SEYED AHMAD HASHEMIAN - Israels Neuman, PLC AHMAD HASHEMIAN CRD# 1574079 Currently employed by and...

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BrokerCheck Report SEYED AHMAD HASHEMIAN Section Title Report Summary Broker Qualifications Registration and Employment History Disclosure Events CRD# 1574079 1 2 - 3 4 - 5 6 Page(s)

Transcript of SEYED AHMAD HASHEMIAN - Israels Neuman, PLC AHMAD HASHEMIAN CRD# 1574079 Currently employed by and...

BrokerCheck Report

SEYED AHMAD HASHEMIAN

Section Title

Report Summary

Broker Qualifications

Registration and Employment History

Disclosure Events

CRD# 1574079

1

2 - 3

4 - 5

6

Page(s)

About BrokerCheck®

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

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· BrokerCheck reports for individual brokers include information such as employment history, professionalqualifications, disciplinary actions, criminal convictions, civil judgments and arbitration awards. BrokerCheckreports for brokerage firms include information on a firm’s profile, history, and operations, as well as many of thesame disclosure events mentioned above.

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· The information contained in BrokerCheck comes from FINRA’s Central Registration Depository, orCRD® and is a combination of:

o information FINRA and/or the Securities and Exchange Commission (SEC) require brokers andbrokerage firms to submit as part of the registration and licensing process, and

o information that regulators report regarding disciplinary actions or allegations against firms or brokers.

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

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SEYED AHMAD HASHEMIAN

CRD# 1574079

Currently employed by and registered with thefollowing Firm(s):

CENTAURUS FINANCIAL, INC.2300 E. KATELLA AVENUESUITE #200ANAHEIM, CA 92806CRD# 30833Registered with this firm since: 10/06/2009

CENTAURUS FINANCIAL, INC.11601 MONTGOMERY BLVD., NEALBUQUERQUE, NM 87111CRD# 30833Registered with this firm since: 10/06/2009

CENTAURUS FINANCIAL, INC.1502 E. WARNER AVENUESUITE #ESANTA ANA, CA 92705CRD# 30833Registered with this firm since: 10/06/2009

Report Summary for this Broker

This report summary provides an overview of the broker's professional background and conduct. Additionalinformation can be found in the detailed report.

Disclosure Events

All individuals registered to sell securities or provideinvestment advice are required to disclose customercomplaints and arbitrations, regulatory actions,employment terminations, bankruptcy filings, andcriminal or civil judicial proceedings.

Are there events disclosed about this broker? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 1

Criminal 1

Customer Dispute 9

Termination 2

Investment Adviser RepresentativeInformation

http://www.adviserinfo.sec.gov

The information below represents the individual'srecord as a broker. For details on this individual'srecord as an investment adviser representative,visit the SEC's Investment Adviser PublicDisclosure website at

Broker Qualifications

This broker is registered with:

1 Self-Regulatory Organization

5 U.S. states and territories

This broker has passed:

0 Principal/Supervisory Exams

1 General Industry/Product Exam

2 State Securities Law Exams

Registration History

This broker was previously registered with thefollowing securities firm(s):

FIRST ALLIED SECURITIES, INC.CRD# 32444ALBUQUERQUE, NM05/2008 - 10/2009

FFP SECURITIES, INC.CRD# 16337ALBUQUERQUE, NM09/1996 - 05/2008

NYLIFE SECURITIES INC.CRD# 5167NEW YORK, NY07/1987 - 08/1996

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Broker Qualifications

Registrations

This section provides the self-regulatory organizations (SROs) and U.S. states/territories the broker is currentlyregistered and licensed with, the category of each license, and the date on which it became effective. This section alsoprovides, for every brokerage firm with which the broker is currently employed, the address of each branch where thebroker works.

This individual is currently registered with 1 SRO and is licensed in 5 U.S. states and territories through his orher employer.

Employment 1 of 1Firm Name:

Main Office Address:

Firm CRD#:

CENTAURUS FINANCIAL, INC.

30833

2300 E. KATELLA AVENUESUITE #200ANAHEIM, CA 92806

SRO Category Status Date

FINRA General Securities Representative APPROVED 10/06/2009

U.S. State/Territory

Category Status Date

California Agent APPROVED 10/07/2009

Louisiana Agent APPROVED 10/06/2009

New Mexico Agent APPROVED 11/23/2009

Ohio Agent APPROVED 10/13/2016

Texas Agent APPROVED 01/04/2010

Branch Office Locations

CENTAURUS FINANCIAL, INC.1502 E. WARNER AVENUESUITE #ESANTA ANA, CA 92705

CENTAURUS FINANCIAL, INC.11601 MONTGOMERY BLVD., NEALBUQUERQUE, NM 87111

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Broker Qualifications

Industry Exams this Broker has Passed

This individual has passed 0 principal/supervisory exams, 1 general industry/product exam, and 2 statesecurities law exams.

This section includes all securities industry exams that the broker has passed. Under limited circumstances, a brokermay attain a registration after receiving an exam waiver based on exams the broker has passed and/or qualifying workexperience. Any exam waivers that the broker has received are not included below.

Exam Category Date

Principal/Supervisory Exams

No information reported.

Exam Category Date

General Industry/Product Exams

General Securities Representative Examination 07/18/1987Series 7

Exam Category Date

State Securities Law Exams

Uniform Securities Agent State Law Examination 06/09/1992Series 63

Uniform Combined State Law Examination 10/03/2002Series 66

Additional information about the above exams or other exams FINRA administers to brokers and other securitiesprofessionals can be found at www.finra.org/brokerqualifications/registeredrep/.

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Registration and Employment History

Registration History

Registration Dates Firm Name CRD# Branch Location

The broker previously was registered with the following firms:

05/2008 - 10/2009 FIRST ALLIED SECURITIES, INC. 32444 ALBUQUERQUE, NM

09/1996 - 05/2008 FFP SECURITIES, INC. 16337 ALBUQUERQUE, NM

07/1987 - 08/1996 NYLIFE SECURITIES INC. 5167 NEW YORK, NY

Employment History

Employment Dates Employer Name Employer Location

This section provides up to 10 years of an individual broker's employment history as reported by the individual broker onthe most recently filed Form U4.

Please note that the broker is required to provide this information only while registered with FINRA or a nationalsecurities exchange and the information is not updated via Form U4 after the broker ceases to be registered.Therefore, an employment end date of "Present" may not reflect the broker's current employment status.

10/2009 - Present CENTAURUS FINANCIAL, INC. ANAHEIM, CA

09/1987 - Present CAPITAL ASPECTS ALBUQUERQUE, NM

05/2008 - 10/2009 FIRST ALLIED ADVISORY SERVICES, INC. SAN DIEGO, CA

05/2008 - 10/2009 FIRST ALLIED SECURITIES, INC. SAN DIEGO, CA

01/2007 - 05/2008 FIRST ADVISORS, INC. CHESTERFIELD, MO

09/1996 - 05/2008 FFP SECURITIES, INC. CHESTERFIELD, MO

08/2001 - 01/2007 FFP ADVISORY SERVICES, INC. CHESTERFIELD, MO

Other Business Activities

This section includes information, if any, as provided by the broker regarding other business activities the broker iscurrently engaged in either as a proprietor, partner, officer, director, employee, trustee, agent or otherwise. This sectiondoes not include non-investment related activity that is exclusively charitable, civic, religious or fraternal and isrecognized as tax exempt.

