRADER ANDMARKET MAKER, ON BEHALF OF ALPINE SECURITIES CORPORATION,FILED FORM 211 APPLICATIONS TO QUOTE THE SECURITIES OF TWOISSUERS ON THE OVER-THE-COUNTER BULLETIN BOARD (OTCBB) ANDPREPARED A FORM FOR ONE OF THE ISSUERS AND SIGNED THEAPPLICATION AS THE PERSON FINRA SHOULD CONTACT FOR ADDITIONALINFORMATION REGARDING THE APPLICATION. SHARES OF ONE STOCKWERE DELIVERED TO A FORMER FIRM PRINCIPAL IN CERTIFICATE FORM.THE INDIVIDUAL AND THE FORMER FIRM PRINCIPAL TRANSFERRED SOMEOF THE SHARES TO THE INDIVIDUAL'S RELATIVE AND THE REMAINDER TOENTITIES AFFILIATED WITH HIS FAMILY AND THE FIRM. NEITHER THEINDIVIDUAL NOR THE FIRM PROVIDED BONA FIDE SERVICES, INCLUDINGINVESTMENT BANKING SERVICES TO EITHER ISSUER, OR TO ANY OTHERPERSON OR ENTITY AFFILIATED WITH OR RELATED TO THEM. THESHARES CONSTITUTED CONSIDERATION TO THE INDIVIDUAL AND THEFIRM FOR FILING THE FORM 211 APPLICATIONS, ENTERING QUOTATIONSAND ACTING AS A MARKET MAKER IN THE SECURITIES. THE FIRM, ACTINGTHROUGH THE INDIVIDUAL, WAS THE ONLY MARKET MAKER ENTERINGQUOTATIONS IN THE SECURITY. THE FIRM, ACTING THROUGH THEINDIVIDUAL, ENTERED NON-BONA FIDE QUOTATIONS IN THE SECURITYAND SOLD SHARES FROM HIS RELATIVES' ACCOUNTS FOR A TOTAL OF$70,454. THE INDIVIDUAL ARRANGED FOR A RELATIVE TO TRANSFERSHARES TO AN AUTOMOBILE DEALERSHIP IN EXCHANGE FOR THEPURCHASE OF A CAR AND HE AGREED THAT HE WOULD BUY BACK THESHARES FOR AN AMOUNT EQUAL TO THE PRICE HE AND HIS RELATIVEAGREED THEY OWED TO PAY FOR THE VEHICLE. TO FACILITATE THEPURCHASE, HE ARRANGED FOR THE DEALERSHIP TO OPEN A SECURITIESACCOUNT AT THE FIRM FOR THE PURPOSE OF DEPOSITING THE SHARESAND PROMPTLY SELLING THEM TO THE INDIVIDUAL OR THE FIRM; THEDEALERSHIP TRANSACTED NO OTHER TRADES IN ANY OTHERSECURITIES IN ITS FIRM ACCOUNT. THE FIRM, ACTING THROUGH ITSTRADER AND MARKET MAKER, PUBLISHED OR CIRCULATED, OR CAUSEDTO BE PUBLISHED OR CIRCULATED, A COMMUNICATION REPORTING ATRANSACTION WITHOUT BELIEVING THAT THE TRANSACTION WAS A BONAFIDE PURCHASE OR SALE, AND QUOTED THE BID PRICE AND ASK PRICE INTHE SECURITY, WITHOUT BELIEVING THAT SUCH QUOTATIONSREPRESENTED A BONA FIDE BID FOR, OF OFFER OF, THE SECURITY. THEFIRM FAILED TO INCLUDE AS REVENUES OR ASSET AMONG ITS BOOKSAND RECORDS ITS RECEIPT OF NUMEROUS SHARES IN SECURITIES OFFIVE ISSUERS AND NUMEROUS WARRANTS IN FOUR ISSUERS; THEREBYFAILING TO ACCURATELY MAKE AND KEEP CURRENT ITS LEDGERS, OROTHER RECORDS, REFLECTING ALL ASSETS, LIABILITIES, INCOME ANDEXPENSE AND CAPITAL ACCOUNTS. DESPITE THE FACT THAT THE FIRM'SMARKET MAKER RECEIVED PAYMENT FOR FILING FORMS 211, MAKINGMARKETS IN TWO SECURITIES AND ENTERING QUOTATIONS IN THESECURITIES, NO FIRM SUPERVISORY PERSONNEL MADE ANY EFFORT TOREASONABLY SUPERVISE HIS ACTIVITIES. NO ONE AT THE FIRM TOOKADEQUATE MEASURES TO ENSURE HE DID NOT RECEIVE PAYMENT FORMARKET MAKING AND THAT HE DID NOT ENTER NON-BONA FIDEQUOTATIONS IN A SECURITY OR ENGAGE IN A NON-BONA FIDETRANSACTION IN THE SECURITY. THE FIRM'S SUPERVISORY SYSTEM DIDNOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDNASD RULES CONCERNING NASD RULES 2460, 3310 AND IM 3310.


Resolution:

Other Sanctions Ordered: UNDERTAKING TO REVISE FIRM'S WRITTEN SUPERVISORY PROCEDURES

Sanction Details: $82,500.00 PAID BY CHECK 12/06/11

Firm Statement THE FIRM WAS SOLD IN MARCH 2011 AND ALL RELEVANT PARTIESINVOLVED IN THIS ACTION ARE NO LONGER WITH THE FIRM. THE VALUEOF THE SECURITIES RECEIVED AND NOT REPORTED AS INCOME FORPRIVATE PLACEMENT OFFERINGS WAS MINISCULE AND WAS OFFSETCOMPLETELY BY EXPENSE TO REGISTERED REPRESENTATIVES.CONSEQUENTLY, NET INCOME TO THE FIRM WAS ZERO.



Disclosure 4 of 41

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Allegations: SECTION 5 OF THE SECURITIES ACT OF 1933 AND NASD RULES 2110 AND3010: RESPONDENT ALPINE SECURITIES CORPORATION OFFERED ANDSOLD THROUGH THE MEANS OF INTERSTATE COMMERCE OVER 2 BILLIONUNREGISTERED SHARES WITHOUT AN EXEMPTION. THE FIRM ALSOFAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SYSTEM TO SUPERVISETHE ACTIVITIES OF ITS ASSOCIATED PERSONS THAT WERE REASONABLYDESIGNED TO DETECT AND PREVENT THE SALE OF UNREGISTEREDSECURITIES.







Initiated By: FINRA





Principal Product Type: Other

Other Product Type(s): UNREGISTERED SHARES

Allegations: SECTION 5 OF THE SECURITIES ACT OF 1933 AND NASD RULES 2110 AND3010: RESPONDENT ALPINE SECURITIES CORPORATION OFFERED ANDSOLD THROUGH THE MEANS OF INTERSTATE COMMERCE OVER 2 BILLIONUNREGISTERED SHARES WITHOUT AN EXEMPTION. THE FIRM ALSOFAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SYSTEM TO SUPERVISETHE ACTIVITIES OF ITS ASSOCIATED PERSONS THAT WERE REASONABLYDESIGNED TO DETECT AND PREVENT THE SALE OF UNREGISTEREDSECURITIES.


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 $40,000.


No




Allegations: ALPINE SECURITIES VIOLATED NASD RULE 2110, BY SELLINGUNREGISTERED SECURITIES AND VIOLTED NASD RULES 3010 AND 2110 BYFAILING TO ESTABLISH, MAINTAIN AND ENFORCE A SYSTEM, TOSUPERVISE THE ACTIVITIES OF ITS ASSOCIATED PERSONS THAT WEREREASONABLY DESIGNED TO DETECT AND PREVENT THE SALE OFUNREGISTERED SECURITIES.








Initiated By: FINRA


Censure


FINE OF $40,000





ALPINE SECURITIES VIOLATED NASD RULE 2110, BY SELLINGUNREGISTERED SECURITIES AND VIOLTED NASD RULES 3010 AND 2110 BYFAILING TO ESTABLISH, MAINTAIN AND ENFORCE A SYSTEM, TOSUPERVISE THE ACTIVITIES OF ITS ASSOCIATED PERSONS THAT WEREREASONABLY DESIGNED TO DETECT AND PREVENT THE SALE OFUNREGISTERED SECURITIES.


Resolution:

Other Sanctions Ordered: NONE

Sanction Details: $40,000 FINE PAID BY APPLICANT IN JANUARY 2010 UPON RECEIPT OFINVOICE.

Firm Statement AN UNDERTAKING TO REVISE AND UPDATE THE POLICIES ANDPROCEDURES BY ALPINE SECURITIES IS NOT REQUIRED BY THE AWC.THE VIOLATIONS OCCURRED IN 2006 AND 2007. THE AWC STATES THAT "DURING 2008 AND BEFORE THE COMMENCEMENT OF ENFORCEMENT'SINVESTIGATION, THE FIRM ADOPTED ADDITIONAL FORMAL WRITTENPOLICIES WITH REGARD TO SALES OF UNREGISTERED SECURITIESWHICH INCLUDE DETAILED PROCEDURES."



Disclosure 5 of 41

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Allegations: SEC RULE 10B-10, NASD RULES 2110, 3010 - ALPINE SECURITIESCORPORATION FAILED TO DISCLOSE CORRECT INFORMATION ONCUSTOMER CONFIRMATIONS. THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDNASD RULES CONCERNING ORDER HANDLING, BEST EXECUTION, TRADEREPORTING, SALES TRANSACTIONS, SEC REGULATION SHO AND THEORDER AUDIT TRAIL SYSTEM (OATS).








Initiated By: FINRA






Other Product Type(s): UNSPECIFIED SECURITIES

SEC RULE 10B-10, NASD RULES 2110, 3010 - ALPINE SECURITIESCORPORATION FAILED TO DISCLOSE CORRECT INFORMATION ONCUSTOMER CONFIRMATIONS. THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDNASD RULES CONCERNING ORDER HANDLING, BEST EXECUTION, TRADEREPORTING, SALES TRANSACTIONS, SEC REGULATION SHO AND THEORDER AUDIT TRAIL SYSTEM (OATS).


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 $18,500 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING ORDERHANDLING, BEST EXECUTION, TRADE REPORTING, SALESTRANSACTIONS, SEC REGULATION SHO AND OATS WITHIN 30 DAYS OFACCEPTANCE OF THIS AWC BY THE NAC.


No




Allegations: THE FIRM FAILED TO DISCLOSE CORRECT INFORMATION ON CUSTOMERCONFIRMATIONS AND THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS AND THE RULES OF NASD, CONCERNING ORDERHANDLING, BEST EXECUTION, TRADE REPORTING, SALESTRANSACTIONS, SEC REG SHO AND OATS.








Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)


Censure


FINE OF $18,500





THE FIRM FAILED TO DISCLOSE CORRECT INFORMATION ON CUSTOMERCONFIRMATIONS AND THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS AND THE RULES OF NASD, CONCERNING ORDERHANDLING, BEST EXECUTION, TRADE REPORTING, SALESTRANSACTIONS, SEC REG SHO AND OATS.


Resolution:

Other Sanctions Ordered: AN UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORYPROCEDURES.

Sanction Details: PAID $18,500 BY CHECK ON 6/17/2009. COMPRISED OF A $6,000 FINE FORTHE RULE 10B-10 VIOLATIONS AND A $12,500 FINE FOR THE SUPERVISIONVIOLATIONS. NO CONTROL AFFILIATES SANCTIONED.



Disclosure 6 of 41

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Initiated By: FINRA

Allegations: NASD RULES 2110, 3010, 8211, 8213 - ALPINE SECURITIES CORPORATIONFAILED TO REPORT ACCURATE TRADING INFORMATION THROUGH THESUBMISSION OF ELECTRONIC BLUE SHEETS IN RESPONSE TO REQUESTSFOR SUCH INFORMATION BY FINRA, SPECIFICALLY, THE FIRM FAILED TOINCLUDE THE SHORT SALE INDICATOR FOR SOME ELECTRONIC BLUESHEETS RECORDS. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDEFOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITH APPLICABLE SECURITIES LAWS, REGULATIONS AND FINRA RULESCONCERNING THE SUBMISSION OF ELECTRONIC BLUE SHEET DATA.







Initiated By: FINRA








Resolution:




No




Initiated By: FINRA


Censure





Allegations: INACCURATE BLUE SHEET DATA AND DEFICIENT SUPERVISORYPROCEDURES.









Censure


FINE $15000


Resolution:


Sanction Details: $10000 FOR INACCURATE BLUE SHEETS AND $5000 FOR DEFICIENTSUPERVISORY PROCEDURES.

Firm Statement JANUARY 1, 2005 THROUGH AUGUST 31, 2005 THE FIRM FAILED TOREPORT ACURATE TRADING INFORMATION THROUGH THE SUBMISSIONOF ELECTRONIC BLUE SHEETS IN RESPONSE TO REQUESTS FOR SUCHINFORMATION BY FINRA.



Disclosure 7 of 41

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Allegations: SEC RULES 203(B)(3), 203(B)(3)(III), NASD RULES 2110, 3010, 6130(D)(6) -ALPINE SECURITIES CORPORATION HAD FAIL TO DELIVER POSITIONS INTHRESHOLD SECURITIES AT A REGISTERED CLEARING AGENCY FOR 13CONSECUTIVE SETTLEMENT DAYS AND FAILED TO IMMEDIATELY CLOSEOUT THE POSITIONS BY PURCHASING SECURITIES OF LIKE KIND ANDQUANTITY. THE FIRM HAD A FAIL TO DELIVER POSITION IN A THRESHOLDSECURITY AT A REGISTERED CLEARING AGENCY FOR 13 CONSECUTIVESETTLEMENT DAYS AND WITHOUT CLOSING OUT THE POSITION BYPURCHASING SECURITIES OF LIKE KIND AND QUANTITY, IT FAILED TOBORROW THE SECURITY OR ENTER INTO A BONA FIDE ARRANGEMENT TOBORROW THE SECURITY BEFORE EXECUTING PROPRIETARY SHORTSALES IN CONNECTION WITH ITS MARKET MAKING ACTIVITIES IN THESECURITY. THE FIRM INCORRECTLY REPORTED TO THE NASDAQ MARKETCENTER THAT CUSTOMER SALE TRANSACTIONS IN A SECURITY UNDERSEC RULE 144 WERE LONG SALES; INCORRECTLY REPORTED TO THENASDAQ MARKET CENTER PROPRIETARY SALE TRANSACTIONS IN ASECURITY IN CONNECTION WITH ITS MARKET MAKING ACTIVITIES ASEXEMPT SHORT SALES. THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDNASD RULES RELATING TO NASD RULE 6130(D)(6) AND SEC RULES 200(G)(ORDER MARKING), 203(A) (LONG SALES), 203(B) (LOCATEREQUIREMENTS), 203(B)(3) AND 203(B)(3)(III) (PRE-BORROWREQUIREMENTS).







Initiated By: NASD






Other Product Type(s): THRESHOLD SECURITIES

SEC RULES 203(B)(3), 203(B)(3)(III), NASD RULES 2110, 3010, 6130(D)(6) -ALPINE SECURITIES CORPORATION HAD FAIL TO DELIVER POSITIONS INTHRESHOLD SECURITIES AT A REGISTERED CLEARING AGENCY FOR 13CONSECUTIVE SETTLEMENT DAYS AND FAILED TO IMMEDIATELY CLOSEOUT THE POSITIONS BY PURCHASING SECURITIES OF LIKE KIND ANDQUANTITY. THE FIRM HAD A FAIL TO DELIVER POSITION IN A THRESHOLDSECURITY AT A REGISTERED CLEARING AGENCY FOR 13 CONSECUTIVESETTLEMENT DAYS AND WITHOUT CLOSING OUT THE POSITION BYPURCHASING SECURITIES OF LIKE KIND AND QUANTITY, IT FAILED TOBORROW THE SECURITY OR ENTER INTO A BONA FIDE ARRANGEMENT TOBORROW THE SECURITY BEFORE EXECUTING PROPRIETARY SHORTSALES IN CONNECTION WITH ITS MARKET MAKING ACTIVITIES IN THESECURITY. THE FIRM INCORRECTLY REPORTED TO THE NASDAQ MARKETCENTER THAT CUSTOMER SALE TRANSACTIONS IN A SECURITY UNDERSEC RULE 144 WERE LONG SALES; INCORRECTLY REPORTED TO THENASDAQ MARKET CENTER PROPRIETARY SALE TRANSACTIONS IN ASECURITY IN CONNECTION WITH ITS MARKET MAKING ACTIVITIES ASEXEMPT SHORT SALES. THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDNASD RULES RELATING TO NASD RULE 6130(D)(6) AND SEC RULES 200(G)(ORDER MARKING), 203(A) (LONG SALES), 203(B) (LOCATEREQUIREMENTS), 203(B)(3) AND 203(B)(3)(III) (PRE-BORROWREQUIREMENTS).


