CUNA BROKERAGE SERVICES, INC.Firm Profile Firm Names and Locations Its fiscal year ends in December....

BrokerCheck Report

CUNA BROKERAGE SERVICES, INC.

Section Title

Report Summary

Firm History

CRD# 13941

1

9

Firm Profile 2 - 8

Page(s)

Firm Operations 10 - 16

Disclosure Events 17

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CRD# 13941

SEC# 8-30027

Main Office Location

2000 HERITAGE WAYWAVERLY, IA 50677Regulated by FINRA Kansas City Office

Mailing Address

2000 HERITAGE WAYWAVERLY, IA 50677

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

Business Telephone Number

319-352-4090

https://www.adviserinfo.sec.gov

Report Summary for this Firm

This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.

Disclosure Events

Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.

Are there events disclosed about this firm? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 3

Arbitration 6

Firm Profile

This firm is classified as a corporation.

This firm was formed in Wisconsin on 05/11/1983.

Its fiscal year ends in December.

Firm History

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

Firm Operations

Is this brokerage firm currently suspended with anyregulator? No

This firm conducts 4 types of businesses.

This firm is affiliated with financial or investmentinstitutions.

This firm has referral or financial arrangements withother brokers or dealers.

This firm is registered with:

• the SEC• 1 Self-Regulatory Organization• 52 U.S. states and territories

www.finra.org/brokercheck User Guidance

1©2021 FINRA. All rights reserved. Report about CUNA BROKERAGE SERVICES, INC.

https://adviserinfo.sec.gov/firm/summary/13941


http://www.finra.org/brokercheck

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This firm is classified as a corporation.

This firm was formed in Wisconsin on 05/11/1983.

CRD#

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

Firm Profile

Firm Names and Locations

Its fiscal year ends in December.


SEC#

13941

8-30027

Main Office Location

Mailing Address

Business Telephone Number

Doing business as CUNA BROKERAGE SERVICES, INC.

319-352-4090

Regulated by FINRA Kansas City Office



Other Names of this Firm

Name Where is it used

CBSI DBA ALASKA USA FINANCIAL PLANNING & INVESTMENTSERVICES

CA, WA

CBSI DBA FIBRE FINANCIAL GROUP RETIREMENT & INVESTMENTSERVICES

OR, WA

CBSI DBA GLOBAL RETIREMENT AND INVESTMENT SERVICES WA

CBSI DBA GREAT NORTHWEST RETIREMENT & INVESTMENTSERVICES

WA

CBSI DBA HORIZON RETIREMENT & INVESTMENTS WA

CBSI DBA MEMBERS FINANCIAL ADVISORS WA






CBSI DBA RED CANOE FINANCIAL GROUP WA

CBSI DBA UNITUS FINANCIAL ADVISORS OR, WA





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?

CUNA MUTUAL INVESTMENT CORPORATION

OWNER

75% or more

No

Domestic Entity

04/1993

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


ANDERSON, MICHAEL FRANK

DIRECTOR

Less than 5%

No

Individual

12/2015

No

6607015



Position


Position Start Date

BARBATO, PAUL DAMIEN

SECRETARY, DIRECTOR

Less than 5%

Individual

12/2018

7064310








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

No

Position



Position Start Date


BROCK, JENNY MARIE

TREASURER

Less than 5%

No

Individual

01/2017

No

6654483



Position



Position Start Date


COMFORT, ROBERT JAMES

PRESIDENT

Less than 5%

No

Individual

07/2017

Yes

1264061



HANSEN, ROSS DRECHSEL

1277867








Firm Profile

Position



Position Start Date


VICE PRESDENT, ASSOCIATE GENERAL COUNSEL

Less than 5%

No

Individual

09/2015

No

1277867


Position



Position Start Date


KARLS, WILLIAM A

DIRECTOR

Less than 5%

No

Individual

08/2017

No

6847792



Position


Position Start Date


LANDERS, JOHN MONROE JR.