CAPITAL RISK SERVICES, NON-INVESTMENT RELATED, 11601 MONTGOMERY BLVD., NE, ALBUQUERQUE, NM,87111, CAPTIVE INSURANCE FOR PERSONAL LIABILITY INSURANCE OF AHMAD HASHEMIAN ONLY,PRESIDENT, SINCE 4/27/2015, DEVOTED TIME IS 1 HR A MONTH, MANAGEMENT AND INSURANCE FUNDREVIEW. SUMMIT, LLC, MANAGING PARTNER, BOARD MEMBER, SINCE 6/30/1998, 11601 MONTGOMERY BLVD.,NE, ALBUQUERQUE, NM 87111, TRAILER PARK/MOBILE/MANAGEMENT, DEVOTED TIME IS 2 HRS A MONTH,NON-INVESTMENT RELATED.

PARS, LLC, MANAGING PARTNER, BOARD MEMBER, SINCE 1/1/1997, 11601 MONTGOMERY BLVD., NE,ALBUQUERQUE, NM 87111, COMMERCIAL PROPERTY RENTAL MANAGEMENT, DEVOTED TIME IS 5 HRS AMONTH, NON-INVESTMENT RELATED.

NASEEM, LLC, MANAGING PARTNER, BOARD MEMBER, SINCE 6/1/2003, AT 11601 MONTGOMERY BLVD., NE,ALBUQUERQUE, NM 87111, COMMERCIAL PROPERTY RENTAL MANAGEMENT, DEVOTED TIME IS 3 HRS AMONTH, NON-INVESTMENT RELATED.

DBA CAPITAL ASPECTS, MANAGING MEMBER, SINCE 9/1/1978, 11601 MONTGOMERY BLVD., NE,ALBUQUERQUE, NM 87111, PRODUCER/AGENT FOR VARIOUS LIFE, HEALTH, DI, LTC CARRIERS EITHERDIRECTLY OR VIA A GA/MGA/IMO, DEVOTED TIME IS 80 HRS A MONTH, NON-INVESTMENT RELATED.

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Registration and Employment History

Other Business Activities, continued

CAPITAL RISK SERVICES, NON-INVESTMENT RELATED, 11601 MONTGOMERY BLVD., NE, ALBUQUERQUE, NM,87111, CAPTIVE INSURANCE FOR PERSONAL LIABILITY INSURANCE OF AHMAD HASHEMIAN ONLY,PRESIDENT, SINCE 4/27/2015, DEVOTED TIME IS 1 HR A MONTH, MANAGEMENT AND INSURANCE FUNDREVIEW. SUMMIT, LLC, MANAGING PARTNER, BOARD MEMBER, SINCE 6/30/1998, 11601 MONTGOMERY BLVD.,NE, ALBUQUERQUE, NM 87111, TRAILER PARK/MOBILE/MANAGEMENT, DEVOTED TIME IS 2 HRS A MONTH,NON-INVESTMENT RELATED.

PARS, LLC, MANAGING PARTNER, BOARD MEMBER, SINCE 1/1/1997, 11601 MONTGOMERY BLVD., NE,ALBUQUERQUE, NM 87111, COMMERCIAL PROPERTY RENTAL MANAGEMENT, DEVOTED TIME IS 5 HRS AMONTH, NON-INVESTMENT RELATED.

NASEEM, LLC, MANAGING PARTNER, BOARD MEMBER, SINCE 6/1/2003, AT 11601 MONTGOMERY BLVD., NE,ALBUQUERQUE, NM 87111, COMMERCIAL PROPERTY RENTAL MANAGEMENT, DEVOTED TIME IS 3 HRS AMONTH, NON-INVESTMENT RELATED.

DBA CAPITAL ASPECTS, MANAGING MEMBER, SINCE 9/1/1978, 11601 MONTGOMERY BLVD., NE,ALBUQUERQUE, NM 87111, PRODUCER/AGENT FOR VARIOUS LIFE, HEALTH, DI, LTC CARRIERS EITHERDIRECTLY OR VIA A GA/MGA/IMO, DEVOTED TIME IS 80 HRS A MONTH, NON-INVESTMENT RELATED.

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Disclosure Events

What you should know about reported disclosure events:

1. All individuals registered to sell securities or provide investment advice are required to disclose customercomplaints and arbitrations, regulatory actions, employment terminations, bankruptcy filings, and criminal or civiljudicial proceedings.

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 broker is required to disclose a particular

criminal event. o A customer dispute must involve allegations that a broker engaged in activity that violates certain rules

or conduct governing the industry and that the activity resulted in damages of at least $5,000. o

3. Disclosure events in BrokerCheck reports come from different sources: o As mentioned at the beginning of this report, information contained in BrokerCheck comes from brokers,

brokerage firms and regulators. When more than one of these sources reports information for the samedisclosure event, all versions of the event will appear in the BrokerCheck report. The different versionswill be separated by a solid line with the reporting source labeled.

o4. 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. Pleasenote that brokers and brokerage firms may choose to settle customer disputes or regulatorymatters for business or other reasons.

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

For your convenience, below is a matrix of the number and status of disclosure events involving this broker.Further information regarding these events can be found in the subsequent pages of this report. You also maywish to contact the broker to obtain further information regarding these events.

Final On AppealPending

Regulatory Event 0 1 0

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Criminal 0 1 0

Customer Dispute 0 9 N/A

Termination N/A 2 N/A

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Disclosure Event Details

When evaluating this information, please keep in mind that a discloure event may be pending or involve allegationsthat are contested and have not been resolved or proven. The matter may, in the end, be withdrawn, dismissed,resolved in favor of the broker, or concluded through a negotiated settlement for certain business reasons (e.g., tomaintain customer relationships or to limit the litigation costs associated with disputing the allegations) with noadmission or finding of wrongdoing.

This report provides the information exactly as it was reported to CRD and therefore some of the specific data fieldscontained in the report may be blank if the information was not provided to CRD.

Regulatory - Final

This type of disclosure event may involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulatory such as the Securities and Exchange Commission,foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation orsuspension of a broker's authority to act as an attorney, accountant, or federal contractor.

Disclosure 1 of 1

Reporting Source: Regulator

Regulatory Action InitiatedBy:

FINRA

Sanction(s) Sought: Other: N/A

Date Initiated: 05/11/2010

Docket/Case Number: 2008012757901

Employing firm when activityoccurred which led to theregulatory action:

FIRST ALLIED SECURITIES, INC.