Resolution:




No




Allegations: ALPINE HAD A FAIL TO DELIVER POSITION IN A THRESHOLD SECURITY FORTHIRTEEN CONSECUTIVE DAYS AND FAILED TO CLOSE OUT THE POSITIONBY PUCHASING SECURITIES OF LIKE KIND AND QUANTITY. ALPINE ALSOFAILED TO BORROW THE SECURITY AND INCORRECTLY REPORTEDTRANSACTIONS IN CONNECTION WITH ITS MARKET MAKING ACTIVITIES ASEXEMPT SHORT SALES. THE FIRMS SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS. (SHO RULES)








Initiated By: NASD


Censure


FINE





ALPINE HAD A FAIL TO DELIVER POSITION IN A THRESHOLD SECURITY FORTHIRTEEN CONSECUTIVE DAYS AND FAILED TO CLOSE OUT THE POSITIONBY PUCHASING SECURITIES OF LIKE KIND AND QUANTITY. ALPINE ALSOFAILED TO BORROW THE SECURITY AND INCORRECTLY REPORTEDTRANSACTIONS IN CONNECTION WITH ITS MARKET MAKING ACTIVITIES ASEXEMPT SHORT SALES. THE FIRMS SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS. (SHO RULES)


Resolution:


Sanction Details: $27,500 FINE DUE AND PAYABLE UPON NOTICE FROM THE NASD.

Firm Statement THE FIRM AGREES TO PAY A FINE OF $27,500 DUE AND PAYABLE UPONNOTICE FROM THE NASD.



Disclosure 8 of 41

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Allegations: ON MAY 19, 2006, THE BANKING COMMISSIONER ISSUED A NOTICE OFINTENT TO DENY THE BROKER-DEALER REGISTRATION OF ALPINESECURITIES CORPORATION (DOCKET NO. ND-2006-7246-S). THE FIRMMAINTAINS ITS PRINCIPAL OFFICE AT 440 EAST 400 SOUTH, SUITE 200,SALT LAKE CITY, UTAH. ALTHOUGH THE FIRM HAD APPLIED TOWITHDRAW ITS REGISTRATION APPLICATION, CONNECTICUT LAWPERMITS THE INITIATION OF DENIAL PROCEEDINGS WITHIN ONE YEARFOLLOWING THE EFFECTIVE DATE OF ANY SUCH WITHDRAWAL. THEACTION WAS PREDICATED ON MULTIPLE SANCTIONS IMPOSED AGAINSTTHE RESPONDENT BY THE NATIONAL ASSOCIATION OF SECURITIESDEALERS, INC. BETWEEN 2001 AND 2005, INCLUDING FINES IMPOSED FORFAILING TO IMPLEMENT EFFECTIVE ANTI-MONEY LAUNDERINGPROCEDURES AND FAILING TO EXERCISE SUPERVISORY CONTROLS.







Initiated By: CONNECTICUT


Denial



Docket/Case Number: ND-2006-7246-S

URL for Regulatory Action:



ON MAY 19, 2006, THE BANKING COMMISSIONER ISSUED A NOTICE OFINTENT TO DENY THE BROKER-DEALER REGISTRATION OF ALPINESECURITIES CORPORATION (DOCKET NO. ND-2006-7246-S). THE FIRMMAINTAINS ITS PRINCIPAL OFFICE AT 440 EAST 400 SOUTH, SUITE 200,SALT LAKE CITY, UTAH. ALTHOUGH THE FIRM HAD APPLIED TOWITHDRAW ITS REGISTRATION APPLICATION, CONNECTICUT LAWPERMITS THE INITIATION OF DENIAL PROCEEDINGS WITHIN ONE YEARFOLLOWING THE EFFECTIVE DATE OF ANY SUCH WITHDRAWAL. THEACTION WAS PREDICATED ON MULTIPLE SANCTIONS IMPOSED AGAINSTTHE RESPONDENT BY THE NATIONAL ASSOCIATION OF SECURITIESDEALERS, INC. BETWEEN 2001 AND 2005, INCLUDING FINES IMPOSED FORFAILING TO IMPLEMENT EFFECTIVE ANTI-MONEY LAUNDERINGPROCEDURES AND FAILING TO EXERCISE SUPERVISORY CONTROLS.


Resolution:


Sanction Details: ORDER DENYING REGISTRATION AS BROKER-DEALER ENTERED JULY 14,2006.

Regulator Statement THE RESPONDENT WAS AFFORDED AN OPPORTUNITY TO REQUEST AHEARING ON THE NOTICE OF INTENT TO DENY REGISTRATION ASBROKER-DEALER. UPDATE: IN DENYING THE RESPONDENT'S BROKER-DEALER REGISTRATION ON JULY 14, 2006, THE COMMISSIONERINCORPORATED AS FINDINGS THE ALLEGATIONS MADE IN THE MAY 19,2006 NOTICE OF INTENT TO DENY REGISTRATION AS BROKER-DEALER.ALTHOUGH THE RESPONDENT HAD INITIALLY REQUESTED A HEARING ONTHE NOTICE OF INTENT TO DENY REGISTRATION AS BROKER-DEALER,THAT REQUEST WAS LATER WITHDRAWN.


No

Sanctions Ordered: Revocation/Expulsion/Denial

Order


Allegations: ALPINE AND ITS PRINCIPALS WERE THE SUBJECT OF NASD SANCTIONSWITHIN THE LAST TEN YEARS, THE EFFECTS OF WHICH HAD NOT BEENSTAYED OR OVERTURNED.







Initiated By: STATE OF CONNECTICUT


Denial



Docket/Case Number: ND-2006-7246-S



Allegations: ALPINE AND ITS PRINCIPALS WERE THE SUBJECT OF NASD SANCTIONSWITHIN THE LAST TEN YEARS, THE EFFECTS OF WHICH HAD NOT BEENSTAYED OR OVERTURNED.


Resolution:


Sanction Details: ORDER DENYING REGISTRATION AS A BROKER-DEALER.

Firm Statement ALPINE APPLIED FOR REGISTRATION IN CONNECTICUT (CT), ON 1/7/2005.ALPINE FILED WITHDRAWAL OF APPLICATION ON 10/12/2005 ANDWITHDRAWAL BECAME EFFECTIVE ON 1/10/2006. CT ISSUED NOTICE OFINTENT TO DENY REGISTRATION AND NOTICE OF RIGHT TO HEARING.BELIEVING THE MATTER MOOT SINCE APPLICATION HAD ALREADY BEENWITHDRAWN, ALPINE FAILED TO REQUEST A HEARING AND A POST-WITHDRAWAL ORDER OF DENIAL WAS ISSUED BY CONNECTICUTBECAUSE IT FOUND THAT ALPINE AND ITS PRINCIPAL WERE THE SUBJECTOF NASD SANCTIONS WITHIN THE LAST TEN YEARS.


Order

Disclosure 9 of 41

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Allegations: SEC RULE 17A-3, NASD CONDUCT RULES 2110, 3010, 3110, 3011, 2510(B),3010(A), 3110(B), 3110(C)(3) ALPINE SECURITIES CORPORATION FAILED TOPROPERLY IDENTIFY AND VERIFY PUBLIC CUSTOMERS, PURSUANT TOTHE FIRM'S WRITTEN ANTI-MONEY LAUNDERING (AML) PROCEDURES.THE FIRM EXECUTED ORDERS PLACED BY A PURPORTEDREPRESENTATIVE OF THE CUSTOMERS', WITHOUT RECEIVING PRIORWRITTEN AUTHORIZATION FROM THE CUSTOMERS. THE FIRMINACCURATELY MARKED ORDER TICKETS FOR SELLING SHAREHOLDERSOF A STOCK AS "UNSOLICITED" INSTEAD OF "SOLICITED". MOREOVER,THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLE DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOAPPLICABLE SECURITIES LAWS AND REGULATIONS, AND RULES OF NASD,CONCERNING: BOOKS AND RECORDS, ANTI-MONEY LAUNDERING, ANDDISCRETIONARY TRADING AUTHORITY. THE FIRM'S SUPERVISORYSYSTEM ALSO DID PROVIDE FOR ADEQUATE AND REASONABLESUPERVISION OF ITS PRESIDENT AND CHIEF COMPLIANCE OFFICER. INADDITION, ALPINE SECURITIES FAILED TO ENFORCE THE FIRM'S WRITTENSUPERVISORY PROCEDURES RELATING TO MAKING AND KEEPINGCURRENT BOOKS AND RECORDS, EXERCISING DISCRETIONARY POWERIN CUSTOMERS' ACCOUNTS WITHOUT THE CUSTOMERS PROVIDINGPRIOR WRITTEN AUTHORIZATION TO A STATED INDIVIDUAL, ANDCOMPLYING WITH ANTI-MONEY LAUNDERING LAWS.







Initiated By: NASD






Other Product Type(s): STOCKS

SEC RULE 17A-3, NASD CONDUCT RULES 2110, 3010, 3110, 3011, 2510(B),3010(A), 3110(B), 3110(C)(3) ALPINE SECURITIES CORPORATION FAILED TOPROPERLY IDENTIFY AND VERIFY PUBLIC CUSTOMERS, PURSUANT TOTHE FIRM'S WRITTEN ANTI-MONEY LAUNDERING (AML) PROCEDURES.THE FIRM EXECUTED ORDERS PLACED BY A PURPORTEDREPRESENTATIVE OF THE CUSTOMERS', WITHOUT RECEIVING PRIORWRITTEN AUTHORIZATION FROM THE CUSTOMERS. THE FIRMINACCURATELY MARKED ORDER TICKETS FOR SELLING SHAREHOLDERSOF A STOCK AS "UNSOLICITED" INSTEAD OF "SOLICITED". MOREOVER,THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLE DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOAPPLICABLE SECURITIES LAWS AND REGULATIONS, AND RULES OF NASD,CONCERNING: BOOKS AND RECORDS, ANTI-MONEY LAUNDERING, ANDDISCRETIONARY TRADING AUTHORITY. THE FIRM'S SUPERVISORYSYSTEM ALSO DID PROVIDE FOR ADEQUATE AND REASONABLESUPERVISION OF ITS PRESIDENT AND CHIEF COMPLIANCE OFFICER. INADDITION, ALPINE SECURITIES FAILED TO ENFORCE THE FIRM'S WRITTENSUPERVISORY PROCEDURES RELATING TO MAKING AND KEEPINGCURRENT BOOKS AND RECORDS, EXERCISING DISCRETIONARY POWERIN CUSTOMERS' ACCOUNTS WITHOUT THE CUSTOMERS PROVIDINGPRIOR WRITTEN AUTHORIZATION TO A STATED INDIVIDUAL, ANDCOMPLYING WITH ANTI-MONEY LAUNDERING LAWS.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS ALPINE SECURITIESCORPORATION CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS; THEREFORE THE FIRM IS CENSURED, FINED $22,500,AND CONSENTS TO AN UNDERTAKING TO REVISE ITS WRITTENSUPERVISORY PROCEDURES WITH RESPECT TO COMPLIANCE WITHRESPECT TO APPLICABLE SECURITIES LAWS AND REGULATIONS, ANDRULES OF NASD, CONCERNING: BOOKS AND RECORDS, ANTI-MONEYLAUNDERING, AND DISCRETIONARY TRADING AUTHORITY.


No








Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS ALPINE SECURITIESCORPORATION CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS; THEREFORE THE FIRM IS CENSURED, FINED $22,500,AND CONSENTS TO AN UNDERTAKING TO REVISE ITS WRITTENSUPERVISORY PROCEDURES WITH RESPECT TO COMPLIANCE WITHRESPECT TO APPLICABLE SECURITIES LAWS AND REGULATIONS, ANDRULES OF NASD, CONCERNING: BOOKS AND RECORDS, ANTI-MONEYLAUNDERING, AND DISCRETIONARY TRADING AUTHORITY.


Initiated By: NASD


Undertaking


FINE $22500.00





Allegations: VIOLATIONS OF CONDUCT RULES 2110, 2510, 3010, 3011, 3110 AND SECRULES 17A-3 AND 17A-4. THIS MATTER IS A RESULT OF THE DEPT OFMARKET REGULATIONS EXAMINATION INTO TRADING ACTIVITY OF ALPS INTHE SECURITIES OF KUBLA KHAN, INC.



Resolution:

Other Sanctions Ordered: UNDERTAKING TO REVISE WRITTEN SUPERVISORY PROCEDURES.

Sanction Details: FINE $22,500.00 FOR ALPINE. UNDERTAKING TO REVISE WRITTENSUPERVISORY PROCEDURES AND SUBMIT WITHIN 30 BUSINESS DAYS TOMARKET REGULATION A SIGNED, DATED LETTER PROVIDING (1)REFERENCE TO THIS MATTER (2) REPRESENTATION THAT THE FIRM HASREVISED ITS WRITTEN SUPERVISORY PROCEDURES AND (3) THE DATETHE REVISED PROCEDURES WERE IMPLEMENTED. MR. PETERSON WASSUSPENDED FROM ASSOCIATION WITH ANY NASD MEMBER IN ANYCAPACITY FOR 30 BUSINESS DAYS, AND SUSPENDED FROM ASSOCIATIONWITH ANY NASD MEMBER IN A PRINCIPAL OR SUPERVISORY CAPACITYFOR 60 BUSINESS DAYS. THE SUSPENSIONS BEGAN SEPT. 19, 2005; THESUSPENSION IN ANY CAPACITY WILL CONCLUDE AT THE CLOSE OFBUSINESS OCTOBER 28, 2005. THE FINE TO MR. PETERSON WAS $25,000.

Sanctions Ordered: CensureMonetary/Fine $22,500.00Suspension







FINE $22,500.00 FOR ALPINE. UNDERTAKING TO REVISE WRITTENSUPERVISORY PROCEDURES AND SUBMIT WITHIN 30 BUSINESS DAYS TOMARKET REGULATION A SIGNED, DATED LETTER PROVIDING (1)REFERENCE TO THIS MATTER (2) REPRESENTATION THAT THE FIRM HASREVISED ITS WRITTEN SUPERVISORY PROCEDURES AND (3) THE DATETHE REVISED PROCEDURES WERE IMPLEMENTED. MR. PETERSON WASSUSPENDED FROM ASSOCIATION WITH ANY NASD MEMBER IN ANYCAPACITY FOR 30 BUSINESS DAYS, AND SUSPENDED FROM ASSOCIATIONWITH ANY NASD MEMBER IN A PRINCIPAL OR SUPERVISORY CAPACITYFOR 60 BUSINESS DAYS. THE SUSPENSIONS BEGAN SEPT. 19, 2005; THESUSPENSION IN ANY CAPACITY WILL CONCLUDE AT THE CLOSE OFBUSINESS OCTOBER 28, 2005. THE FINE TO MR. PETERSON WAS $25,000.

Disclosure 10 of 41

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Initiated By: NASD




Docket/Case Number: CLG050041



Allegations: NASD RULES 2110, 6955(A), 3010 - RESPONDENT MEMBER TRANSMITTEDTO OATS REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, ORIMPROPERLY FORMATTED DATA WHICH REPRESENTED NINE PERCENT OFALL REPORTS TRANSMITTED BY THE FIRM DURING THE REVIEW PERIOD;THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOTHE APPICABLE SECURITIES LAWS AND REGULATIONS AND THE RULESOF NASD CONCERNING OATS.



Resolution:

Other Sanctions Ordered: UNDERTAKING: TO REVISE, WITHIN 30 BUSINESS DAYS OF ACCEPTANCEOF THIS AWC, ITS WRITTEN SUPERVISORY PROCEDURES WITH RESPECTTO OATS.


No







https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=CLG050041



Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, ALPINE SECURITIESCORPORATION CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED AND FINED$20,000.


Initiated By: NATIONAL ASSOCIATION OF SECURITY DEALERS


Censure


FINE


Docket/Case Number: CLG050041



Allegations: ALPINE TRANSMITTED TO OATS, VIA THE BLOOMBERG TRADING SYSTEM,REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLYFORMATTED DATA. SPECIFICALLY, THE REPORTS CONTAINEDINACCURATE TIMESTAMPS. ADDITIONALLY, ALPINE'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLESECURITIES LAWS AND REGULATIONS, AND THE RULES OF NASD,CONCERNING OATS.



Resolution:


Sanction Details: $10,000.00 FINE FOR THE OATS VIOLATIONS AND A $10,000.00 FINE FORTHE SUPERVISION VIOLATION







https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=CLG050041


$10,000.00 FINE FOR THE OATS VIOLATIONS AND A $10,000.00 FINE FORTHE SUPERVISION VIOLATION

Disclosure 11 of 41

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Initiated By: NASD




Docket/Case Number: C3A040036



Allegations: NASD CONDUCT RULES 2110 AND 3010 AND NASD MARKETPLACE RULE6130(D)(6) - RESPONDENT MEMBER INACCURATELY REPORTEDCUSTOMER SALES AS SHORT TRANSACTIONS; AND, DID NOT ESTABLISH ASYSTEM OR WRITTEN SUPERVISORY PROCEDURES REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH NASD MARKETPLACE RULE6130(D)(6).



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENTMEMBER CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED$10,000.


No



iReporting Source: 40©2020 FINRA. All rights reserved. Report about ALPINE SECURITIES CORPORATION





Reporting Source: Firm

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS


Censure


FINE OF $10,000.





Allegations: ALPINE INACCURATELY REPORTED 4,348 CUSTOMER SALES AS SHORTTRANSACTIONS CONSTITUTING A VIOLATION OF NASD MARKETPLACERULE 6130(D), APPLICABLE TO REPORTING SHORT SALES.



