Brokercheck Report TRUIST INVESTMENT SERVICES, INC
BrokerCheck Report TRUIST INVESTMENT SERVICES, INC. CRD# 17499
Section Title Page(s) Report Summary 1
Firm Profile 2 - 10
Firm History 11
Firm Operations 12 - 26
Disclosure Events 27
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CRD# 17499 This report summary provides an overview of the brokerage firm. Additional information for this firm can be found in the detailed report. SEC# 8-35355 Firm Profile Disclosure Events Main Office Location This firm is classified as a corporation. 303 PEACHTREE CENTER AVE This firm was formed in Georgia on 11/27/1985. Brokerage firms are required to disclose certain SUITE 140 Its fiscal year ends in December. criminal matters, regulatory actions, civil judicial ATLANTA, GA 30303 proceedings and financial matters in which the firm or Regulated by FINRA Atlanta Office Firm History one of its control affiliates has been involved. Mailing Address Information relating to the brokerage firm's history Are there events disclosed about this firm? Yes 303 PEACHTREE CENTER AVE such as other business names and successions SUITE 140 (e.g., mergers, acquisitions) can be found in the ATLANTA, GA 30303 detailed report. The following types of disclosures have been reported: Business Telephone Number Firm Operations Type Count 800-874-4770 This firm is registered with: Regulatory Event 12 • the SEC Arbitration 13 This firm is a brokerage firm and an investment • 1 Self-Regulatory Organization Bond 2 adviser firm. For more information about • 53 U.S. states and territories investment adviser firms, visit the SEC's Investment Adviser Public Disclosure website at: Is this brokerage firm currently suspended with any regulator? No https://www.adviserinfo.sec.gov This firm conducts 19 types of businesses. This firm is affiliated with financial or investment institutions. This firm has referral or financial arrangements with other brokers or dealers.
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 1 www.finra.org/brokercheck User Guidance Firm Profile
This firm is classified as a corporation. This firm was formed in Georgia on 11/27/1985. Its fiscal year ends in December.
Firm Names and Locations This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailing addresses, telephone number, and any alternate name by which the firm conducts business and where such name is used.
TRUIST INVESTMENT SERVICES, INC. Doing business as TRUIST INVESTMENT SERVICES, INC. CRD# 17499 SEC# 8-35355
Main Office Location 303 PEACHTREE CENTER AVE SUITE 140 ATLANTA, GA 30303 Regulated by FINRA Atlanta Office
Mailing Address 303 PEACHTREE CENTER AVE SUITE 140 ATLANTA, GA 30303
Business Telephone Number 800-874-4770
Other Names of this Firm
Name Where is it used SUNTRUST INVESTMENT SERVICES, INC. AK, AL, AR, AZ, CA, CO, CT, DC, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, OR, PA, PR, RI, SC, SD, TN, TX, UT, VA, VI, VT, WA, ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. WI, WV, WY 2 AK, AL, AR, AZ, CA, CO, CT, DC, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, OR, PA, PR, www.finra.org/brokercheck RI, SC, SD, TN, TX, User Guidance UT, VA, VI, VT, WA, WI, WV, WY
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 3 www.finra.org/brokercheck User Guidance Firm Profile This section provides information relating to all direct owners and executive officers of the brokerage firm. Direct Owners and Executive Officers
Legal Name & CRD# (if any): TRUIST FINANCIAL CORPORATION Is this a domestic or foreign Domestic Entity entity or an individual?
Position HOLDING COMPANY Position Start Date 12/2019 Percentage of Ownership 75% or more Does this owner direct the Yes management or policies of the firm?
Is this a public reporting Yes company?
Legal Name & CRD# (if any): CARON, PAUL STEPHEN 2451071 Is this a domestic or foreign Individual entity or an individual?
Position COMPLIANCE OFFICER Position Start Date 10/2018 Percentage of Ownership Less than 5% Does this owner direct the No management or policies of the firm?
Is this a public reporting No company?
Legal Name & CRD# (if any): CRAM, BRYAN SCOTT 2723431 Is this a domestic or foreign Individual entity or an individual?
Position EXECUTIVE VICE PRESIDENT/VICE CHAIRMAN Position Start Date 05/2020 Percentage of Ownership Less than 5% ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 4 www.finra.org/brokercheck User Guidance Firm Profile
Direct Owners and Executive Officers (continued) Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?
Is this a public reporting No company?
Legal Name & CRD# (if any): DOWHOWER, BRIAN SEAN 4202574 Is this a domestic or foreign Individual entity or an individual?
Position DIRECTOR Position Start Date 03/2016 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?
Is this a public reporting No company?
Legal Name & CRD# (if any): GALE, MICHAEL ALAN 871952 Is this a domestic or foreign Individual entity or an individual?
Position COMPLIANCE OFFICER Position Start Date 10/2018 Percentage of Ownership Less than 5% Does this owner direct the No management or policies of the firm?
Is this a public reporting No company?
Legal Name & CRD# (if any): HECHTLINGER, SUSAN
©2021 FINRA. All rights reserved. Report about2890466 TRUIST INVESTMENT SERVICES, INC. 5 www.finra.org/brokercheck User Guidance Firm Profile
Direct Owners and Executive Officers (continued) 2890466 Is this a domestic or foreign Individual entity or an individual?
Position DIRECTOR/CHIEF COMPLIANCE OFFICER/SENIOR VICE PRESIDENT Position Start Date 01/2010 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?
Is this a public reporting No company?
Legal Name & CRD# (if any): MCCALLUM, CHARLES FALCONER III 2697260 Is this a domestic or foreign Individual entity or an individual?
Position SENIOR VICE CHAIRMAN/CHIEF OPERATING OFFICER/CORPORATE SECRETARY Position Start Date 03/2016 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?
Is this a public reporting No company?
Legal Name & CRD# (if any): NORMAN, ANNMARIE CARROLL 2993726 Is this a domestic or foreign Individual entity or an individual?
Position COMPLIANCE OFFICER Position Start Date 10/2018 Percentage of Ownership Less than 5% Does this owner direct the No management©2021 FINRA. All orrights policies reserved. of Report about TRUIST INVESTMENT SERVICES, INC. 6 the firm? www.finra.org/brokercheck User Guidance Firm Profile
Direct Owners and Executive Officers (continued) Does this owner direct the No management or policies of the firm?
Is this a public reporting No company?
Legal Name & CRD# (if any): PEARSON, MICHAEL EUGENE 2751813 Is this a domestic or foreign Individual entity or an individual?
Position COMPLIANCE OFFICER Position Start Date 10/2018 Percentage of Ownership Less than 5% Does this owner direct the No management or policies of the firm?
Is this a public reporting No company?
Legal Name & CRD# (if any): RICH, SARAH DODGE 6037161 Is this a domestic or foreign Individual entity or an individual?
Position CHIEF FINANCIAL OFFICER/TREASURER Position Start Date 01/2020 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?
Is this a public reporting No company?
Legal Name & CRD# (if any): RICHARDSON, CHRISTINA ADINIG 4154128
Is©2021 this FINRA. a domestic All rights orreserved. foreign Report aboutIndividual TRUIST INVESTMENT SERVICES, INC. 7 entity or an individual? www.finra.org/brokercheck User Guidance Firm Profile
Direct Owners and Executive Officers (continued) Is this a domestic or foreign Individual entity or an individual?
Position COMPLIANCE OFFICER Position Start Date 10/2018 Percentage of Ownership Less than 5% Does this owner direct the No management or policies of the firm?
Is this a public reporting No company?
Legal Name & CRD# (if any): SPEETJENS, FELICIA ANN 3197366 Is this a domestic or foreign Individual entity or an individual?
Position DIRECTOR Position Start Date 03/2016 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?
Is this a public reporting No company?
Legal Name & CRD# (if any): THOMPSON, JOSEPH MARBERRY 1995122 Is this a domestic or foreign Individual entity or an individual?
Position CHAIRMAN OF THE BOARD/PRESIDENT/CEO Position Start Date 08/2014 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm? ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 8 www.finra.org/brokercheck User Guidance Firm Profile
Direct Owners and Executive Officers (continued) Does this owner direct the Yes management or policies of the firm?
Is this a public reporting No company?
Legal Name & CRD# (if any): TYSON, TONYA 1987448 Is this a domestic or foreign Individual entity or an individual?
Position CHIEF OPERATIONS OFFICER/SENIOR VICE PRESIDENT/ASSISTANT CORPORATE SECRETARY Position Start Date 05/2020 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?
Is this a public reporting No company?
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 9 www.finra.org/brokercheck User Guidance Firm Profile This section provides information relating to any indirect owners of the brokerage firm. Indirect Owners No information reported.
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 10 www.finra.org/brokercheck User Guidance Firm History This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.
No information reported.
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 11 www.finra.org/brokercheck User Guidance Firm Operations
Registrations This section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatory organizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered and licensed, 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 53 U.S. states and territories. Federal Regulator Status Date Effective SEC Approved 02/07/1986
SEC Registration Questions This firm is registered with the SEC as: A broker-dealer: Yes A broker-dealer and government securities broker or dealer: Yes A government securities broker or dealer only: No This firm has ceased activity as a government securities broker or dealer: No
Self-Regulatory Organization Status Date Effective FINRA Approved 07/11/1986
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Registrations (continued) U.S. States & Status Date Effective U.S. States & Status Date Effective Territories Territories Alabama Approved 03/05/1987 North Carolina Approved 12/04/1986 Alaska Approved 04/25/1996 North Dakota Approved 03/13/1996 Arizona Approved 05/21/1996 Ohio Approved 01/25/1999 Arkansas Approved 01/31/1996 Oklahoma Approved 01/03/1995 California Approved 09/05/1986 Oregon Approved 03/07/1996 Colorado Approved 07/31/1986 Pennsylvania Approved 08/28/1986 Connecticut Approved 08/25/1986 Puerto Rico Approved 03/11/1996 Delaware Approved 01/18/1995 Rhode Island Approved 09/18/1986 District of Columbia Approved 02/15/1995 South Carolina Approved 01/09/1987 Florida Approved 08/26/1986 South Dakota Approved 01/29/1996 Georgia Approved 07/11/1986 Tennessee Approved 08/20/1986 Hawaii Approved 11/12/1996 Texas Approved 02/18/1987 Idaho Approved 01/23/1996 Utah Approved 01/23/1996 Illinois Approved 05/05/1987 Vermont Approved 03/20/1987 Indiana Approved 01/26/1987 Virgin Islands Approved 02/05/2021 Iowa Approved 03/07/1996 Virginia Approved 08/12/1986 Kansas Approved 01/22/1987 Washington Approved 08/11/1986 Kentucky Approved 07/31/1986 West Virginia Approved 03/06/1987 Louisiana Approved 09/17/1986 Wisconsin Approved 10/21/1996 Maine Approved 01/02/1987 Wyoming Approved 02/02/1996 Maryland Approved 04/27/1987 Massachusetts Approved 02/27/1987 Michigan Approved 08/11/1987 Minnesota Approved 03/12/1987 Mississippi Approved 01/23/1987 Missouri Approved 04/14/1987 Montana Approved 07/25/1988 Nebraska Approved 01/19/1999 Nevada Approved 01/04/1996 New Hampshire Approved 02/22/1996 New Jersey Approved 04/13/1987 New Mexico Approved 06/18/1996 New York Approved 12/29/1986
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 13 www.finra.org/brokercheck User Guidance Firm Operations
Types of Business This section provides the types of business, including non-securities business, the brokerage firm is engaged in or expects to be engaged in. This firm currently conducts 19 types of businesses. Types of Business
Broker or dealer retailing corporate equity securities over-the-counter Broker or dealer selling corporate debt securities Underwriter or selling group participant (corporate securities other than mutual funds) Mutual fund retailer U S. government securities dealer U S. government securities broker Municipal securities broker Broker or dealer selling variable life insurance or annuities Solicitor of time deposits in a financial institution Put and call broker or dealer or option writer Broker or dealer selling securities of non-profit organizations (e.g., churches, hospitals) Broker or dealer selling tax shelters or limited partnerships in primary distributions Broker or dealer selling tax shelters or limited partnerships in the secondary market Non-exchange member arranging for transactions in listed securities by exchange member Trading securities for own account Private placements of securities Broker or dealer selling interests in mortgages or other receivables Broker or dealer involved in a networking, kiosk or similar arrangment with a: bank, savings bank or association, or credit union Other - ACTING AS A CUSTODIAN/TRUSTEE FOR BROKERAGE IRA
Other Types of Business This firm does not effect transactions in commodities, commodity futures, or commodity options. This firm does engage in other non-securities business. Non-Securities Business Description: FIXED INSURANCE AND ANNUITIES
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 14 www.finra.org/brokercheck User Guidance 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: NATIONAL FINANCIAL SERVICES LLC CRD #: 13041 Business Address: 161 DEVONSHIRE STREET BOSTON, MA 02110 Effective Date: 08/16/1999 Description: TRUIST INVESTMENT SERVICES, INC. MAINTAINS A FULLY DISCLOSED CLEARING AGREEMENT WITH NATIONAL FINANCIAL SERVICES LLC, (NFS) AND IS AN INTRODUCING BROKER DEALER TO NFS.