Product Type: Other: VARIABLE LIFE SETTLEMENT

Allegations: NASD RULE 2110-HASHEMIAN ACTED AS A BROKER FOR A CUSTOMER INVARIABLE LIFE SETTLEMENTS. HASHEMIAN NEVER INFORMED THECUSTOMER OF THE GROSS PURCHASE PRICE FOR ANY OF THETRANSACTIONS AND HE ALSO NEVER INFORMED THE CUSTOMER OF THEAMOUNT OF THE COMMISSIONS HE RECEIVED FROM THE CUSTOMER INONE OF THE LIFE SETTLEMENTS, WHICH WAS NOT CONDUCTEDTHROUGH HASHEMIAN'S MEMBER FIRM. IN EACH OF THE LIFESETTLEMENTS, THE PURCHASE AGREEMENT ONLY STATED THE NETPURCHASE PRICE RECEIVED BY THE CUSTOMER.

Current Status: Final

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Resolution: Acceptance, Waiver & Consent(AWC)

Resolution Date: 05/11/2010

Sanctions Ordered:

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

No

CensureCivil and Administrative Penalty(ies)/Fine(s)

If the regulator is the SEC,CFTC, or an SRO, did theaction result in a finding of awillful violation or failure tosupervise?

No

(1) willfully violated anyprovision of the SecuritiesAct of 1933, the SecuritiesExchange Act of 1934, theInvestment Advisers Act of1940, the InvestmentCompany Act of 1940, theCommodity Exchange Act, orany rule or regulation underany of such Acts, or any ofthe rules of the MunicipalSecurities Rulemaking Board,or to have been unable tocomply with any provision ofsuch Act, rule or regulation?

(2) willfully aided, abetted,counseled, commanded,induced, or procured theviolation by any person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any of suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board? or

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(2) willfully aided, abetted,counseled, commanded,induced, or procured theviolation by any person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any of suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board? or

(3) failed reasonably tosupervise another personsubject to your supervision,with a view to preventing theviolation by such person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board?

Monetary Related Sanction: Civil and Administrative Penalty(ies)/Fine(s)

Total Amount: $10,000.00

Portion Levied againstindividual:

$10,000.00

Monetary Sanction 1 of 1

Payment Plan:

Is Payment Plan Current:

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Regulator Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, HASHEMIANCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE HE IS CENSURED AND FINED $10,000.

Date Paid by individual: 05/18/2010

Was any portion of penaltywaived?

No

Amount Waived:

Is Payment Plan Current:

iReporting Source: Broker

Regulatory Action InitiatedBy:

FINRA

Sanction(s) Sought: Other: N/A

Date Initiated: 05/11/2010

Docket/Case Number: 2008012757901

Employing firm when activityoccurred which led to theregulatory action:

FIRST ALLIED SECURITIES, INC.

Product Type: Other: VARIABLE LIFE SETTLEMENT

Allegations: NASD RULE 2110-HASHEMIAN ACTED AS A BROKER FOR A CUSTOMER INVARIABLE LIFE SETTLEMENTS. HASHEMIAN NEVER INFORMED THECUSTOMER OF THE GROSS PURCHASE PRICE FOR ANY OF THETRANSACTIONS AND HE ALSO NEVER INFOMRED THE CUSTOMER OF THEAMOUNT OF THE COMMISSIONS HE RECEIVED FROM THE CUSTOMER INONE OF THE LIFE SETTLEMENTS, WHICH WAS NOT CONDUCTEDTHROUGH HASHEMIAN'S MEMBER FIRM. IN EACH OF THE LIFESETTLEMENTS, THE PURCHASE AGREEMENT ONLY STATED THE NETPURCHASE PRICE RECEIVED BY THE CUSTOMER.

Current Status: Final

Resolution: Acceptance, Waiver & Consent(AWC)

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Resolution Date: 05/11/2010

Sanctions Ordered:

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

No

CensureCivil and Administrative Penalty(ies)/Fine(s)

Monetary Related Sanction: Civil and Administrative Penalty(ies)/Fine(s)

Total Amount: $10,000.00

Portion Levied againstindividual:

$10,000.00

Date Paid by individual: 05/03/2010

Was any portion of penaltywaived?

No

Amount Waived:

Monetary Sanction 1 of 1

Payment Plan: CREDIT CARD AUTHORIZATION FOR THE FULL AMOUNT

Is Payment Plan Current: Yes

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Criminal - Final Disposition

This type of disclosure event involves a criminal charge against the broker that has resulted in a conviction, acquittal,dismissal, or plea. The criminal matter may pertain to any felony or certain misdemeanor offenses, including bribery,perjury, forgery, counterfeiting, extortion, fraud, and wrongful taking of property.

Disclosure 1 of 1

Reporting Source: Broker

Charge Date: 08/18/1984

Current Status: Final

Status Date: 09/17/1984

If charge(s) were broughtagainst an organization overwhich broker exercisedcontrol:

Organization Name:

Investment RelatedBusiness:

No

Broker’s Position:

Name of Court: SECOND JUDICIAL DISTRICT COURT

Location of Court: BERNALILLO, NM

Docket/Case #: CASE # UNKNOWN

Formal Charges werebrought in:

DISTRICT COURT

Disposition Date: 09/17/1984

Sentence/Penalty: (A) CHARGE DROPPED/ACQUITTED; (B)09/17/1984; (C)N/A; (E)N/A; (F)N/A;(G) N/A.

FormalCharge(s)/Description:

CHILD ABUSE

No of Counts: 1

Felony or Misdemeanor: Felony

Plea for each charge: NOT GUILTY

Disposition of charge: Acquitted

Charge(s) 1 of 1

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Broker Statement THE CASE WAS DISMISSED BY THE JUDGE. IT NEVER WENT TO TRIAL ANDTHE COURT NO LONGER HAS ANY RECORD OF THIS INCIDENT.

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Customer Dispute - Award/Judgment

This type of disclosure event involves a final, consumer-initiated, investment-related arbitration or civil suit containingallegations of sales practice violations against the broker that resulted in an arbitration award or civil judgment for thecustomer.

Disclosure 1 of 1

Reporting Source: Regulator

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

Centaurus Financial, Inc.

suitability; fraudulent or negligent material misrepresentations and omission ofmaterial information; violation of FINRA Rules 2010, IM-2310-2, and 2020;violation of the New Mexico Unfair Practices Act; and violation of Section 11 of theSecurities Act of 1933.

Product Type: Other: various securities

Alleged Damages: $10,686,077.00

Arbitration/Reparation Claimfiled with and Docket/CaseNo.:

FINRA - CASE #14-02450

Date Notice/Process Served: 08/05/2014

Arbitration Pending? No

Disposition: Award

Disposition Date: 06/03/2016

Disposition Detail: Respondent was a subject of the customers Statement of Claim for this Arbitrationalleging that he with his member firm' contributed to the sales practice violations.Accordingly Respondent's member firm is liable for and shall pay a claimantcompensatory damages in the amount of $150,000.00, plus interest.