CHIEF COMPLIANCE OFFICER

Less than 5%

Individual

08/2018

Yes

6494292









Firm Profile



No

Yes

Position



Position Start Date


RODRIGUEZ, ABIGAIL

DIRECTOR

Less than 5%

No

Individual

10/2019

No

7199272



Position



Position Start Date


SWEITZER, DAVID LAWRENCE

DIRECTOR

Less than 5%

No

Individual

10/2016

Yes

6731574








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

Indirect Owners

Firm Profile

CMFG LIFE INSURANCE COMPANY

100% OWNER CMIC

CUNA MUTUAL INVESTMENT CORPORATION

75% or more

No

Domestic Entity

07/1985

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established









Firm History

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

No information reported.






Firm Operations

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

This firm is currently registered with the SEC, 1 SRO and 52 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 08/08/1983

Self-Regulatory Organization Status Date Effective

FINRA Approved 11/09/1983






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 09/06/1984

Alaska Approved 11/14/1986

Arizona Approved 03/08/1984

Arkansas Approved 02/09/1984

California Approved 12/09/1983

Colorado Approved 11/21/1983

Connecticut Approved 02/23/1984

Delaware Approved 05/24/1984

District of Columbia Approved 01/29/1986

Florida Approved 06/04/1984

Georgia Approved 02/16/1984

Hawaii Approved 01/29/1986

Idaho Approved 05/11/1984

Illinois Approved 01/03/1984

Indiana Approved 03/26/1984

Iowa Approved 10/10/1984

Kansas Approved 12/19/1983

Kentucky Approved 06/25/1984

Louisiana Approved 03/03/1986

Maine Approved 02/19/1985

Maryland Approved 06/26/1984

Massachusetts Approved 12/27/1983

Michigan Approved 12/16/1983

Minnesota Approved 06/15/1984

Mississippi Approved 06/18/1984

Missouri Approved 10/18/1983

Montana Approved 01/04/1984

Nebraska Approved 01/12/2001

Nevada Approved 11/22/1983

New Hampshire Approved 08/09/1984

New Jersey Approved 07/27/1984

New Mexico Approved 03/21/1984

New York Approved 01/27/1984

U.S. States &Territories

Status Date Effective

North Carolina Approved 11/22/1983

North Dakota Approved 03/08/1984

Ohio Approved 03/01/1984

Oklahoma Approved 07/06/1984

Oregon Approved 07/10/1984

Pennsylvania Approved 07/16/1984

Puerto Rico Approved 11/06/2002

Rhode Island Approved 05/07/1984

South Carolina Approved 03/09/1984

South Dakota Approved 08/02/1984

Tennessee Approved 01/24/1984

Texas Approved 01/11/1985

Utah Approved 12/06/1984

Vermont Approved 02/13/1984

Virginia Approved 10/28/1983

Washington Approved 06/25/1984

West Virginia Approved 07/31/1984

Wisconsin Approved 12/06/1983

Wyoming Approved 02/06/1984






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.

This firm currently conducts 4 types of businesses.

Types of Business

Mutual fund retailer

Broker or dealer selling variable life insurance or annuities

Investment advisory services

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






Firm Operations

Clearing Arrangements

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

Introducing Arrangements

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

Name: PERSHING LLC

Business Address: 95 CHRISTOPHER COLUMBUS DRIVEJERSEY CITY, NJ 07399

CRD #: 7560

Effective Date: 08/14/1996

Description: APPLICANT CONTRACTS WITH PERSHING LLC. ALL CLIENT FUNDS ANDSECURITIES ARE DIRECTED TO PERSHING LLC. COMPENSATIONRECEIVED BY CBSI, INC. IS COMMISSIONS AND FEES GENERATED ONTHE TRANSACTIONS CLEARED AND/OR ASSETS HELD BY PERSHINGLLC. JUNE 1, 1999, CBS, INC. AND PERSHING LLC ENTERED A WRITTENAGREEMENT WHEREBY ANY PROPRIETARY ACCOUNTS HELD BY CBSI,INC. ARE ACCOUNTED FOR IN COMPLIANCE WITH NASD NOTICE TOMEMBERS 98-99.






Firm Operations

Industry Arrangements

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

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

Name: ENVESTNET

Business Address: 35 EAST WACKER DRIVE, 24TH FLOORCHICAGO, IL 60601


Description: THE VENDOR HOSTS SOME OF THE FIRM'S RIA ACCOUNT RECORDSAND CLIENT REPORTS.