Resolution:


Sanction Details: ALPINE INNACURATELY REPORTED 4,348 CUSTOMER SALES AS SHORTTRANSACTIONS. ALPINE ALSO DID NOT ESTABLISH A SYSTEM ORWRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TODETECT THIS INNACURACY AND ACHIEVE COMPLIANCE WITH NASDMARKETPLACE RULE 6130(D)(6).



Disclosure 12 of 41

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Allegations: NASD RULES 2110,4632(A),4642(A), 6620,6620(A) - WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTED TOTHE ENTRY OF FINDINGS THAT IT FAILED WITHIN 90 SECONDS AFTEREXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OFTRANSACTIONS IN OTC/OTBB SECURITIES; FAILED WITHIN 90 SECONDSAFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OFTRANSACTIONS IN OTC/OTCBB SECURITIES AND FAILED TO DESIGNATETHROUGH ACT SUCH LAST SALE REPORTS AS LATE;REPORTED TO ACTLAST SALE REPORTS OF TRANSACTIONS IN OTC/OTCBB SECURITIES ONAN "AS OF" BASIS WHEN ELECTRONIC SUBMISSION ON THE TRADE DATEOF SUCH TRANSACTIONS WAS POSSIBLE THROUGH ACT;INCORRECTLYDESIGNATED AS ".SLD" ONE LAST SALE REPORT OF A TRANSACTION IN ANNM SECURITY REPORTED TO ACT WITHIN 90 SECONDS OF EXECUTION;INCORRECTLY DESIGNATED AS ".SLD" LAST SALE REPORTS OFTRANSACTIONS IN SC SECURITIES REPORTED TO ACT WITHIN 90SECONDS OF EXECUTION; INCORRECTLY DESIGNATED AS ".SLD" LASTSALE REPORTS OF TRANSACTIONS IN OTC/OTCBB SECURITIESREPORTED TO ACT WITHIN 90 SECONDS OF EXECUTION; INCORRECTLYDESIGNATED AS ".PRP" THROUGH ACT LAST SALE REPORTS OFTRANSACTIONS IN OTC/OTCBB SECURITIES.







Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.




Docket/Case Number: CMS020099


Other Product Type(s): UNKNOWN TYPE OF SECURITIES

NASD RULES 2110,4632(A),4642(A), 6620,6620(A) - WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTED TOTHE ENTRY OF FINDINGS THAT IT FAILED WITHIN 90 SECONDS AFTEREXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OFTRANSACTIONS IN OTC/OTBB SECURITIES; FAILED WITHIN 90 SECONDSAFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OFTRANSACTIONS IN OTC/OTCBB SECURITIES AND FAILED TO DESIGNATETHROUGH ACT SUCH LAST SALE REPORTS AS LATE;REPORTED TO ACTLAST SALE REPORTS OF TRANSACTIONS IN OTC/OTCBB SECURITIES ONAN "AS OF" BASIS WHEN ELECTRONIC SUBMISSION ON THE TRADE DATEOF SUCH TRANSACTIONS WAS POSSIBLE THROUGH ACT;INCORRECTLYDESIGNATED AS ".SLD" ONE LAST SALE REPORT OF A TRANSACTION IN ANNM SECURITY REPORTED TO ACT WITHIN 90 SECONDS OF EXECUTION;INCORRECTLY DESIGNATED AS ".SLD" LAST SALE REPORTS OFTRANSACTIONS IN SC SECURITIES REPORTED TO ACT WITHIN 90SECONDS OF EXECUTION; INCORRECTLY DESIGNATED AS ".SLD" LASTSALE REPORTS OF TRANSACTIONS IN OTC/OTCBB SECURITIESREPORTED TO ACT WITHIN 90 SECONDS OF EXECUTION; INCORRECTLYDESIGNATED AS ".PRP" THROUGH ACT LAST SALE REPORTS OFTRANSACTIONS IN OTC/OTCBB SECURITIES.


Resolution:


Sanction Details: CENSURED AND FINED $7,500




Allegations: NASD RULES 2110, 4632(A),4642(A),6620,6620(A)-WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, MEMBER CONSENTED TO ENTRY OFFINDINGS THAT IT FAILED WITHIN 90 SECONDS TO TRANSMIT THROUGHACT LAST SALE REPORTS OF TRANSACTIONS IN OTC SECURITIES;FAILEDTO DESIGNATE THROUGH ACT SUCH LAST SALE REPORTS ASLATE;REPORTED TO ACT LAST SALE REPORTS ON AN "AS OF"BASIS WHENELECTRONIC SUBMISSION ON THE TRADE DATE WAS POSSIBLE THROUGHACT;INCORRECTLY DESIGNATED AS ".SLD" ONE LAST SALE REPORT OF ATRANSACTION IN A NNM SECURITY REPORTED TO ACT WITHIN 90SECONDS OF EXECUTION; INCORRECTLY DESIGNATED AS ".SLD" LASTSALE REPORTS OF SECURITIES REPORTED TO ACT WITHIN 90 SECONDSOF EXECUTION;INCORRECTLY DESIGNATED AS ".PRP" THROUGH ACTLAST SALE REPORTS OF TRANSACTIONS IN OTC/OTCBB SECURITIES.







Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS (NASD)


Censure






NASD RULES 2110, 4632(A),4642(A),6620,6620(A)-WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, MEMBER CONSENTED TO ENTRY OFFINDINGS THAT IT FAILED WITHIN 90 SECONDS TO TRANSMIT THROUGHACT LAST SALE REPORTS OF TRANSACTIONS IN OTC SECURITIES;FAILEDTO DESIGNATE THROUGH ACT SUCH LAST SALE REPORTS ASLATE;REPORTED TO ACT LAST SALE REPORTS ON AN "AS OF"BASIS WHENELECTRONIC SUBMISSION ON THE TRADE DATE WAS POSSIBLE THROUGHACT;INCORRECTLY DESIGNATED AS ".SLD" ONE LAST SALE REPORT OF ATRANSACTION IN A NNM SECURITY REPORTED TO ACT WITHIN 90SECONDS OF EXECUTION; INCORRECTLY DESIGNATED AS ".SLD" LASTSALE REPORTS OF SECURITIES REPORTED TO ACT WITHIN 90 SECONDSOF EXECUTION;INCORRECTLY DESIGNATED AS ".PRP" THROUGH ACTLAST SALE REPORTS OF TRANSACTIONS IN OTC/OTCBB SECURITIES.


Resolution:


Sanction Details: CENSURED AND FINED $7500



Disclosure 13 of 41

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Allegations: NASD CONDUCT RULE 2110 AND 3010 - WITHOUT ADMITTING OR DENYINGTHE ALLEGATIONS, THE FIRM CONSENTED TO THE FINDINGS THAT IT'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOTHE APPLICABLE SECURITIES LAWS AND REGULATIONS CONCERNINGANTI-COMPETITIVE BEHAVIOR. SPECIFICALLY, THE FIRM'S SUPERVISORYSYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURESPROVIDING FOR: 1) THE IDENTIFICATION OF THE PERSONS(S)RESPONSBILE AT THE FIRM TO ENSURE COMPLIANCE WITH THEAPPLICABLE RULES; 2) A STATEMENT OF THE STEP(S) THAT SUCHPERSON(S) SHOULD TAKE TO ENSURE COMPLIANCE THEREWITH; 3) ASTATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCHSTEP(S); AND, (4) A STATEMENT AS TO HOW ENFORCEMENT OF SUCHWRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED AS THEFIRM.














NASD CONDUCT RULE 2110 AND 3010 - WITHOUT ADMITTING OR DENYINGTHE ALLEGATIONS, THE FIRM CONSENTED TO THE FINDINGS THAT IT'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOTHE APPLICABLE SECURITIES LAWS AND REGULATIONS CONCERNINGANTI-COMPETITIVE BEHAVIOR. SPECIFICALLY, THE FIRM'S SUPERVISORYSYSTEM DID NOT INCLUDE WRITTEN SUPERVISORY PROCEDURESPROVIDING FOR: 1) THE IDENTIFICATION OF THE PERSONS(S)RESPONSBILE AT THE FIRM TO ENSURE COMPLIANCE WITH THEAPPLICABLE RULES; 2) A STATEMENT OF THE STEP(S) THAT SUCHPERSON(S) SHOULD TAKE TO ENSURE COMPLIANCE THEREWITH; 3) ASTATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCHSTEP(S); AND, (4) A STATEMENT AS TO HOW ENFORCEMENT OF SUCHWRITTEN SUPERVISORY PROCEDURES SHOULD BE DOCUMENTED AS THEFIRM.


Resolution:


Sanction Details: CENSURED AND FINED $5,000.




Initiated By: NASD REGULATION INC






Allegations: CONDUCT RULES 2110 AND 3010. FAILURE TO DISTRIBUTE WRITTENPREOCEDURES CONCERNING ANTI-COMPETITIVE BEHAVIOR.









Resolution:


Sanction Details: $5000.00 FINE SOLELY TO ALPINE.

Firm Statement 3/19/2002 NOTICE OF ACCEPTANCE. PAYMENT MADE.



Disclosure 14 of 41

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Allegations: NASD CONDUCT RULE 2110 AND 3010(B) - WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, THE RESPONDENT CONSENTED TO THEENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH ADEQUATE WRITTENSUPERVISORY PROCEDURES REASONABLY DESIGNED TO DETECT ANDPREVENT THE SALE OF UNREGISTERED SECURITIES BY ASSOCIATEDPERSONS.



Resolution:










Sanction Details: CENSURED AND FINED $10,000, JOINTLY AND SEVERALLY.


Initiated By: NASD







Allegations: NASD CONDUCT RULE 2110 AND 3010(B) - WITHOUT ADMITTING ORDENYING THE ALLEGATIONS, ALPINE, ACTING THROUGH PETERSONFAILED TO ESTABLISH ADEQUATE WRITTEN SUPERVISORY PROCEDURESREASONABLY DESIGNED TO DETECT AND PREVENT THE SALE OFUNREGISTERED SECURITIES BY ASSOCIATED PERSONS.



Resolution:


Sanction Details: FOR WRITTEN SUPERVISORY PROCEDURES ALPINE IN CENSURED ANDFINED $10,000.00, JOINTLY AND SERVERALLY.

Firm Statement 3/19/2002 NOTICE OF ACCEPTANCE. PAYMENT MADE.



Disclosure 15 of 41

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Allegations: THE ALLEGATIONS ARE THAT I EXECUTED AN UNAUTHORIZED TRADE IN ACUSTOMER'S ACCOUNT IN VIOLATION OF ARTICLE III, SECTION I OF THENASD'S RULES OF FAIR PRACTICE. THE PURCHASE TRANSACTION INQUESTION WAS FOR $4,959. HOWEVER, THE CUSTOMER FAILED TO PAYFOR THE PURCHASE OF THE SECURITIES IN HIS ACCOUNT AND NOACTION WAS TAKEN TO COLLECT THE PAYMENT. THEREFORE, THECUSTOMER DID NOT INCUR ANY FINANCIAL DAMAGES.







Initiated By: NASD


Censure






Allegations: THE ALLEGATIONS ARE THAT I EXECUTED AN UNAUTHORIZED TRADE IN ACUSTOMER'S ACCOUNT IN VIOLATION OF ARTICLE III, SECTION I OF THENASD'S RULES OF FAIR PRACTICE. THE PURCHASE TRANSACTION INQUESTION WAS FOR $4,959. HOWEVER, THE CUSTOMER FAILED TO PAYFOR THE PURCHASE OF THE SECURITIES IN HIS ACCOUNT AND NOACTION WAS TAKEN TO COLLECT THE PAYMENT. THEREFORE, THECUSTOMER DID NOT INCUR ANY FINANCIAL DAMAGES.


Resolution:


Sanction Details: ON NOVEMBER 21, 1994 DISTRICT NO. 3 NOTIFIED RESPONDENT CLARKJOHNSTON THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENTNO. C3A940054 WAS ACCEPTED; THEREFORE, HE IS CENSURED ANDFINED $5,000.

Firm Statement PAID 3/28/1995 INVOICE 95-3A-149.


Consent

Disclosure 16 of 41

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Allegations: 07-17-01, SEC RULE 11AC1-1,NASD RULES 2110,3010,3320, 4613(B) -RESPONDENT MEMBER FAILED TO EXECUTE ORDERS PRESENTED TOTHE FIRM AT THE FIRM'S PUBLISHED BID OR OFFER IN AN AMOUNT UP TOITS PUBLISHED QUOTATION SIZE AND THEREBY FAILED TO HONOR ITSPUBLISHED QUOTATION; AND THE FIRM'S SUPERVISORY SYSTEM FAILEDTO PROVIDE FOR SUPERVISION RESONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO APPLICABLE SECURITIES LAWS ANDREGULATIONS CONCERNING FIRM QUOTATIONS.













Other Product Type(s): UNKNOWN TYPE OF SECURITIES

07-17-01, SEC RULE 11AC1-1,NASD RULES 2110,3010,3320, 4613(B) -RESPONDENT MEMBER FAILED TO EXECUTE ORDERS PRESENTED TOTHE FIRM AT THE FIRM'S PUBLISHED BID OR OFFER IN AN AMOUNT UP TOITS PUBLISHED QUOTATION SIZE AND THEREBY FAILED TO HONOR ITSPUBLISHED QUOTATION; AND THE FIRM'S SUPERVISORY SYSTEM FAILEDTO PROVIDE FOR SUPERVISION RESONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO APPLICABLE SECURITIES LAWS ANDREGULATIONS CONCERNING FIRM QUOTATIONS.


Resolution:


Sanction Details: CENSURED, FINED $10,000 AND REQUIRED TO UNDERTAKE TO REVISETHE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TOFIRM QUOTATIONS. ALTHOUGH THE STAFF MAY REVIEW THE REVISEDPROCEDURES, SAID REVIEW SHALL IN NO WAY CONSTITUTE ANAPPROVAL OF THE REVISED PROCEDURES. THE FAILURE OF THE STAFFTO ALERT THE FIRM TO ANY DEFICIENCIES IN THE REVISED PROCEDURESSHALL NOT PRECLUDE THE STAFF FROM INSTITUTING A SUBSEQUENTDISCIPLINARY ACTION AS A RESULT OF DEFICIENCIES IN THE REVISEDPROCEDURES.




Initiated By: NASD REGULATION INC


Censure


Docket/Case Number: CMS-010103-AWC



Allegations: VIOLATION OF NASD CONDUCT RULES 2110 & 3010.








Censure


BACKING AWAY. ORDER TO SUBMIT COPIES OF REVISED PROCEDURESINTENDED TO CORRECT ALLEGED RULE VIOLATIONS WITHIN 30 DAYS OFDATE OF AWC LETTER.


Resolution:

Other Sanctions Ordered: SUMISSION OF REVISED PROCEDURES

Sanction Details: SUBMISSION OF REVISED PROCEDURES WITHIN 30 DAYS OFACCEPTANCE OF THIS AWC BY NAC.

Firm Statement PAYMENT OF $10,000 REMITTED 7/16/2001.COPY OF NEW PROCEDURES SUBMITTED 7/19/2001.



Disclosure 17 of 41

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Initiated By: MISSOURI.


Cease and Desist



Docket/Case Number: AO-87-81




Allegations: ALPINE SECURITIES CORP., AGREED TO OFFER RESCISSION TO ALLMISSOURI RESIDENTS WITH WHOM IT EFFECTED SECURITIESTRANSACTIONS WITHOUT BEING REGISTERED AS A BROKER-DEALER...



Resolution:

Sanctions Ordered: Cease and Desist/Injunction

Consent







Sanction Details: CEASE AND DESIST ORDER.

Regulator Statement 11/25/87-FORM U6 (8109-32787) DISCLOSES: ALPINE SECURITIESCORP., AGREED TO OFFER RESCISSION TO ALL MISSOURI RESIDENTSWITHWHOM IT EFFECTED SECURITIES TRANSACTIONS WITHOUT BEINGREGISTERED AS A BROKER-DEALER. DOCKET/CASE NO. AO-87-81, DATEDNOVEMBER 12, 1987.



Initiated By: STATE OF MISSOURI, SECRETARY OF STATE, DIVISION OF SECURITIES


Cease and Desist



Docket/Case Number: A0-87-81



Allegations: VIOLATIONS OF THE BROKER-DEALER REGISTRATION PROVISION OF THEREVISED STATUTES OF MISSOURI, 1986, AS AMENDED.



Resolution:

Other Sanctions Ordered: A CONSENT ORDER TO CEASE AND DESIST WAS ENTERED WITHOUTADMITTING OR DENYING THE ALLEGATIONS THEREIN WHICH ALSOPROVIDED THAT ALPINE WOULD OFFER RECISSIONS TO ALL MISSOURIRESIDENTS.

Sanction Details: ON DECEMBER 11, 1987, AFTER ALOINE HAD COMPLETED THE REQUIREDRECISSIONS, THE MISSOURI DIVISION OF SECURITIES ENTERED ANDORDER TO VACATING THE CEASE AND DESIST ORDER.


Consent

i50©2020 FINRA. All rights reserved. Report about ALPINE SECURITIES CORPORATION





Disclosure 18 of 41




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



Docket/Case Number: MS-542-AWC



Allegations: LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) ALLEGESVIOLATIONS OF PART VI, SECTION 4(A) OF SCHEDULE D IN THATRESPONDENT FAILED TO REPORT THEIR NASDAQ VOLUME.