Arbitration Information

iReporting Source: Firm

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

FIRST ALLIED SECURITIES AND CENTAURUS FINANCIAL

FROM 2005 TO PRESENT, CLAIMANTS ALLEGE UNSUITABLE INVESTMENTS,OVERCONCENTRATION, FAILURE TO CONDUCT REASONABLE DUEDILIGENCE, FRAUDULENT OR NEGLIGENT MATERIALMISREPRESENTATIONS OR OMITTED MATERIAL INFORMATION, ANDFAILURE TO SUPERVISE.

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FROM 2005 TO PRESENT, CLAIMANTS ALLEGE UNSUITABLE INVESTMENTS,OVERCONCENTRATION, FAILURE TO CONDUCT REASONABLE DUEDILIGENCE, FRAUDULENT OR NEGLIGENT MATERIALMISREPRESENTATIONS OR OMITTED MATERIAL INFORMATION, ANDFAILURE TO SUPERVISE.

Product Type: Annuity-FixedAnnuity-VariableReal Estate SecurityOther: EIAS, PRIVATE EQUITY

Alleged Damages: $1,500,000.00

Date Complaint Received: 08/13/2014

Complaint Pending? No

Status:

Status Date: 06/23/2015

Settlement Amount: $130,000.00

Individual ContributionAmount:

$0.00

Customer Complaint Information

Settled

Is this an oral complaint? No

Is this a written complaint? No

Is this an arbitration/CFTCreparation or civil litigation?

Yes

Arbitration/Reparation forumor court name and location:

FINRA

Docket/Case #: 14-02450

Filing date ofarbitration/CFTC reparationor civil litigation:

08/05/2014

iReporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

FIRST ALLIED SECURITIES, INC. AND CENTAURUS FINANCIAL, INC.

ALLEGATIONS INCLUDE NEGLIGENCE, MISREPRESENTATION ANDUNSUITABILITY, VIOLATIONS OF FINRA AND SEC RULES, VIOLATION OF THENEW MEXICO AND FAIR PRACTICES ACT CONCERNING THE INVESTMENTSPURCHASED FROM 2005 TO 2012.

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ALLEGATIONS INCLUDE NEGLIGENCE, MISREPRESENTATION ANDUNSUITABILITY, VIOLATIONS OF FINRA AND SEC RULES, VIOLATION OF THENEW MEXICO AND FAIR PRACTICES ACT CONCERNING THE INVESTMENTSPURCHASED FROM 2005 TO 2012.

Product Type: Annuity-VariableInsuranceOil & GasReal Estate Security

Alleged Damages: $1,500,000.00

Date Complaint Received: 08/13/2014

Complaint Pending? No

Status:

Status Date: 06/03/2016

Settlement Amount: $150,000.00

Individual ContributionAmount:

$0.00

Broker Statement I EMPHATICALLY DENY ANY WRONGDOING AS IT RELATES TO THISARBITRATION CLAIM. THE RECOMMENDATIONS ON WHICH THE CLAIM ISBASED WERE CLEARLY APPROPRIATE AT THE TIME OF PURCHASE ANDBASED ON THE CLIENTS' FINANCIAL SITUATION, INVESTMENT OBJECTIVESAND RISK TOLERANCE LEVEL. THE CUSTOMERS READ THEPROSPECTUSES AND UNDERSTOOD ALL RISKS AND HAVE SIGNEDDOCUMENTATION CONFIRMING THE SAME. OVER THE COURSE OF THESEVERAL YEAR RELATIONSHIP WITH THE CLIENTS. THERE WAS NEVERANY INDICATION FROM THE CLIENTS OF ANY CONCERNS OR PROBLEMWITH ANY OF THE INVESTMENTS MADE OR OF MY SERVICE AS THEIRREPRESENTATIVE. ALL ALLEGATIONS RAISED IN THIS ARBITRATION CLAIMARE EXPRESSLY DENIED. FIRST ALLIED SECURITIES, SETTLED ON06/23/2015 FOR $130,000.00, INDIVIDUAL CONTRIBUTED $0.00. CENTAURUSFINANCIAL INC. HAS A HEARING SET FOR 05/2016.

Customer Complaint Information

Arbitration Award/Monetary Judgment (for claimants/plaintiffs)

Is this an oral complaint? No

Is this a written complaint? No

Is this an arbitration/CFTCreparation or civil litigation?

Yes

Arbitration/Reparation forumor court name and location:

FINRA

Docket/Case #: 14-02450

Filing date ofarbitration/CFTC reparationor civil litigation:

08/05/2014

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I EMPHATICALLY DENY ANY WRONGDOING AS IT RELATES TO THISARBITRATION CLAIM. THE RECOMMENDATIONS ON WHICH THE CLAIM ISBASED WERE CLEARLY APPROPRIATE AT THE TIME OF PURCHASE ANDBASED ON THE CLIENTS' FINANCIAL SITUATION, INVESTMENT OBJECTIVESAND RISK TOLERANCE LEVEL. THE CUSTOMERS READ THEPROSPECTUSES AND UNDERSTOOD ALL RISKS AND HAVE SIGNEDDOCUMENTATION CONFIRMING THE SAME. OVER THE COURSE OF THESEVERAL YEAR RELATIONSHIP WITH THE CLIENTS. THERE WAS NEVERANY INDICATION FROM THE CLIENTS OF ANY CONCERNS OR PROBLEMWITH ANY OF THE INVESTMENTS MADE OR OF MY SERVICE AS THEIRREPRESENTATIVE. ALL ALLEGATIONS RAISED IN THIS ARBITRATION CLAIMARE EXPRESSLY DENIED. FIRST ALLIED SECURITIES, SETTLED ON06/23/2015 FOR $130,000.00, INDIVIDUAL CONTRIBUTED $0.00. CENTAURUSFINANCIAL INC. HAS A HEARING SET FOR 05/2016.

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Customer Dispute - Settled

This type of disclosure event involves a consumer-initiated, investment-related complaint, arbitration proceeding or civilsuit containing allegations of sale practice violations against the broker that resulted in a monetary settlement to thecustomer.

Disclosure 1 of 5

Reporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

FFP SECURITIES, INC.

MISREPRESENTATION (DECEPTIVE TRADE PRACTICES), COMMON LAWFRAUD

Product Type: Other

Other Product Type(s): VARIABLE UNIVERSAL LIFE POLICY

Alleged Damages: $50,000.00

Date Complaint Received: 03/18/2004

Complaint Pending? No

Status:

Status Date: 03/18/2004

Settlement Amount:

Individual ContributionAmount:

Court Details: IN THE COUNTY COURT AT LAW NUMBER CC#5 EL PASCO COUNTY, TEXAS- CASE #2003-4336

Date Notice/Process Served: 03/18/2004

Litigation Pending? No

Disposition: Settled

Disposition Date: 02/08/2005

Monetary CompensationAmount:

$28,000.00

Individual ContributionAmount:

$9,333.00

Customer Complaint Information

Civil Litigation Information

Litigation

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Individual ContributionAmount:

$9,333.00

Broker Statement CASE FILED WITH COURT SEPTEMBER 29, 2003; DEFAULT JUDGMENT WASTAKEN AGAINST DEFENDANTS. DEFENDANTS TO FILE MOTION TO SETASIDE DEFAULT JUDGMENT. THIS STATEMENT IS TO PROVIDE FURTHERCOMMENT ON THE [CUSTOMER] CIVIL LITIGATION THAT WAS SETTLED ON2/8/05. PLEASE NOTE THAT NO PARTY (AIG, [THIRD PARTY] AND AHMADHASHEMIAN) IN THIS LITIGATION MAKES ANY ACKNOWLEDGMENT ORADMISSION OF ANY LIABILITY TO ANY OTHER PARTY AND EACH PARTYEXPRESSLY AGREES THE SETTLEMENT WAS IN THE BEST INTEREST TOTHE CLIENT AND CARRIER, AIG.