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 15 www.finra.org/brokercheck User Guidance Firm Operations Industry Arrangements
This firm does have books or records maintained by a third party. Name: TRUIST FINANCIAL CORPORATION Business Address: 8201 IBM DRIVE CHARLOTTE, NC 28262 Effective Date: 03/24/2021 Description: TRUIST INVESTMENT SERVICES, INC. HAS ENGAGED TRUIST FINANCIAL CORPORATION RELATED TO ELECTRONIC RECORDS STORAGE. Name: TRUIST FINANCIAL CORPORATION Business Address: 49 GREEN PACE DRIVE ZEBULON, NC 27597 Effective Date: 03/24/2021 Description: TRUIST INVESTMENT SERVICES, INC. HAS ENGAGED TRUIST FINANCIAL CORPORATION RELATED TO ELECTRONIC RECORDS STORAGE. Name: 4U PLATFORM, LLC Business Address: 613 TALCOTT AVENUE LEMONT, IL 60439 Effective Date: 03/11/2021 Description: TRUIST INVESTMENT SERVICES, INC. HAS ENGAGED 4U PLATFORM, LLC RELATED TO ELECTRONIC RECORDS STORAGE. Name: TERRAPIN TECHNOLOGIES, INC. Business Address: 8375 DOMINION PARKWAY PLANO, TX 75024 Effective Date: 02/17/2021 Description: TRUIST INVESTMENT SERVICES, INC. HAS ENGAGED TERRAPIN TECHNOLOGIES RELATED TO ELECTRONIC RECORDS STORAGE AT OFF SITE FACILITIES. Name: ACCENT TECHNOLOGIES, INC. Business Address: 6905 N. WICKHAM ROAD MELBOURNE, FL 32940 Effective Date: 01/11/2021 ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 16 www.finra.org/brokercheck User Guidance Firm Operations Industry Arrangements (continued) Effective Date: 01/11/2021 Description: TRUIST FINANCIAL CORPORATION HAS ENGAGED ACCENT RELATED TO ELECTRONIC RECORDS STORAGE AT OFF SITE FACILITIES. THIS ENGAGEMENT COVERS AFFILIATES OF TRUIST FINANCIAL CORPORATION, INCLUDING TRUIST INVESTMENT SERVICES, INC. Name: DBCOM CONSULTING INC. Business Address: 2 RESEARCH WAY PRINCETON, NJ 08540 Effective Date: 02/17/2021 Description: TRUIST INVESTMENT SERVICES, INC. HAS ENGAGED DBCOM CONSULTING RELATED TO ELECTRONIC RECORDS STORAGE AT OFF SITE FACILITIES. Name: GLOBAL RELAY COMMUNICATIONS INC. Business Address: 7445 TRAMERE DR MISSISSAUGA, ONTARIO, CANADA L5S 1L4 Effective Date: 01/11/2021 Description: TRUIST INVESTMENT SERVICES, INC. HAS ENGAGED GLOBAL RELAY RELATED TO ELECTRONIC RECORDS STORAGE AT OFF SITE FACILITIES. Name: GLOBAL RELAY COMMUNICATIONS INC. Business Address: 22 GOSTICK PLACE NORTH VANCOUVER, BRITISH COLUMBIA, CANADA V7M 3N2 Effective Date: 01/11/2021 Description: TRUIST INVESTMENT SERVICES, INC. HAS ENGAGED GLOBAL RELAY RELATED TO ELECTRONIC RECORDS STORAGE AT OFF SITE FACILITIES. Name: RR DONNELLEY & SONS COMPANY Business Address: 35 WEST WACKER DRIVE STE 3600 CHICAGO, IL 60601 Effective Date: 01/21/2021 Description: TRUIST FINANCIAL CORPORATION HAS ENGAGED RR DONNELLEY & SONS COMPANY RELATED TO ELECTRONIC RECORDS STORAGE AT OFF SITE FACILITIES. THIS ENGAGEMENT COVERS AFFILIATES OF TRUIST FINANCIAL CORPORATION, INCLUDING TRUIST INVESTMENT SERVICES, INC. ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 17 www.finra.org/brokercheck User Guidance TRUIST FINANCIAL CORPORATION HAS ENGAGED RR DONNELLEY & Firm Operations SONS COMPANY RELATED TO ELECTRONIC RECORDS STORAGE AT OFF SITE FACILITIES. THIS ENGAGEMENT COVERS AFFILIATES OF Industry Arrangements (continued)TRUIST FINANCIAL CORPORATION, INCLUDING TRUIST INVESTMENT SERVICES, INC. Name: TERRAPIN TECHNOLOGIES, INC. Business Address: 3255 NEIL ARMSTRONG BLVD EAGAN, MN 55121 Effective Date: 02/17/2021 Description: TRUIST INVESTMENT SERVICES, INC. HAS ENGAGED TERRAPIN TECHNOLOGIES RELATED TO ELECTRONIC RECORDS STORAGE AT OFF SITE FACILITIES. Name: PROOFPOINT, INC Business Address: 375 RIVERSIDE PARKWAY LITHIA SPRINGS, GA 30122 Effective Date: 11/20/2019 Description: TRUIST FINANCIAL CORPORATION HAS A SERVICES AGREEMENT WITH PROOFPOINT,INC RELATED TO BOOKS AND RECORDS STORAGE AT OFF SITE FACILITIES. THIS AGREEMENT COVERS AFFILIATES OF TRUIST FINANCIAL CORPORATION INCLUDING TRUIST INVESTMENT SERVICES,INC. Name: PROOFPOINT, INC Business Address: 2401 WALSH AVENUE SANTA CLARA, CA 95054 Effective Date: 11/20/2019 Description: TRUIST FINANCIAL CORPORATION HAS A SERVICES AGREEMENT WITH PROOFPOINT,INC RELATED TO BOOKS AND RECORDS STORAGE AT OFF SITE FACILITIES. THIS AGREEMENT COVERS AFFILIATES OF TRUIST FINANCIAL CORPORATION INCLUDING TRUIST INVESTMENT SERVICES,INC. Name: REGED, INC. Business Address: 311 EDDY LANE FRANKLIN, TN 37064 Effective Date: 10/28/2019 Description: REGED, INC. MAINTAINS RECORDS ON BEHALF OF TRUIST INVESTMENT SERVICES, INC. AT THIS DISASTER RECOVERY DATA STORAGE FACILITY Name: VIEWPOINTE ARCHIVE SERVICES, L.L.C. Business Address: IBM DATA CENTER ©2021 FINRA. All rights reserved. Report 6300about TRUISTDIAGONAL INVESTMENT HWY SERVICES, INC. 18 BOULDER, CO 80301 www.finra.org/brokercheck User Guidance Firm Operations
BusinessIndustry Address: Arrangements (continued)IBM DATA CENTER 6300 DIAGONAL HWY BOULDER, CO 80301 Effective Date: 06/02/2017 Description: TRUIST BANK HAS A SERVICES AGREEMENT WITH VIEWPOINTE RELATED TO ELECTRONIC RECORDS STORAGE AT OFF SITE FACILITIES. THIS AGREEMENT COVERS AFFILIATES OF TRUIST BANK, INCLUDING TRUISTINVESTMENT SERVICES, INC. Name: VIEWPOINTE ARCHIVE SERVICES, L.L.C. Business Address: IBM DATA CENTER 1000 BELLEVIEW ST. DALLAS, TX 75215 Effective Date: 06/02/2017 Description: TRUIST BANK HAS A SERVICES AGREEMENT WITH VIEWPOINTE RELATED TO ELECTRONIC RECORDS STORAGE AT OFF SITE FACILITIES. THIS AGREEMENT COVERS AFFILIATES OF TRUIST BANK, INCLUDING TRUIST INVESTMENT SERVICES, INC. Name: BUSINESS INFORMATION GROUP, A VERTICAL SCREEN COMPANY Business Address: 251 VETERANS WAY WARMINSTER, PA 18954 Effective Date: 03/06/2017 Description: TRUIST BANK HAS A SERVICES AGREEMENT WITH BUSINESS INFORMATION GROUP, A VERTICAL SCREEN COMPANY RELATED TO BOOKS AND RECORDS STORAGE AT OFF SITE FACILITIES. THIS AGREEMENT COVERS AFFILIATES OF TRUIST BANK, INCLUDING TRUIST INVESTMENT SERVICES, INC. Name: REGED, INC. Business Address: 5301 DEPARTURE DRIVE SUITE 111 RALEIGH, NC 27616 Effective Date: 12/31/2013 Description: REGED, INC. MAINTAINS RECORDS ON BEHALF OF TRUIST INVESTMENT SERVICES, INC. AT A DATA STORAGE FACILITY Name: TRUIST FINANCIAL CORPORATION Business Address: 303 PEACHTREE CENTER AVENUE ATLANTA, GA 30303 Effective Date: 11/30/2012 ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 19 www.finra.org/brokercheck User Guidance Firm Operations Industry Arrangements (continued) Effective Date: 11/30/2012 Description: TRUIST FINANCIAL CORPORATION BOOKS AND RECORDS STORAGE FACILITY (FORMERLY A SUNTRUST BANKS, INC. FACILITY) Name: NATIONAL FINANCIAL SERVICES LLC CRD #: 13041 Business Address: ONE SPARTAN WAY MERRIMACK, NH 03054 Effective Date: 08/16/1999 Description: TRUIST INVESTMENT SERVICES, INC. MAINTAINS RECORDS IN THE OFF-SITE FACILITY OF NFS, MERRIMAC DATA CENTER. Name: NATIONAL FINANCIAL SERVICES LLC CRD #: 13041 Business Address: 400 PURITAN WAY MARLBOROUGH, MA 20110 Effective Date: 08/16/1999 Description: TRUIST INVESTMENT SERVICES, INC. MAINTAINS RECORDS IN THE OFF-SITE FACILITY OF NFS, MARLBORO DATA CENTER. Name: NATIONAL FINANCIAL SERVICES LLC CRD #: 13041 Business Address: 6001 WEST CAMPUS CIRCLE IRVING, TX 75063 Effective Date: 08/16/1999 Description: TRUIST INVESTMENT SERVICES, INC. MAINTAINS RECORDS IN THE OFF-SITE FACILITY OF NFS, DALLAS DATA CENTER. Name: VITAL RECORDS CONTROL INC Business Address: 1944 RUFFIN MILL ROAD COLONIAL HEIGHTS, VA 23834 Effective Date: 08/16/1999 Description: TRUIST BANK HAS A SERVICES AGREEMENT WITH VITAL RECORDS CONTROL INC. RELATED TO RECORDS STORAGE AT OFF SITE FACILITIES. THIS AGREEMENT COVERS AFFILIATES OF TRUIST BANK, INCLUDING TRUIST INVESTMENT SERVICES, INC. Name: IRON MOUNTAIN ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 20 www.finra.org/brokercheck User Guidance Firm Operations Industry Arrangements (continued) Business Address: 6111 LIVE OAK PARKWAY NORCROSS, GA 30093 Effective Date: 08/16/1999 Description: TRUIST BANK HAS A SERVICES AGREEMENT WITH IRON MOUNTAIN RELATED TO BOOKS AND RECORDS STORAGE AT OFF SITE FACILITIES. THIS AGREEMENT COVERS AFFILIATES OF TRUIST BANK, INCLUDING TRUIST INVESTMENT SERVICES,INC. This firm does have accounts, funds, or securities maintained by a third party. Name: NATIONAL FINANCIAL SERVICES LLC CRD #: 13041 Business Address: 161 DEVONSHIRE STREET BOSTON, MA 02110 Effective Date: 08/16/1999 Description: TRUIST INVESTMENT SERVICES, INC. MAINTAINS A FULLY DISCLOSED EXECUTION AND CLEARING ARRANGEMENT WITH NATIONAL FINANCIAL SERVICES LLC (NFS); FIRM MAINTAINS ITS PROPRIETARY ACCOUNTS WITH NFS. This firm does have customer accounts, funds, or securities maintained by a third party. Name: NATIONAL FINANCIAL SERVICES LLC CRD #: 13041 Business Address: 161 DEVONSHIRE STREET BOSTON, MA 02110 Effective Date: 08/16/1999 Description: TRUIST INVESTMENT SERVICES, INC. MAINTAINS A FULLY DISCLOSED EXECUTION AND CLEARING ARRANGEMENT WITH NATIONAL FINANCIAL SERVICES LLC (NFS) FOR EQUITIES, CERTAIN MUTUAL FUNDS AND OTHER SECURITIES. CERTAIN CUSTOMER ACCOUNTS AND MONIES ARE HELD BY NFS.
Control Persons/Financing 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.
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 21 www.finra.org/brokercheck User Guidance Firm Operations
Organization Affiliates This section provides information on control relationships the firm has with other firms in the securities, investment advisory, or banking business.
This firm is, directly or indirectly: · in control of · controlled by · or under common control with the following partnerships, corporations, or other organizations engaged in the securities or investment advisory business. PRECEPT ADVISORY GROUP LLC is under common control with the firm. CRD #: 152776 Business Address: 130 THEORY SUITE 200 IRVINE, CA 92617 Effective Date: 12/06/2019 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: PRECEPT ADVISORY GROUP, LLC IS AN SEC REGISTERED INVESTMENT ADVISER AND A DIVISION OF MCGRIFF INSURANCE SERVICES, OWNED BY TRUIST INSURANCE HOLDINGS, INC. TRUIST INSURANCE HOLDINGS, INC. IS A WHOLLY OWNED SUBSIDIARY OF TRUIST BANK, A NORTH CAROLINA CHARTERED BANK, WHICH IS WHOLLY OWNED BY TRUIST FINANCIAL CORPORATION, THE PARENT COMPANY OF THE APPLICANT.
P.J. ROBB VARIABLE CORPORATION is under common control with the firm. CRD #: 38339 Business Address: 6075 POPLAR AVENUE SUITE 400 MEMPHIS, TN 38119 Effective Date: 12/06/2019 Foreign Entity: No Country: Securities Activities: Yes ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 22 www.finra.org/brokercheck User Guidance Firm Operations
Organization Affiliates (continued)
Securities Activities: Yes Investment Advisory No Activities: Description: P.J. ROBB IS A FINRA MEMBER BROKER-DEALER WHOLLY OWNED BY CRUMP LIFE INSURANCE SERVICES, INC, A WHOLLY OWNED SUBSIDIARY OF TRUIST INSURANCE HOLDINGS, INC. TRUIST INSURANCE HOLDINGS, INC. IS A WHOLLY OWNED SUBSIDIARY OF TRUIST BANK, A NORTH CAROLINA CHARTERED BANK, WHICH IS WHOLLY OWNED BY TRUIST FINANCIAL CORPORATION, THE PARENT COMPANY OF THE APPLICANT.
MCGRIFF INSURANCE SERVICES, INC. is under common control with the firm. Business Address: 3605 GLENWOOD AVENUE SUITE 201 RALEIGH, NC 27612 Effective Date: 12/06/2019 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: MCGRIFF INSURANCE SERVICES, INC. IS A SUBSIDIARY OF TRUIST INSURANCE HOLDINGS, INC. WHICH IS A WHOLLY OWNED SUBSIDIARY OF TRUIST BANK, A NORTH CAROLINA CHARTERED BANK. TRUIST BANK IS WHOLLY OWNED BY TRUIST FINANCIAL CORPORATION, THE PARENT COMPANY OF THE APPLICANT. BB&T INSURANCE SERVICES BEGAN DOING BUSINESS AS MCGRIFF INSURANCE SERVICES ON JUNE 25, 2018.
STERLING CAPITAL MANAGEMENT LLC is under common control with the firm. CRD #: 135405 Business Address: 4350 CONGRESS STREET CHARLOTTE, NC 28209 Effective Date: 12/06/2019 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities:©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 23 www.finra.org/brokercheck User Guidance Firm Operations
Organization Affiliates (continued)
Investment Advisory Yes Activities: Description: STERLING CAPITAL MANAGEMENT, LLC, AN SEC REGISTERED INVESTMENT ADVISOR, IS WHOLLY OWNED BY TRUIST FINANCIAL CORPORATION, THE PARENT COMPANY OF APPLICANT.
TRUIST BANK is under common control with the firm. Business Address: 200 WEST SECOND STREET WINSTON SALEM, NC 27101 Effective Date: 12/07/2019 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: TRUIST BANK IS WHOLLY OWNED BY TRUIST FINANCIAL CORPORATION, THE PARENT COMPANY OF APPLICANT.
TRUIST ADVISORY SERVICES, INC. is under common control with the firm. CRD #: 283390 Business Address: 303 PEACHTREE CENTER AVENUE SUNTRUST GARDEN OFFICES SUITE 140 ATLANTA, GA 30303 Effective Date: 04/18/2016 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: TRUIST ADVISORY SERVICES, INC., AN SEC REGISTERED INVESTMENT ADVISOR, IS WHOLLY OWNED BY TRUIST FINANCIAL CORPORATION, THE PARENT COMPANY OF APPLICANT.
GFO ADVISORY SERVICES, LLC is under common control with the firm. Business Address: 150 SOUTH US HIGWAY 1 ©2021 FINRA. All rights reserved. Report aboutJUPITER, TRUIST FL INVESTMENT 33477 SERVICES, INC. 24 www.finra.org/brokercheck User Guidance Firm Operations
Organization Affiliates (continued) Business Address: 150 SOUTH US HIGWAY 1 JUPITER, FL 33477 Effective Date: 04/19/2001 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: GFO ADVISORY SERVICES, LLC, AN SEC REGISTERED INVESTMENT ADVISOR, IS 99.9% OWNED BY GENSPRING HOLDINGS, INC. WHICH IS WHOLLY OWNED BY TRUIST FINANCIAL CORPORATION, THE PARENT COMPANY OF APPLICANT AND 0.1% OWNED BY SUNTRUST NLIP, INC., WHICH IS WHOLLY OWNED BY TRUIST FINANCIAL CORPORATION.
TRUIST SECURITIES, INC. is under common control with the firm. CRD #: 6271 Business Address: 3333 PEACHTREE ROAD, N.E. ATLANTA FINANCIAL CENTER, SOUTH TOWER, 9TH FLOOR ATLANTA, GA 30326 Effective Date: 08/01/2007 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: TRUIST SECURITIES, INC. IS WHOLLY OWNED BY TRUIST FINANCIAL CORPORATION, THE PARENT COMPANY OF APPLICANT.
This firm is 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
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 25 www.finra.org/brokercheck User Guidance Firm Operations
Organization Affiliates (continued)
TRUIST FINANCIAL CORPORATION is a Bank Holding Company and controls the firm. Business Address: 214 NORTH TRYON STREET CHARLOTTE, NC 28202 Effective Date: 12/06/2019 Description: APPLICANT IS WHOLLY OWNED BY TRUIST FINANCIAL CORPORATION.