Name: EAI INFORMATION SYSTEMS

Business Address: HEADQUARTERS8700 SW CREEKSIDE PLACE SUITE ABEAVERTON, OR 97008


Description: THE VENDOR HOSTS SOME OF THE FIRM'S BOOKS AND RECORDSPERTAINING TO CLIENTS, ACCOUNTS, TRANSACTIONS,CHECKS/CERTIFICATES AND CORRESPONDENCE.

Name: SMARSH, INC.

Business Address: 851 SW 6TH AVE.PORTLAND, OR 97204


Description: THE VENDOR, SMARSH, PROVIDES THE FIRM'S EMAIL REVIEW ANDRETENTION SYSTEM.

Name: REGED, INC.

Business Address: 215 SOUTHPORT DR.SUITE 1000MORRISVILLE, NC 27560


Description: THE VENDOR, REGED, HOSTS THE FIRM'S ONLINE BRANCH OFFICEINSPECTION TOOL, ANNUAL COMPLIANCE QUESTIONNAIRES AND FIRMELEMENT EDUCATION RESULTS.

Name: PERSHING LLC

CRD #: 756014©2021 FINRA. All rights reserved. Report about CUNA BROKERAGE SERVICES, INC.





Firm Operations

Industry Arrangements (continued)

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

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

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

Control Persons/Financing


CRD #: 7560


Description: AN AGREEMENT IS IN PLACE BETWEEN APPLICANT AND PERSHING,LLC FOR WHICH PERSHING CARRIES CASH AND MARGIN ACCOUNTSOF THE CUSTOMERS INTRODUCED BY THE APPLICANT AND CLEARSTRANSACTIONS ON A FULLY DISCLOSED BASIS. OPERATIONALACCOUNTS FOR THE APPLICANT TO SUPPORT THESE FUNCTIONS AREHELD BY PERSHING, LLC.

Name: PERSHING LLC


CRD #: 7560


Description: AN AGREEMENT IS IN PLACE BETWEEN APPLICANT AND PERSHING,LLC FOR WHICH PERSHING CARRIES CASH AND MARGIN ACCOUNTSOF THE CUSTOMERS INTRODUCED BY THE APPLICANT AND CLEARSTRANSACTIONS ON A FULLY DISCLOSED BASIS.






Firm Operations

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

This firm is, directly or indirectly:

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

Yes

No

No

10/01/1989

P.O BOX 2970MADISON, WI 53701-2970

105960

MEMBERS CAPITAL ADVISORS, INC. is under common control with the firm.

CUNA BROKERAGE IS OWNED BY CUNA MUTUAL INVESTMENTCORPORATION. CUNA MUTUAL INVESTMENT CORPORATION IS OWNED100% BY CUNA MUTUAL INSURANCE SOCIETY. MEMBERS CAPITALADVISORS IS OWNED 100% BY CUNA MUTUAL INVESTMENTCORPORATION.

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 0 3 0

Arbitration N/A 6 N/A






Disclosure Event Details

What you should know about reported disclosure events:

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

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

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

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

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

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

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

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

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

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

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

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

Regulatory - Final

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

Disclosure 1 of 3

Reporting Source: Firm

Allegations: CONTROL AFFILIATE COMPLETED AN APPLICATION TO PURCHASESECURITIES, AFTER WHICH CHANGED THE ORDER TICKET WITHOUTCOMPLAINANT'S INFORMED CONSENT. FIRM FAILED TO SUPERVISE ITSEMPLOYEE CONCERNING ADVERTISING MATERIALS AND ACTIONSREGARDING THE CUSTOMER COMPLAINT.

Current Status: Final






Initiated By: BRETT OLIN, CHIEF OF ENFORCEMENTSECURITIES DIVISION, OF THE OFFICE OF THE SECRETARY OF STATE,STATE OF NEVADA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

ADMINISTRATIVE CONSENT ORDER

Date Initiated: 07/23/2020

Docket/Case Number: FILE NO. INV20-022

Principal Product Type: CD(s)

Other Product Type(s):

Allegations: CONTROL AFFILIATE COMPLETED AN APPLICATION TO PURCHASESECURITIES, AFTER WHICH CHANGED THE ORDER TICKET WITHOUTCOMPLAINANT'S INFORMED CONSENT. FIRM FAILED TO SUPERVISE ITSEMPLOYEE CONCERNING ADVERTISING MATERIALS AND ACTIONSREGARDING THE CUSTOMER COMPLAINT.