Disclosure 2 of 5

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Reporting Source: Firm

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

NEW YORK LIFE INSURANCE CO.

CUSTOMER [CUSTOMER] ALLEGES THAT, WITH RESPECT AVARIABLE UNIVERSAL LIFE POLICY RECOMMENDED BY FORMER REPHASHEMIAN, SHE "WAS NOT MADE AWARE THAT THIS POLICY INVOLVESTHE INVESTMENT IN STOCKS AND BONDS, AND THAT MY [HER] POLICY ISBEING MINIMALLY FUNDED". CUSTOMER HAS ALSO ALLEGED THATFORMERREP HASHEMIAN DID NOT INFORM HER THAT "THE PROPER OWNERSHIPFORTHIS POLICY SHOULD BE AN IRREVOCABLE TRUST OR THAT THE POLICYSHOULD BE OWNED BY MY[HER] SON". CUSTOMER IS REQUESTINGCANCELLATION OF THE POLICY AND THE ISSUANCE OF A NEW WHOLELIFEPOLICY WITH THE CORRECT SETUP. MR. HASHEMIAN HAS DENIED ANYWRONGDOINGS WITH RESPECT TO HIS SALES TO THE CUSTOMERS.

Product Type: Insurance

Other Product Type(s): VARIABLE LIFE INSURANCE

Alleged Damages: $11,900.00

Date Complaint Received: 02/28/1997

Complaint Pending? No

Status:

Customer Complaint Information

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Status:

Status Date: 05/22/1997

Settlement Amount: $11,941.41

Individual ContributionAmount:

$0.00

Firm Statement UPON REVIEW, THE COMPANY HAS OFFERED TO EXCHANGE[CUSTOMER'S] VARIABLE UNIVERSAL LIFE POLICY FOR A NEW WHOLELIFE POLICY. THE COMPANY WILL APPLY THE CASH VALUE FROM HER VULPOLICY, WAIVING ALL APPLICABLE SURRENDER CHARGES AS WELL AS APARTIAL PAYMENT ON THE NEW WHOLE LIFE POLICY WHICH WILL BEISSUED USING HER CURRENT AGE.

Settled

iReporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations: CUSTOMER [CUSTOMER] ALLEGED THAT SHE WAS NOTMADE AWARE THAT HER VARIABLE UNIVERSAL LIFE POLICY INVOLVEDINVESTMENT IN STOCKS AND BONDS AND THAT HER POLICY WOULD BEMINIMALLY FUNDED. SHE ALLEGED THAT SHE WAS NOT INFORMED THATTHE OWNERSHIP FOR THIS POLICY SHOULD BE AN IRREVOCALBE TRUSTORTHAT THE POLICY SHOULD BE OWNED BY HER SON. SHE REQUESTEDCANCELLATION OF THIS POLICY AND ISSUANCE OF A NEW WHOLE LIFEPOLICY BY NEW YORK LIFE INSURANCE COMPANY.

Product Type: Other

Other Product Type(s): VARIABLE UNIVERSAL LIFE

Alleged Damages: $11,900.00

Date Complaint Received: 02/28/1997

Complaint Pending? No

Status:

Status Date: 05/22/1997

Settlement Amount: $11,941.41

Individual ContributionAmount:

$0.00

Customer Complaint Information

Settled

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Individual ContributionAmount:

$0.00

Broker Statement BASED ON THE INFORMATION RECEIVED ON THE AMENDED FORM U-5FILED BY NEW YORK LIFE. NYLIFE OFFERED TO EXCHANGE THE VULPOLICY FOR A NEW WHOLE LIFEPOLICY. NYLIFE WILL APPLY THE CASH VALUE FROM THE VUL POLICY,WAIVING ALL APPLICABLE SURRENDER CHARGES, AS WELL AS A PARTIALPAYMENT ON THE NEW WHOLE LIFE POLICYWHICH WILL BE ISSUED USING HER CURRENT AGE.THE COMMISSION WAS REVERSED FROM MR. HASHEMIAN AND WAS PAIDTO THE NEW REP. AFTER I LEFT NEW YORK LIFE, THE CLIENT WASCONTACTED BY ANOTHER NYL AGENT AND AS A RESULT, A COMPLAINTAROSE AND INITIATED AT THAT TIME. THE CASH SETTLED FOR THEVALUE OF THE CONTRACT.

Disclosure 3 of 5

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Reporting Source: Firm

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

NEW YORK LIFE INSURANCE CO.

THE [CUSTOMERS] ALLEGE MISREPRESENTATION BY FORMER REPHASHEMIAN WITH REGARD TO VARIOUS WHOLE LIFE INSURANCEPOLICIES. SPECIFICALLY, THEY CLAIM THAT MR. HASHEMIANREPRESENTED TO THEM THAT "WE COULD WITHDRAW OUR MONEY WITHINTEREST ANYTIME WE WANTED AND THAT THERE WOULD BE NOPREMIUMS.WE ALSO DID NOT KNOW THAT THE ORIGINAL[WHOLE LIFE] POLICY16-101-597 WOULD BE A LOAN ON [WHOLE LIFE POLICY] [BAN] ANDINTEREST WOULD BE CHARGED." THE [CUSTOMERS] ARE SEEKING ASURRENDER OF A VARIABLE AND A WHOLE LIFE POLICY PLUS INTEREST,AND HAVE ALSO REQUESTED THAT THEY BE ADVISED OF "WHAT MONIES,IF ANY, HAVE BEEN TAKEN OUT OF A VARIABLE ANNUITY POLICY". MR.HASHEMIAN HAS DENIED ANY WRONGDOING WITH RESPECT TO HISSALES TO THE CUSTOMERS.

Product Type: Insurance

Other Product Type(s): TRADITIONAL WHOLE LIFE INSURANCE

Alleged Damages: $31,000.00

Date Complaint Received: 02/07/1997

Customer Complaint Information

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Complaint Pending? No

Status:

Status Date: 04/11/1997

Settlement Amount: $31,674.35

Individual ContributionAmount:

$0.00

Firm Statement THE COMPANY OFFERED TO SURRENDER THE VARIABLE UNIVERSAL LIFEPOLICY AND RETURN THE CASH VALUE, WAIVING ALLSURRENDER CHARGES, TOTALLING $31,674.35. IN REGARDS TO THEWHOLE LIFE POLICY, [CUSTOMER] ELECTED TO RESOLVE THIS MATTER BYSUBMITTING IT TO A COMPANY-SPONSORED ALTERNATIVE DISPUTERESOLUTION PROGRAM. COMPANY RECORDS SHOWED NOWITHDRAWALS WERE MADE ON THE VARIABLE ANNUITY POLICY. THESURRENDER VALUE OF WHICH WAS $70,148.41 AS OF 3/27/97.