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 26 www.finra.org/brokercheck User Guidance Disclosure Events
All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal or civil 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 or one of its control affiliates. Further information regarding these events can be found in the subsequent pages of this report. Pending Final On Appeal Regulatory Event 0 12 0 Arbitration N/A 13 N/A Bond N/A 2 N/A
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 27 www.finra.org/brokercheck User Guidance
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 includes summary information regarding FINRA arbitration awards in cases where the brokerage firm was named 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 firm and a regulator report information for the same event, both versions of the event will appear in the BrokerCheck report. The different versions will be separated by a solid line with the reporting source labeled. 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 party charged 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 for business or other reasons. § A "resolved" matter usually involves no payment to the customer and no finding of wrongdoing on the part of the individual broker. Such matters generally involve customer disputes. 5. You may wish to contact the brokerage firm to obtain further information regarding any of the disclosure 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 state securities 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 or suspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federal contractor. Disclosure 1 of 12 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED ©2021 FINRA. All rights reserved. Report aboutTO THE TRUIST SANCTIONS INVESTMENT AND SERVICES, TO THE INC. ENTRY OF FINDINGS THAT IT FAILED TO 28 ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM OR WSPS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA'S SUITABILITY RULE AS IT RELATES TO NON-TRADITIONAL EXCHANGE TRADED FUNDS (NT-ETFS), PARTICULARLY IN CONNECTION WITH CERTAIN OF THE UNIQUE FEATURES AND RISKS ASSOCIATED WITH NT-ETFS, INCLUDING THE RISKS ASSOCIATED WITH HOLDING NT-ETFS FOR EXTENDED PERIODS. THE FINDINGS STATED THAT THE FIRM DID NOT HAVE REASONABLE PROCEDURES OR GUIDANCE TO REPRESENTATIVES OR SUPERVISORS REGARDING HOW TO DETERMINE WHETHER AN NT-ETF WAS SUITABLE FOR CUSTOMERS GIVEN THE UNIQUE FEATURES AND RISKS OF THOSE PRODUCTS. THE FIRM DID NOT HAVE ANY SYSTEMS IN PLACE, SUCH AS AN ALERT OR EXCEPTION REPORT, TO ASSIST IN MONITORING THE HOLDING PERIODS FOR NT-ETFS. THERE IS ALSO NO EVIDENCE THAT ANYONE AT THE FIRM CONDUCTED A CUSTOMER- SPECIFIC SUITABILITY ANALYSIS FOR NT-ETF POSITIONS HELD FOR PERIODS LONGER THAN ONE DAY, NOR DID THE WSPS REQUIRE SUCH AN ANALYSIS. ALTHOUGH THE FIRM REQUIRED ITS REPRESENTATIVES TO COMPLETE AN ONLINE TRAINING COURSE PRIOR TO RECOMMENDING TRANSACTIONS INVOLVING NT-ETFS, THE TRAINING DID NOT DESCRIBE HOW TO MONITOR ONGOING HOLDING PERIODS AND THE RELATED IMPACT ON SUITABILITY. AS A RESULT, CERTAIN FIRM CUSTOMERS HELD POSITIONS IN NT-ETFS FOR EXTENDED PERIODS OF TIME. THE FIRM EXECUTED SOLICITED NT-ETF TRANSACTIONS IN RETAIL CUSTOMER ACCOUNTS TOTALING OVER $2.8 MILLION IN PRINCIPAL AMOUNT. THESE SUPERVISORY FAILURES RESULTED IN LOSSES OF $584,466.13 IN FIRM CUSTOMER ACCOUNTS. THE FIRM HAS ALREADY VOLUNTARILY FULLY PAID IN RESTITUTION TO THESE CUSTOMERS. www.finra.org/brokercheck User Guidance
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM OR WSPS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA'S SUITABILITY RULE AS IT RELATES TO NON-TRADITIONAL EXCHANGE TRADED FUNDS (NT-ETFS), PARTICULARLY IN CONNECTION WITH CERTAIN OF THE UNIQUE FEATURES AND RISKS ASSOCIATED WITH NT-ETFS, INCLUDING THE RISKS ASSOCIATED WITH HOLDING NT-ETFS FOR EXTENDED PERIODS. THE FINDINGS STATED THAT THE FIRM DID NOT HAVE REASONABLE PROCEDURES OR GUIDANCE TO REPRESENTATIVES OR SUPERVISORS REGARDING HOW TO DETERMINE WHETHER AN NT-ETF WAS SUITABLE FOR CUSTOMERS GIVEN THE UNIQUE FEATURES AND RISKS OF THOSE PRODUCTS. THE FIRM DID NOT HAVE ANY SYSTEMS IN PLACE, SUCH AS AN ALERT OR EXCEPTION REPORT, TO ASSIST IN MONITORING THE HOLDING PERIODS FOR NT-ETFS. THERE IS ALSO NO EVIDENCE THAT ANYONE AT THE FIRM CONDUCTED A CUSTOMER- SPECIFIC SUITABILITY ANALYSIS FOR NT-ETF POSITIONS HELD FOR PERIODS LONGER THAN ONE DAY, NOR DID THE WSPS REQUIRE SUCH AN ANALYSIS. ALTHOUGH THE FIRM REQUIRED ITS REPRESENTATIVES TO COMPLETE AN ONLINE TRAINING COURSE PRIOR TO RECOMMENDING TRANSACTIONS INVOLVING NT-ETFS, THE TRAINING DID NOT DESCRIBE HOW TO MONITOR ONGOING HOLDING PERIODS AND THE RELATED IMPACT ON SUITABILITY. AS A RESULT, CERTAIN FIRM CUSTOMERS HELD POSITIONS IN NT-ETFS FOR EXTENDED PERIODS OF TIME. THE FIRM EXECUTED SOLICITED NT-ETF TRANSACTIONS IN RETAIL CUSTOMER ACCOUNTS TOTALING OVER $2.8 MILLION IN PRINCIPAL AMOUNT. THESE SUPERVISORY FAILURES RESULTED IN LOSSES OF $584,466.13 IN FIRM CUSTOMER ACCOUNTS. THE FIRM HAS ALREADY VOLUNTARILY FULLY PAID IN RESTITUTION TO THESE CUSTOMERS. Initiated By: FINRA Date Initiated: 05/18/2020 Docket/Case Number: 2018057530701
Principal Product Type: Other Other Product Type(s): NON-TRADITIONAL EXCHANGE TRADED FUNDS Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:
Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/18/2020
©2021Does FINRA.the order All rights constitute reserved. a Report aboutNo TRUIST INVESTMENT SERVICES, INC. 29 final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance
Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $50,000.00 Disgorgement/Restitution Other Sanctions Ordered: CERTIFICATION Sanction Details: THE FIRM WAS CENSURED, FINED $50,000, ORDERED TO PAY $584,466.13 IN RESTITUTION TO CUSTOMERS AND ORDERED TO CERTIFY, WITHIN 60 DAYS, THAT IT HAS PREPAID SUCH RESTITUTION IN THE AMOUNT OF $584,466.13. THE FIRM HAS ALREADY VOLUNTARILY FULLY PAID IN RESTITUTION TO THE CUSTOMERS. FINES PAID IN FULL ON MAY 26, 2020. i Reporting Source: Firm Current Status: Final Allegations: THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES ("WSPS") THAT WERE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH FINRA RULE 2111 IN RELATION TO SOLICITED SALES OF NON-TRADITIONAL EXCHANGE TRADED FUNDS ("NT-ETFS") BY ITS REGISTERED REPRESENTATIVES. Initiated By: FINRA Date Initiated: 05/01/2020 Docket/Case Number: 2018057530701
Principal Product Type: Other Other Product Type(s): NON-TRADITIONAL EXCHANGE TRADED FUNDS ("NT-ETFS") Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE; RESTITUTION Sought:
Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/18/2020 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine TRUIST INVESTMENT $50,000.00 SERVICES, INC. 30 Disgorgement/Restitution www.finra.org/brokercheck User Guidance
Sanctions Ordered: Censure Monetary/Fine $50,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: RESTITUTION HAS BEEN PAID IN FULL. THE FINE AMOUNT OF $50,000 WAS PAID ON 5/26/2020. Firm Statement THE FIRM WAS CENSURED, FINED $50,000, AND PAID $584,466.13 IN RESTITUTION TO CUSTOMERS. FINE PAID ON 5/26/2020. RESTITUTION HAS BEEN PAID IN FULL. i Disclosure 2 of 12 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMIN RELEASE 34-81611; IA RELEASE 4769, SEPTEMBER 14, 2017: THE SECURITIES AND EXCHANGE COMMISSION (COMMISSION) DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 (EXCHANGE ACT) AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AGAINST SUNTRUST INVESTMENT SERVICES, INC. (THE FIRM). THE FIRM BREACHED ITS FIDUCIARY DUTY TO ITS ADVISORY CLIENTS, MADE INADEQUATE DISCLOSURES THAT FAILED TO EXPLAIN CERTAIN CONFLICTS OF INTEREST, AND HAD DEFICIENCIES IN COMPLIANCE POLICIES AND PROCEDURES IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PROCESSES. SPECIFICALLY, THE FIRM'S INVESTMENT ADVISER REPRESENTATIVES (IARS) PURCHASED, RECOMMENDED, OR HELD "CLASS A" MUTUAL FUND SHARES FOR ADVISORY CLIENTS WHEN LESS-EXPENSIVE "CLASS I" SHARES OF THE SAME MUTUAL FUNDS WERE AVAILABLE. MORE THAN 4,500 CLIENT ACCOUNTS OF THE FIRM WERE AFFECTED. A SIGNIFICANT DIFFERENCE BETWEEN CLASS A AND CLASS I SHARES IS THAT CLASS A SHARES OFTEN CARRY ONGOING MARKETING AND DISTRIBUTION FEES IMPOSED PURSUANT TO SECTION 12(B) OF THE ADVISERS ACT AND RULE 12B-1 THEREUNDER (12B-1 FEES). THE 12B-1 FEES ARE PAID BY A MUTUAL FUND OUT OF FUND ASSETS AND PASSED BACK THROUGH AS COMPENSATION TO THE FIRM BY THE FUND'S DISTRIBUTOR. THE FIRM THEN SHARES A PORTION OF THE 12B-1 FEES WITH ITS IARS WHO ARE ALSO REGISTERED REPRESENTATIVES OF THE FIRM. THE FIRM AND ITS IARS RECEIVED AT LEAST $1,148,071.77 IN AVOIDABLE 12B-1 FEES PAID BY THE FUNDS IN WHICH THE ADVISORY CLIENTS WERE INVESTED. THESE 12B-1 FEES DECREASED THE VALUE OF THE ADVISORY CLIENTS' INVESTMENTS IN THE MUTUAL FUNDS AND INCREASED THE COMPENSATION PAID TO THE ©2021 FINRA. All rights reserved. Report aboutFIRM TRUIST AND INVESTMENTITS IARS. THE SERVICES, FIRM DIDINC. NOT ADEQUATELY INFORM ITS 31 ADVISORY CLIENTS OF THE CONFLICTS OF INTEREST PRESENTED BY ITS IARS' SHARE CLASS SELECTIONS AND THE RECEIPT BY THE FIRM AND THE IARS OF 12B-1 FEES. THE FIRM DISCLOSED IN ITS FORM ADV PART 2A BROCHURES FOR ITS INVESTMENT ADVISORY PROGRAMS THAT THE FIRM "MAY" RECEIVE 12B-1 FEES AS A RESULT OF INVESTMENTS IN CERTAIN MUTUAL FUNDS AND - FOR SEVERAL FIRM PROGRAMS - THAT SUCH FEES PRESENTED A "CONFLICT OF INTEREST." HOWEVER, THE FIRM DID NOT DISCLOSE IN ITS FORM ADV PART 2A BROCHURES OR OTHERWISE THAT MANY MUTUAL FUNDS OFFERED A VARIETY OF SHARE CLASSES, INCLUDING SOME THAT DID NOT CHARGE 12B-1 FEES AND WERE, ACCORDINGLY, LESS EXPENSIVE FOR ELIGIBLE INVESTORS. THE FIRM FAILED TO DISCLOSE TO AFFECTED CLIENTS THAT AN IAR COULD PURCHASE, HOLD, OR RECOMMEND MUTUAL FUND INVESTMENTS IN SHARE CLASSES THAT PAID 12B-1 FEES TO THE FIRM, WHICH THE FIRM ULTIMATELY SHARED WITH ITS IARS AS COMPENSATION, EVEN THOUGH SUCH CLIENTS ALSO WERE ELIGIBLE TO INVEST IN SHARE CLASSES OF THE SAME MUTUAL FUNDS THAT DID NOT CHARGE SUCH FEES AND WERE LESS EXPENSIVE. THE FAILURE BY THE FIRM TO MAKE ADEQUATE DISCLOSURES CONCERNING ITS IARS' SHARE CLASS SELECTIONS WAS MISLEADING TO INVESTORS IN LIGHT OF THE FIRM'S INVESTING ITS CLIENTS IN MORE EXPENSIVE MUTUAL FUND SHARE CLASSES WHEN LOWER-COST OPTIONS OF THE SAME FUNDS WERE AVAILABLE. THE FIRM'S PRACTICE OF INVESTING CLIENTS IN MUTUAL FUND SHARE CLASSES WITH 12B-1 FEES RATHER THAN LOWER-FEE SHARE CLASSES WAS ALSO INCONSISTENT WITH THE FIRM'S DUTY TO SEEK BEST EXECUTION FOR ITS CLIENTS. OVER TIME, AS CLASS I SHARES BECAME INCREASINGLY AVAILABLE TO NONINSTITUTIONAL INVESTORS, THE FIRM DID NOT UPDATE ITS COMPLIANCE POLICIES AND PROCEDURES TO REQUIRE IARS SPECIFICALLY TO IDENTIFY OR EVALUATE AVAILABLE INSTITUTIONAL SHARE CLASSES AND DID NOT UPDATE OR ENHANCE ITS POLICIES OR PROCEDURES TO ADDRESS INSTANCES IN WHICH IARS WERE RECOMMENDING, PURCHASING, OR HOLDING CLASS A