Resolution:


Sanction Details: FINE

Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-542-AWC:

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) ALLEGESVIOLATIONS OF PART VI, SECTION 4(A) OF SCHEDULE D IN THATRESPONDENT FAILED TO REPORT THEIR NASDAQ VOLUME. THE AWC WASACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON 10/29/87 ANDTHE NATIONAL BUSINESS CONDUCT COMMITTEE ON 11/23/87. $1,000FINE PAID

Sanctions Ordered: Monetary/Fine $1,000.00



Initiated By: MARKET SURVEILLANCE COMMITTEE

Allegations: VIOLATIONS OF PART IV, SECTION 4(A) OF SCHEDULE D IN THAT ALPINEFAILED TO REPORT ITS NASDAQ VOLUME.















Resolution:


Sanction Details: PAID



Disclosure 19 of 41

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Initiated By: STATE OF NORTH DAKOTA




Docket/Case Number:



Allegations: VIOLATIONS OF THE BROKER-DEALER



Resolution:


Order







Sanction Details: CONSENTED TO THE ORDER


Disclosure 20 of 41

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Initiated By: BANKING COMMISSIONER, DEPT OF BANKING, ST OF CONNECTICUT




Docket/Case Number: FILE NO. 87-05-1279



Allegations: VIOLATIONS OF THE BROKER-DEALER, AGENT, AND SECURITIESREGISTRATION PROVISIONS OF THE CONNICTICUT UNIFORM SECURITIESACT.



Resolution:

Other Sanctions Ordered: PROHIBITS ALPINE FROM APPLYING FOR BROKER-DEALER,REGISTRATION IN THE STATE OF CONNECTICUT FOR A PERIOD FO THREEYEARS. THE ORDER ALSO PROHIBITS PETERSON AND WICKHAM FROMAPPLYING FOR REGISTRATION AS AGENTS IN THE STATE OFCONNECTICUT FOR A PERIOD OF ONE YEAR. ALPINE, PETERSON, ANDWICKHAM CONSENTED TO THE ENTRY OF THE ORDER WITHOUTADMITTING OR DENYING THE ALLEGATIONS SET FORTH THEREIN.



Consent

Disclosure 21 of 41

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Other


FINE OF $1000.00





Allegations: RESPONDENT FIRM: FAILED TO COMPLY WITH THE LIMIT ORDER DISPLAYRULES. SPECIFICALLY, THE FIRM DID NOT UPDATE ITS QUOTE TOREFLECT THE CUSTOMER LIMIT PRICE; DID NOT UPDATE ITS QUOTATIONIN A TIMELY MANNER; AND DID NOT UPDATE ITS QUOTATION SIZE IN ATIMELY MANNER. (NASD CONDUCT RULE 2110 AND SEC RULE 11AC1-4.)



Resolution:


Sanction Details: FINE OF $1,000.00

Regulator Statement 01-11-00, $1,000 PAID ON 9/27/99, INVOICE #99-3A-791




Initiated By: NASD




Allegations: ALLEGED FAILURE TO COMPLY WITH THE LIMIT ORDER DISPLAY RULES.SPECIFICALLY, THE FIRM DID NOT UDPADE IT'S QUOTE TO REFLECT THECUSTOMER LIMIT PRICE; DID NOT UPDATE IT'S QUOTATION IN A TIMELYMANNER; AND DID NOT UPDATE IT'S QUOTATION SIZE IN A TIMELYMANNER. NASD CONDUCT RULE 2110 AND SEC RULE 11AC1-4.








Other





Resolution:


Sanction Details: FINE OF $1,000.

Firm Statement 1-11-2000, $1,000 PAID ON 9/27/1999, INVOICE #99-3A-791.



Disclosure 22 of 41

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Initiated By: ILLINOIS






Principal Product Type:


Allegations:



Resolution:


Sanctions Ordered: Monetary/FineSuspension

Order







Sanction Details:

Regulator Statement 1/21/88-FORMS U6 (8247 thru 8250-01188) DISCLOSES: ALPINESECURITIES CORP.'S REGISTRATION HAS BEEN SUSPENDED FOR APERIODOF 6 MONTHS. IN ADDITION, ALPINE WAS ORDERED TO PAY ANADMINSTRATIVE FINE EQUAL TO PROFITS AND COMMISSIONS EARNEDFROMTHE SALE OF SECURITIES BY AND THROUGH CERTAIN UNREGISTEREDAGENTS. AGENTS, ROSS WHITTIER BOTTOMLY, STEVEN JAY PORTER, ANDNANCY LYNN WICKHAM, EACH HAS AGREED BY MEANS OF A STIPULATION,TO SUSPENSION OF THEIR REGISTRATIONS AS SALESPERSONS INILLINOISFOR A PERIOD OF SIX MONTHS. THE SUSPENSIONS WERE BASED UPONSALES OF SECURITIES WHEN NEITHER THE AGENTS NOR THEIR BROKERDEALER (ALPINE SECURITIES CORP.) WERE REGISTERED IN ILLINOIS.DOCKET/CASE NOS. 87-24; 87-25; AND 87-26; DATED DECEMBER 31,1987. ******************* 9/20/88-AMENDED FORM U6 (8140-25788)DISCLOSES ILLINOIS HAS DETERMINED THAT ALPINE SECURITIES HASCOMPLIED WITH ALL PROVISIONS OF A PRIOR ADMINISTRATIVE ORDER.THE SUSPENSION OF ALPINE'S DEALER REGISTRATION HAS BEENCOMPLETED AND ALPINE IS CURRENTLY DEEMED TO BE REGISTERED INTHESTATE OF ILLINOIS. DOCKET/CASE NO. 87-25, DATED SEPTEMBER 6,1988.


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







Allegations: TRANSACTIONS WITH UNREGISTERED AGENTS








Resolution:

Other Sanctions Ordered: FINES IN COMMISSIONS RECEIVED FROM UNREGISTERED AGENTS.SUSPENDED REGISTRATION FOR 6 MONTH PERIOD.PROHIBITED ALPINE FROM ACTING AS AN UNDERWRITER OR CO-UNDERWRITER IN THE STATE OF ILLINOIS FOR A PERIOD OF ONE YEAR,AND REQUIRED THE FIRM TO MAKE A GRANT OF $10,000 TO THE ILLINOISINVESTOR PROTECTION AND EDUCATION PROGRAM. ALPINE DID NOTADMIT OR DENY ALLEGED VIOLATIONS OF THE AGENT REGISTRATIONPROVISIONS OF THE ILLINOIS SECURITIES LAW.


Sanctions Ordered: Monetary/Fine $10,000.00Suspension

Stipulation and Consent

Disclosure 23 of 41

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Initiated By: IDAHO




Docket/Case Number:




Allegations:



Resolution:


Sanction Details:


Consent






Sanction Details:

Regulator Statement 2/7/89: FORM U6 (8004-1889) DISCLOSES: ALPINE SECURITEIS CORP.WAS ACCUSED OF SELLING SECURITIES IN IDAHO WHEN NOTREGISTEREDAS A BROKER DEALER. ALPINE CONSENTED TO AN AGREEMENT ANDORDERADMITTING VIOLATIONS, OFFERING RECISSION TO IDAHO PURCHASERS,AGREED TO BECOME REGISTERED WITH A 30 DAY SUSPENSION, AND ONEYEAR PROBATION, AND TO CONDUCT ADEQUATE SUPERVISION. ALPINEPAIDA $2,000 FINE AND EACH AGENT PAID A $750 FINE.


Initiated By: STATE OF IDAHO, DEPT OF FINANCE, SECURITIES BUREAU


Other


AGREEMENT TO REGISTER


Docket/Case Number: 1988-7-32



Allegations: VIOLATIONS OF BROKER-DEALER, AGENT, AND SECURITIESREGISTRATION PROVISIONS OF THE IDAHO SECURITIES ACT.



Resolution:

Other Sanctions Ordered: THE TERMS OF THE AGREEMENT AND ORDER REQUIRE THAT ALPINEBECOME REGISTERED AS A BROKER-DEALER WITH THE STATE OF IDAHO.ONCE EFFECTIVE, ALPINE'S REGISTRATION WILL BE SUSPENDED FOR APERIOD OF 30 CALENDAR DAYS AND THEN BE PLACED ON A PROBATIONFOR A PERIOD OF ONE YEAR. ALPINE IS ALSO REQUIRED TO OFFERRECISSION TO IDAHO RESIDENTS WHO PURCHASED SECURITIESTHROUGH ALPINE WHEN IT WAS NOT REGISTERED AS A BROKER-DEALERWITH THE STATE OF IDAHO. FINALLY, ALPINE IS REQUIRED TO COLLECT AFINE OF $750.00 FOR EACH AGENT WHO CONDUCTED SALES IN IDAHO ATA TIME WHEN NEITHER ALPINE NOR THE AGENT WAS REGISTERED WITHTHE STATE OF IDAHO.


Order






THE TERMS OF THE AGREEMENT AND ORDER REQUIRE THAT ALPINEBECOME REGISTERED AS A BROKER-DEALER WITH THE STATE OF IDAHO.ONCE EFFECTIVE, ALPINE'S REGISTRATION WILL BE SUSPENDED FOR APERIOD OF 30 CALENDAR DAYS AND THEN BE PLACED ON A PROBATIONFOR A PERIOD OF ONE YEAR. ALPINE IS ALSO REQUIRED TO OFFERRECISSION TO IDAHO RESIDENTS WHO PURCHASED SECURITIESTHROUGH ALPINE WHEN IT WAS NOT REGISTERED AS A BROKER-DEALERWITH THE STATE OF IDAHO. FINALLY, ALPINE IS REQUIRED TO COLLECT AFINE OF $750.00 FOR EACH AGENT WHO CONDUCTED SALES IN IDAHO ATA TIME WHEN NEITHER ALPINE NOR THE AGENT WAS REGISTERED WITHTHE STATE OF IDAHO.


Disclosure 24 of 41

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Allegations:



Resolution:


Sanction Details:

Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-583-AWC:

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) ALLEGESVIOLATIONS OF PART VI, SECTION 4(a) OF SCHEDULE D IN THATRESPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME. THE AWCWASACCEPTED BY THE MARKET SURVEILLANCE COMMITTEE ON 10/29/87 ANDBY THE NATIONAL BUSINESS CONDUCT COMMITTEE ON 11/23/87. $250FINE PAID

Sanctions Ordered: Monetary/Fine $250.00

Consent

iReporting Source: 59©2020 FINRA. All rights reserved. Report about ALPINE SECURITIES CORPORATION













Allegations: VIOLATIONS OF PART IV, SECTION 49(A) OF SCHEDULE D IN THAT ALPINEFAILED TO REPORT ITS NASDAQ VOLUME.



Resolution:





Disclosure 25 of 41

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Initiated By: VIRGINIA




Docket/Case Number: SEC870075




Allegations:









Resolution:


Sanction Details:

Regulator Statement 11/10/87-FORM U6 (8068-31087) DISCLOSES: VIOLATED VIRGINIACODE SECTION 13.1-504(a) and (b) BY TRANSACTING BUSINESS IN THECOMMONWEALTH OF VIRGINIA WITHOUT BEING REGISTERED AS ABROKER-DEALER UNDER THE PROVISIONS OF THE VIRGINIA SECURITIESACT AND EMPLOYED UNREGISTERED AGENTS. A COMPROMISESETTLEMENTWAS ACCEPTED BY THE STATE CORPORATION COMMISSION WHEREBYALPINESECURITIES CORP. WITHOUT ADMITTING OR DENYING THE ALLEGATIONSWAS PENALIZED $2,000 AND ORDERED NOT TO DIRECTLY OR INDIRECTLYOFFER FOR SALE OR SELL SECURITIES IN THE COMMONWEALTH OFVIRGINIA UNLESS ALPINE SECURITIES CORP. AND ITS AGENTS AREAPPROPRIATELY REGISTERED UNDER THE VIRGINIA SECURITIES ACTUNLESS THE TRANSACTION IS EXEMPTED BY THE VIRGINIA SECURITIESACT. COPY OF JUDGMENT OF COMPROMISE AND SETTLEMENT ISATTACHED. DOCKET/CASE NO. SEC870075, DATED OCTOBER 29, 1987.


Consent


Initiated By: COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION




Docket/Case Number: SEC870075



Allegations: VIOLATIONS OF A BROKER-DEALER AND AGENT REGISTRATIONPROVISIONS OF THE VIRGINIA SECURITIES ACT.









Resolution:


Sanction Details: ALPINE CONSENTED TO THE ENTRY OF THE JUDGEMENT OFCOMPROMISE AND SETTLEMENT WITHOUT ADMITTING OR DENYING THEALLEGATIONS SET FORTH THEREIN.

PAID


Consent

Disclosure 26 of 41

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Allegations:



Resolution:


Sanction Details:

Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-478-AWC, FILED2/5/87:

LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) ALLEGESVIOLATIONS OF PART I, SECTION C.3.(c) OF SCHEDULE D IN THATRESPONDENT (ALPINE SECURITIES CORP) FAILED TO REPORT ITSNASDAQVOLUME. THE AWC WAS ACCEPTED BY THE MARKET SURVEILLANCECOMMITTEE ON 3/19/87 AND BY THE NATIONAL BUSINESS CONDUCTCOMMITTEE ON 7/29/87. $250 FINE

******* NFC #233 - $250.00 FINE PAID $2/24/87 ********


Consent






MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-478-AWC, FILED2/5/87:


******* NFC #233 - $250.00 FINE PAID $2/24/87 ********


Initiated By: NASD







Allegations: VIOLATIONS OF PART I, SECTION C.3.(C) OF SCHEDULE D IN THAT ALPINEFAILED TO REPORT ITS NASDAQ VOLUME.



Resolution:





Disclosure 27 of 41

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Allegations:














Allegations:


Resolution:


Sanction Details:

Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-509-AWC, FILED4/23/87:


********* NFC #280 - $250 FINE PAID 10/6/87 ********


Consent


Initiated By: NASD



Allegations: VIOLATION OF PART 1, SECION C.3.(C) OF SCHEDULE D IN THAT ALPINEFAILED TO REPORT ITS NASDAQ VOLUME.













Resolution:





Disclosure 28 of 41

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Allegations:



Resolution:


Sanction Details:


Consent






Sanction Details:

Regulator Statement ON AUGUST 16, 1995, THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT NO. C3A950034 SUBMITTED BY RESPONDENTS ALPINESECURITIES CORPORATION AND TODD GROSKREUTZ WAS ISSUED;THEREFORE, THEY ARE CENSURED AND FINED $5,000, JOINTLY ANDSEVERALLY - (ARTICLE III, SECTION 1 OF THE RULES OF FAIRPRACTICE - RESPONDENT MEMBER, ACTING THROUGH RESPONDENTGROSKREUTZ, RECEIVED STOCK CERTIFICATES FROM 9 PUBLICCUSTOMERSWHICH WERE REGISTERED IN NAMES OF INDIVIDUALS OR ENTITIESOTHERTHAN THE CUSTOMERS FROM WHOM THEY WERE RECEIVED AND WHICHHADAGGREGATE MARKET VALUES IN EXCESS OF $10,000, BUT FAILED TOMAKE THE REQUIRED INQUIRIES OF THE SECURITIES INFORMATIONCENTER PURSUANT TO SEC RULE 17f-1(d)).

**$5,000.00 J&S PAID ON 9/05/95, INVOICE #95-3A-507**


Initiated By: NASD


Censure






Allegations: RESPONDENT MEMBER, ACTING THROUGH GROSKREUTZ, AS FINANCIALPRINCIPAL, RECEIVED STOCK CERTIFICATES FROM APPROX 9CUSTOMERS WHICH WERE REGISTERED IN NAMES OTHER THAN THECUSTOMER. ALL SIGNATURES WERE GUARANTEED AND IN NEGOTIABLEFORM. HOWEVER, THE VALUES WERE IN EXCESS OF $10,000 AND THEFIRM FAILED TO MAKE THE REQUIRED INQUIRIES OF THE S.I.C. PURSUANTTO SEC RULE 17F-1(D).


Resolution: Acceptance, Waiver & Consent(AWC)







Resolution:


Sanction Details: JOINT AND SEVERAL FINE WITH GROSKREUTZ $5000.00.

Firm Statement FIND PAID 8/24/1995.



