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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CUNA BROKERAGE SERVICES, INC.
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
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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.
CUNA BROKERAGE SERVICES, INC.
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
2000 HERITAGE WAYWAVERLY, IA 50677
2000 HERITAGE WAYWAVERLY, IA 50677
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
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CBSI DBA RED CANOE FINANCIAL GROUP WA
CBSI DBA UNITUS FINANCIAL ADVISORS OR, WA
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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
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
ANDERSON, MICHAEL FRANK
DIRECTOR
Less than 5%
No
Individual
12/2015
No
6607015
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
Position
Percentage of Ownership
Position Start Date
BARBATO, PAUL DAMIEN
SECRETARY, DIRECTOR
Less than 5%
Individual
12/2018
7064310
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
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Direct Owners and Executive Officers (continued)
Firm Profile
Percentage of Ownership
Is this a public reportingcompany?
Does this owner direct themanagement or policies ofthe firm?
Less than 5%
No
No
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
BROCK, JENNY MARIE
TREASURER
Less than 5%
No
Individual
01/2017
No
6654483
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
COMFORT, ROBERT JAMES
PRESIDENT
Less than 5%
No
Individual
07/2017
Yes
1264061
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
HANSEN, ROSS DRECHSEL
1277867
Legal Name & CRD# (if any):
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Direct Owners and Executive Officers (continued)
Firm Profile
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
VICE PRESDENT, ASSOCIATE GENERAL COUNSEL
Less than 5%
No
Individual
09/2015
No
1277867
Is this a domestic or foreignentity or an individual?
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
KARLS, WILLIAM A
DIRECTOR
Less than 5%
No
Individual
08/2017
No
6847792
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
Position
Percentage of Ownership
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
LANDERS, JOHN MONROE JR.
CHIEF COMPLIANCE OFFICER
Less than 5%
Individual
08/2018
Yes
6494292
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
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Direct Owners and Executive Officers (continued)
Firm Profile
Is this a public reportingcompany?
Does this owner direct themanagement or policies ofthe firm?
No
Yes
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
RODRIGUEZ, ABIGAIL
DIRECTOR
Less than 5%
No
Individual
10/2019
No
7199272
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
SWEITZER, DAVID LAWRENCE
DIRECTOR
Less than 5%
No
Individual
10/2016
Yes
6731574
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
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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
Legal Name & CRD# (if any):
Is this a domestic or foreignentity or an individual?
Company through whichindirect ownership isestablished
Relationship to Direct Owner
Relationship Established
Percentage of Ownership
Does this owner direct themanagement or policies ofthe firm?
Is this a public reportingcompany?
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Firm History
This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.
No information reported.
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Firm Operations
RegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.
This firm is currently registered with the SEC, 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
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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
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Firm Operations
Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.
This firm currently conducts 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
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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.
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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
Effective Date: 12/01/2018
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
Effective Date: 01/05/2007
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
Effective Date: 01/27/2015
Description: THE VENDOR, SMARSH, PROVIDES THE FIRM'S EMAIL REVIEW ANDRETENTION SYSTEM.
Name: REGED, INC.
Business Address: 215 SOUTHPORT DR.SUITE 1000MORRISVILLE, NC 27560
Effective Date: 01/01/2006
Description: THE VENDOR, REGED, HOSTS THE FIRM'S ONLINE BRANCH OFFICEINSPECTION TOOL, ANNUAL COMPLIANCE QUESTIONNAIRES AND FIRMELEMENT EDUCATION RESULTS.
Name: PERSHING LLC
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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
Business Address: 95 CHRISTOPHER COLUMBUS DRIVEJERSEY CITY, NJ 07399
CRD #: 7560
Effective Date: 08/14/1996
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
Business Address: 96 CHRISTOPHER COLUMBUS DRIVEJERSEY CITY, NJ 07399
CRD #: 7560
Effective Date: 08/14/1996
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.
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Firm Operations
Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.
This firm is, directly or indirectly:
· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.
Yes
No
No
10/01/1989
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
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Disclosure Events
All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.
Final On AppealPending
Regulatory Event 0 3 0
Arbitration N/A 6 N/A
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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
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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.
Current Status: Final
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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 12/05/2001
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 Date: 12/05/2001
Resolution:
Other Sanctions Ordered:
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)
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iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS (NASD)
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
NONE
Date Initiated: 12/05/2001
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.
Current Status: Final
Resolution Date: 12/05/2001
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
Reporting Source: Regulator
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.
Current Status: Final
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Initiated By: FLORIDA DIVISION OF SECURITIES AND INVESTORPROTECTION
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 04/10/1998
Docket/Case Number: 2647-S-4/98
URL for Regulatory Action:
Principal Product Type:
Other Product Type(s):
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 Date: 04/10/1998
Resolution:
Other Sanctions Ordered:
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
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iReporting Source: Firm
Initiated By: FLORIDA, DEPARTMENT OF BANKING AND FINANCE, DIVISION OFSECURITIES
Principal Sanction(s)/ReliefSought:
Cease and Desist
Other Sanction(s)/ReliefSought:
Date Initiated: 02/10/1998
Docket/Case Number: NO. 2647-S-4/98
Principal Product Type: No Product
Other Product Type(s):
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.
Current Status: Final
Resolution Date: 04/10/1998
Resolution:
Other Sanctions Ordered:
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
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Arbitration Award - Award / Judgment
Brokerage firms are not required to report arbitration claims filed against them by customers; however, BrokerCheckprovides summary information regarding FINRA arbitration awards involving securities and commodities disputesbetween public customers and registered securities firms in this section of the report. The full text of arbitration awards issued by FINRA is available at www.finra.org/awardsonline.
Disclosure 1 of 6
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
11/09/2000
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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Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
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.
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Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUALFUNDS
$133,500.00
AWARD AGAINST PARTY
02/17/2004
$28,164.68
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 3 of 6
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Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
06/02/2003
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
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 4 of 6
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Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Allegations:
NASD
ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE
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Arbitration Forum:
Case Initiated:
Case Number:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
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
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 5 of 6
i
Reporting Source: Regulator
Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
07/15/2005
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
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
Disclosure 6 of 6
i
Reporting Source: Regulator
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Type of Event: ARBITRATION
Arbitration Forum:
Case Initiated:
Case Number:
Allegations:
Disputed Product Type:
Sum of All Relief Requested:
Disposition:
Disposition Date:
Sum of All Relief Awarded:
NASD
02/14/2006
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
There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.
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