SHARES WHEN LESS COSTLY CLASS I SHARES WERE AVAILABLE. BY VIRTUE OF THE CONDUCT DESCRIBED THE FIRM WILLFULLY VIOLATED SECTIONS 206(2), 206(4) AND 207 OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. SEC ADMIN RELEASE 34-81611; IA RELEASE 4769, SEPTEMBER 14, 2017: THE SECURITIES AND EXCHANGE COMMISSION (COMMISSION) DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 (EXCHANGE ACT) AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AGAINST SUNTRUST INVESTMENT SERVICES, INC. (THE FIRM). THE FIRM BREACHED ITS FIDUCIARY DUTY TO ITS ADVISORY CLIENTS, MADE INADEQUATE DISCLOSURES THAT FAILED TO EXPLAIN CERTAIN CONFLICTS OF INTEREST, AND HAD DEFICIENCIES IN COMPLIANCE POLICIES AND PROCEDURES IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PROCESSES. SPECIFICALLY, THE FIRM'S INVESTMENT ADVISER REPRESENTATIVES (IARS) PURCHASED, RECOMMENDED, OR HELD "CLASS A" MUTUAL FUND SHARES FOR ADVISORY CLIENTS WHEN LESS-EXPENSIVE "CLASS I" SHARES OF THE SAME MUTUAL FUNDS WERE AVAILABLE. MORE THAN 4,500 CLIENT ACCOUNTS OF THE FIRM WERE AFFECTED. A SIGNIFICANT DIFFERENCE BETWEEN CLASS A AND CLASS I SHARES IS THAT CLASS A SHARES OFTEN CARRY ONGOING MARKETING AND DISTRIBUTION FEES IMPOSED PURSUANT TO SECTION 12(B) OF THE ADVISERS ACT AND RULE 12B-1 THEREUNDER (12B-1 FEES). THE 12B-1 FEES ARE PAID BY A MUTUAL FUND OUT OF FUND ASSETS AND PASSED BACK THROUGH AS COMPENSATION TO THE FIRM BY THE FUND'S DISTRIBUTOR. THE FIRM THEN SHARES A PORTION OF THE 12B-1 FEES WITH ITS IARS WHO ARE ALSO REGISTERED www.finra.org/brokercheck REPRESENTATIVES OF THE FIRM. THE FIRM AND ITS IARS RECEIVED AT User Guidance LEAST $1,148,071.77 IN AVOIDABLE 12B-1 FEES PAID BY THE FUNDS IN WHICH THE ADVISORY CLIENTS WERE INVESTED. THESE 12B-1 FEES DECREASED THE VALUE OF THE ADVISORY CLIENTS' INVESTMENTS IN THE MUTUAL FUNDS AND INCREASED THE COMPENSATION PAID TO THE FIRM AND ITS IARS. THE FIRM DID NOT ADEQUATELY INFORM ITS ADVISORY CLIENTS OF THE CONFLICTS OF INTEREST PRESENTED BY ITS IARS' SHARE CLASS SELECTIONS AND THE RECEIPT BY THE FIRM AND THE IARS OF 12B-1 FEES. THE FIRM DISCLOSED IN ITS FORM ADV PART 2A BROCHURES FOR ITS INVESTMENT ADVISORY PROGRAMS THAT THE FIRM "MAY" RECEIVE 12B-1 FEES AS A RESULT OF INVESTMENTS IN CERTAIN MUTUAL FUNDS AND - FOR SEVERAL FIRM PROGRAMS - THAT SUCH FEES PRESENTED A "CONFLICT OF INTEREST." HOWEVER, THE FIRM DID NOT DISCLOSE IN ITS FORM ADV PART 2A BROCHURES OR OTHERWISE THAT MANY MUTUAL FUNDS OFFERED A VARIETY OF SHARE CLASSES, INCLUDING SOME THAT DID NOT CHARGE 12B-1 FEES AND WERE, ACCORDINGLY, LESS EXPENSIVE FOR ELIGIBLE INVESTORS. THE FIRM FAILED TO DISCLOSE TO AFFECTED CLIENTS THAT AN IAR COULD PURCHASE, HOLD, OR RECOMMEND MUTUAL FUND INVESTMENTS IN SHARE CLASSES THAT PAID 12B-1 FEES TO THE FIRM, WHICH THE FIRM ULTIMATELY SHARED WITH ITS IARS AS COMPENSATION, EVEN THOUGH SUCH CLIENTS ALSO WERE ELIGIBLE TO INVEST IN SHARE CLASSES OF THE SAME MUTUAL FUNDS THAT DID NOT CHARGE SUCH FEES AND WERE LESS EXPENSIVE. THE FAILURE BY THE FIRM TO MAKE ADEQUATE DISCLOSURES CONCERNING ITS IARS' SHARE CLASS SELECTIONS WAS MISLEADING TO INVESTORS IN LIGHT OF THE FIRM'S INVESTING ITS CLIENTS IN MORE EXPENSIVE MUTUAL FUND SHARE CLASSES WHEN LOWER-COST OPTIONS OF THE SAME FUNDS WERE AVAILABLE. THE FIRM'S PRACTICE OF INVESTING CLIENTS IN MUTUAL FUND SHARE CLASSES WITH 12B-1 FEES RATHER THAN LOWER-FEE SHARE CLASSES WAS ALSO INCONSISTENT WITH THE FIRM'S DUTY TO SEEK BEST EXECUTION FOR ITS CLIENTS. OVER TIME, AS CLASS I SHARES BECAME INCREASINGLY AVAILABLE TO NONINSTITUTIONAL INVESTORS, THE FIRM DID NOT UPDATE ITS COMPLIANCE POLICIES AND PROCEDURES TO REQUIRE IARS SPECIFICALLY TO IDENTIFY OR EVALUATE AVAILABLE INSTITUTIONAL SHARE CLASSES AND DID NOT UPDATE OR ENHANCE ITS POLICIES OR PROCEDURES TO ADDRESS INSTANCES IN WHICH IARS WERE RECOMMENDING, PURCHASING, OR HOLDING CLASS A SHARES WHEN LESS COSTLY CLASS I SHARES WERE AVAILABLE. BY VIRTUE OF THE CONDUCT DESCRIBED THE FIRM WILLFULLY VIOLATED SECTIONS 206(2), 206(4) AND 207 OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 09/14/2017 Docket/Case Number: 3-18178
Principal Product Type: Mutual Fund(s) Other Product Type(s): ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 32 www.finra.org/brokercheck User Guidance
Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:
Resolution: Order Resolution Date: 09/14/2017 Does the order constitute a Yes final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $1,148,071.77 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: PREJUDGMENT INTEREST; NO LATER THAN 200 DAYS FOLLOWING THE DATE OF THIS ORDER, THE FIRM WILL PROVIDE TO THE COMMISSION STAFF AN ACCOUNTING OF REIMBURSEMENTS OF OUTSTANDING REBATES TO AFFECTED CLIENTS, THE ACCURACY OF WHICH MUST BE CERTIFIED BY THE APPROPRIATE OFFICER AT THE FIRM. Sanction Details: THE FIRM WAS CENSURED, SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2), 206(4) AND 207 OF THE ADVISERS ACT AND RULE 206(4)- 7 THEREUNDER, DISGORGE $34,560.93 AND PAY PREJUDGMENT INTEREST OF $4,950.66, NO LATER THAN 200 DAYS FOLLOWING THE DATE OF THIS ORDER, THE FIRM WILL PROVIDE TO THE COMMISSION STAFF AN ACCOUNTING OF REIMBURSEMENTS OF OUTSTANDING REBATES TO AFFECTED CLIENTS, THE ACCURACY OF WHICH MUST BE CERTIFIED BY THE APPROPRIATE OFFICER AT THE FIRM, AND ORDERED TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $1,148,071.77. Regulator Statement IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THE FIRM HAS SUBMITTED AN OFFER OF SETTLEMENT (THE OFFER) WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER THE FIRM AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THE FIRM CONSENTS TO THE ENTRY OF THIS ©2021 FINRA. All rights reserved. Report aboutORDER TRUIST INSTITUTING INVESTMENT SERVICES,ADMINISTRATIVE INC. AND CEASE-AND-DESIST 33 PROCEEDINGS PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER (ORDER). THE FIRM WILLFULLY VIOLATED SECTIONS 206(2), 206(4) AND 207 OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE FIRM'S OFFER. ACCORDINGLY, PURSUANT TO SECTION 15(B)(4) OF THE EXCHANGE ACT AND SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT, IT IS HEREBY ORDERED THAT THE FIRM SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2), 206(4) AND 207 OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. THE FIRM IS CENSURED. THE FIRM SHALL, WITHIN 210 DAYS AFTER ENTRY OF THIS ORDER, DISGORGE $34,560.93 AND PAY PREJUDGMENT INTEREST OF $4,950.66. NO LATER THAN 200 DAYS FOLLOWING THE DATE OF THIS ORDER, THE FIRM WILL PROVIDE TO THE COMMISSION STAFF AN ACCOUNTING OF REIMBURSEMENTS OF OUTSTANDING REBATES TO AFFECTED CLIENTS, THE ACCURACY OF WHICH MUST BE CERTIFIED BY THE APPROPRIATE OFFICER AT THE FIRM. THE FIRM SHALL, WITHIN 10 DAYS AFTER ENTRY OF THIS ORDER, PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $1,148,071.77. IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, THE FIRM HAS SUBMITTED AN OFFER OF SETTLEMENT (THE OFFER) WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE www.finra.org/brokercheck COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE User Guidance FINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER THE FIRM AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, THE FIRM CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER (ORDER). THE FIRM WILLFULLY VIOLATED SECTIONS 206(2), 206(4) AND 207 OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE FIRM'S OFFER. ACCORDINGLY, PURSUANT TO SECTION 15(B)(4) OF THE EXCHANGE ACT AND SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT, IT IS HEREBY ORDERED THAT THE FIRM SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2), 206(4) AND 207 OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. THE FIRM IS CENSURED. THE FIRM SHALL, WITHIN 210 DAYS AFTER ENTRY OF THIS ORDER, DISGORGE $34,560.93 AND PAY PREJUDGMENT INTEREST OF $4,950.66. NO LATER THAN 200 DAYS FOLLOWING THE DATE OF THIS ORDER, THE FIRM WILL PROVIDE TO THE COMMISSION STAFF AN ACCOUNTING OF REIMBURSEMENTS OF OUTSTANDING REBATES TO AFFECTED CLIENTS, THE ACCURACY OF WHICH MUST BE CERTIFIED BY THE APPROPRIATE OFFICER AT THE FIRM. THE FIRM SHALL, WITHIN 10 DAYS AFTER ENTRY OF THIS ORDER, PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $1,148,071.77. i Reporting Source: Firm Current Status: Final Allegations: BETWEEN 12/2011 AND 6/2015, THE FIRM BREACHED ITS FIDUCIARY DUTY TO ADVISORY CLIENTS, MADE INADEQUATE DISCLOSURES THAT FAILED TO EXPLAIN CERTAIN CONFLICTS OF INTEREST, AND HAD DEFICIENCIES IN COMPLIANCE POLICIES AND PROCEDURES IN CONNECTION WITH MUTUAL FUND SHARE CLASS SELECTION PROCESSES. Initiated By: U.S. SECURITIES AND EXCHANGE COMMISSION Date Initiated: 09/14/2017 Docket/Case Number: 3-18178
Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief CIVIL AND ADMINISTRATIVE PENALTY/FINE Sought: RESTITUTION ©2021 FINRA. All rights reserved. Report aboutCENSURE TRUIST INVESTMENT SERVICES, INC. 34 www.finra.org/brokercheck User Guidance
Other Sanction(s)/Relief CIVIL AND ADMINISTRATIVE PENALTY/FINE Sought: RESTITUTION CENSURE
Resolution: Settled Resolution Date: 09/14/2017 Sanctions Ordered: Censure Monetary/Fine $1,148,071.77 Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: 1) FIRM SHALL WITHIN 210 DAYS OF ENTRY OF ORDER DISGORGE $34,560.93 AND PAY PREJUDGMENT INTEREST OF $4,950.66 TO THE COMMISSION; (2) WITHIN 200 DAYS FOLLOWING THE DATE OF ORDER PROVIDE AN ACCOUNTING OF REIMBURSEMENTS OF OUTSTANDING REBATES TO AFFECTED CLIENTS; (3) WITHIN 10 DAYS AFTER ENTRY OF ORDER PAY A CIVIL MONETARY PENALTY OF $1,148,071.77 TO THE COMMISSION. Firm Statement BETWEEN 12/2011 AND 6/2015, THE FIRM BREACHED ITS FIDUCIARY DUTY TO ADVISORY CLIENTS, MADE INADEQUATE DISCLOSURES THAT FAILED TO EXPLAIN CERTAIN CONFLICTS OF INTEREST, AND HAD DEFICIENCIES IN COMPLIANCE POLICES AND PROCEDURES IN CONNECTION WITH MUTUAL FUND SHARE CLASS SELECTION PROCESSES. DISPOSITION CONDITIONS AND DATES: (1) FIRM SHALL WITHIN 210 DAYS OF ENTRY OF ORDER DISGORGE $34,560.93 AND PAY PREJUDGMENT INTEREST OF $4,950.66 TO THE COMMISSION; (2) WITHIN 200 DAYS FOLLOWING THE DATE OF ORDER PROVIDE AN ACCOUNTING OF REIMBURSEMENTS OF OUTSTANDING REBATES TO AFFECTED CLIENTS; (3) WITHIN 10 DAY AFTER ENTRY OF ORDER PAY A CIVIL MONETARY PENALTY OF $1,148,071.77 TO THE COMMISSION. i Disclosure 3 of 12 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO MONITOR THE PROPER ASSESSMENT OF FEES CHARGED TO CERTAIN INVESTMENT ADVISORY ACCOUNTS. THE FINDINGS STATED THAT THE FIRM OVERCHARGED INVESTMENT ADVISORY FEES TO 926 CLIENT ACCOUNTS ENROLLED IN ONE OF THE FIRM'S INVESTMENT ADVISORY PROGRAMS. THESE OVERCHARGES ©2021 FINRA. All rights reserved. Report aboutRESULTED TRUIST INVESTMENT FROM THE SERVICES, INSTALLATION INC. OF NEW FEE ENGINE SOFTWARE BY 35 THE FIRM'S CLEARING FIRM THAT, WITHOUT THE FIRM'S KNOWLEDGE, FAILED TO CORRECTLY BUNDLE CERTAIN ASSET CLASSES FOR THE PURPOSE OF CALCULATING BREAKPOINT DISCOUNTS FOR FEES. THE FIRM FAILED TO DISCOVER THE INVESTMENT ADVISORY FEE OVERCHARGES FOR A PERIOD OF APPROXIMATELY TWO AND A HALF YEARS. ADDITIONALLY, THE FIRM FAILED TO CONDUCT ADEQUATE PERIODIC REVIEWS TO ENSURE THAT THE PROPER FEES WERE ASSESSED FOR CERTAIN INVESTMENT ADVISORY ACCOUNTS. THE FIRM HAS REIMBURSED ALL AFFECTED CLIENTS IN THE TOTAL AMOUNT OF APPROXIMATELY $421,743 PLUS INTEREST. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM www.finra.org/brokercheck REASONABLY DESIGNED TO MONITOR THE PROPER ASSESSMENT OF User Guidance FEES CHARGED TO CERTAIN INVESTMENT ADVISORY ACCOUNTS. THE FINDINGS STATED THAT THE FIRM OVERCHARGED INVESTMENT ADVISORY FEES TO 926 CLIENT ACCOUNTS ENROLLED IN ONE OF THE FIRM'S INVESTMENT ADVISORY PROGRAMS. THESE OVERCHARGES RESULTED FROM THE INSTALLATION OF NEW FEE ENGINE SOFTWARE BY THE FIRM'S CLEARING FIRM THAT, WITHOUT THE FIRM'S KNOWLEDGE, FAILED TO CORRECTLY BUNDLE CERTAIN ASSET CLASSES FOR THE PURPOSE OF CALCULATING BREAKPOINT DISCOUNTS FOR FEES. THE FIRM FAILED TO DISCOVER THE INVESTMENT ADVISORY FEE OVERCHARGES FOR A PERIOD OF APPROXIMATELY TWO AND A HALF YEARS. ADDITIONALLY, THE FIRM FAILED TO CONDUCT ADEQUATE PERIODIC REVIEWS TO ENSURE THAT THE PROPER FEES WERE ASSESSED FOR CERTAIN INVESTMENT ADVISORY ACCOUNTS. THE FIRM HAS REIMBURSED ALL AFFECTED CLIENTS IN THE TOTAL AMOUNT OF APPROXIMATELY $421,743 PLUS INTEREST. Initiated By: FINRA Date Initiated: 09/02/2014 Docket/Case Number: 2011029668001
Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:
Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/02/2014 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $80,000.00 Other Sanctions Ordered: Sanction Details: SEE ABOVE Regulator Statement FINE PAID IN FULL ON SEPTEMBER 15, 2014. i Reporting Source: Firm
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 36 www.finra.org/brokercheck User Guidance
Current Status: Final Allegations: NASD RULE 3010(A) AND FINRA RULE 2010 -- DURING THE PERIOD FROM JANUARY 1, 2009 THROUGH JULY 31, 2011, SUNTRUST INVESTMENT SERVICES, INC. ALLEGEDLY FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO MONITOR THE PROPER ASSESSMENT OF FEES CHARGED TO 926 INVESTMENT ADVISORY ACCOUNTS. Initiated By: FINRA Date Initiated: 09/02/2014 Docket/Case Number: 2011029668001
Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:
Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/02/2014 Sanctions Ordered: Censure Monetary/Fine $80,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM ACCEPTED AND CONSENTED TO THE ENTRY OF FINDINGS AND TO THE IMPOSITION OF A CENSURE AND FINE OF $80,000. Firm Statement THROUGH THE AWC ACCEPTED BY FINRA ON SEPTEMBER 2, 2014, THE FIRM CONSENTED TO THE ENTRY OF FINDINGS AND TO THE IMPOSITION OF A CENSURE AND FINE OF $80,000 WITHOUT ADMITTING OR DENYING THE FINDINGS, SOLELY FOR THE PURPOSES OF THAT PROCEEDING, AND WITHOUT ADJUDICATION OF ANY ISSUE OF LAW OR FACT. THE FIRM SELF- REPORTED THIS MATTER TO FINRA AND VOLUNTARILY REIMBURSED A TOTAL OF $444,361.78, INCLUDING INTEREST, TO ALL AFFECTED ACCOUNTS. i Disclosure 4 of 12 Reporting Source: Regulator
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 37 www.finra.org/brokercheck User Guidance
Current Status: Final Allegations: NASD RULES 2110, 2210, 2211, 3010, MSRB RULES G-21, G-27: THE FIRM USED MATERIALS WITH CUSTOMERS AND PROSPECTIVE CUSTOMERS THAT WERE NOT FAIR AND BALANCED AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATING THE FACTS IN REGARD TO PURCHASES OF AUCTION RATE SECURITIES (ARS). AMONG OTHER THINGS, THE MATERIALS USED BY THE FIRM FAILED TO ADEQUATELY DISCLOSE THE RISKS OF INVESTING IN ARS, INCLUDING THE RISK THAT ARS AUCTIONS COULD FAIL, THAT INVESTMENTS IN ARS COULD BECOME ILLIQUID, AND THAT CUSTOMERS MIGHT BE UNABLE TO OBTAIN ACCESS TO FUNDS INVESTED IN ARS FOR SUBSTANTIAL PERIODS OF TIME. THE MATERIALS USED BY THE FIRM ALSO MADE INAPPROPRIATE COMPARISONS BETWEEN ARS AND OTHER MATERIALLY DIFFERENT INVESTMENTS. THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES, AND FAILED TO ESTABLISH AND MAINTAIN PROCEDURES THAT WERE REASONABLY DESIGNED TO ENSURE THAT IT MARKETED AND SOLD ARS IN COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND APPLICABLE NASD AND MSRB RULES. FOR INSTANCE, THE FIRM FAILED TO MAINTAIN PROCEDURES REASONABLY DESIGNED TO ENSURE THAT ITS REGISTERED REPRESENTATIVES ACCURATELY DESCRIBED ARS TO CUSTOMERS DURING SALES PRESENTATIONS AND THAT REPRESENTATIVES PROVIDED CUSTOMERS WITH ADEQUATE DISCLOSURE OF THE RISKS OF ARS, INCLUDING THE RISK THAT ARS AUCTIONS COULD FAIL AND THAT INVESTMENTS IN ARS COULD THEREFORE BECOME ILLIQUID. THE FIRM ALSO FAILED TO PROVIDE ADEQUATE TRAINING TO ITS REGISTERED REPRESENTATIVES REGARDING THE FEATURES AND CHARACTERISTICS OF ARS, ESPECIALLY THOSE AFFECTING LIQUIDITY, AND THE DIFFERENCE BETWEEN ARS AND OTHER INVESTMENTS. FURTHER, THE FIRM FAILED TO ESTABLISH AND MAINTAIN PROCEDURES THAT WERE REASONABLY DESIGNED TO ENSURE THAT THE WRITTEN MATERIALS IT USED IN CONNECTION WITH THE MARKETING AND SALES OF ARS COMPLIED WITH THE APPROPRIATE DISCLOSURE STANDARDS IN NASD RULES 2210 AND 2211 AND MSRB RULE G-21. Initiated By: FINRA Date Initiated: 07/26/2011 Docket/Case Number: 2008016036101
Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Other Sought: ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 38 www.finra.org/brokercheck User Guidance
Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:
Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/26/2011 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $400,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE IT IS CENSURED, FINED $400,000 ($200,000 OF WHICH PERTAINS TO VIOLATIONS OF MSRB RULES G-27 AND G-21). THE FIRM FURTHER AGREES TO THE FOLLOWING UNDERTAKING: THE FIRM HAS COMPLETED ITS VOLUNTARY REPURCHASE AT PAR OF ARS THAT WERE SUBJECT TO AUCTIONS THAT CONSISTENTLY FAILED DURING THE PERIOD FROM FEBRUARY 28, 2008 THROUGH NOVEMBER 24, 2008, AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTIONS (ELIGIBLE ARS) FROM CERTAIN ARS INVESTORS (RELEVANT CLASS). COMMENCING NO LATER THAN SIX MONTHS FROM THE DATE THE AWC IS ACCEPTED BY FINRA, THE FIRM AGREES TO CONTINUE TO MAKE ITS BEST EFFORTS TO PROVIDE LIQUIDITY TO ALL OTHER INVESTORS NOT IN THE RELEVANT CLASS BUT WHO PURCHASED ARS FROM THE FIRM. NO LATER THAN SIX MONTHS FROM THE DATE THE AWC IS ACCEPTED, ANY INVESTOR IN THE RELEVANT CLASS THAT THE FIRM CAN REASONABLY IDENTIFY WHO SOLD ARS BELOW PAR BETWEEN FEBRUARY 28, 2008 AND THE DATE THE AWC IS ACCEPTED BY FINRA, WILL BE PAID THE DIFFERENCE BETWEEN PAR AND THE PRICE AT WHICH THE INVESTORS SOLD THE ARS. THE FIRM AGREES TO ARBITRATE CLAIMS FOR CONSEQUENTIAL DAMAGES FILED BY INVESTORS IN THE RELEVANT CLASS RELATING TO ARS THROUGH A SPECIAL ARBITRATION PROGRAM (SAP) IN ACCORDANCE WITH RULES SET FORTH BY FINRA DISPUTE RESOLUTION UNDER THE AUTHORITY OF THIS AWC. NO LATER THAN SIXTY DAYS FOLLOWING THE DATE OF THIS AWC, THE FIRM SHALL NOTIFY INVESTORS IN THE RELEVANT CLASS THAT THEY ARE ELIGIBLE TO SEEK CONSEQUENTIAL DAMAGES RELATED TO ARS THROUGH THE SAP. ©2021 FINRA. All rights reserved. Report about[CONTINUED TRUIST INVESTMENT IN COMMENT] SERVICES, INC. 39 WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE IT IS CENSURED, FINED $400,000 ($200,000 OF WHICH PERTAINS TO VIOLATIONS OF MSRB RULES G-27 AND G-21). THE FIRM FURTHER AGREES TO THE FOLLOWING UNDERTAKING: THE FIRM HAS COMPLETED ITS VOLUNTARY REPURCHASE AT PAR OF ARS THAT WERE SUBJECT TO AUCTIONS THAT CONSISTENTLY FAILED DURING THE PERIOD FROM FEBRUARY 28, 2008 THROUGH NOVEMBER 24, 2008, AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTIONS (ELIGIBLE ARS) FROM CERTAIN ARS INVESTORS (RELEVANT CLASS). COMMENCING NO LATER THAN SIX MONTHS FROM THE DATE THE AWC IS ACCEPTED BY FINRA, THE FIRM AGREES TO CONTINUE TO MAKE ITS BEST EFFORTS TO PROVIDE LIQUIDITY TO ALL OTHER INVESTORS NOT IN THE RELEVANT CLASS BUT WHO PURCHASED ARS FROM THE FIRM. NO LATER THAN SIX MONTHS FROM THE DATE THE AWC IS ACCEPTED, ANY INVESTOR IN THE RELEVANT CLASS THAT THE FIRM CAN REASONABLY IDENTIFY WHO SOLD ARS BELOW PAR BETWEEN FEBRUARY 28, 2008 AND THE DATE THE AWC IS ACCEPTED BY FINRA, WILL BE PAID THE DIFFERENCE BETWEEN PAR AND THE PRICE AT WHICH THE INVESTORS SOLD THE ARS. THE FIRM AGREES TO ARBITRATE CLAIMS FOR CONSEQUENTIAL DAMAGES FILED BY INVESTORS IN THE RELEVANT CLASS RELATING TO ARS THROUGH A SPECIAL ARBITRATION PROGRAM www.finra.org/brokercheck (SAP) IN ACCORDANCE WITH RULES SET FORTH BY FINRA DISPUTE User Guidance RESOLUTION UNDER THE AUTHORITY OF THIS AWC. NO LATER THAN SIXTY DAYS FOLLOWING THE DATE OF THIS AWC, THE FIRM SHALL NOTIFY INVESTORS IN THE RELEVANT CLASS THAT THEY ARE ELIGIBLE TO SEEK CONSEQUENTIAL DAMAGES RELATED TO ARS THROUGH THE SAP. [CONTINUED IN COMMENT] Regulator Statement [CONTINUED FROM SANCTION DETAIL]: THE FIRM SHALL PROVIDE FINRA WITH A REPORT NO LATER THAN 30 DAYS FOLLOWING THE DATE OF THIS AWC SETTING FORTH (A) THE NAMES AND ACCOUNT NUMBERS OF EACH ARS CUSTOMER TO WHOM THE BUYBACK OFFER WAS MADE, (B) AN ACCOUNTING OF EACH INSTANCE IN WHICH SUCH ARS CUSTOMERS ACCEPTED THE BUYBACK OFFER AND SOLD ARS HOLDING TO THE FIRM, AND (C) THE NAMES, ACCOUNT NUMBERS, AND AN ACCOUNTING OF THOSE CUSTOMERS PAID. THE FIRM SHALL ALSO NOTIFY FINRA WITHIN 30 DAYS OF THE COMPLETION OF THE BEST EFFORTS UNDERTAKING SET FORTH ABOVE OF THE NATURE AND RESULTS OF SUCH EFFORTS. THE ACCURACY OF SUCH REPORTS SHALL BE CERTIFIED BY THE CHIEF COMPLIANCE OFFICER OF THE FIRM. IN DETERMINING THE APPROPRIATE SANCTIONS IN THIS MATTER, FINRA NOTES THAT THE FIRM HAS ADDRESSED SOME OF THE HARM SUSTAINED BY ITS CUSTOMERS AS A RESULT OF THE ILLIQUIDITY IN THE ARS MARKET. SPECIFICALLY, FOLLOWING THE ARS FAILURES IN FEBRUARY 2008, THE FIRM REPURCHASED ARS ON A CUSTOMER-BY-CUSTOMER BASIS. IN DECEMBER 2008, THE FIRM VOLUNTARILY COMMENCED A BROADER BUYBACK OF ARS, INCLUDING OFFERING TO BUY BACK ALL ARS PURCHASED PRIOR TO FEBRUARY 28, 2008, THAT CONSISTENTLY FAILED FOLLOWING THAT DATE, FROM CERTAIN CUSTOMERS WHO HELD ARS IN FIRM ACCOUNTS OR WHO HAD PURCHASED ARS FROM THE FIRM AND HAD TRANSFERRED THE ACCOUNT TO ANOTHER BROKER-DEALER. TO DATE, THE FIRM HAS REPURCHASED APPROXIMATELY $262.2 MILLION IN ARS FROM THESE CUSTOMERS, AND EACH REPURCHASE WAS MADE AT PAR. i Reporting Source: Firm Current Status: Final Allegations: NASD RULES 2110, 2210, 2211, 3010, MSRB RULES G-21, G-27: THE FIRM USED MATERIALS WITH CUSTOMERS AND PROSPECTIVE CUSTOMERS THAT WERE NOT FAIR AND BALANCED AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATING THE FACTS IN REGARD TO PURCHASES OF AUCTION RATE SECURITIES (ARS). AMONG OTHER THINGS, THE MATERIALS USED BY THE FIRM FAILED TO ADEQUATELY DISCLOSE THE RISKS OF INVESTING IN ARS, INCLUDING THE RISK THAT ARS AUCTIONS COULD FAIL, THAT INVESTMENTS IN ARS COULD BECOME ILLIQUID, AND THAT CUSTOMERS MIGHT BE UNABLE TO OBTAIN ACCESS TO FUNDS INVESTED IN ARS FOR SUBSTANTIAL