Resolution Date: 07/23/2020

Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM AND CONTROL AFFILIATE WERE JOINTLY AND SEVERALLYASSESSED A CIVIL PENALTY OF $35,000 AND ORDERED TO COMPLY WITHTHE NEVADA UNIFORM SECURITIES ACT.

Sanctions Ordered: Monetary/Fine $35,000.00

Consent

Disclosure 2 of 3

i

Reporting Source: Regulator

Allegations: NASD RULES 2110,2310(A),2310(B),3010(A),3010(B) - WITHOUT ADMITTINGOR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTEDTO THE ENTRY OF FINDINGS THAT, ACTING THROUGH ITS COMPLIANCEOFFICER, FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE ADEQUATEWRITTEN SUPERVISORY PROCEDURES GOVERNING THE SALE OFVARIABLE ANNUITIES AND VARIABLE UNIVERSAL LIFE INSURANCE; FAILEDTO MAINTAIN BOOKS AND RECORDS REQUIRED BY THE FIRM'SPROCEDURES IN THAT A "COVER LETTER" WHICH THE FIRM REQUIREDREPRESENTATIVES TO PREPARE FOR THE PURPOSE OF RECORDING THERATIONALE OF A RECOMMENDATION TO EXCHANGE A VARIABLE PRODUCTWAS MISSING FORM THE FILES IN EXCHANGE TRANSACTIONS; FAILED TODEMONSTRATE THAT IT MADE REASONABLE EFFORTS TO OBTAININFORMATION CONCERNING CUSTOMERS' FINANCIAL STATUS, TAXSTATUS, INVESTMENT OBJECTIVES, AND OTHER INFORMATIONNECESSARY TO MAKING A DETERMINATION OF SUITABILITY ANDCONDUCTING RELATED SUPERVISORY REVIEWS, OR INFORMATIONREQUIRED TO BE OBTAINED BY THE FIRM'S PROCEDURES;ACTINGTHROUGH AN INDIVIDUAL, RECOMMENDED AND ENGAGED IN A VARIABLEANNUITY CONTRACT PURCHASE TRANSACTION IN THE ACCOUNT OF APUBLIC CUSTOMER WITHOUT REASONABLE GORUNDS FOR BELIEVINGTHE RECOMMENDATION AND RESULTANT TRANSACTION WERE SUITABLEFOR THE CUSTOMER ON THE BASIS OF THE CUSTOMER'S FINANCIALSITUATION, INVESTMENT OBJECTIVES, AND NEEDS; AND, ACTINGTHROUGH ANOTHER INDIVIDUAL, RECOMMENDED AND ENGAGED IN AVARIABLE ANNUITY CONTRACT PURCHASE TRANSACTION IN THEACCOUNT OF A PUBLIC CUSTOMER AND FAILED TO COMMUNICATE AMATERIAL FACT WITH RESPECT TO INVESTMENT IN LIGHT OF THECUSTOMER'S AGE AND INVESTMENT TIME HORIZON, SPECIFICALLY, THE10 PER CENT ADDITIONAL TAX ON EARLY DISTRIBUTIONS FROMDEFERRED ANNUITY CONTRACTS.







Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.