Settled

iReporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations: THE [CUSTOMERS] ALLEGED MISREPRESENTATION WITHREGARD TO VARIOUS WHOLE LIFE INSURANCE POLICIES AND THAT IREPRESENTED TO THEM THAT THEY COULD WITHDRAW THEIR MONEYWITHINTEREST ANYTIME THEY WANTED AND THAT THERE WOULD BE NOPREMIUMS. THEY ALSO ALLEGED THEY DID NOT KNOW THE ORIGINALWHOLE LIFE POLICY 16-101-597 WOULD BE A LOAN ON WHOLE LIFEPOLICY 42-576-545 AND INTEREST WOULD BE CHARGED. THE[CUSTOMERS]WERE SEEKING SURRENDER OF VARIABLE AND A WHOLE LIFE POLICYPLUSINTEREST. THEY ALSO REQUESTED THAT THEY BE ADVISED OFWHATEVER MONIES, IF ANY, HAVE BEEN OUT OF A VARIABLE ANNUITYPOLICY.

Product Type: Insurance

Other Product Type(s): VARIABLE ANNUITY

Alleged Damages: $31,000.00

Customer Complaint Information

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Date Complaint Received: 02/07/1997

Complaint Pending? No

Status:

Status Date: 04/11/1997

Settlement Amount: $31,674.35

Individual ContributionAmount:

$0.00

Broker Statement BASED ON THE INFORMATION RECEIVED ON THE AMENDED FORM U-5.NYLIFE OFFERED TO SURRENDER THE VUL POLICY AND RETURN THECASH VALUE, WAIVING ALLSURRENDER CHARGES, TOTALING $31,674.35. IN REGARDS TO THEWHOLE LIFE POLICY, THE CLIENT ELECTED TO RESOLVE THIS MATTER BYSUBMITTING IT A COMPANY-SPONSORED ALTERNATIVE DISPUTERESOLUTION PROGRAM. NYLIFE RECORDS SHOWED NO WITHDRAWALSWERE MADE ON THE VA POLICY. THE SURRENDER VALUE OF WHICH WAS$70,148.41 AS OF 03/27/97. UNDER THE DISPUTE, THE CLIENT WASQUALIFIED FOR THE CLASS ACTION SUIT AGAINST NYLIFE FOR DIVIDENDREDUCTION. ON THE VA POLICY, NYLIFE DID NOT LOSE ANY MONEY, THECLIENT WAS ONLY PAID THE CASH VALUE OF THE POLICY. AFTER I LEFTNEW YORK LIFE, THE CLIENT WAS CONTACTED BY ANOTHER NYL AGENTAND AS A RESULT, A COMPLAINT AROSE AND INITIATED AT THAT TIME.THE CASH SETTLED FOR THE VALUE OF THE CONTRACT.

Customer Complaint Information

Settled

Disclosure 4 of 5

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Reporting Source: Firm

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

NEW YORK LIFE INSURANCE CO.

CUSTOMER [CUSTOMER] ALLEGES MISREPRESENTATION BYMR. HASHEMIAN IN THE SALE OF A VARIABLE UNIVERSAL LIFEINSURANCE POLICY. SHE CLAIMS "SHE HAD BEEN TRAVELING AND NOTIN RECEIPT OF SAID POLICY, NOR DID I (SHE) RECEIVE A PROSPECTUSCOVERING THE DETAILS OF THIS POLICY." CUSTOMER [CUSTOMER]SEEKSTHE CANCELLATION OF THIS POLICY.

Product Type: Insurance

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Other Product Type(s): VARIABLE UNIVERSAL LIFE INSURANCE

Alleged Damages: $43,000.00

Date Complaint Received: 06/20/1996

Complaint Pending? No

Status:

Status Date: 11/27/1996

Settlement Amount: $43,661.34

Individual ContributionAmount:

$0.00

Firm Statement UPON DISCUSSION, CUSTOMER [CUSTOMER] HAS DECIDED TOPURCHASE A SINGLE PREMIUM DEFERRED ANNUITY. [CUSTOMER] HASACCEPTED THE COMPANY'S OFFER TO RESCIND THE VARIABLE POLICYANDAPPLY THE TOTAL PREMIUMS PAID AS A 1035 EXCHANGE TO THE NEWANNUITY POLICY. MR. HASHEMIAN DID NOT CONTRIBUTE FINANCIALLYTO THE SETTLEMENT.

Customer Complaint Information

Settled

iReporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations: MISREPRESENTATION. IN [CUSTOMER'S] LETTER DATED 09-09-96, SHE ISREQUESTING TOEXERCISE HER 30-DAY FREE-LOOK PROVISION ON HER VARIABLEUNIVERSAL LIFE POLICY NO. 63-526-989.

Product Type: Other

Other Product Type(s): VARIABLE UNIVERSAL LIFE

Alleged Damages:

Date Complaint Received: 06/20/1996

Complaint Pending? No

Status:

Customer Complaint Information

Settled

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Status:

Status Date: 11/27/1996

Settlement Amount: $43,661.34

Individual ContributionAmount:

$0.00

Broker Statement CUSTOMER DECIDED TO PURCHASE A SINGLE PREMIUM DEFERREDANNUITY. CLIENT ACCEPTED NYLIFE'S OFFER TO RESCIND THE VARIABLEPOLICY AND APPLY THE TOTAL PREMIUMS PAID AS A 1035 EXCHANGE TOTHE NEW ANNUITY POLICY. MR. HASHEMIAN DID NOT CONTRIBUTEFINANCIALLY TO THE SETTLEMENT. THE COMMISSIONS WERE REVERSEDFROM MR. HASHEMIAN AND PAID TO THE NEW AGENT WHO CONVINCEDTHE CLIENT TO MAKE THE CHANGE.[CUSTOMER] CONTACTED MR. HASHEMIAN STATINGTHAT SHE REVIEWED HER VARIABLE UNIVERSAL LIFE POLICY AND THATSHE WANTED TO CHANGE IT TO AN ANNUITY. SHE WROTE A HANDWRITTEN LETTER DATED 09-09-96 AND SENT IT ALONG WITH HERORIGINAL POLICY TO MR. HASHEMIAN TO EXERCISE HER 30-DAY FREELOOK PROVISION. THESE ITEMS WERE AIRBORNE EXPRESSED TO NEWYORK LIFE`S HOME OFFICE ON 09-12-96. [CUSTOMER] WASPROVIDED A PROSPECTUS AND ILLUSTRATION ON 04-04-96. AFTER I LEFTNEW YORK LIFE, THE CLIENT WAS CONTACTED BY ANOTHER NYL AGENTAND AS A RESULT, A COMPLAINT AROSE AND INITIATED AT THAT TIME. THECASH SETTLED FOR THE VALUE OF THE CONTRACT.