PERIODS OF TIME. THE MATERIALS USED BY THE FIRM ALSO MADE INAPPROPRIATE COMPARISONS BETWEEN ARS AND OTHER MATERIALLY DIFFERENT INVESTMENTS. THE FIRM ©2021 FINRA. All rights reserved. Report aboutFAILED TRUIST TO INVESTMENT ESTABLISH SERVICES, AND MAINTAIN INC. A SUPERVISORY SYSTEM, 40 INCLUDING WRITTEN SUPERVISORY PROCEDURES, AND FAILED TO ESTABLISH AND MAINTAIN PROCEDURES THAT WERE REASONABLY DESIGNED TO ENSURE THAT IT MARKETED AND SOLD ARS IN COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND APPLICABLE NASD AND MSRB RULES. FOR INSTANCE, THE FIRM FAILED TO MAINTAIN PROCEDURES REASONABLY DESIGNED TO ENSURE ITS REGISTERED REPRESENTATIVES ADEQUATELY DESCRIBED ARS TO CUSTOMERS DURING SALES PRESENTATIONS AND THAT REPRESENTATIVES PROVIDED CUSTOMERS WITH ADEQUATE DISCLOSURE OF THE RISKS OF ARS, INCLUDING THE RISK THAT ARS AUCTIONS COULD FAIL AND THAT INVESTMENTS IN ARS COULD THEREFORE BECOME ILLIQUID. THE FIRM ALSO FAILED TO PROVIDE ADEQUATE TRAINING TO ITS REPRESENTATIVES REGARDING THE FEATURES AND CHARACTERISTICS OF ARS, ESPECIALLY THOSE AFFECTING LIQUIDITY, AND THE DIFFERENCE BETWEEN ARS AND OTHER INVESTMENTS. FURTHER, THE FIRM FAILED TO ESTABLISH AND MAINTAIN PROCEDURES THAT WERE REASONABLY DESIGNED TO ENSURE THAT THE WRITTEN MATERIALS IT USED IN CONNECTION WITH THE MARKETING AND SALES OF ARS COMPLIED WITH THE APPROPRIATE DISCLOSURE STANDARDS IN NASD RULES 2210 AND 2211 AND MSRB RULE G-21. NASD RULES 2110, 2210, 2211, 3010, MSRB RULES G-21, G-27: THE FIRM USED MATERIALS WITH CUSTOMERS AND PROSPECTIVE CUSTOMERS THAT WERE NOT FAIR AND BALANCED AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATING THE FACTS IN REGARD TO PURCHASES OF AUCTION RATE SECURITIES (ARS). AMONG OTHER THINGS, THE MATERIALS USED BY THE FIRM FAILED TO ADEQUATELY DISCLOSE THE RISKS OF INVESTING IN ARS, INCLUDING THE RISK THAT ARS AUCTIONS www.finra.org/brokercheck COULD FAIL, THAT INVESTMENTS IN ARS COULD BECOME ILLIQUID, AND User Guidance THAT CUSTOMERS MIGHT BE UNABLE TO OBTAIN ACCESS TO FUNDS INVESTED IN ARS FOR SUBSTANTIAL PERIODS OF TIME. THE MATERIALS USED BY THE FIRM ALSO MADE INAPPROPRIATE COMPARISONS BETWEEN ARS AND OTHER MATERIALLY DIFFERENT INVESTMENTS. THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES, AND FAILED TO ESTABLISH AND MAINTAIN PROCEDURES THAT WERE REASONABLY DESIGNED TO ENSURE THAT IT MARKETED AND SOLD ARS IN COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND APPLICABLE NASD AND MSRB RULES. FOR INSTANCE, THE FIRM FAILED TO MAINTAIN PROCEDURES REASONABLY DESIGNED TO ENSURE ITS REGISTERED REPRESENTATIVES ADEQUATELY DESCRIBED ARS TO CUSTOMERS DURING SALES PRESENTATIONS AND THAT REPRESENTATIVES PROVIDED CUSTOMERS WITH ADEQUATE DISCLOSURE OF THE RISKS OF ARS, INCLUDING THE RISK THAT ARS AUCTIONS COULD FAIL AND THAT INVESTMENTS IN ARS COULD THEREFORE BECOME ILLIQUID. THE FIRM ALSO FAILED TO PROVIDE ADEQUATE TRAINING TO ITS REPRESENTATIVES REGARDING THE FEATURES AND CHARACTERISTICS OF ARS, ESPECIALLY THOSE AFFECTING LIQUIDITY, AND THE DIFFERENCE BETWEEN ARS AND OTHER INVESTMENTS. FURTHER, THE FIRM FAILED TO ESTABLISH AND MAINTAIN PROCEDURES THAT WERE REASONABLY DESIGNED TO ENSURE THAT THE WRITTEN MATERIALS IT USED IN CONNECTION WITH THE MARKETING AND SALES OF ARS COMPLIED WITH THE APPROPRIATE DISCLOSURE STANDARDS IN NASD RULES 2210 AND 2211 AND MSRB RULE G-21. Initiated By: FINRA Date Initiated: 07/26/2011 Docket/Case Number: 2008016036101
Principal Product Type: Other Other Product Type(s): AUCTION RATE SECURITIES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:
Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/26/2011 Sanctions Ordered: Censure Monetary/Fine $400,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE IT IS CENSURED, FINED $400,000 ($200,000 OF WHICH ©2021 FINRA. All rights reserved. Report aboutPERTAINS TRUIST INVESTMENTTO VIOLATIONS SERVICES, OF MSRBINC. RULES G-27 AND G-21). THE FIRM 41 FURTHER AGREES TO THE FOLLOWING UNDERTAKING: THE FIRM HAS COMPLETED ITS VOLUNTARY REPURCHASE AT PAR OF ARS THAT WERE SUBJECT TO AUCTIONS THAT CONSISTENTLY FAILED FROM FEBRUARY 28, 2008 THROUGH NOVEMBER 24, 2008, AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTIONS (ELIGIBLE ARS) FROM CERTAIN ARS INVESTORS (RELEVANT CLASS). COMMENCING NO LATER THAN SIX MONTHS FROM THE DATE OF THE AWC IS ACCEPTED BY FINRA, THE FIRM AGREES TO CONTINUE TO MAKE ITS BEST EFFORTS TO PROVIDE LIQUIDITY TO ALL OTHER INVESTORS NOT IN THE RELEVANT CLASS BUT WHO PURCHASED ARS FROM THE FIRM. NO LATER THAN SIX MONTHS FROM THE DATE THE AWC IS ACCEPTED, ANY INVESTOR IN THE RELEVANT CLASS THAT THE FIRM CAN REASONABLY IDENTIFY WHO SOLD ARS BELOW PAR BETWEEN FEBRUARY 28, 2008 AND THE DATE THE AWC IS ACCEPTED BY FINRA, WILL BE PAID THE DIFFERENCE BETWEEN PAR AND THE PRICE AT WHICH THE INVESTORS SOLD THE ARS. THE FIRM AGREES TO ARBITRATE CLAIMS FOR CONSEQUENTIAL DAMAGES FILED BY INVESTORS IN THE RELEVANT CLASS RELATING TO ARS THROUGH A SPECIAL ARBITRATION PROGRAM (SAP) IN ACCORDANCE WITH RULES SET FORTH BY FINRA DISPUTE RESOLUTION UNDER THE AUTHORITY OF THIS AWC. NO LATER THAN SIXTY DAYS FOLLOWING THE DATE OF THIS AWC, THE FIRM SHALL NOTIFY INVESTORS IN THE RELEVANT CLASS THAT THEY ARE ELIGIBLE TO SEEK CONSEQUENTIAL DAMAGES RELATED TO ARS THROUGH THE SAP. [CONTINUED IN COMMENT] www.finra.org/brokercheck User Guidance
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE IT IS CENSURED, FINED $400,000 ($200,000 OF WHICH PERTAINS TO VIOLATIONS OF MSRB RULES G-27 AND G-21). THE FIRM FURTHER AGREES TO THE FOLLOWING UNDERTAKING: THE FIRM HAS COMPLETED ITS VOLUNTARY REPURCHASE AT PAR OF ARS THAT WERE SUBJECT TO AUCTIONS THAT CONSISTENTLY FAILED FROM FEBRUARY 28, 2008 THROUGH NOVEMBER 24, 2008, AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTIONS (ELIGIBLE ARS) FROM CERTAIN ARS INVESTORS (RELEVANT CLASS). COMMENCING NO LATER THAN SIX MONTHS FROM THE DATE OF THE AWC IS ACCEPTED BY FINRA, THE FIRM AGREES TO CONTINUE TO MAKE ITS BEST EFFORTS TO PROVIDE LIQUIDITY TO ALL OTHER INVESTORS NOT IN THE RELEVANT CLASS BUT WHO PURCHASED ARS FROM THE FIRM. NO LATER THAN SIX MONTHS FROM THE DATE THE AWC IS ACCEPTED, ANY INVESTOR IN THE RELEVANT CLASS THAT THE FIRM CAN REASONABLY IDENTIFY WHO SOLD ARS BELOW PAR BETWEEN FEBRUARY 28, 2008 AND THE DATE THE AWC IS ACCEPTED BY FINRA, WILL BE PAID THE DIFFERENCE BETWEEN PAR AND THE PRICE AT WHICH THE INVESTORS SOLD THE ARS. THE FIRM AGREES TO ARBITRATE CLAIMS FOR CONSEQUENTIAL DAMAGES FILED BY INVESTORS IN THE RELEVANT CLASS RELATING TO ARS THROUGH A SPECIAL ARBITRATION PROGRAM (SAP) IN ACCORDANCE WITH RULES SET FORTH BY FINRA DISPUTE RESOLUTION UNDER THE AUTHORITY OF THIS AWC. NO LATER THAN SIXTY DAYS FOLLOWING THE DATE OF THIS AWC, THE FIRM SHALL NOTIFY INVESTORS IN THE RELEVANT CLASS THAT THEY ARE ELIGIBLE TO SEEK CONSEQUENTIAL DAMAGES RELATED TO ARS THROUGH THE SAP. [CONTINUED IN COMMENT] Firm Statement [CONTINUED FROM SANCTION DETAIL]: THE FIRM SHALL PROVIDE FINRA WITH A REPORT NO LATER THAN 30 DAYS FOLLOWING THE DATE OF THIS AWC SETTING FORTH (A) THE NAMES OF AND ACCOUNT NUMBERS OF EACH ARS CUSTOMER TO WHOM THE BUYBACK OFFER WAS MADE, (B) AN ACCOUNTING OF EACH INSTANCE IN WHICH SUCH ARS CUSTOMERS ACCEPTED THE BUYBACK OFFER AND SOLD ARS HOLDING TO THE FIRM, AND (C) THE NAMES, ACCOUNT NUMBERS, AND AN ACCOUNTING OF THOSE CUSTOMERS PAID. THE FIRM SHALL ALSO NOTIFY FINRA WITHIN 30 DAYS OF THE COMPLETION OF THE BEST EFFORTS UNDERTAKING SET FORTH ABOVE OF THE NATURE AND RESULTS OF SUCH EFFORTS. THE ACCURACY OF SUCH REPORTS SHALL BE CERTIFIED BY THE CHIEF COMPLIANCE OFFICER OF THE FIRM. IN DETERMINING THE APPROPRIATE SANCTIONS IN THIS MATTER, FINRA NOTES THAT THE FIRM HAS ADDRESSED SOME OF THE HARM SUSTAINED BY ITS CUSTOMERS AS A RESULT OF THE ILLIQUIDITY IN THE ARS MARKET. SPECIFICALLY, FOLLOWING THE ARS FAILURES IN FEBRUARY 2008, THE FIRM REPURCHASED ARS ON A CUSTOMER-BY-CUSTOMER BASIS. IN DECEMBER 2008, THE FIRM VOLUNTARILY COMMENCED A BROADER BUYBACK OF ARS, INCLUDING OFFERING TO BUY BACK ALL ARS PURCHASED PRIOR TO FEBRUARY 28, 2008, THAT CONSISTENTLY FAILED FOLLOWING THAT DATE, FROM CERTAIN CUSTOMERS WHO HELD ARS IN ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 42 FIRM ACCOUNTS OR WHO HAD PURCHASED ARS FROM THE FIRM AND HAD TRANSFERRRED THE ACCOUNT TO ANOTHER BROKER-DEALER. TO DATE, THE FIRM HAS REPURCHASED APPROXIMATELY $262.2 MILLION IN ARS FROM THESE CUSTOMERS, AND EACH REPURCHASE WAS MADE AT PAR. [CONTINUED FROM SANCTION DETAIL]: THE FIRM SHALL PROVIDE FINRA WITH A REPORT NO LATER THAN 30 DAYS FOLLOWING THE DATE OF THIS AWC SETTING FORTH (A) THE NAMES OF AND ACCOUNT NUMBERS OF EACH ARS CUSTOMER TO WHOM THE BUYBACK OFFER WAS MADE, (B) AN ACCOUNTING OF EACH INSTANCE IN WHICH SUCH ARS CUSTOMERS ACCEPTED THE BUYBACK OFFER AND SOLD ARS HOLDING TO THE FIRM, AND (C) THE NAMES, ACCOUNT NUMBERS, AND AN ACCOUNTING OF THOSE CUSTOMERS PAID. THE FIRM SHALL ALSO NOTIFY FINRA WITHIN 30 DAYS OF THE COMPLETION OF THE BEST EFFORTS UNDERTAKING SET FORTH ABOVE OF THE NATURE AND RESULTS OF SUCH EFFORTS. THE ACCURACY OF SUCH REPORTS SHALL BE CERTIFIED BY THE CHIEF COMPLIANCE OFFICER OF THE FIRM. IN DETERMINING THE APPROPRIATE SANCTIONS IN THIS MATTER, FINRA NOTES THAT THE FIRM HAS ADDRESSED SOME OF THE HARM SUSTAINED BY ITS CUSTOMERS AS A RESULT OF THE ILLIQUIDITY IN THE ARS MARKET. SPECIFICALLY, FOLLOWING THE ARS FAILURES IN FEBRUARY 2008, THE FIRM www.finra.org/brokercheck REPURCHASED ARS ON A CUSTOMER-BY-CUSTOMER BASIS. IN User Guidance DECEMBER 2008, THE FIRM VOLUNTARILY COMMENCED A BROADER BUYBACK OF ARS, INCLUDING OFFERING TO BUY BACK ALL ARS PURCHASED PRIOR TO FEBRUARY 28, 2008, THAT CONSISTENTLY FAILED FOLLOWING THAT DATE, FROM CERTAIN CUSTOMERS WHO HELD ARS IN FIRM ACCOUNTS OR WHO HAD PURCHASED ARS FROM THE FIRM AND HAD TRANSFERRRED THE ACCOUNT TO ANOTHER BROKER-DEALER. TO DATE, THE FIRM HAS REPURCHASED APPROXIMATELY $262.2 MILLION IN ARS FROM THESE CUSTOMERS, AND EACH REPURCHASE WAS MADE AT PAR. i Disclosure 5 of 12 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 2310 AND 3010: RESPONDENT SUNTRUST INVESTMENT SERVICES, INC., THROUGH FORMER BROKERS, ENGAGED IN A PATTERN OF UNSUITABLE SHORT-TERM UIT, CEF AND MUTUAL FUND TRANSACTIONS IN THE ACCOUNTS OF CUSTOMERS, MANY WHOM WERE ELDERLY AND UNSOPHISTICATED AND HAD LISTED MODERATE INVESTMENT OBJECTIVES AND LIMITED INVESTMENT EXPERIENCE. THE FIRM, THROUGH THE BROKERS, ALSO RECOMMENDED UNSUITABLE TRANSACTIONS ON MARGIN IN CUSTOMERS' ACCOUNTS, FAILING TO DISCLOSE TO THE CUSTOMERS THE RISKS AND COSTS ASSOCIATED WITH TRADING ON MARGIN, AND LACKING A REASONABLE BASIS FOR BELIEVING THAT SUCH RECOMMENDATIONS WERE SUITABLE GIVEN EACH CUSTOMER'S INVESTMENT OBJECTIVES, FINANCIAL SITUATION AND NEEDS. THE FIRM APPROVED THE UNSUITABLE SHORT-TERM UIT AND CEF TRANSACTIONS, INCLUDING TRANSACTIONS PLACED USING MARGIN, BUT FAILED TO RESPOND ADEQUATELY TO RED FLAGS INDICATING THAT BROKERS WERE ENGAGED IN A PATTERN OF