Docket/Case Number: C05010054

Principal Product Type: Annuity(ies) - Variable

Other Product Type(s): VARIABLE UNIVERSAL LIFE INSURANCE

NASD RULES 2110,2310(A),2310(B),3010(A),3010(B) - WITHOUT ADMITTINGOR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER CONSENTEDTO THE ENTRY OF FINDINGS THAT, ACTING THROUGH ITS COMPLIANCEOFFICER, FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE ADEQUATEWRITTEN SUPERVISORY PROCEDURES GOVERNING THE SALE OFVARIABLE ANNUITIES AND VARIABLE UNIVERSAL LIFE INSURANCE; FAILEDTO MAINTAIN BOOKS AND RECORDS REQUIRED BY THE FIRM'SPROCEDURES IN THAT A "COVER LETTER" WHICH THE FIRM REQUIREDREPRESENTATIVES TO PREPARE FOR THE PURPOSE OF RECORDING THERATIONALE OF A RECOMMENDATION TO EXCHANGE A VARIABLE PRODUCTWAS MISSING FORM THE FILES IN EXCHANGE TRANSACTIONS; FAILED TODEMONSTRATE THAT IT MADE REASONABLE EFFORTS TO OBTAININFORMATION CONCERNING CUSTOMERS' FINANCIAL STATUS, TAXSTATUS, INVESTMENT OBJECTIVES, AND OTHER INFORMATIONNECESSARY TO MAKING A DETERMINATION OF SUITABILITY ANDCONDUCTING RELATED SUPERVISORY REVIEWS, OR INFORMATIONREQUIRED TO BE OBTAINED BY THE FIRM'S PROCEDURES;ACTINGTHROUGH AN INDIVIDUAL, RECOMMENDED AND ENGAGED IN A VARIABLEANNUITY CONTRACT PURCHASE TRANSACTION IN THE ACCOUNT OF APUBLIC CUSTOMER WITHOUT REASONABLE GORUNDS FOR BELIEVINGTHE RECOMMENDATION AND RESULTANT TRANSACTION WERE SUITABLEFOR THE CUSTOMER ON THE BASIS OF THE CUSTOMER'S FINANCIALSITUATION, INVESTMENT OBJECTIVES, AND NEEDS; AND, ACTINGTHROUGH ANOTHER INDIVIDUAL, RECOMMENDED AND ENGAGED IN AVARIABLE ANNUITY CONTRACT PURCHASE TRANSACTION IN THEACCOUNT OF A PUBLIC CUSTOMER AND FAILED TO COMMUNICATE AMATERIAL FACT WITH RESPECT TO INVESTMENT IN LIGHT OF THECUSTOMER'S AGE AND INVESTMENT TIME HORIZON, SPECIFICALLY, THE10 PER CENT ADDITIONAL TAX ON EARLY DISTRIBUTIONS FROMDEFERRED ANNUITY CONTRACTS.


Resolution:


Sanction Details: CENSURED AND FINED $100,000, $25,000 OF WHICH IS JOINTLY ANDSEVERALLY

Sanctions Ordered: CensureMonetary/Fine $100,000.00

Acceptance, Waiver & Consent(AWC)






iReporting Source: Firm

Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS (NASD)


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


NONE


Docket/Case Number: C05010054

Principal Product Type: Annuity(ies) - Variable

Other Product Type(s): ALSO VARIABLE UNIVERSAL LIFE INSURANCE

Allegations: FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE ADEQUATEWRITTEN SUPERVISORY PROCEDURES RE: SALE OF VA AND VUL; FIRMFAILED TO MAINTAIN CERTAIN RECORDS RECORDING RATIONALE FOREXCHANGE; FIRM FAILED TO DEMONSTRATE REASONABLE EFFORTSMADE TO OBTAIN CUSTOMER INFO NEEDED FOR SUITABILITYDETERMINATION.



Resolution:

Other Sanctions Ordered: NONE

Sanction Details: FIRM PAID A $100,000 FINE ON DECEMBER 13, 2001.

Firm Statement FIRM SETTLED CHARGES DESCRIBED IN ITEM 7. ABOVE ON DECEMBER 5,2001 WITHOUT ADMITTING OR DENYING NASD REGULATION ALLEGATIONS.FINES WERE PAID AND CENSURE.

Sanctions Ordered: CensureMonetary/Fine $100,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 3 of 3

i


Allegations: THE FLORIDA DEPARTMENT OF BANKING AND FINANCEALLEGES THAT CUNA BROKERAGE SERVICES, INC. CONDUCTEDSECURITIESBUSINESS IN FLORIDA THROUGH ONE OR MORE BRANCH OFFICESWITHOUTTHE BENEFIT OF LAWFUL REGISTRATION.







Initiated By: FLORIDA DIVISION OF SECURITIES AND INVESTORPROTECTION




Docket/Case Number: 2647-S-4/98

URL for Regulatory Action:

Principal Product Type:


THE FLORIDA DEPARTMENT OF BANKING AND FINANCEALLEGES THAT CUNA BROKERAGE SERVICES, INC. CONDUCTEDSECURITIESBUSINESS IN FLORIDA THROUGH ONE OR MORE BRANCH OFFICESWITHOUTTHE BENEFIT OF LAWFUL REGISTRATION.