Settled

Disclosure 5 of 5

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Reporting Source: Firm

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

NEW YORK LIFE INSURANCE CO.

THROUGH HER DAUGHTER AND ATTORNEY, THE CUSTOMER ALLEGESTHAT THE SALE OF VARIABLEUNIVERSAL LIFE INSURANCE WAS "UNNECESSARY" AND "INAPPROPRIATE". CUSTOMER ALLEGES THAT SHE HAD NO KNOWLEDGETHAT SHE WAS PURCHASING A VARIABLE UNIVERSAL LIFE POLICY UNTILSHE RECEIVED A BILL FOR A $20,000 PREMIUM.

Product Type: Insurance

Other Product Type(s): VARIABLE UNIVERSAL LIFE INSURANCE

Alleged Damages: $280,000.00

Customer Complaint Information

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Date Complaint Received: 04/08/1996

Complaint Pending? No

Status:

Status Date: 08/03/1996

Settlement Amount: $282,446.46

Individual ContributionAmount:

$0.00

Firm Statement NEW YORK LIFE HAS RECINDED ALL OF THE CUSTOMER'S LIFE ANDVARIABLE ANNUITY POLICIES AND REFUNDED THE CUSTOMER A TOTAL OF$282,446.46, WHICH INCLUDED INTEREST OF 6% PLUS $2,500 FORATTORNEY'S FEES. IN A DETAILED STATEMENT, MR. HASHEMIANDISPUTES THE ALLEGATIONS MADE BY THE CUSTOMER. A COPY OF MR.HASHEMIAN'S LETTER WAS PROVIDED TO THE NASD UPON ITS REQUEST.

Customer Complaint Information

Settled

iReporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

NEW YORK LIFE INS.

THROUGH HER DAUGHTER & ATTORNEY, CLIENTALLEGES THAT SALE OF VUL INSURANCE WAS UNNECESSARY &INAPPROPRIATE. CUSTOMER ALLEGES THAT SHE HAD NO KNOWLEDGETHATSHE WAS PURCHASING A VUL POLICY, UNTIL SHE RECEIVED A BILL FOR$20,000 PREMIUM.

Product Type: Other

Other Product Type(s): VARIABLE UNIVERSAL LIFE

Alleged Damages:

Date Complaint Received: 04/08/1996

Complaint Pending? No

Status:

Status Date: 08/03/1996

Settlement Amount:

Customer Complaint Information

Settled

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Settlement Amount: $282,446.46

Individual ContributionAmount:

$0.00

Broker Statement NYLIFE RESCINDED THE VUL POLICY IN QUESTION WITH RETURN OF ALLPREMIUMS PAID WITH INTEREST PLUS $2,500 FOR ATTORNEY'S FEES. IN ADETAILED STATEMENT, MR. HASHEMIAN DISPUTES THE ALLEGATIONSMADE BY THE CLIENT. THE COMMISSIONS WERE REVERSED FROM MR.HASHEMIAN AND PAID TO A NEW AGENT. AFTER I LEFT NEW YORK LIFE,THE CLIENT WAS CONTACTED BY ANOTHER NYL AGENT AND AS A RESULT,A COMPLAINT AROSE AND INITIATED AT THAT TIME. THE CASH SETTLEDFOR THE VALUE OF THE CONTRACT.

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Customer Dispute - Closed-No Action/Withdrawn/Dismissed/Denied

This type of disclosure event involves (1) a consumer-initiated, investment-related arbitration or civil suit containingallegations of sales practice violations against the individual broker that was dismissed, withdrawn, or denied; or (2) aconsumer-initiated, investment-related written complaint containing allegations that the broker engaged in sales practiceviolations resulting in compensatory damages of at least $5,000, forgery, theft, or misappropriation, or conversion of fundsor securities, which was closed without action, withdrawn, or denied.

Disclosure 1 of 3

Reporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

FFP SECURITIES

CLIENT IS ALLEGING THAT RR MISLED HIM AS TO THE AMOUNT OFPREMIUMS THAT WOULD BE DUE ON HIS FLEXIBLE PREMIUM ADJUSTABLELIFE INSURANCE POLICY WHICH HE PURCHASED IN FEBRUARY 2005

Product Type: Insurance

Alleged Damages: $12,700.00

Date Complaint Received: 10/28/2008

Complaint Pending? No

Status:

Status Date: 02/24/2009

Settlement Amount:

Individual ContributionAmount:

Broker Statement AT THE TIME OF THE SALE, THE TRANSACTION TO PURCHASE THEUNIVERSAL LIFE WITH LINCOLN FINANCIAL WAS SUITABLE. SINCE THEN,HIS FINANCIAL SITUATION HAS CHANGED. HE CHOSE THE UNIVERSAL LIFEOVER TERM BEING HE DID NOT WANT TO PAY ANY PREMIUMS OUT-OF-POCKET AT THE TIME AND COULD 1035 EXCHANGE HIS EXISTINGCONTRACT WITH EQUITABLE TO HELP PAY FOR THE INSURANCE INITIALLY.HE WAS AWARE THAT THE POLICY ONLY LASTED UNTIL THE AGE OF 65AND HE WOULD HAVE TO PAY FURTHER PREMIUMS IF HE DECIDED TOKEEP LONGER. HE STATED HE ONLY NEEDED THE COVERAGE FOR A FEWYEARS BEING HE WAS MAINLY INSURING TO PROTECT HIS YOUNGDAUGHTER. THERE WAS NO MISREPRESENTATION AS ALL APPROPRIATEDISCLOSURES WERE MADE, PRESENTED AND SIGNED BY THE CLIENT.

Customer Complaint Information

Denied

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Disclosure 2 of 3

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Reporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

FFP SECURITIES, INC.

THE CUSTOMERS ALLEGE THAT THE REP SOLD THEM POLICIES THATWERE NOT SUITABLE.

Product Type: Other

Other Product Type(s): AIG VARIABLE LIFE PRODUCTS

Alleged Damages: $160,000.00

Date Complaint Received: 02/05/2004

Complaint Pending? No

Status:

Status Date: 03/29/2005

Settlement Amount:

Individual ContributionAmount:

Customer Complaint Information

Closed/No Action

Disclosure 3 of 3

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Reporting Source: Firm

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

NYLIFE SECURITIES INC.

WITH REGARD TO TWO VARIABLE LIFE INSURANCE POLICIES PURCHASEDIN MAY AND JUNE 1997, THE CUSTOMER, THROUGH HER ATTORNEY,ALLEGES THAT SHE WAS TOLD AND SUBSEQUENTLY PURCHASED THEPOLICIES WITH THE UNDERSTANDING "THAT AFTER A CERTAIN PERIOD OFTIME SHE WOULD NOT HAVE TO PAY THE PREMIUMS...THAT THE CASHVALUE IN THE POLICIES WOULD KEEP THEM IN FULL FORCE." THECUSTOMER REQUESTS THE RETURN OF ALL PREMIUMS PAID ON THEPOLICIES WHICH IS REFLECTED IN THE AMOUNT LISTED BELOW.