Disclosure 29 of 41

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Docket/Case Number: CMS920063-AWC



Allegations:



Resolution:


Sanction Details:

Regulator Statement 6/24/92: MARKET SURVEILLANCE COMMITTEE COMPLAINT #CMS920063-AWC(A) LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED APRIL 7,1992 AGAINST RESPONDENT MEMBER ALPINE SECURITIES CORP.ALLEGINGVIOLATIONS OF PARTS VI, SECTION 5(a) OF SCHEDULE D IN THAT THEFOLLOWING REPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME:

THE LETTER OF ACCEPTANCE, WAVIER AND CONSENT WAS ACCEPTED BYTHE MARKET SURVEILLANCE COMMITTEE ON MAY 8, 1992 AND BY THENATIONAL BUSINESS CONDUCT COMMITTEE ON JUNE 19, 1992. $1,000.00FINE. **$1,000.00 PAID ON 9/1/92 INVOICE #92-MS-763**


Consent






6/24/92: MARKET SURVEILLANCE COMMITTEE COMPLAINT #CMS920063-AWC(A) LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED APRIL 7,1992 AGAINST RESPONDENT MEMBER ALPINE SECURITIES CORP.ALLEGINGVIOLATIONS OF PARTS VI, SECTION 5(a) OF SCHEDULE D IN THAT THEFOLLOWING REPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME:

THE LETTER OF ACCEPTANCE, WAVIER AND CONSENT WAS ACCEPTED BYTHE MARKET SURVEILLANCE COMMITTEE ON MAY 8, 1992 AND BY THENATIONAL BUSINESS CONDUCT COMMITTEE ON JUNE 19, 1992. $1,000.00FINE. **$1,000.00 PAID ON 9/1/92 INVOICE #92-MS-763**


Initiated By: NASD







Allegations: THE LETTER ALLEGED VIOLATIONS OF PART VI, SECTION 5(A) OFSCHEDULE D OF THE ASSOCIATION'S BY-LAWS IN THE ALPINE FAILED TOREPORT ITS NASDAQ VOLUME ON DECEMBER 27, 1991.



Resolution:





Disclosure 30 of 41

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Docket/Case Number: CMS920014 AWC

Allegations:













Resolution:


Sanction Details:

Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #CMS920014 AWC (A)LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED FEBRUARY 11,1992 AGAINST RESPONDENT MEMBER ALPINE SECURITIES CORP.ALLEGINGVIOLATIONS OF PART VI, SECTION 5(a) OF SCHEDULE D IN THAT THEFOLLOWING RESPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME:

THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BYTHE MARKET SURVEILLANCE COMMITTEE ON MARCH 18, 1992 AND BY THENATIONAL BUSINESS CONDUCT COMMITTEE ON APRIL 7, 1992. ***$1,000.00 FINE*** ***$1,000.00 PAID ON 5/5/92 INVOICE #92-MS-398***


Consent


Initiated By: NASD





Allegations: THE LETTER ALLEGES VIOLATIONS OF PART VI, SECTION 5(A) OFSCHEDULE D OF THE ASSOCIATION'S BY-LAWS IN THAT ALPINE FAILED TOREPORT ITS NASDAQ VOLUME ON 10/31/91.











Resolution:





Disclosure 31 of 41

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Allegations:



Resolution:


Sanction Details:

Regulator Statement 3/2/92: MARKET SURVEILLANCE COMMITTEE COMPLAINT# CMS910178AWC:

A LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED DECEMBER 4,1991 AGANIST RESPONDENT MEMBER ALPINE SECURITIES CORPORATIONALLEGING VIOLATIONS OF PART VI, SECTION 5(a) OF SCHEDULE D INTHAT RESPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME:

THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BYTHE MARKET SURVEILLANCE COMMITTEE ON JANUARY 27, 1991 AND BYTHE NATIONAL BUSINESS CONDUCT COMMITTEE ON FEBRUARY 21, 1992. ***750.00 FINE******$750.00 PAID ON 3/17/92 INVOICE #92-MS-244***


Consent






3/2/92: MARKET SURVEILLANCE COMMITTEE COMPLAINT# CMS910178AWC:

A LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED DECEMBER 4,1991 AGANIST RESPONDENT MEMBER ALPINE SECURITIES CORPORATIONALLEGING VIOLATIONS OF PART VI, SECTION 5(a) OF SCHEDULE D INTHAT RESPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME:

THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BYTHE MARKET SURVEILLANCE COMMITTEE ON JANUARY 27, 1991 AND BYTHE NATIONAL BUSINESS CONDUCT COMMITTEE ON FEBRUARY 21, 1992. ***750.00 FINE******$750.00 PAID ON 3/17/92 INVOICE #92-MS-244***


Initiated By: NASD







Allegations: THE LETTER ALLEGED VIOLATIONS OF PART VI, SECTION 5(A) OFSCHEDULE D OF THE ASSOCIATION'S BY-LAWS IN THAT ALPINE FAILED TOREPORT ITS NASDAQ VOLUME ON 7/30/91 AND 9/23/91.



Resolution:





Disclosure 32 of 41

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Allegations:



Resolution:


Sanction Details:

Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-1044-AWC (A)LETTEROF ACCEPTANCE, WAIVER AND CONSENT FILED FEBRUARY 25, 1991AGAINST RESPONDENT MEMBER ALPINE SECURITIES CORPORATIONALLEGING VIOLATIONS OF SECTIONS 2 AND 3 OF SCHEDULE H OF THEASSOCIATION'S BY-LAWS.

THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED ONAPRIL 5, 1991 AND BY THE NATIONAL BUSINESS CONDUCT COMMITTEE ONJUNE 11, 1991. $500.00 FINE. ***$500.00 PAID ON 7/2/91 INVOICE #91-12-723***


Consent


Initiated By: NASD

Allegations: THE LETTER ALLEGES VIOLATIONS OF SCHEDULE H OF THEASSOCIATION'S BY-LAWS PERTAINING TO PRICE AND VOLUME REPORTINGDISCREPANCIES INVOLVING NON-NASDAQ/OTC SECURITIES.







Initiated By: NASD








Resolution:





Disclosure 33 of 41

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Allegations:



Resolution:


Decision







Sanction Details:

Regulator Statement COMPLAINT NO. C3A910060 (DISTRICT NO. 3) FILED JUNE 5, 1991AGAINST RESPONDENTS ALPINE SECURITIES CORPORATION, DOYLE RAYMOUSER AND VIRGIL MARK PETERSON ALLEGING VIOLATIONS OFARTICLEIII, SECTION 1 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENTMEMBER, ACTING THROUGH RESPONDENTS MOUSER AND PETERSON,EXECUTED TRANSACTIONS IN DESIGNATED SECURITIES WITHOUTOBTAINING ALL OF THE REQUIRED INFORMATION AND DETERMINATION OFSUITABILITY IN CONTRAVENTION OF SEC RULE 15c2-6.

DECISION RENDERED AUGUST 9, 1991, WHEREIN RESPONDENTS ARECENSURED AND FINED $1,500, JOINTLY AND SEVERALLY AND ASSESSEDCOSTS OF $564.10, JOINTLY AND SEVERALLY. IF NO FURTHER ACTION,DECISION IS FINAL SEPTEMBER 25, 1991.

SEPTEMBER 25, 1991 - DECISION IS FINAL. ***$2,064.10 PAID ON 10/24/91 INVOICE 91-3A-1137***



Initiated By: DISTRICT 3, NASD







Allegations: VIOLATIONS OF ARTICLE III, SECTION 1 OF THE RULES OF FAIR PRACTICEIN THAT RESPONDENT MEMBER, ACTING THROUGH PETERSON ANDMOUSER, EXECUTED TRANSACTIONS IN DESIGNATED SECURITIESWITHOUT OBTAINING ALL OF THE REQUIRED INFORMATION ANDDETERMINATION OF SUITABILITY REGARDING SEC RULE 15C2-6.









Resolution:


Sanction Details: PAID IN FULL 10/24/1991.

Sanctions Ordered: CensureMonetary/Fine $564.10

Settled

Disclosure 34 of 41

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Initiated By: WI




Docket/Case Number: X-88029(E)




Allegations: OFFER AND SALE OF UNREGISTERED COMMON STOCKBY UNLICENSED BD; EMPLOYING AN UNLICENSED AGENT TO REPRESENTTHEM IN WI



Resolution:


Sanction Details: PROHIBITED FROM OFFERS OR SALES OF UNREGISTEREDSECURITIES IN WI; FROM ACTING AS AN UNLICENSED BROKER-DEALER INWI; AND FROM EMPLOYING AN UNLICENSED AGENT TO REPRESENT THEMINWI.

Sanctions Ordered:

Decision





www.finra.org/brokercheck User GuidancePROHIBITED FROM OFFERS OR SALES OF UNREGISTEREDSECURITIES IN WI; FROM ACTING AS AN UNLICENSED BROKER-DEALER INWI; AND FROM EMPLOYING AN UNLICENSED AGENT TO REPRESENT THEMINWI.

Regulator Statement Not Provided


Initiated By: COMMISSIONER OF SECURITIES, STATE OF WISCONSIN




Docket/Case Number: X-88029 (E)



Allegations: THE STIPULATION ALLEGES VIOLATIONS OF THE BROKER-DEALER, AGENT,AND SECURITIES REGISTRATION PROVISIONS OF THE UNIFORMSECURITIES LAWS OF WISCONSIN ON APRIL 27, 1987.



Resolution:

Other Sanctions Ordered: THE ORDER PROHIBITS ALPINE FROM SELLING SECURITIES IN WISCONSINUNLESS SUCH SECURITIES ARE REGISTERED, FROM TRANSACTINGBUSINESS IN WISCONSIN AS A BROKER-DEALER UNLESS LICENSED ASSUCH, AND EMPLOYING ANY AGENT UNLESS SUCH AGENT IS REGISTEREDIN WISCONSIN AS SUCH OR EXEMPT FROM REGISTRATION.

Sanction Details: ORDER OF PROHIBITION, UNLESS LICENSED

Firm Statement ALPINE STIPULATED TO THE ENTRY OF THE ORDER AND WAIVED ITSRIGHTS TO A HEARING.

Sanctions Ordered:

Stipulation and Consent

Disclosure 35 of 41

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Allegations:











Docket/Case Number: DEN-775-AWC



Allegations:


Resolution:


Sanction Details:

Regulator Statement ON DECEMBER 9, 1988, THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT NO. DEN-775-AWC (DISTRICT NO. 3) SUBMITTED BYRESPONDENTS ALPINE SECURITIES CORPORATION, VIRGIL MARKPETERSON, NANCY L. WICKHAM, STEPHEN J. PORTER, RALPH F. PARSONAND MARLEN V. JOHNSON WAS ACCEPTED; THEREFORE, RESPONDENTMEMBER IS CENSURED AND FINED $1,000; RESPONDENT PETERSON ISCENSURED, FINED $1,000 AND ORDERED TO DISGORGE $36.00;RESPONDENT WICKHAM IS CENSURED, FINED $2,500, ORDERED TODISGORGE $1,000 AND SUSPENDED FROM ASSOCIATION WITH ANYMEMBEROF THE NASD IN ANY CAPACITY FOR FIVE BUSINESS DAYS; RESPONDENTPORTER IS CENSURED, FINED $3,500, ORDERED TO DISGORGE $225, ANDSUSPENDED FROM ASSOCIATION WITH ANY MEMBER OF THE NASD INANYCAPACITY FOR FIVE BUSINESS DAYS; RESPONDENT PARSON ISCENSURED,FINED $2,500, ORDERED TO DISGORGE $840, AND SUSPENDED FROMASSOCIATION WITH ANY MEMBER OF THE NASD IN ANY CAPACITY FORFIVE BUSINESS DAYS; AND, RESPONDENT JOHNSON IS CENSURED, FINED$1,000 AND ORDERED TO DISGORGE $800 - (ARTICLE III, SECTION 1OF THE RULES OF FAIR PRACTICE - ON SEVERAL SEPARATE OCCASIONSAND IN CONTRAVENTION OF THE BOARD OF GOVERNORS FREE-RIDINGANDWITHHOLDING INTERPRETATION, RESPONDENT MEMBER, ACTINGTHROUGHRESPONDENTS PETERSON, WICKHAM, PORTER, PARSON AND JOHNSON,SOLDSHARES OF A NEW ISSUE THAT TRADED AT AN IMMEDIATE PREMIUM INTHE SECONDARY MARKET TO RESTRICTED PERSONS). ****$1,000.00 PAID ON 9/18/90 INVOICE #90-03-1015***


Consent






ON DECEMBER 9, 1988, THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT NO. DEN-775-AWC (DISTRICT NO. 3) SUBMITTED BYRESPONDENTS ALPINE SECURITIES CORPORATION, VIRGIL MARKPETERSON, NANCY L. WICKHAM, STEPHEN J. PORTER, RALPH F. PARSONAND MARLEN V. JOHNSON WAS ACCEPTED; THEREFORE, RESPONDENTMEMBER IS CENSURED AND FINED $1,000; RESPONDENT PETERSON ISCENSURED, FINED $1,000 AND ORDERED TO DISGORGE $36.00;RESPONDENT WICKHAM IS CENSURED, FINED $2,500, ORDERED TODISGORGE $1,000 AND SUSPENDED FROM ASSOCIATION WITH ANYMEMBEROF THE NASD IN ANY CAPACITY FOR FIVE BUSINESS DAYS; RESPONDENTPORTER IS CENSURED, FINED $3,500, ORDERED TO DISGORGE $225, ANDSUSPENDED FROM ASSOCIATION WITH ANY MEMBER OF THE NASD INANYCAPACITY FOR FIVE BUSINESS DAYS; RESPONDENT PARSON ISCENSURED,FINED $2,500, ORDERED TO DISGORGE $840, AND SUSPENDED FROMASSOCIATION WITH ANY MEMBER OF THE NASD IN ANY CAPACITY FORFIVE BUSINESS DAYS; AND, RESPONDENT JOHNSON IS CENSURED, FINED$1,000 AND ORDERED TO DISGORGE $800 - (ARTICLE III, SECTION 1OF THE RULES OF FAIR PRACTICE - ON SEVERAL SEPARATE OCCASIONSAND IN CONTRAVENTION OF THE BOARD OF GOVERNORS FREE-RIDINGANDWITHHOLDING INTERPRETATION, RESPONDENT MEMBER, ACTINGTHROUGHRESPONDENTS PETERSON, WICKHAM, PORTER, PARSON AND JOHNSON,SOLDSHARES OF A NEW ISSUE THAT TRADED AT AN IMMEDIATE PREMIUM INTHE SECONDARY MARKET TO RESTRICTED PERSONS). ****$1,000.00 PAID ON 9/18/90 INVOICE #90-03-1015***


Initiated By: DISTRICT BUSINESS CONDUCT COMMITTEE FOR DISTRICT NO. 3 OF NASD




Docket/Case Number: DEN-775



Allegations: DECEMBER 9, 1988, THE AWC ALLEGES VIOLATIONS OF ARTICLE III,SECTION 1 OF THE ASSOCIATION'S RULES OF FAIR PRACTICE AND THEBOARD OF GOVERNORS' INTERPRETATION REGARDING FREE-RIDING ANDWITHHOLDING.



Resolution:

Other Sanctions Ordered: FINE AGAINST MARK PETERSON




Disclosure 36 of 41

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Allegations:














Allegations:


Resolution:


Sanction Details:

Regulator Statement ON DECEMBER 12, 1989, THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT NO. DEN-895-AWC (DISTRICT NO. 3) SUBMITTED BYRESPONDENTS ALPINE SECURITIES CORPORATION AND VIRGIL MARKPETERSON WAS ACCEPTED; THEREFORE, THEY ARE CENSURED ANDFINED$1,000, JOINTLY AND SEVERALLY - (ARTICLE III, SECTION 1 OF THERULES OF FAIR PRACTICE - IN CONNECTION WITH ITS PARTICIPATION INTHE DISTRIBUTION OF SECURITIES, RESPONDENT MEMBER, ACTINGTHROUGH RESPONDENT PETERSON, FAILED TO PROPERLY ESCROWCUSTOMERFUNDS). ****$1,000.00 J&S PAID ON 2/6/90 INVOICE #90-03-23****


Consent


Allegations: VIOLATIONS OF ARTICLE III, SECTION 1, OF THE ASSOCIATION'S RULES OFFAIR PRACTICE IN THAT THE FIRM ACTING THROUGH PETERSON FAILEDTO PROPERLY ESCROW CUSTOMER FUNDS IN CONNECTION WITH ITSPARITICIPATION IN THE DISTRIBUTION OF SECURITIES OF CORNERSTONECAPITAL CORPORATION AS REQUIRED BY SEC RULE 15C2-4.







Initiated By: DISTRICT BUSINESS CONDUCT COMMITTEE FOR DISTRICT NO.3 OF NASD







VIOLATIONS OF ARTICLE III, SECTION 1, OF THE ASSOCIATION'S RULES OFFAIR PRACTICE IN THAT THE FIRM ACTING THROUGH PETERSON FAILEDTO PROPERLY ESCROW CUSTOMER FUNDS IN CONNECTION WITH ITSPARITICIPATION IN THE DISTRIBUTION OF SECURITIES OF CORNERSTONECAPITAL CORPORATION AS REQUIRED BY SEC RULE 15C2-4.


Resolution:





Disclosure 37 of 41

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Initiated By: NORTH CAROLINA




Docket/Case Number: 89-056-RF




Allegations:


Resolution: Consent80©2020 FINRA. All rights reserved. Report about ALPINE SECURITIES CORPORATION






Resolution:

Regulator Statement *12/14/89 FORM U-6 (8006 31989) DISCLOSES: ALPINE SECURITIESCORPORATION FILED AN APPLICATION TO BECOME A NORTH CAROLINASECURITIES DEALER BUT FAILED TO DISCLOSE A PREVIOUSDISCIPLINARYEVENT. THE RESPONDENT WAS ALLOWED TO WITHDRAW ITSAPPLICATION,WITH PREJUDICE, AND AGREED TO THE STIPULATION THAT IT NOTRE-APPLY FOR A LICENSE FOR TWO YEARS. DOCKET/CASE NO. 89-056-RF,DATED 11/6/89.