Resolution:


Sanction Details: ON 4/10/98, THE FLORIDA DEPARTMENT OF BANKING ANDFINANCE ISSUED A FINAL ORDER ENTERING INTO A STIPULATION ANDCONSENT AGREEMENT REGARDING RESPONDENT CUNA BROKERAGESERVICES.THE FINAL ORDER INCORPORATED THE STIPULATION AND CONSENTAGREEMENT DATED 4/9/98, IN WHICH THE RESPONDENT CUNABROKERAGESERVICES NEITHER ADMITTED NOR DENIED THE DEPARTMENT'SALLEGATIONS. PURSUANT TO THE AGREEMENT, CUNA BROKERAGESERVICESAGREED TO CEASE AND DESIST ALL PRESENT AND FUTURE VIOLATIONSOFCHAPTER 517, F.S., AND THE RULES PROMULGATED THEREUNDER AND TOPAY AN ADMINISTRATIVE FINE IN THE AMOUNT OF $5,000. THEDEPARTMENT AGREED TO APPROVE THE APPLICATIONS FILED BY CUNABROKERAGE SERVICES FOR REGISTRATION OF ITS BRANCH OFFICES INFLORIDA.

Regulator Statement CONTACT: NANCY WOOD AT (850) 488-9530.

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

Stipulation and Consent






iReporting Source: Firm

Initiated By: FLORIDA, DEPARTMENT OF BANKING AND FINANCE, DIVISION OFSECURITIES


Cease and Desist



Docket/Case Number: NO. 2647-S-4/98

Principal Product Type: No Product


Allegations: THE FIRM FAILED TO TIMELY RENEW THE REGISTRATION OF 18 BRANCHOFFICES BY THE DEADLINE OF MARCH 31, 1998. IN ADDITION, DURING ANEXAMINATION, THE FLORIDA DEPT. OF BANKING AND FINANCE BECAMEAWARE THAT A CUNA BRANCH OFFICE CONDUCTED SECURITIESBUSINESS WITHOUT BENEFIT OF LAWFUL REGISTRATION AND MAY HAVEDONE SO AT OTHER LOCATIONS.



Resolution:


Sanction Details: CUNA BROKERAGE SERVICES, INC. NEITHER ADMITTING NOR DENYINGTHAT A BRANCH OFFICE CONDUCTED SECURITIES BUSINESS WITHOUTTHE BENEFIT OF A LAWFUL REGISTRATION AGREED TO CEASE ANDDESIST ALL PRESENT AND FUTURE VIOLATIONS OF CHAPTER 517,FLORIDA STATUTES. FURTHER, CBS, INC. AGREED TO PAYMENT OF ANADMINISTRATIVE FINE OF $5,000. THE MATTER IS RESOLVED ANDCONCLUDED.

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

Settled






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 6


Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

11/09/2000

00-04474

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

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

$100,000.00

AWARD AGAINST PARTY

03/28/2002

$20,000.00

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

Disclosure 2 of 6

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

01/31/2003

02-06445

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

ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUALFUNDS 24©2021 FINRA. All rights reserved. Report about CUNA BROKERAGE SERVICES, INC.




www.finra.org/awardsonline

https://www.finra.org/arbitration-mediation/arbitration-awards-online?search=00-04474





Disposition:

Disposition Date:


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

$133,500.00

AWARD AGAINST PARTY

02/17/2004

$28,164.68


Disclosure 3 of 6

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

06/02/2003

03-03849

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

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

$300,000.00

AWARD AGAINST PARTY

07/30/2004

$23,000.00


Disclosure 4 of 6

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Arbitration Forum:

Allegations:

NASD

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







Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


NASD

02/09/2004

04-00734

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

$420,000.00

AWARD AGAINST PARTY

03/01/2005

$98,500.01


Disclosure 5 of 6

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

07/15/2005

05-03167

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

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

$480,000.00

AWARD AGAINST PARTY

12/19/2006

$11,000.00


Disclosure 6 of 6

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

02/14/2006

06-00636

ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

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

$3,600,000.00

AWARD AGAINST PARTY

01/05/2007

$31,000.01








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