Product Type: Insurance

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Other Product Type(s): VARIABLE LIFE INSURANCE

Alleged Damages: $182,306.93

Date Complaint Received: 12/04/2001

Complaint Pending? No

Status:

Status Date: 12/31/2001

Settlement Amount:

Individual ContributionAmount:

Firm Statement UPON REVIEW OF POLICY RECORDS AND DATA, NEW YORK LIFE DID NOTFIND SUFFICIENT EVIDENCE TO SUPPORT THE CUSTOMER'S CLAIMS. NOOFFER OF COMPENSATION HAS BEEN MADE TO THE CUSTOMER.COMPANY RECORDS REFLECT MR. HASHEMIAN'S AFFILIATION WITH THECOMPANY ENDED IN AUGUST 1996. THESE POLICIES WERE PURCHASEDBY THE CUSTOMER IN 1997 THROUGH ANOTHER REGISTEREDREPRESENTATIVE.

Customer Complaint Information

Denied

iReporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

NYLIFE SECURITIES INC.

WITH REGARD TO TWO VARIABLE LIFE INSURANCE POLICIES PURCHASEDIN MAY AND JUNE 1997, THE CUSTOMER, THROUGH HER ATTORNEY,ALLEGES THAT SHE WAS TOLD AND SUBSEQUENTLY PURCHASED THEPOLICIES WITH THE UNDERSTANDING "THAT AFTER A CERTAIN PERIOD OFTIME SHE WOULD NOT HAVE TO PAY THE PREMIUMS...THAT THE CASHVALUE IN THE POLICIES WOULD KEEP THEM IN FULL FORCE." THECUSTOMER REQUESTS THE RETURN OF ALL PREMIUMS PAID ON THEPOLICIES WHICH IS REFLECTED IN THE AMOUNT LISTED BELOW.

Product Type: Insurance

Other Product Type(s): VARIABLE LIFE INSURANCE

Alleged Damages: $182,306.93

Date Complaint Received:

Customer Complaint Information

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Date Complaint Received: 12/04/2001

Complaint Pending? No

Status:

Status Date: 12/31/2001

Settlement Amount:

Individual ContributionAmount:

Broker Statement I WAS NOT REGISTERED WITH NYLIFE SECURITIES, INC. AT THE TIME THEABOVE MENTIONED POLICIES WERE SOLD TO THE CLIENT. THEY WERESOLD BY A DIFFERENT REPRESENTATIVE. UPON REVIEW OF POLICYRECORDS AND DATA, NEW YORK LIFE DID NOT FIND SUFFICIENTEVIDENCE TO SUPPORT THE CUSTOMER'S CLAIMS. NO OFFER OFCOMPENSATION HAS BEEN MADE TO THE CUSTOMER. COMPANYRECORDS REFLECT MR. HASHEMIAN'S AFFILIATION WITH THE COMPANYENDED IN AUGUST 1996. THESE POLICIES WERE PURCHASED BY THECUSTOMER IN 1997 THROUGH ANOTHER REGISTERED REPRESENTATIVE.

Denied

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Employment Separation After Allegations

This type of disclosure event involves a situation where the broker voluntarily resigned, was discharged, or was permittedto resign after being accused of (1) violating investment-related statutes, regulations, rules or industry standards ofconduct; (2) fraud or the wrongful taking of property; or (3) failure to supervise in connection with investment-relatedstatutes, regulations, rules, or industry standards of conduct.

Disclosure 1 of 2

Reporting Source: Firm

Employer Name: FIRST ALLIED SECURITIES, INC.

Termination Type: Permitted to Resign

Termination Date: 10/02/2009

Allegations: SHARING COMMISSIONS WITH UNAFFILIATED PERSON(S) IN VIOLATION OFFIRST ALLIED SECURITIES, INC. POLICY.

Product Type: Other: EQUITY INDEXED ANNUITY

iReporting Source: Broker

Employer Name: FIRST ALLIED SECURITIES, INC.

Termination Type: Permitted to Resign

Termination Date: 10/07/2009

Allegations: SHARING COMMISSIONS WITH UNAFFILIATED PERSON(S) IN VIOLATION OFFASI POLICY.

Product Type: Other: EIA

Broker Statement EQUITY INDEX ANNUITIES ARE NOT CONSIDERED A SECURITIES PRODUCT& THUS NOT GOVERNED BY FINRA. I UNDERSTOOD THE FIRM WANTED TOHAVE PREAPPROVAL OF ANY EIA BUSINESS WHICH IS WHY I SUBMITTED ITFOR APPROVAL. IN THE NAF, IT WAS MENTIONED THAT THE CLIENT WASAN AGENT FOR MASS MUTUAL INSURANCE. HE WAS A NON-SECURITIESAGENT. HE CAME TO ME FOR ADVICE ON HIS FINANCIAL SITUATION, ANDAS A RESULT, THE COMMISSION WAS SPLIT. I HAD NO KNOWLEDE THATSPLITTING THE COMMISSION ON A NON-SECURITIES PRODUCT REQUIREDPREAPPROVAL BY THE FIRM. FFP HAS NEVER PROVIDED ANY WRITTENPOLICY OR ANY ACKNOWLEDGEMENT SIGNED BY ME THAT I WAS AWAREOF THIS POLICY.

Disclosure 2 of 2

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Reporting Source: Broker

Employer Name: NEW YORK LIFE INSURANCE

Termination Type: Discharged

Termination Date: 09/08/1996

Allegations: BASED UPON CUSTOMER COMPLAINTS RECEIVED FROM GENE & MARYDRAKE THROUGH THEIR ATTORNEY HOWARD RUBENSTEIN AND MARJORYBALTHAZOR THROUGH ATTORNEY RICHARD GREGORY AND RUTHANNBALTHAZOR PETTERSON ("THE COMPLAINTANTS") AN INTERNAL REVIEWWAS INITIATED REGARDING MR. HASHEMIAN'S SALES PRACTICES. IT WASMENTIONED THAT IT WAS IN THEBEST INTEREST OF NEW YORK LIFE TO TERMINATE MR. HASHEMIAN'SCONTRACTS WITH NEW YORK LIFE INSURANCE COMPANY ANDSUBSIDIARIES AND HIS REGISTRATIONS WITH NYLIFE SECURITIES.

Product Type: No Product

Other Product Types:

Broker Statement NO FINE OR PENALITES. I AM NO LONGER AN AGENTWITH NY LIFE.I WAS ON 5 WEEKS VACATION AND RETURNED ON AUG. 6,1996. ON AUG. 8TH, I HAD A MEETING SCHEDULED WITH A NYLIFEATTORNEY ANDANOTHER ATTORNEY REGARDING A CLIENT CASE. AT THAT MEETING, NYINFORMEDME OF MY TERMINATION.

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