Consent


Initiated By: DEPUTY SECURITIES ADMINISTRATOR OF THE NORTH CAROLINA DSSD




Docket/Case Number: 89-056-RF



Allegations: BY AGREEMENT OF BOTH PARTIES, ALPINE SECURITIES APPLICATION TOBECOME WITHDRAWN WITH PREJUDICE, AND ALPINE SECURITIESAGREED NOT TO RE-APPLY IN NORTH CAROLINA FOR A PERIOD OF TWOYEARS FROM OCTOBER 15, 1989.



Resolution: Order

Disclosure 38 of 41

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Allegations:







Initiated By: OKLAHOMA




Docket/Case Number:





Resolution:


Sanction Details:

Regulator Statement 8/29/88-FORMS U6 (8189/8190-23288) DISCLOSE DENIAL OFREGISTRATION OF ALPINE SECURITIES CORPORATION DUE TO PASTDISCIPLINARY HISTORY. NO DOCKET/CASE NUMBER PROVIDED, DATEDAUGUST 11, 1988. (SUPPORTING DOCUMENTS ATTACHED)


Decision


Initiated By: STATE OF OKLAHOMA, ADMINSTRATOR OF THE DEPARTMENT OFSECURITIES


Denial


OF APPLICATION


Docket/Case Number:



Allegations: DENIED APPLICATION DUE TO PAST DISCIPLINARY HISTORY








OF APPLICATION


Resolution: Order

Disclosure 39 of 41

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Allegations:



Resolution:


Sanction Details:

Regulator Statement COMPLAINT NO. DEN-708 FILED AUGUST 5, 1987 BY DISTRICT NO. 3AGAINST RESPONDENTS ALPINE SECURITIES CORPORATION, VEE L.BALLARD, NANCY L. WICKHAM, STPEHEN J. PORTER AND MARKPETERSONALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1 AND 27(a) OF THERULES OF FAIR PRACTICE IN THAT RESPONDENT BALLARD PURCHASED,AND RESPONDENTS PORTER AND WICKHAM EFFECTED THE PURCHASES,SECURITIES WHICH TRADED AT IMMEDIATE PREMIUMS IN THESECONDARYMARKET IN CONTRAVENTION OF THE BOARD OF GOVERNORS'INTERPRETATION WITH RESPECT TO FREE-RIDING AND WITHHOLDING;RESPONDENT BALLARD FAILED TO RESPOND TO THE ASSOCIATION'SREQUESTS FOR INFORMATION MADE PURSUANT TO ARTICLE IV, SECTION5OF THE RULES OF FAIR PRACTICE; AND, RESPONDENTS MEMBER ANDPETERSON FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTENPROCEDURES WHICH WOULD ENABLE THEM TO SUPERVISE PROPERLYTHEACTIVITIES OF RESPONDENTS PORTER AND WICKHAM.DECISION RENDERED MAY 11, 1988, WHEREIN THE OFFER OFSETTLEMENTSUBMITTED BY THE RESPONDENTS WAS ACCEPTED; THEREFORE,RESPONDENTBALLARD IS CENSURED, FINED $5,000.00, ORDERED TO DISGORGE$4,087.00 AND SUSPENDED FROM ASSOCIATION WITH ANY MEMBER OFTHEASSOCIATION IN ANY CAPACITY FOR TEN (10) BUSINESS DAYS,RESPONDENT WICKHAM IS CENSURED, FINED $1,000.00 AND ORDERED TODISGORGE $288.00, RESPONDENT PORTER IS CENSURED, FINED $1,000.00AND ORDERED TO DISGORGE $225.00, AND RESPONDENTS MEMBER ANDPETERSON ARE CENSURED AND FINED $1,000.00, JOINTLY ANDSEVERALLY. ************* $1,000 PAID J&S 8-12-88.


Decision & Order of Offer of Settlement






COMPLAINT NO. DEN-708 FILED AUGUST 5, 1987 BY DISTRICT NO. 3AGAINST RESPONDENTS ALPINE SECURITIES CORPORATION, VEE L.BALLARD, NANCY L. WICKHAM, STPEHEN J. PORTER AND MARKPETERSONALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1 AND 27(a) OF THERULES OF FAIR PRACTICE IN THAT RESPONDENT BALLARD PURCHASED,AND RESPONDENTS PORTER AND WICKHAM EFFECTED THE PURCHASES,SECURITIES WHICH TRADED AT IMMEDIATE PREMIUMS IN THESECONDARYMARKET IN CONTRAVENTION OF THE BOARD OF GOVERNORS'INTERPRETATION WITH RESPECT TO FREE-RIDING AND WITHHOLDING;RESPONDENT BALLARD FAILED TO RESPOND TO THE ASSOCIATION'SREQUESTS FOR INFORMATION MADE PURSUANT TO ARTICLE IV, SECTION5OF THE RULES OF FAIR PRACTICE; AND, RESPONDENTS MEMBER ANDPETERSON FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTENPROCEDURES WHICH WOULD ENABLE THEM TO SUPERVISE PROPERLYTHEACTIVITIES OF RESPONDENTS PORTER AND WICKHAM.DECISION RENDERED MAY 11, 1988, WHEREIN THE OFFER OFSETTLEMENTSUBMITTED BY THE RESPONDENTS WAS ACCEPTED; THEREFORE,RESPONDENTBALLARD IS CENSURED, FINED $5,000.00, ORDERED TO DISGORGE$4,087.00 AND SUSPENDED FROM ASSOCIATION WITH ANY MEMBER OFTHEASSOCIATION IN ANY CAPACITY FOR TEN (10) BUSINESS DAYS,RESPONDENT WICKHAM IS CENSURED, FINED $1,000.00 AND ORDERED TODISGORGE $288.00, RESPONDENT PORTER IS CENSURED, FINED $1,000.00AND ORDERED TO DISGORGE $225.00, AND RESPONDENTS MEMBER ANDPETERSON ARE CENSURED AND FINED $1,000.00, JOINTLY ANDSEVERALLY. ************* $1,000 PAID J&S 8-12-88.


Initiated By: DISTRICT BUSINESS CONDUCT COMMITTEE FOR DISTRICT NO.3, NASD







Allegations: VIOLATIONS OF THE FREE-RIDING AND WITHHOLDING INTERPRETATIONSOF THE NASD'S RULE OF FAIR PRACTICE AND FAILURE TO SUPERVISE.



Resolution: Settled








Sanction Details: PAID. ALPINE SUBMITTED OFFER WITHOUT ADMITTING OR DENYING THEALLEGATIONS SET FORTH THEREIN.


Disclosure 40 of 41

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Allegations:



Resolution:


Sanction Details:

Regulator Statement ON MARCH 3, 1988, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENTNO. DEN-725-AWC (DISTRICT NO. 3) SUBMITTED BY RESPONDENTS ALPINESECURITIES CORP., VIRGIL MARK PETERSON AND LEONARD DEE HALLWASACCEPTED; THEREFORE, THEY ARE FINED $12,000, JOINTLY ANDSEVERALLY, VIRGIL MARK PETERSON IS SUSPENDED FROM ASSOCIATIONWITH ANY MEMBER OF THE ASSOCIATION IN ANY CAPACITY FOR FIVE (5)BUSINESS DAYS AND LEONARD DEE HALL IS SUSPENDED FROMASSOCIATIONWITH ANY MEMBER OF THE ASSOCIATION IN ANY CAPACITY FOR TEN (10)BUSINESS DAYS (ARTICLE III, SECTION 1 OF THE RULES OF FAIRPRACTICE - ALPINE SECURITIES CORP., OPERATING THROUGHRESPONDENTS PETERSON AND HALL, CONDUCTED A SECURITIESBUSINESSWHILE FAILING TO MAINTAIN THE MINIMUM NET CAPITAL REQUIRED; AND,FAILED TO MAINTAIN SUFFICIENT FUNDS IN ITS SPECIAL RESERVE BANKACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERS). ******* $12,000PAID J&S 6-10-88.


Consent






ON MARCH 3, 1988, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENTNO. DEN-725-AWC (DISTRICT NO. 3) SUBMITTED BY RESPONDENTS ALPINESECURITIES CORP., VIRGIL MARK PETERSON AND LEONARD DEE HALLWASACCEPTED; THEREFORE, THEY ARE FINED $12,000, JOINTLY ANDSEVERALLY, VIRGIL MARK PETERSON IS SUSPENDED FROM ASSOCIATIONWITH ANY MEMBER OF THE ASSOCIATION IN ANY CAPACITY FOR FIVE (5)BUSINESS DAYS AND LEONARD DEE HALL IS SUSPENDED FROMASSOCIATIONWITH ANY MEMBER OF THE ASSOCIATION IN ANY CAPACITY FOR TEN (10)BUSINESS DAYS (ARTICLE III, SECTION 1 OF THE RULES OF FAIRPRACTICE - ALPINE SECURITIES CORP., OPERATING THROUGHRESPONDENTS PETERSON AND HALL, CONDUCTED A SECURITIESBUSINESSWHILE FAILING TO MAINTAIN THE MINIMUM NET CAPITAL REQUIRED; AND,FAILED TO MAINTAIN SUFFICIENT FUNDS IN ITS SPECIAL RESERVE BANKACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERS). ******* $12,000PAID J&S 6-10-88.


Initiated By: DISTRICT BUSINESS CONDUCT COMMITTEE FOR DISTRICT NO.3 OF NASD







Allegations: VIOLATIONS OF ARTICLE III, SECTION I OF THE ASSOCIATION'S RULES OFFAIR PRACTICE CONSISTING OF FAILURE TO MAINTAIN THE MINIMUM NETCAPITAL AND FAILURE TO MAINTAIN SUFFICIENT FUNDS IN ITS SPECIALRESERVE BANK ACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERSAS REQUIRED BY THE NET CAPITAL AND CUSTOMER PROTECTION RULESPROMULGATED UNDER THE SECURITES EXCHANGE ACT OF 1934, ASAMENDED.



Resolution:

Other Sanctions Ordered: PETERSON CONSENTED TO A SUSPENSION FROM ASSOCIATIONS WITH AMEMBER FIRM FOR (5) BUSINESS DAYS; AND HALL CONSENTED TO ASUSPENSION FROM ASSOCIATION WITH A MEMBER FIRM FOR TEN (10)BUSINESS DAYS.



Consent






Disclosure 41 of 41

i






Docket/Case Number: MS-102 SC



Allegations:



Resolution:


Sanction Details:

Regulator Statement 1/13/85 - MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-102 SCFILED 4/9/85 ALLEGING "NO VOLUME". EFFECTIVE 4/23/85 ALPINESECURITIES CORPORATION WAS FINED $250.00.


Decision


Initiated By: MARKET SURVELLANCE COMMITTEE


Docket/Case Number: MS-102 SC



Allegations: FAILURE TO ACCURATELY REPORT NASDAQ VOLUME











Resolution:










Regulatory - Pending

This type of disclosure event may include a pending formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulatory agency such as the Securities and ExchangeCommission, foreign financial regulatory body) for alleged violations of investment-related rules or regulations.

Disclosure 1 of 1


Allegations: THE FIRM WAS NAMED A RESPONDENT IN A FINRA COMPLAINT ALLEGINGTHAT IN THE FACE OF SIGNIFICANT AND MOUNTING FINANCIALDIFFICULTIES, IT IMPLEMENTED A SERIES OF EXORBITANT ANDARBITRARY FEES, AND THEN USED THE FEES AS A PRETEXT TO CONVERTITS RETAIL CUSTOMERS' SECURITIES. THE COMPLAINT ALLEGES THATINDEED, THE FEES CAUSED CUSTOMERS TO INCUR SIGNIFICANT DEBITSIN THEIR ACCOUNTS, AT WHICH POINT THE FIRM TOLD ITS CUSTOMERSTHAT IT WOULD LIQUIDATE THEIR SECURITIES OR TRANSFER THEM TOPROPRIETARY ACCOUNTS BELONGING TO THE FIRM IN ORDER TOSATISFY THE DEBITS. IN ONE MONTH, THE FIRM MOVED OVER $950,000 OFCUSTOMER'S SECURITIES TO ITS PROPRIETARY ACCOUNTS IN ORDER TOCOVER THESE DEBITS. ALSO, THE FIRM CONVERTED CUSTOMER'SSECURITIES BY MISAPPROPRIATING EVERY CUSTOMER POSITION VALUEDAT $1,500 OR LESS ON THE GROUNDS THAT SUCH SECURITIES WERE "WORTHLESS." THE FIRM CONVERTED CUSTOMER'S SECURITIES BYDEEMING THOSE SECURITIES "ABANDONED," AND MOVING THEM INTOTHE FIRM ABANDONED SECURITIES ACCOUNTS. THE FIRM TOOK THESEACTIONS INTENTIONALLY AND WITHOUT CUSTOMER AUTHORIZATION. ITWAS NOT ENTITLED TO ANY OF THE CUSTOMER'S FUNDS OR SECURITIESOVER WHICH IT TOOK OWNERSHIP. THE FIRM TOOK CUSTOMER'S FUNDSAND SECURITIES WITH THE INTENT OF DEPRIVING CUSTOMERS OF THEIRACCOUNT ASSETS, AND CUSTOMERS WERE DEPRIVED OF THEIRACCOUNT ASSETS. THE COMPLAINT ALSO ALLEGES THAT BY TAKINGCUSTOMER'S FUNDS AND SECURITIES IN THE MANNERS ALREADYDESCRIBED, THE FIRM USED THEM FOR PURPOSES NOT DIRECTED BYTHE CUSTOMERS AND COMMINGLED THEM WITH NONCUSTOMER'SFUNDS AND SECURITIES. THIS WAS AN IMPROPER USE OF CUSTOMER'SFUNDS AND SECURITIES. THE COMPLAINT FURTHER ALLEGES THAT THEFIRM COMMITTED UNAUTHORIZED TRADING BY THE EXECUTION OF ASECURITIES TRANSACTION IN CUSTOMER'S ACCOUNT WITHOUT FIRSTOBTAINING THE CUSTOMER'S AUTHORIZATION OR CONSENT. THE FIRMMOVED CUSTOMER'S SECURITIES FROM CUSTOMER'S ACCOUNTS TO ITSPROPRIETARY ACCOUNT TO COVER OUTSTANDING DEBITS, SOLEHUNDREDS OF CUSTOMER'S POSITIONS TO ITSELF FOR A PENNY PERPOSITION, AND MOVED CUSTOMER'S SECURITIES TO ITS ABANDONEDSECURITIES ACCOUNTS, WHEN THE CUSTOMERS DID NOT AUTHORIZETHOSE TRANSACTIONS. IN ADDITION, THE COMPLAINT ALLEGES THAT THEFIRM CHARGED UNFAIR PRICES AND COMMISSIONS. WHEN THE FIRMSOLD THE CUSTOMER'S POSITIONS TO ITSELF FOR THE PENNY PERPOSITION, THE PRICE WAS UNFAIR, AND NOT REASONABLY RELATED TOTHE CURRENT MARKET PRICES. MOREOVER, THE COMPLAINT ALLEGESTHAT THE FIRM ASSESSED UNREASONABLE AND DISCRIMINATORY FEESTO CUSTOMERS. THESE INCLUDED A $5,000 MONTHLY FEE THAT THE FIRMCHARGED TO CUSTOMERS, SIMPLY FOR HAVING AN ACCOUNT AT THEFIRM AND ASSESSED THE $5,000 MONTHLY ACCOUNT FEEINCONSISTENTLY. IN ADDITION, THE FIRM CHARGED A $1,500 FEE TOCUSTOMERS FOR CERTIFICATE WITHDRAWALS THAT WASUNREASONABLE, ALONG WITH UNREASONABLE ILLIQUIDITY ANDVOLATILITY FEE. FURTHERMORE, THE COMPLAINT ALLEGES THAT THEFIRM MADE UNAUTHORIZED CAPITAL WITHDRAWALS. THE FIRM DID NOTOBTAIN FINRA'S APPROVAL FOR PAYMENTS THAT EXCEEDED 10 PERCENTOF THE FIRM'S EXCESS NET CAPITAL. THE PURPOSE OF THE PAYMENTSWAS TO WITHDRAW CAPITAL WITHOUT FINRA'S APPROVAL, AS PART OF ACOORDINATED EFFORT TO DISSIPATE FIRM ASSETS. IN TOTAL, THROUGHTHESE PAYMENTS, THE FIRM WITHDREW OVER $2.8 MILLION FROM THEFIRM IN A FOUR-MONTH PERIOD.

Current Status: Pending






Initiated By: FINRA


Cease and Desist




Principal Product Type: Penny Stock(s)

Other Product Type(s): UNSPECIFIED SECURITIES

THE FIRM WAS NAMED A RESPONDENT IN A FINRA COMPLAINT ALLEGINGTHAT IN THE FACE OF SIGNIFICANT AND MOUNTING FINANCIALDIFFICULTIES, IT IMPLEMENTED A SERIES OF EXORBITANT ANDARBITRARY FEES, AND THEN USED THE FEES AS A PRETEXT TO CONVERTITS RETAIL CUSTOMERS' SECURITIES. THE COMPLAINT ALLEGES THATINDEED, THE FEES CAUSED CUSTOMERS TO INCUR SIGNIFICANT DEBITSIN THEIR ACCOUNTS, AT WHICH POINT THE FIRM TOLD ITS CUSTOMERSTHAT IT WOULD LIQUIDATE THEIR SECURITIES OR TRANSFER THEM TOPROPRIETARY ACCOUNTS BELONGING TO THE FIRM IN ORDER TOSATISFY THE DEBITS. IN ONE MONTH, THE FIRM MOVED OVER $950,000 OFCUSTOMER'S SECURITIES TO ITS PROPRIETARY ACCOUNTS IN ORDER TOCOVER THESE DEBITS. ALSO, THE FIRM CONVERTED CUSTOMER'SSECURITIES BY MISAPPROPRIATING EVERY CUSTOMER POSITION VALUEDAT $1,500 OR LESS ON THE GROUNDS THAT SUCH SECURITIES WERE "WORTHLESS." THE FIRM CONVERTED CUSTOMER'S SECURITIES BYDEEMING THOSE SECURITIES "ABANDONED," AND MOVING THEM INTOTHE FIRM ABANDONED SECURITIES ACCOUNTS. THE FIRM TOOK THESEACTIONS INTENTIONALLY AND WITHOUT CUSTOMER AUTHORIZATION. ITWAS NOT ENTITLED TO ANY OF THE CUSTOMER'S FUNDS OR SECURITIESOVER WHICH IT TOOK OWNERSHIP. THE FIRM TOOK CUSTOMER'S FUNDSAND SECURITIES WITH THE INTENT OF DEPRIVING CUSTOMERS OF THEIRACCOUNT ASSETS, AND CUSTOMERS WERE DEPRIVED OF THEIRACCOUNT ASSETS. THE COMPLAINT ALSO ALLEGES THAT BY TAKINGCUSTOMER'S FUNDS AND SECURITIES IN THE MANNERS ALREADYDESCRIBED, THE FIRM USED THEM FOR PURPOSES NOT DIRECTED BYTHE CUSTOMERS AND COMMINGLED THEM WITH NONCUSTOMER'SFUNDS AND SECURITIES. THIS WAS AN IMPROPER USE OF CUSTOMER'SFUNDS AND SECURITIES. THE COMPLAINT FURTHER ALLEGES THAT THEFIRM COMMITTED UNAUTHORIZED TRADING BY THE EXECUTION OF ASECURITIES TRANSACTION IN CUSTOMER'S ACCOUNT WITHOUT FIRSTOBTAINING THE CUSTOMER'S AUTHORIZATION OR CONSENT. THE FIRMMOVED CUSTOMER'S SECURITIES FROM CUSTOMER'S ACCOUNTS TO ITSPROPRIETARY ACCOUNT TO COVER OUTSTANDING DEBITS, SOLEHUNDREDS OF CUSTOMER'S POSITIONS TO ITSELF FOR A PENNY PERPOSITION, AND MOVED CUSTOMER'S SECURITIES TO ITS ABANDONEDSECURITIES ACCOUNTS, WHEN THE CUSTOMERS DID NOT AUTHORIZETHOSE TRANSACTIONS. IN ADDITION, THE COMPLAINT ALLEGES THAT THEFIRM CHARGED UNFAIR PRICES AND COMMISSIONS. WHEN THE FIRMSOLD THE CUSTOMER'S POSITIONS TO ITSELF FOR THE PENNY PERPOSITION, THE PRICE WAS UNFAIR, AND NOT REASONABLY RELATED TOTHE CURRENT MARKET PRICES. MOREOVER, THE COMPLAINT ALLEGESTHAT THE FIRM ASSESSED UNREASONABLE AND DISCRIMINATORY FEESTO CUSTOMERS. THESE INCLUDED A $5,000 MONTHLY FEE THAT THE FIRMCHARGED TO CUSTOMERS, SIMPLY FOR HAVING AN ACCOUNT AT THEFIRM AND ASSESSED THE $5,000 MONTHLY ACCOUNT FEEINCONSISTENTLY. IN ADDITION, THE FIRM CHARGED A $1,500 FEE TOCUSTOMERS FOR CERTIFICATE WITHDRAWALS THAT WASUNREASONABLE, ALONG WITH UNREASONABLE ILLIQUIDITY ANDVOLATILITY FEE. FURTHERMORE, THE COMPLAINT ALLEGES THAT THEFIRM MADE UNAUTHORIZED CAPITAL WITHDRAWALS. THE FIRM DID NOTOBTAIN FINRA'S APPROVAL FOR PAYMENTS THAT EXCEEDED 10 PERCENTOF THE FIRM'S EXCESS NET CAPITAL. THE PURPOSE OF THE PAYMENTSWAS TO WITHDRAW CAPITAL WITHOUT FINRA'S APPROVAL, AS PART OF ACOORDINATED EFFORT TO DISSIPATE FIRM ASSETS. IN TOTAL, THROUGHTHESE PAYMENTS, THE FIRM WITHDREW OVER $2.8 MILLION FROM THEFIRM IN A FOUR-MONTH PERIOD.


Sanction Details: FURTHERMORE, BASED UPON THE PARTIES' CONSENT, FINRA ISSUED ATEMPORARY CEASE AND DESIST CONSENT ORDER. FINRA ORDERED THEFIRM TO CEASE AND DESIST FROM ANY CONDUCT CONSTITUTING ACONVERSION OF CUSTOMER'S FUNDS AND SECURITIES, A MISUSE OFCUSTOMER'S ASSETS, AND THE EFFECTING OF ANY UNAUTHORIZEDTRANSACTIONS IN CUSTOMER'S ACCOUNTS. FURTHER, THE FIRM IS TOCEASE AND DESIST FROM PLACING DEBITS IN CUSTOMER'S ACCOUNTSAND FROM TRANSFERRING CASH FROM CUSTOMER'S ACCOUNTS TOCOVER DEBITS, ALL RESULTING FROM ITS $5,000 MONTHLY ACCOUNTFEE, AND FROM SELLING, JOURNALING, OR OTHERWISE TRANSFERRINGSECURITIES FROM CUSTOMER'S ACCOUNTS TO FIRM-OWNED ACCOUNTSIN ORDER TO SATISFY DEBITS RESULTING FROM ITS $5,000 MONTHLYACCOUNT FEE. THE FIRM IS TO REVERSE THE $5,000 MONTHLY ACCOUNTFEE ASSESSED IN ALL CURRENTLY OPEN CUSTOMER ACCOUNTS. THEFIRM IS TO CEASE AND DESIST FROM SELLING, JOURNALING, OROTHERWISE TRANSFERRING SECURITIES FROM CUSTOMER'S ACCOUNTSON THE GROUND THAT IT HAS DEEMED SUCH SECURITIES "WORTHLESS"OR "ABANDONED", AND FROM CHARGING THE $1,500 RE-CERTIFICATIONFEE. MOREOVER, THE FIRM IS TO CEASE AND DESIST FROM CHARGINGTHE ILLIQUIDITY AND VOLATILITY FEE, EXCEPT THAT IT SHALL BEALLOWED TO CHARGE AN ILLIQUIDITY AND VOLATILITY FEE THAT ISREASONABLE, AND DOES NOT EXCEED $250 PER TRANSACTION, ANDPROVIDE A FULL ACCOUNTING TO FINRA, WITHIN TEN BUSINESS DAYS OFTHE ISSUANCE OF THE ORDER.

Sanctions Ordered:







FURTHERMORE, BASED UPON THE PARTIES' CONSENT, FINRA ISSUED ATEMPORARY CEASE AND DESIST CONSENT ORDER. FINRA ORDERED THEFIRM TO CEASE AND DESIST FROM ANY CONDUCT CONSTITUTING ACONVERSION OF CUSTOMER'S FUNDS AND SECURITIES, A MISUSE OFCUSTOMER'S ASSETS, AND THE EFFECTING OF ANY UNAUTHORIZEDTRANSACTIONS IN CUSTOMER'S ACCOUNTS. FURTHER, THE FIRM IS TOCEASE AND DESIST FROM PLACING DEBITS IN CUSTOMER'S ACCOUNTSAND FROM TRANSFERRING CASH FROM CUSTOMER'S ACCOUNTS TOCOVER DEBITS, ALL RESULTING FROM ITS $5,000 MONTHLY ACCOUNTFEE, AND FROM SELLING, JOURNALING, OR OTHERWISE TRANSFERRINGSECURITIES FROM CUSTOMER'S ACCOUNTS TO FIRM-OWNED ACCOUNTSIN ORDER TO SATISFY DEBITS RESULTING FROM ITS $5,000 MONTHLYACCOUNT FEE. THE FIRM IS TO REVERSE THE $5,000 MONTHLY ACCOUNTFEE ASSESSED IN ALL CURRENTLY OPEN CUSTOMER ACCOUNTS. THEFIRM IS TO CEASE AND DESIST FROM SELLING, JOURNALING, OROTHERWISE TRANSFERRING SECURITIES FROM CUSTOMER'S ACCOUNTSON THE GROUND THAT IT HAS DEEMED SUCH SECURITIES "WORTHLESS"OR "ABANDONED", AND FROM CHARGING THE $1,500 RE-CERTIFICATIONFEE. MOREOVER, THE FIRM IS TO CEASE AND DESIST FROM CHARGINGTHE ILLIQUIDITY AND VOLATILITY FEE, EXCEPT THAT IT SHALL BEALLOWED TO CHARGE AN ILLIQUIDITY AND VOLATILITY FEE THAT ISREASONABLE, AND DOES NOT EXCEED $250 PER TRANSACTION, ANDPROVIDE A FULL ACCOUNTING TO FINRA, WITHIN TEN BUSINESS DAYS OFTHE ISSUANCE OF THE ORDER.

Regulator Statement ASSOCIATED CASE NUMBER TCDO190001-


Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY


Cease and Desist


IN CONNECTION WITH THE COMPLAINT FOR THE SUBJECT DISCIPLINARYPROCEEDING, FINRA ISSUED TO APPLICANT A NOTICE OF INITIATION OFPROCEEDING SEEKING A TEMPORARY CEASE AND DESIST ORDERPURSUANT TO FINRA RULE 9810.





Allegations: FINRA ALLEGES THAT CERTAIN FEES IMPOSED BY ALPINE AREUNREASONABLE, CLAIMS THAT IMPOSITION OF THOSE FEESCONSTITUTES "CONVERSION," OBJECTS TO THE PROCESS EMPLOYED BYTHE FIRM TO IDENTIFY AND TO CLOSE ACCOUNTS HOLDING "WORTHLESS" SECURITIES, AND CLAIMS THAT TRANSFER OF CERTAINSECURITIES IDENTIFIED BY THE FIRM AS "WORTHLESS" CONSTITUTESUNAUTHORIZED TRADING. FINRA ALSO CLAIMS THAT CERTAIN PAYMENTSMADE BY ALPINE PURSUANT TO ITS LEASE, AND PURSUANT TO AFINANCING AGREEMENT, CONSTITUTED UNAPPROVED CAPITALWITHDRAWALS.

Current Status: Pending







IN CONNECTION WITH THE COMPLAINT FOR THE SUBJECT DISCIPLINARYPROCEEDING, FINRA ISSUED TO APPLICANT A NOTICE OF INITIATION OFPROCEEDING SEEKING A TEMPORARY CEASE AND DESIST ORDERPURSUANT TO FINRA RULE 9810.

Firm Statement THE MATTER WAS FILED ON OR ABOUT JULY 25, 2019, AND IS CURRENTLYSCHEDULED TO PROCEED TO A HEARING ON AUGUST 9, 2019 ANDAUGUST 10, 2019 IN RELATION TO FINRA'S APPLICATION FOR ATEMPORARY CEASE AND DESIST ORDER.






Civil - On Appeal

This type of disclosure event involves an injunction issued by a court within the last 10 years in connection withinvestment-related activity that is currently on appeal, or a finding by a court of a violation of any investment-relatedstatute or regulation that is currently on appeal.

Disclosure 1 of 1


SEC LITIGATION RELEASE NO. 23853 / JUNE 5, 2017:THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION"), FOR ITS COMPLAINT AGAINST DEFENDANT ALPINESECURITIES CORPORATION ("ALPINE"), ALLEGES THAT CASE CONCERNSALPINE'S PRACTICES RELATING TO FILING SUSPICIOUS ACTIVITYREPORTS ("SARS") WITH THE U.S. TREASURY DEPARTMENT'S FINANCIALCRIMES ENFORCEMENT NETWORK ("FINCEN"). ALPINE ACTS AS ACLEARING FIRM FOR MANY MICROCAP OVER-THE-COUNTER ("OTC")STOCK TRANSACTIONS. SINCE 2011, ALPINE HAS CLEARED THOUSANDSOF DEPOSITS OF MICROCAP SECURITIES, MOST OF THEM INVOLVINGSCOTTSDALE CAPITAL ADVISORS CORP. ("SCOTTSDALE") AS THEINTRODUCING BROKER, AND MANY OF WHICH WERE USED AS PART OFVARIOUS STOCK MANIPULATION AND OTHER SCHEMES.THE BANK SECRECY ACT AND ITS IMPLEMENTING REGULATIONS REQUIREBROKER-DEALERS TO FILE SARS WITH FINCEN TO REPORT CERTAINSUSPICIOUS TRANSACTIONS CONDUCTED BY, AT, OR THROUGH THEIRFIRMS. THE INSTRUCTIONS TO FINCEN'S SAR FORM GENERALLY REQUIREBROKER-DEALERS TO SUBMIT SARS WITH NARRATIVES THAT DESCRIBEWHAT IS UNUSUAL, IRREGULAR, OR SUSPICIOUS ABOUT THETRANSACTIONS. FINCEN'S REGULATIONS FURTHER IMPOSE DEADLINESFOR FILING SARS AND IMPOSE RECORD KEEPING REQUIREMENTSRELATED TO BROKER-DEALER SAR FILINGS. SECTION 17(A) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-8THEREUNDER REQUIRE BROKER-DEALERS TO COMPLY WITH THERECORDKEEPING, RETENTION, AND REPORTING OBLIGATIONS OF THEBSA AND ITS IMPLEMENTING REGULATIONS.ALPINE HAD A BSA COMPLIANCE PROGRAM THAT INCLUDED, AMONGOTHER THINGS, WRITTEN SUPERVISORY PROCEDURES ("WSPS") ANDFORMAL AND INFORMAL TRAINING. FROM AT LEAST MAY 17, 2011THROUGH DECEMBER 31, 2015 (THE "RELEVANT PERIOD"), ALPINE'S BSACOMPLIANCE PROGRAM DID NOT ACCURATELY REPRESENT WHAT ALPINEDID IN PRACTICE. AS IMPLEMENTED IN PRACTICE, ALPINE'S POLICIES ANDPROCEDURES DID NOT RESULT IN THE FILING OF SARS IN THE MANNERREQUIRED BY THE BSA AND BY ALPINE'S BSA COMPLIANCE PROGRAM.ALPINE ROUTINELY AND SYSTEMATICALLY FAILED TO IDENTIFY ANDREPORT SUSPICIOUS ACTIVITY IN ITS SAR FILINGS OF WHICH IT WASAWARE.ALPINE'S FAILURE TO MEANINGFULLY IMPLEMENT ITS BSA COMPLIANCEPROGRAM AND FILE SARS AS REQUIRED BY THE RULES IMPLEMENTINGTHE BSA AND ITS OWN BSA COMPLIANCE PROGRAM UNDERMINED THEPURPOSES OF THE BSA AND DEPRIVED U.S. REGULATORS AND LAWENFORCEMENT OF KEY FINANCIAL INTELLIGENCE. A PROPERLYDESIGNED AND IMPLEMENTED BSA COMPLIANCE PROGRAM MAKES ITDIFFICULT FOR ILLICIT ACTORS TO OPERATE THROUGH LEGITIMATEFINANCIAL INSTITUTIONS WITHOUT DETECTION BY BRINGING SUSPICIOUSACTIVITY TO LIGHT. HOWEVER, BY FAILING TO FILE SARS WHENREQUIRED, AND OMITTING MATERIAL INDICIA OF SUSPICIOUS ACTIVITYFROM THE SARS IT DID FILE, ALPINE'S DEFICIENT IMPLEMENTATION OFITS BSA COMPLIANCE PROGRAM AND RESULTING DEFICIENT SAR FILINGSFACILITATED ILLICIT ACTORS' EVASION OF SCRUTINY BY U.S.REGULATORS AND LAW ENFORCEMENT, AND PROVIDED THEM WITHACCESS TO THE MARKETS THEY MIGHT OTHERWISE HAVE BEEN DENIED.ALPINE'S WRITTEN BSA COMPLIANCE PROGRAM DID NOT ACCURATELYREFLECT WHAT THE FIRM DID IN PRACTICE. ALPINE'S DAY TO DAY BSACOMPLIANCE PROGRAM OPERATION FELL SHORT OF WHAT WASACTUALLY PRESCRIBED BY ITS POLICIES AND PROCEDURES. AS ARESULT, ALPINE ROUTINELY FAILED TO IDENTIFY AND REPORTSUSPICIOUS ACTIVITY AS REQUIRED BY SECTION 17(A) OF THEEXCHANGE ACT AND RULE 17A-8 THEREUNDER, AND ITS OWN BSACOMPLIANCE PROGRAM.

Allegations:

Current Status: On Appeal

Appellate Court Name andDate Appeal Filed:

APPEALED FILED ON OCT. 10, 2019, TO THE UNITED STATES COURT OFAPPEALS FOR THE SECOND CIRCUIT AND THE COURT ORDER DONE ONOCT. 18, 2019. A TEMPORARY STAY OF THE JUDGMENT -






Initiated By: THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Relief Sought: Injunction

Other Relief Sought: CIVIL MONEY PENALTIES

Date Court Action Filed: 06/05/2017


Other Product Types:

Court Details: UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEWYORK, CASE NO. 7:17-CV-4179

SEC LITIGATION RELEASE NO. 23853 / JUNE 5, 2017:THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION"), FOR ITS COMPLAINT AGAINST DEFENDANT ALPINESECURITIES CORPORATION ("ALPINE"), ALLEGES THAT CASE CONCERNSALPINE'S PRACTICES RELATING TO FILING SUSPICIOUS ACTIVITYREPORTS ("SARS") WITH THE U.S. TREASURY DEPARTMENT'S FINANCIALCRIMES ENFORCEMENT NETWORK ("FINCEN"). ALPINE ACTS AS ACLEARING FIRM FOR MANY MICROCAP OVER-THE-COUNTER ("OTC")STOCK TRANSACTIONS. SINCE 2011, ALPINE HAS CLEARED THOUSANDSOF DEPOSITS OF MICROCAP SECURITIES, MOST OF THEM INVOLVINGSCOTTSDALE CAPITAL ADVISORS CORP. ("SCOTTSDALE") AS THEINTRODUCING BROKER, AND MANY OF WHICH WERE USED AS PART OFVARIOUS STOCK MANIPULATION AND OTHER SCHEMES.THE BANK SECRECY ACT AND ITS IMPLEMENTING REGULATIONS REQUIREBROKER-DEALERS TO FILE SARS WITH FINCEN TO REPORT CERTAINSUSPICIOUS TRANSACTIONS CONDUCTED BY, AT, OR THROUGH THEIRFIRMS. THE INSTRUCTIONS TO FINCEN'S SAR FORM GENERALLY REQUIREBROKER-DEALERS TO SUBMIT SARS WITH NARRATIVES THAT DESCRIBEWHAT IS UNUSUAL, IRREGULAR, OR SUSPICIOUS ABOUT THETRANSACTIONS. FINCEN'S REGULATIONS FURTHER IMPOSE DEADLINESFOR FILING SARS AND IMPOSE RECORD KEEPING REQUIREMENTSRELATED TO BROKER-DEALER SAR FILINGS. SECTION 17(A) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND RULE 17A-8THEREUNDER REQUIRE BROKER-DEALERS TO COMPLY WITH THERECORDKEEPING, RETENTION, AND REPORTING OBLIGATIONS OF THEBSA AND ITS IMPLEMENTING REGULATIONS.ALPINE HAD A BSA COMPLIANCE PROGRAM THAT INCLUDED, AMONGOTHER THINGS, WRITTEN SUPERVISORY PROCEDURES ("WSPS") ANDFORMAL AND INFORMAL TRAINING. FROM AT LEAST MAY 17, 2011THROUGH DECEMBER 31, 2015 (THE "RELEVANT PERIOD"), ALPINE'S BSACOMPLIANCE PROGRAM DID NOT ACCURATELY REPRESENT WHAT ALPINEDID IN PRACTICE. AS IMPLEMENTED IN PRACTICE, ALPINE'S POLICIES ANDPROCEDURES DID NOT RESULT IN THE FILING OF SARS IN THE MANNERREQUIRED BY THE BSA AND BY ALPINE'S BSA COMPLIANCE PROGRAM.ALPINE ROUTINELY AND SYSTEMATICALLY FAILED TO IDENTIFY ANDREPORT SUSPICIOUS ACTIVITY IN ITS SAR FILINGS OF WHICH IT WASAWARE.ALPINE'S FAILURE TO MEANINGFULLY IMPLEMENT ITS BSA COMPLIANCEPROGRAM AND FILE SARS AS REQUIRED BY THE RULES IMPLEMENTINGTHE BSA AND ITS OWN BSA COMPLIANCE PROGRAM UNDERMINED THEPURPOSES OF THE BSA AND DEPRIVED U.S. REGULATORS AND LAWENFORCEMENT OF KEY FINANCIAL INTELLIGENCE. A PROPERLYDESIGNED AND IMPLEMENTED BSA COMPLIANCE PROGRAM MAKES ITDIFFICULT FOR ILLICIT ACTORS TO OPERATE THROUGH LEGITIMATEFINANCIAL INSTITUTIONS WITHOUT DETECTION BY BRINGING SUSPICIOUSACTIVITY TO LIGHT. HOWEVER, BY FAILING TO FILE SARS WHENREQUIRED, AND OMITTING MATERIAL INDICIA OF SUSPICIOUS ACTIVITYFROM THE SARS IT DID FILE, ALPINE'S DEFICIENT IMPLEMENTATION OFITS BSA COMPLIANCE PROGRAM AND RESULTING DEFICIENT SAR FILINGSFACILITATED ILLICIT ACTORS' EVASION OF SCRUTINY BY U.S.REGULATORS AND LAW ENFORCEMENT, AND PROVIDED THEM WITHACCESS TO THE MARKETS THEY MIGHT OTHERWISE HAVE BEEN DENIED.ALPINE'S WRITTEN BSA COMPLIANCE PROGRAM DID NOT ACCURATELYREFLECT WHAT THE FIRM DID IN PRACTICE. ALPINE'S DAY TO DAY BSACOMPLIANCE PROGRAM OPERATION FELL SHORT OF WHAT WASACTUALLY PRESCRIBED BY ITS POLICIES AND PROCEDURES. AS ARESULT, ALPINE ROUTINELY FAILED TO IDENTIFY AND REPORTSUSPICIOUS ACTIVITY AS REQUIRED BY SECTION 17(A) OF THEEXCHANGE ACT AND RULE 17A-8 THEREUNDER, AND ITS OWN BSACOMPLIANCE PROGRAM.

Resolution: Other


Sanctions Ordered or ReliefGranted:






Other Sanctions:

Sanction Details:

Regulator Statement DECEMBER 11, 2018: OPINION & ORDER BY THE COURT. THE SEC HASMOVED FOR SUMMARY JUDGMENT AS TO LIABILITY ON THOUSANDS OFVIOLATIONS OF RULE 17A-8. FOR THE REASONS THAT FOLLOW, THE SEC'SMOTION IS GRANTED IN PART. ACCORDINGLY, THE SEC'S JULY 13, 2018MOTION FOR SUMMARY JUDGMENT IS GRANTED IN PART. THE SEC HASSHOWN AS A MATTER OF LAW THAT ALPINE VIOLATED RULE 17A-8 OF THEEXCHANGE ACT REPEATEDLY BY FILING REQUIRED SARS WITH DEFICIENTNARRATIVES, FAILING TO FILE SARS FOR GROUPS OF SUSPICIOUSLIQUIDATION TRANSACTIONS, AND FAILING TO MAINTAIN AND PRODUCESAR SUPPORT FILES.SEPTEMBER 12, 2019: OPINION & ORDER BY THE COURT. PLAINTIFFUNITED STATES SECURITIES AND EXCHANGE COMMISSION ("SEC") SEEKSAN INJUNCTION AND IMPOSITION OF $22,736,000 IN CIVIL PENALTIESAGAINST DEFENDANT ALPINE SECURITIES CORPORATION ("ALPINE") FORALPINE'S 2,720 VIOLATIONS OF ITS OBLIGATION TO FILE SUSPICIOUSACTIVITY REPORTS ("SARS"). ALPINE OPPOSES IMPOSITION OF ANYINJUNCTION AND CONTENDS THAT THE CIVIL PENALTIES SHOULD NOTEXCEED $720,000. ACCORDINGLY, THE SEC'S MAY 3 MOTION FORREMEDIES IS GRANTED IN PART. ALPINE SHALL PAY A CIVIL PENALTY FOR$12,000,000. AN INJUNCTION WILL BE ENTERED AGAINST ALPINE.FINAL JUDGMENT, OCTOBER 9, 2019, BY THE COURT. THE COURT, HAVINGENTERED OPINIONS AND ORDERS FINDING THAT ALPINE SECURITIESCORPORATION ("DEFENDANT") VIOLATED SECTION 17 OF THE SECURITIESEXCHANGE ACT OF 1934 AND RULE 17A-8, AND ON SEPTEMBER 12, 2019,HAVING ORDERED THAT A PERMANENT INJUNCTION WILL BE ENTEREDAGAINST DEFENDANT AND THAT DEFENDANT SHALL PAY A CIVIL PENALTYFOR $12,000,000:IT IS ORDERED THAT DEFENDANT IS PERMANENTLY RESTRAINED ANDENJOINED FROM VIOLATING SECTION 17 OF THE EXCHANGE ACT ANDRULE 17A-8, BY ACTING AS A REGISTERED BROKER OR DEALER WHO ISSUBJECT TO THE REQUIREMENTS OF THE CURRENCY AND FOREIGNTRANSACTIONS REPORTING ACT OF 1970 AND FAILING TO COMPLY WITHTHE REPORTING, RECORDKEEPING AND RECORD RETENTIONREQUIREMENTS OF CHAPTER X OF TITLE 31 OF THE CODE OF FEDERALREGULATIONS. DEFENDANT IS PERMANENTLY RESTRAINED ANDENJOINED FROM FAILING TO, WHERE CHAPTER X OF TITLE 31 OF THECODE OF FEDERAL REGULATIONS AND 240.17A-4 REQUIRE THE SAMERECORDS OR REPORTS TO BE PRESERVED FOR DIFFERENT PERIODS,PRESERVING SUCH RECORDS OR REPORTS FOR THE LONGER PERIOD.DEFENDANT SHALL PAY A CIVIL PENALTY FOR $12,000,000. DEFENDANTSHALL MAKE THIS PAYMENT WITHIN 30 DAYS AFTER ENTRY OF THIS FINALJUDGMENT.

ASSOCIATED DOCKET NUMBER IS 1:17-CV-4179-

ON OCTOBER 10, 2019, THE FIRM APPEALED THE ACTION TO THE UNITEDSTATES COURT OF APPEALS FOR THE SECOND CIRCUIT.OCTOBER 18, 2019: USCA CASE NUMBER 19-3272. APPELLANT ALPINESECURITIES CORPORATION MOVES FOR A STAY OF THE DISTRICTCOURT'S JUDGMENT PENDING THE OUTCOME OF THIS APPEAL. IT ISHEREBY ORDERED THAT A TEMPORARY STAY OF THE JUDGMENT ISGRANTED PENDING THE EXPEDITED DETERMINATION OF APPELLANT'SMOTION FOR A STAY PENDING APPEAL BY A THREE-JUDGE MOTIONSPANEL.






DECEMBER 11, 2018: OPINION & ORDER BY THE COURT. THE SEC HASMOVED FOR SUMMARY JUDGMENT AS TO LIABILITY ON THOUSANDS OFVIOLATIONS OF RULE 17A-8. FOR THE REASONS THAT FOLLOW, THE SEC'SMOTION IS GRANTED IN PART. ACCORDINGLY, THE SEC'S JULY 13, 2018MOTION FOR SUMMARY JUDGMENT IS GRANTED IN PART. THE SEC HASSHOWN AS A MATTER OF LAW THAT ALPINE VIOLATED RULE 17A-8 OF THEEXCHANGE ACT REPEATEDLY BY FILING REQUIRED SARS WITH DEFICIENTNARRATIVES, FAILING TO FILE SARS FOR GROUPS OF SUSPICIOUSLIQUIDATION TRANSACTIONS, AND FAILING TO MAINTAIN AND PRODUCESAR SUPPORT FILES.SEPTEMBER 12, 2019: OPINION & ORDER BY THE COURT. PLAINTIFFUNITED STATES SECURITIES AND EXCHANGE COMMISSION ("SEC") SEEKSAN INJUNCTION AND IMPOSITION OF $22,736,000 IN CIVIL PENALTIESAGAINST DEFENDANT ALPINE SECURITIES CORPORATION ("ALPINE") FORALPINE'S 2,720 VIOLATIONS OF ITS OBLIGATION TO FILE SUSPICIOUSACTIVITY REPORTS ("SARS"). ALPINE OPPOSES IMPOSITION OF ANYINJUNCTION AND CONTENDS THAT THE CIVIL PENALTIES SHOULD NOTEXCEED $720,000. ACCORDINGLY, THE SEC'S MAY 3 MOTION FORREMEDIES IS GRANTED IN PART. ALPINE SHALL PAY A CIVIL PENALTY FOR$12,000,000. AN INJUNCTION WILL BE ENTERED AGAINST ALPINE.FINAL JUDGMENT, OCTOBER 9, 2019, BY THE COURT. THE COURT, HAVINGENTERED OPINIONS AND ORDERS FINDING THAT ALPINE SECURITIESCORPORATION ("DEFENDANT") VIOLATED SECTION 17 OF THE SECURITIESEXCHANGE ACT OF 1934 AND RULE 17A-8, AND ON SEPTEMBER 12, 2019,HAVING ORDERED THAT A PERMANENT INJUNCTION WILL BE ENTEREDAGAINST DEFENDANT AND THAT DEFENDANT SHALL PAY A CIVIL PENALTYFOR $12,000,000:IT IS ORDERED THAT DEFENDANT IS PERMANENTLY RESTRAINED ANDENJOINED FROM VIOLATING SECTION 17 OF THE EXCHANGE ACT ANDRULE 17A-8, BY ACTING AS A REGISTERED BROKER OR DEALER WHO ISSUBJECT TO THE REQUIREMENTS OF THE CURRENCY AND FOREIGNTRANSACTIONS REPORTING ACT OF 1970 AND FAILING TO COMPLY WITHTHE REPORTING, RECORDKEEPING AND RECORD RETENTIONREQUIREMENTS OF CHAPTER X OF TITLE 31 OF THE CODE OF FEDERALREGULATIONS. DEFENDANT IS PERMANENTLY RESTRAINED ANDENJOINED FROM FAILING TO, WHERE CHAPTER X OF TITLE 31 OF THECODE OF FEDERAL REGULATIONS AND 240.17A-4 REQUIRE THE SAMERECORDS OR REPORTS TO BE PRESERVED FOR DIFFERENT PERIODS,PRESERVING SUCH RECORDS OR REPORTS FOR THE LONGER PERIOD.DEFENDANT SHALL PAY A CIVIL PENALTY FOR $12,000,000. DEFENDANTSHALL MAKE THIS PAYMENT WITHIN 30 DAYS AFTER ENTRY OF THIS FINALJUDGMENT.

ASSOCIATED DOCKET NUMBER IS 1:17-CV-4179-

ON OCTOBER 10, 2019, THE FIRM APPEALED THE ACTION TO THE UNITEDSTATES COURT OF APPEALS FOR THE SECOND CIRCUIT.OCTOBER 18, 2019: USCA CASE NUMBER 19-3272. APPELLANT ALPINESECURITIES CORPORATION MOVES FOR A STAY OF THE DISTRICTCOURT'S JUDGMENT PENDING THE OUTCOME OF THIS APPEAL. IT ISHEREBY ORDERED THAT A TEMPORARY STAY OF THE JUDGMENT ISGRANTED PENDING THE EXPEDITED DETERMINATION OF APPELLANT'SMOTION FOR A STAY PENDING APPEAL BY A THREE-JUDGE MOTIONSPANEL.


Initiated By: US SECURITIES AND EXCHANGE COMMISSION

Relief Sought: Cease and Desist

Other Relief Sought: UNSPECIFIED CIVIL DAMAGES IN ADDITION TO THE CEASE AND DESIST.

Date Court Action Filed: 06/05/2017


Other Product Types:

Court Details: UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEWYORK, CIVIL ACTION NO. 7:17-CV-4179

THE COMPLAINT ALLEGES ALPINE VIOLATED SECTION 17(A) OF THESECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-8 THEREUNDER FORFAILURE TO COMPLY WITH THE RECORD KEEPING, RETENTION, ANDREPORTING OBLIGATIONS OF THE BANK SECRECY ACT AND ITSIMPLEMENTING REGULATIONS.

Allegations:

Current Status: On Appeal

Appellate Court Name andDate Appeal Filed:

2ND DISTRICT COURT OF APPEAL. 10/10/2019

Resolution: Judgment Rendered


Other Sanctions:

Sanction Details: THE FINE AND INJUNCTION HAVE BEEN STAYED PENDING APPEAL

Monetary/Fine $12,000,000.00Cease and Desist/Injunction

Sanctions Ordered or ReliefGranted:






Firm Statement THE FINE AND INJUNCTION HAVE BEEN STAYED PENDING APPEAL






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 1


Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

FINRA

12/19/2011

11-04636

ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TOEXECUTE

COMMON STOCK

$15,680.00

AWARD AGAINST PARTY

06/13/2012

$8,478.50

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





www.finra.org/awardsonline

https://www.finra.org/arbitration-mediation/arbitration-awards-online?search=11-04636


End of Report

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