UNSUITABLE SHORT-TERM TRADING OF UITS AND CEFS, AND UNSUITABLE USE OF MARGIN. RED FLAGS INDICATING THAT THE TRANSACTIONS WERE UNSUITABLE INCLUDED: THE PATTERN OF UIT AND CEF PURCHASES AND SALES CONCENTRATED IN THE CUSTOMERS' ACCOUNTS; ANNUAL COMPLIANCE REVIEWS ALERTING THE FIRM TO CERTAIN QUESTIONABLE SHORT-TERM UIT AND CEF TRANSACTIONS; AGGREGATE YEARLY COMMISSIONS COMPRISING A SIGNIFICANT PERCENTAGE OF THE VALUE OF SOME OF THE CUSTOMERS' ACCOUNTS; AND THE FACT THAT MOST OF THE ACCOUNTS WERE OWNED BY ELDERLY CUSTOMERS WITH STATED MODERATE RISK TOLERANCES. THERE WERE ALSO RED FLAGS INDICATING UNSUITABLE USE OF MARGIN, SUCH AS THE AGE, INVESTMENT EXPERIENCE AND OBJECTIVES OF THE CUSTOMERS, TOGETHER WITH MARGIN BALANCES THAT AMOUNTED TO A SIZABLE PERCENTAGE OF THE VALUE OF THE CUSTOMERS' ACCOUNTS. THE FIRM FAILED TO RESPOND ADEQUATELY TO THESE RED FLAGS SURROUNDING THE BROKERS' TRANSACTIONS, FAILED TO CONDUCT ADEQUATE INVESTIGATION INTO THE TRANSACTIONS, INSTEAD RELYING UPON THE BROKERS' EXPLANATIONS FOR THE TRANSACTIONS, AND TOOK NO ©2021 FINRA. All rights reserved. Report aboutACTION, TRUIST SUCH INVESTMENT AS CONTACTING SERVICES, INC. THE CUSTOMERS. THE FIRM FAILED TO 43 ENSURE THAT CUSTOMERS RECEIVED THE MOST FAVORABLE SALES CHARGE DISCOUNT ON ELIGIBLE UIT PURCHASES, THEREBY CAUSING CUSTOMERS TO INCUR UNNECESSARY SALES CHARGES. THE FIRM LACKED ADEQUATE SYSTEMS AND PROCEDURES FOR UITS, CEFS, AND MARGIN ACCOUNTS. EVEN THOUGH UITS AND CEFS COMPRISED A SIGNIFICANT PORTION OF THE FIRM'S BUSINESS, IT DID NOT MAINTAIN REPORTS SPECIFIC TO, AND FAILED TO PROVIDE WRITTEN SUITABILITY GUIDANCE FOR, UITS AND CEFS. THE FIRM ALSO LACKED ADEQUATE SYSTEMS TO REVIEW THE SUITABILITY OF TRANSACTIONS USING MARGIN, AND FAILED TO MAINTAIN ADEQUATE SUPERVISORY SYSTEMS AND WRITTEN PROCEDURES TO SUPERVISE UIT AND CEF SALES AND MARGIN ACTIVITY. NASD RULES 2110, 2310 AND 3010: RESPONDENT SUNTRUST INVESTMENT SERVICES, INC., THROUGH FORMER BROKERS, ENGAGED IN A PATTERN OF UNSUITABLE SHORT-TERM UIT, CEF AND MUTUAL FUND TRANSACTIONS IN THE ACCOUNTS OF CUSTOMERS, MANY WHOM WERE ELDERLY AND UNSOPHISTICATED AND HAD LISTED MODERATE INVESTMENT OBJECTIVES AND LIMITED INVESTMENT EXPERIENCE. THE FIRM, THROUGH THE BROKERS, ALSO RECOMMENDED UNSUITABLE TRANSACTIONS ON MARGIN IN CUSTOMERS' ACCOUNTS, FAILING TO DISCLOSE TO THE CUSTOMERS THE RISKS AND COSTS ASSOCIATED WITH TRADING ON MARGIN, AND LACKING A REASONABLE BASIS FOR BELIEVING THAT SUCH RECOMMENDATIONS WERE SUITABLE GIVEN EACH CUSTOMER'S INVESTMENT OBJECTIVES, FINANCIAL SITUATION AND NEEDS. THE FIRM APPROVED THE UNSUITABLE SHORT-TERM UIT AND CEF TRANSACTIONS, INCLUDING TRANSACTIONS PLACED USING MARGIN, BUT FAILED TO RESPOND ADEQUATELY TO RED FLAGS INDICATING THAT BROKERS WERE ENGAGED IN A PATTERN OF UNSUITABLE SHORT-TERM TRADING OF UITS AND CEFS, AND UNSUITABLE USE OF MARGIN. RED FLAGS INDICATING THAT THE TRANSACTIONS WERE UNSUITABLE INCLUDED: THE PATTERN OF UIT AND CEF PURCHASES AND SALES CONCENTRATED IN THE CUSTOMERS' ACCOUNTS; ANNUAL COMPLIANCE REVIEWS ALERTING THE FIRM TO CERTAIN QUESTIONABLE SHORT-TERM UIT AND CEF TRANSACTIONS; AGGREGATE YEARLY COMMISSIONS COMPRISING A SIGNIFICANT PERCENTAGE OF THE VALUE OF SOME OF THE CUSTOMERS' ACCOUNTS; AND THE FACT THAT MOST OF THE ACCOUNTS WERE OWNED BY ELDERLY CUSTOMERS WITH STATED MODERATE RISK TOLERANCES. THERE WERE ALSO RED FLAGS INDICATING UNSUITABLE USE OF MARGIN, SUCH AS THE AGE, INVESTMENT EXPERIENCE AND OBJECTIVES OF THE CUSTOMERS, TOGETHER WITH MARGIN BALANCES THAT AMOUNTED TO A SIZABLE www.finra.org/brokercheck PERCENTAGE OF THE VALUE OF THE CUSTOMERS' ACCOUNTS. THE FIRM User Guidance FAILED TO RESPOND ADEQUATELY TO THESE RED FLAGS SURROUNDING THE BROKERS' TRANSACTIONS, FAILED TO CONDUCT ADEQUATE INVESTIGATION INTO THE TRANSACTIONS, INSTEAD RELYING UPON THE BROKERS' EXPLANATIONS FOR THE TRANSACTIONS, AND TOOK NO ACTION, SUCH AS CONTACTING THE CUSTOMERS. THE FIRM FAILED TO ENSURE THAT CUSTOMERS RECEIVED THE MOST FAVORABLE SALES CHARGE DISCOUNT ON ELIGIBLE UIT PURCHASES, THEREBY CAUSING CUSTOMERS TO INCUR UNNECESSARY SALES CHARGES. THE FIRM LACKED ADEQUATE SYSTEMS AND PROCEDURES FOR UITS, CEFS, AND MARGIN ACCOUNTS. EVEN THOUGH UITS AND CEFS COMPRISED A SIGNIFICANT PORTION OF THE FIRM'S BUSINESS, IT DID NOT MAINTAIN REPORTS SPECIFIC TO, AND FAILED TO PROVIDE WRITTEN SUITABILITY GUIDANCE FOR, UITS AND CEFS. THE FIRM ALSO LACKED ADEQUATE SYSTEMS TO REVIEW THE SUITABILITY OF TRANSACTIONS USING MARGIN, AND FAILED TO MAINTAIN ADEQUATE SUPERVISORY SYSTEMS AND WRITTEN PROCEDURES TO SUPERVISE UIT AND CEF SALES AND MARGIN ACTIVITY. Initiated By: FINRA Date Initiated: 07/22/2010 Docket/Case Number: 2006007105102
Principal Product Type: Mutual Fund(s) Other Product Type(s): UNIT INVESTMENT TRUST (UIT); CLOSED-END FUND (CEF) Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:
Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/22/2010 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $900,000.00 Other Sanctions Ordered: UNDERTAKINGS: PAY RESTITUTION TO CUSTOMERS IN THE TOTAL AMOUNT OF $539,371.28, WHICH IS THE SUM OF THE UNCOMPENSATED LOSSES INCURRED FROM THE SHORT-TERM TRANSACTIONS IN THE CUSTOMERS' ACCOUNTS AND MARGIN INTEREST, PLUS INTEREST UNTIL THE DATE THIS AWC WAS ACCEPTED BY THE NAC. A REGISTERED PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTED EFFORTS ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 44 UNDERTAKEN TO EFFECT RESTITUTION, NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE ANY CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN 120 DAYS FROM THE DATE THE AWC IS ACCEPTED, OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA STAFF, THE FIRM SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY, OR ABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS LAST KNOWN TO HAVE RESIDED. PROOF OF SUCH ACTION MUST BE MADE WITHIN 14 DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE STATE AUTHORITY. IN ADDITION, THE FIRM WILL PROVIDE REMEDIATION TO CUSTOMERS WHO, DURING THE RELEVANT PERIOD, PURCHASED UITS AND QUALIFIED FOR, BUT DID NOT RECEIVE, THE APPLICABLE ROLLOVER OR EXCHANGE DISCOUNT. WITHIN 30 DAYS OF THE EFFECTIVE DATE OF THE AWC, THE FIRM WILL SUBMIT TO FINRA A PROPOSED PLAN OF HOW IT WILL IDENTIFY AND COMPENSATE CUSTOMERS. THE FIRM SHALL COMPLETE THE REMEDIATION PROCESS WITHIN 120 DAYS FROM THE NOTICE DATE. WITHIN 150 DAYS FROM THE NOTICE DATE, THE FIRM WILL SUBMIT TO FINRA A SCHEDULE OF ALL CUSTOMERS IDENTIFIED DURING THE FIRM'S REVIEW AS HAVING NOT RECEIVED AN APPROPRIATE ROLLOVER OR EXCHANGE DISCOUNT. WITHIN 180 DAYS FROM THE NOTICE DATE, THE FIRM WILL SUBMIT TO FINRA A REPORT THAT EXPLAINS THE RESULTS OF THE FIRM'S IMPLEMENTATION OF ITS PLAN TO IDENTIFY AND COMPENSATE QUALIFYING CUSTOMERS, INCLUDING THE AMOUNTS AND MANNER OF ALL RESTITUTION PAID. CONTINUED IN COMMENTS... UNDERTAKINGS: PAY RESTITUTION TO CUSTOMERS IN THE TOTAL AMOUNT OF $539,371.28, WHICH IS THE SUM OF THE UNCOMPENSATED www.finra.org/brokercheck LOSSES INCURRED FROM THE SHORT-TERM TRANSACTIONS IN THE User Guidance CUSTOMERS' ACCOUNTS AND MARGIN INTEREST, PLUS INTEREST UNTIL THE DATE THIS AWC WAS ACCEPTED BY THE NAC. A REGISTERED PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION, NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC. IF FOR ANY REASON THE FIRM CANNOT LOCATE ANY CUSTOMER AFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN 120 DAYS FROM THE DATE THE AWC IS ACCEPTED, OR SUCH ADDITIONAL PERIOD AGREED TO BY FINRA STAFF, THE FIRM SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY, OR ABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS LAST KNOWN TO HAVE RESIDED. PROOF OF SUCH ACTION MUST BE MADE WITHIN 14 DAYS OF FORWARDING THE UNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATE STATE AUTHORITY. IN ADDITION, THE FIRM WILL PROVIDE REMEDIATION TO CUSTOMERS WHO, DURING THE RELEVANT PERIOD, PURCHASED UITS AND QUALIFIED FOR, BUT DID NOT RECEIVE, THE APPLICABLE ROLLOVER OR EXCHANGE DISCOUNT. WITHIN 30 DAYS OF THE EFFECTIVE DATE OF THE AWC, THE FIRM WILL SUBMIT TO FINRA A PROPOSED PLAN OF HOW IT WILL IDENTIFY AND COMPENSATE CUSTOMERS. THE FIRM SHALL COMPLETE THE REMEDIATION PROCESS WITHIN 120 DAYS FROM THE NOTICE DATE. WITHIN 150 DAYS FROM THE NOTICE DATE, THE FIRM WILL SUBMIT TO FINRA A SCHEDULE OF ALL CUSTOMERS IDENTIFIED DURING THE FIRM'S REVIEW AS HAVING NOT RECEIVED AN APPROPRIATE ROLLOVER OR EXCHANGE DISCOUNT. WITHIN 180 DAYS FROM THE NOTICE DATE, THE FIRM WILL SUBMIT TO FINRA A REPORT THAT EXPLAINS THE RESULTS OF THE FIRM'S IMPLEMENTATION OF ITS PLAN TO IDENTIFY AND COMPENSATE QUALIFYING CUSTOMERS, INCLUDING THE AMOUNTS AND MANNER OF ALL RESTITUTION PAID. CONTINUED IN COMMENTS... Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $900,000, WHICH INCLUDES DISGORGEMENT OF COMMISSIONS RECEIVED OF $223,997, AND SHALL COMPLY WITH THE UNDERTAKINGS. Regulator Statement CONTINUED...THE FIRM FURTHER CONSENTS TO UNDERTAKE TO COOPERATE FULLY WITH FINRA IN ANY AND ALL INVESTIGATIONS, LITIGATION OR OTHER PROCEEDINGS THAT CONCERN, RELATE OR ARISE FROM THE MATTERS DESCRIBED IN THE AWC. i Reporting Source: Firm Current Status: Final Allegations: FINRA ALLEGED VIOLATIONS OF NASD CONDUCT RULES 2110, 2310, 3010. SPECIFICALLY, FINRA ALLEGED THAT SUNTRUST, THROUGH TWO FORMER BROKERS, RECOMMENDED UNSUISTABLE SHORT-TERM UIT, CEF, AND MUTUAL FUND TRANSACTIONS IN THE ACCOUNTS OF CUSTOMERS AND ©2021 FINRA. All rights reserved. Report aboutRECOMMENDED TRUIST INVESTMENT UNSUITABLE SERVICES, TRANSACTIONSINC. ON MARGIN; THAT 45 SUNTRUST FAILED TO SUPERVISE THE TWO BROKERS, AND THAT SUNTRUST FAILED TO ENSURE THAT CUSTOMERS RECEIVED THE MOST FAVORABLE SALES CHARGE DISCOUNTS ON CERTAIN UIT PURCHASES. IN ADDITION, FINRA ALLEGED THAT SUNTRUST LACKED ADEQUATE SYSTEMS AND PROCEDURES RELATING TO UITS, CEFS, AND MARGIN ACCOUNTS. www.finra.org/brokercheck User Guidance FINRA ALLEGED VIOLATIONS OF NASD CONDUCT RULES 2110, 2310, 3010. SPECIFICALLY, FINRA ALLEGED THAT SUNTRUST, THROUGH TWO FORMER BROKERS, RECOMMENDED UNSUISTABLE SHORT-TERM UIT, CEF, AND MUTUAL FUND TRANSACTIONS IN THE ACCOUNTS OF CUSTOMERS AND RECOMMENDED UNSUITABLE TRANSACTIONS ON MARGIN; THAT SUNTRUST FAILED TO SUPERVISE THE TWO BROKERS, AND THAT SUNTRUST FAILED TO ENSURE THAT CUSTOMERS RECEIVED THE MOST FAVORABLE SALES CHARGE DISCOUNTS ON CERTAIN UIT PURCHASES. IN ADDITION, FINRA ALLEGED THAT SUNTRUST LACKED ADEQUATE SYSTEMS AND PROCEDURES RELATING TO UITS, CEFS, AND MARGIN ACCOUNTS. Initiated By: FINRA Date Initiated: 07/22/2010 Docket/Case Number: 2006007105102
Principal Product Type: Unit Investment Trust(s) Other Product Type(s): CEF, MUTUAL FUNDS Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief PAYMENT OF 539371.28 IN RESTITUTION PLUS INTEREST AS SPECIFIC BY Sought: THE AWC AND REMEDIATION TO CUSTOMERS WHO, DURING THE RELEVANT PERIOD, FAILED TO RECEIVE A ROLLOVER OR EXCHANGE DISCOUNT ON ELIGIBLE UIT PURCHASES.
Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/22/2010 Sanctions Ordered: Censure Monetary/Fine $900,000.00 Other Sanctions Ordered: PURSUANT TO THE AWC, SUNTRUST WILL UNDERTAKE TO PAY RESTITUTION TO CUSTOMERS IN THE TOTAL AMOUNT OF $539,371.28 PLUS INTEREST UNTIL THE DATE THE AWC WAS ACCEPTED BY THE NAC. SUNTRUST WILL UNDERTAKE TO PROVIDE REMEDIATION TO CUSTOMERS WHO, DURING THE RELEVANT PERIOD, PURCHASED UITS AND QUALIFIED FOR, BUT DID NOT RECEIVE, AN APPLICABLE ROLLOVER OR EXCHANGE DISCOUNT, PURSUANT TO A PLAN TO BE ACCEPTED BY FINRA. Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, SUNTRUST CONSENTED TO AN AWC WHICH DESCRIBED THE ABOVE SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM WAS CENSURED, FINED $900,000, INCLUDING DISGORGEMENT OF $223,997 IN COMMISSIONS, AND SHALL COMPLY WITH THE UNDERTAKINGS. i Disclosure 6 of 12 Reporting Source: Firm
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 46 www.finra.org/brokercheck User Guidance
Current Status: Final Allegations: ALLEGED FAILURE TO DISCLOSE ARBITRATIONS/LAWSUITS AND AGENCY ACTIONS TO WHICH STIS WAS A PARTY ON STIS'S AND MR. FIELD'S RENEWAL APPLICATIONS FOR INSURANCE AGENT LICENSES IN NEW YORK Initiated By: NEW YORK STATE INSURANCE DEPARTMENT Date Initiated: 01/09/2008 Docket/Case Number: 2008-0228-S
Principal Product Type: Insurance Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief AGREEMENT TO TAKE ALL NECESSARY STEPS TO PREVENT THE Sought: REOCCURRENCE OF SIMILAR VIOLATIONS
Resolution: Stipulation and Consent Resolution Date: 10/01/2008 Sanctions Ordered: Monetary/Fine $2,500.00 Other Sanctions Ordered: AGREEMENT TO TAKE ALL NECESSARY STEPS TO PREVENT THE REOCCURENCE OF SIMILAR VIOLATIONS Sanction Details: STIS PAID A FINE IN THE AMOUNT OF $2500.00 FOR FULL RESOLUTION OF THE ALLEGATIONS. Firm Statement ON JANUARY 9, 2008, STIS AND MR. FIELD RECEIVED A LETTER OF INQUIRY FROM THE NEW YORK STATE INSURANCE DEPARTMENT ASKING WHY CERTAIN ARBITRATION ACTIONS, LAWSUITS, AND AGENCY ACTIONS WERE NOT DISCLOSED ON RENEWAL APPLICATIONS FOR INSURANCE AGENT LICENSE. STIS AND MR. FIELD PROMPTLY RESPONDED ASSERTING THAT SUCH ACTIONS WERE INADVERTENTLY AND UNINTENTIONALLY OMITTED FROM THESE APPLICATIONS. THE INSURANCE DEPARTMENT OFFERED TO SETTLE SUCH ALLEGATIONS IN FULL FOR A FINE OF $2500 AND AN UNDERTAKING TO PREVENT SIMILAR OMISSIONS IN THE FUTURE. STIS PAID THE FINE AND THE MATTER IS CLOSED. i Disclosure 7 of 12 Reporting Source: Regulator Current Status: Final
©2021Allegations: FINRA. All rights reserved. Report aboutNASD TRUIST RULES INVESTMENT 2110, 2440, SERVICES, 3010, INC.3010(A) AND (B): SUNTRUST OPENED OVER 47 2,644 FEE-BASED BROKERAGE PROGRAM ("PORTFOLIO") ACCOUNTS WITHOUT ADEQUATELY ASSESSING WHETHER THE ACCOUNTS WERE APPROPRIATE FOR ITS CUSTOMERS. SUNTRUST FURTHER FAILED TO ADEQUATELY MONITOR THE ACTIVITY IN THE ACCOUNTS TO ENSURE THAT THEY REMAINED APPROPRIATE FOR ITS CUSTOMERS. IT'S PROCEDURES PROVIDED THAT REGISTERED REPRESENTATIVES SHOULD DETERMINE THE SUITABILITY OF PORTFOLIO ACCOUNTS BASED ON, AMONG OTHER THINGS, TRADING ACTIVITY. AT LEAST 36 ACCOUNTS THAT CONDUCTED NO TRADES FOR AT LEAST EIGHT CONSECUTIVE QUARTERS -- AND THOSE 36 ACCOUNTS WERE CHARGED OVER $129,000 IN FEES DURING THE LAST FOUR INACTIVE QUARTERS. THE FIRM FAILED TO ESTABLISH AND ENFORCE A SUPERVISORY SYSTEM AND PROCEDURES REASONABLY DESIGNED TO PROTECT CUSTOMERS FROM BEING ASSESSED BOTH A COMMISSION ON TRANSACTIONS AND A FEE ON THOSE SAME ASSETS WHEN HELD IN ACCOUNTS. IT PERMITTED CUSTOMERS TO EXCLUDE ASSETS THAT WERE PURCHASED WITH A COMMISSION FROM THE ASSET BASE FOR PORTFOLIO FEE CALCULATION PURPOSES. IN 932 INSTANCES, THE FIRM ERRONEOUSLY INCLUDED CUSTOMER ASSETS PURCHASED WITH A COMMISSION IN THE ASSET BASE USED TO CALCULATE THE ACCOUNT FEE. CONSEQUENTLY, CUSTOMERS PAID BOTH A COMMISSION ON THE ASSET AS WELL AS A FEE ON THE VALUE OF THE ASSET PURCHASED. THE DOUBLE CHARGES IN THESE 932 INSTANCES RESULTED IN APPROX. $437,500 IN EXCESS FEES AND/OR COMMISSIONS PAID BY SUNTRUST CUSTOMERS. THE FIRM FAILED TO ESTABLISH A SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO ENSURE THAT IS REG. REPRESENTATIVES CHARGED ITS CUSTOMERS FAIR AND REASONABLE COMMISSIONS ON SECURITIES TRANSACTIONS. THE FIRM EMPLOYED AN AUTOMATED COMMISSION SYSTEM THAT ALLOWED COMMISSIONS OVER FIVE PERCENT TO BE CHARGED ON CERTAIN LOW-PRICED AND LOW- QUANTITY TRANSACTIONS. IT FAILED TO ESTABLISH AN ADEQUATE SYSTEM TO MONITOR SUCH CHARGES WERE FAIR AND REASONABLE. AS A RESULT, CERTAIN CUSTOMERS WERE CHARGED COMMISSIONS THAT EXCEEDED 5%. www.finra.org/brokercheck User Guidance
Allegations: NASD RULES 2110, 2440, 3010, 3010(A) AND (B): SUNTRUST OPENED OVER 2,644 FEE-BASED BROKERAGE PROGRAM ("PORTFOLIO") ACCOUNTS WITHOUT ADEQUATELY ASSESSING WHETHER THE ACCOUNTS WERE APPROPRIATE FOR ITS CUSTOMERS. SUNTRUST FURTHER FAILED TO ADEQUATELY MONITOR THE ACTIVITY IN THE ACCOUNTS TO ENSURE THAT THEY REMAINED APPROPRIATE FOR ITS CUSTOMERS. IT'S PROCEDURES PROVIDED THAT REGISTERED REPRESENTATIVES SHOULD DETERMINE THE SUITABILITY OF PORTFOLIO ACCOUNTS BASED ON, AMONG OTHER THINGS, TRADING ACTIVITY. AT LEAST 36 ACCOUNTS THAT CONDUCTED NO TRADES FOR AT LEAST EIGHT CONSECUTIVE QUARTERS -- AND THOSE 36 ACCOUNTS WERE CHARGED OVER $129,000 IN FEES DURING THE LAST FOUR INACTIVE QUARTERS. THE FIRM FAILED TO ESTABLISH AND ENFORCE A SUPERVISORY SYSTEM AND PROCEDURES REASONABLY DESIGNED TO PROTECT CUSTOMERS FROM BEING ASSESSED BOTH A COMMISSION ON TRANSACTIONS AND A FEE ON THOSE SAME ASSETS WHEN HELD IN ACCOUNTS. IT PERMITTED CUSTOMERS TO EXCLUDE ASSETS THAT WERE PURCHASED WITH A COMMISSION FROM THE ASSET BASE FOR PORTFOLIO FEE CALCULATION PURPOSES. IN 932 INSTANCES, THE FIRM ERRONEOUSLY INCLUDED CUSTOMER ASSETS PURCHASED WITH A COMMISSION IN THE ASSET BASE USED TO CALCULATE THE ACCOUNT FEE. CONSEQUENTLY, CUSTOMERS PAID BOTH A COMMISSION ON THE ASSET AS WELL AS A FEE ON THE VALUE OF THE ASSET PURCHASED. THE DOUBLE CHARGES IN THESE 932 INSTANCES RESULTED IN APPROX. $437,500 IN EXCESS FEES AND/OR COMMISSIONS PAID BY SUNTRUST CUSTOMERS. THE FIRM FAILED TO ESTABLISH A SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO ENSURE THAT IS REG. REPRESENTATIVES CHARGED ITS CUSTOMERS FAIR AND REASONABLE COMMISSIONS ON SECURITIES TRANSACTIONS. THE FIRM EMPLOYED AN AUTOMATED COMMISSION SYSTEM THAT ALLOWED COMMISSIONS OVER FIVE PERCENT TO BE CHARGED ON CERTAIN LOW-PRICED AND LOW- QUANTITY TRANSACTIONS. IT FAILED TO ESTABLISH AN ADEQUATE SYSTEM TO MONITOR SUCH CHARGES WERE FAIR AND REASONABLE. AS A RESULT, CERTAIN CUSTOMERS WERE CHARGED COMMISSIONS THAT EXCEEDED 5%. Initiated By: FINRA Date Initiated: 10/15/2008 Docket/Case Number: E072005012301
Principal Product Type: Other Other Product Type(s): STOCKS Principal Sanction(s)/Relief Sought:
©2021Other FINRA. Sanction(s)/Relief All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 48 Sought: www.finra.org/brokercheck User Guidance
Other Sanction(s)/Relief Sought:
Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/15/2008 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $700,000.00 Other Sanctions Ordered: THE REQUIREMENT TO SUBMIT A CERTIFICATION BY A CORPORATE OFFICER THAT SUNTRUST HAS ISSUED REFUNDS PLUS INTEREST TO IDENTIFIED CUSTOMERS, WHO PAID FEES AND/OR COMMISSIONS IN THE AGGREGATE AMOUNT OF $713,362. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT MEMBER FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $700,000. i Reporting Source: Firm Current Status: Final Allegations: FINRA ALLEGED THAT SUNTRUST VIOLATED NASD CONDUCT RULES 2110, 2440, 3010, 3010(A) AND (B) IN THAT SUNTRUST FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES, REASONABLY DESIGNED TO REVIEW AND MONITOR ITS FEE-BASED BROKERAGE BUSINESS, AND SUNTRUST FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM INCLUDING WRITTEN PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA'S FAIR PRICING RULE. Initiated By: FINANCIAL INDUSTRY REGULATORY AGENCY Date Initiated: 10/15/2008 Docket/Case Number: FINRA NO. E072005012301
Principal Product Type: Other Other Product Type(s): FEE BASED BROKERAGE ACCOUNTS AND EXCESS COMMISSIONS ON EQUITIES OR "STOCKS". ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 49 www.finra.org/brokercheck User Guidance
Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief THE REQUIREMENT TO SUBMIT A CERTIFICATION BY A CORPORATE Sought: OFFICER THAT SUNTRUST HAS ISSUED REFUNDS PLUS INTEREST TO IDENTIFIED CUSTOMERS, WHO PAID FEES AND/OR COMMISSIONS IN THE AGGREGATE AMOUNT OF $713,362
Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/15/2008 Sanctions Ordered: Censure Monetary/Fine $700,000.00 Other Sanctions Ordered: THE REQUIREMENT TO SUBMIT A CERTIFICATION BY A CORPORATE OFFICER THAT SUNTRUST HAS ISSUED REFUNDS PLUS INTEREST TO IDENTIFIED CUSTOMERS WHO PAID FEES AND/OR COMMISSIONS IN THE AGGREGATE AMOUNT OF $713,362. Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, SUNTRUST CONSENTED TO AN AWC WHICH DESCRIBED THE ABOVE SANCTIONS. THE AGGREGATE AMOUNT OF $713,362 WAS PAID OVER THE FOLLOWING TIME PERIODS: NOVEMBER 2005, AUGUST 2006, AND OCTOBER 2007. SUNTRUST PAID A MONETARY FINE IN THE AMOUNT OF $700,000 ON OCTOBER 22, 2008 TO FINRA. Firm Statement ON JUNE 16, 2008 SUNTRUST EXECUTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT (AWC) WHERE IT WITHOUT ADMITTING OR DENYING THE FINDINGS, CONSENTED TO THE ABOVE DESCRIBED SANCTIONS. ON OCTOBER 15, 2008 SUNTRUST RECEIVED FINRA'S NOTICE OF ACCEPTANCE OF AWC FOR E072005012301. SUNTRUST PAID A MONETARY FINE OF $700,000 TO FINRA; AGREED TO A CENSURE; AND SUBMITTED A CERTIFICATION TO FINRA BY A CORPORATE OFFICER THAT SUNTRUST HAD ISSUED REFUNDS PLUS INTEREST TO IDENTIFIED CUSTOMERS WHO PAID FEES AND/OR COMMISSIONS IN THE AGGREGATE AMOUNT OF $713,362. i Disclosure 8 of 12 Reporting Source: Firm Current Status: Final Allegations: FIRM FAILED TO DISCLOSE FINRA (FORMERLY NASD) CONSENT ORDER - AWC - 2004000229 IN A TIMELY MANNER AND ON RENEWAL APPLICATION. Initiated By: STATE OF ALASKA DEPARTMENT OF COMMERCE COMMUNITY AND ECONOMIC DEVELOPMENT Date Initiated: 06/13/2007 ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 50 www.finra.org/brokercheck User Guidance
Date Initiated: 06/13/2007 Docket/Case Number: NO CASE NUMBER
Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief FIRM INSURANCE LICENSE NOT RENEWED Sought:
Resolution: Settled Resolution Date: 08/02/2007 Firm Statement FIRM FAILED TO DISCLOSE FINRA (FORMERLY NASD) CONSENT ORDER - AWC - 2004000229 IN A TIMELY MANNER AND ON RENEWAL APPLICATION. FIRM PAID $400 STATE IMPOSED LATE FILLING FEES. i Disclosure 9 of 12 Reporting Source: Firm Current Status: Final Allegations: INVESTMENT ADVISORY REPRESENTATIVE WAS NOT PROPERLY REGISTERED WITH THE STATE OF MARYLAND TO ACT AS AN INVESTMENT ADVISORY REPRESENTATIVE Initiated By: MARYLAND SECURITIES COMMISSION Date Initiated: 03/06/2006 Docket/Case Number: FA 2000-2028; 2006-0431
Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:
Resolution: Consent Resolution Date: 07/30/2007 Sanctions Ordered: Monetary/Fine $4,500.00
©2021Other FINRA. Sanctions All rights Ordered: reserved. Report aboutNONE TRUIST INVESTMENT SERVICES, INC. 51 www.finra.org/brokercheck User Guidance
Other Sanctions Ordered: NONE Sanction Details: CORPORATION HAS REFUNDED ADVISORY FEES EQUAL TO AMOUNT ALLOCATED TO THE INVESTMENT ADVISER REPRESENTATIVE FOR THE PEROID OF TIME THAT HE WAS NOT REGISTERED AS AN INVESTMENT ADVISER REPRESENTATIVE IN MARYLAND; CORPORATION SHALL FOLLOW COMPLAINCE POLICIES AND PROCEDURES IN CONNECTION WITH THE MATTER. Firm Statement CORPORATION HAS REFUNDED ADVISORY FEES EQUAL TO AMOUNT ALLOCATED TO THE INVESTMENT ADVISER REPRESENTATIVE FOR THE PEROID OF TIME THAT HE WAS NOT REGISTERED AS AN INVESTMENT ADVISER REPRESENTATIVE IN MARYLAND; CORPORATION SHALL FOLLOW COMPLAINCE POLICIES AND PROCEDURES IN CONNECTION WITH THE MATTER. i Disclosure 10 of 12 Reporting Source: Regulator Current Status: Final Allegations: SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-4, NASD RULES 2110 AND 3110 - FROM JANUARY 2002 THROUGH DECEMBER 2005, THE FIRM FAILED TO RETAIN E-MAILS IN COMPLIANCE WITH THE THREE-YEAR RETENTION REQUIREMENT OF SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-4 PROMULGATED THEREUNDER. Initiated By: NASD Date Initiated: 08/07/2006 Docket/Case Number: EAF0401290001
Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:
Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/07/2006 Does the order constitute a No final order based on violations of any laws or ©2021regulations FINRA. All that rights prohibit reserved. Report about TRUIST INVESTMENT SERVICES, INC. 52 fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance
Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $150,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE THE FIRM IS CENSURED AND FINED $150,000. i Reporting Source: Firm Current Status: Final Allegations: FROM JANUARY 2002 THROUGH DECEMBER 2005, SUNTRUST INVESTMENT SERVICES, INC. ("STIS") DID NOT RETAIN E-MAILS AS REQUIRED BY SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 AND NASD CONDUCT RULES 3110 AND 2110. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 08/07/2006 Docket/Case Number: AWC EAF0401290001
Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief A FINE IN THE AMOUNT OF $150,000.00 Sought:
Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/07/2006 Sanctions Ordered: Censure Monetary/Fine $150,000.00 Other Sanctions Ordered: Sanction Details: SUNTRUST INVESTMENT SERVICES AGREED TO PAY $150,000.00 WHICH WAS IMPOSED UPON NOTICE OF AN AWC. ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 53 www.finra.org/brokercheck User Guidance
Firm Statement FROM JANUARY 2002 THROUGH DECEMBER 2005, STIS DID NOT RETAIN E- MAILS AS REQUIRED BY SECTION 17(A) OF THE SECURITIES EXCHANGE ACT AND RULE 17A-4. UNTIL JULY 2003, STIS USED THE E-MAIL RETENTION SYSTEM OF ITS PARENT COMPANY, WHICH RETAINED E-MAIL BY CREATING DAILY ARCHIVAL BACK-UP TAPES OF ALL INCOMING AND OUTGOING E-MAIL. THE DAILY BACK-UP TAPES, HOWEVER, WERE PURGED AFTER 30 DAYS. EVEN AFTER THE FIRM IMPLEMENTED A NEW SYSTEM IN JULY 2003 THAT WAS DESIGNED TO CAPTURE ALL INCOMING AND OUTGOING E-MAIL, E-MAIL SENT TO AND FROM CERTAIN INDIVIDUALS AT STIS WAS NOT RETAINED AS REQUIRED. i Disclosure 11 of 12 Reporting Source: Regulator Current Status: Final Allegations: NASD CONDUCT RULE 2110 AND 3010 AND NASD MARKETPLACE RULE 6230(A)-RESPONDENT FIRM FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES EXECUTED ON A BUSINESS DAY DURING TRACE SYSTEM HOURS WITHIN 45 MINUTES OF THE TIME OF EXECUTION. THE FIRM ALSO FAILED TO REPORT TO TRACE 20 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES EXECUTED ON A BUSINESS DAY AT OR AFTER 12:00 AM EASTERN TIME THROUGH 7:59:59 AM EASTERN TIME WITHIN 45 MINUTES AFTER TRACE SYSTEM OPENS THE SAME BUSINESS DAY. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF NASD, CONCERNING TRACE REPORTING. Initiated By: NASD Date Initiated: 09/09/2005 Docket/Case Number: 2004200022901
Principal Product Type: Other Other Product Type(s): UNSPECIFIED SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:
Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/09/2005 Does the order constitute a No ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 54 final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance
Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $15, 000(CONSISTING OF A $10,000 FINE FOR THE TRACE VIOLATIONS AND A $5,000 FINE FOR THE SUPERVISION VIOLATIONS) AND AN UNDERTAKING TO REVISE THE FIRM'S SUPERVISORY PROCEDURES WITH RESPECT TO AREAS DESCRIBED IN THE ALLEGATIONS. i Reporting Source: Firm Current Status: Final Allegations: STIS FAILED TO REPORT TO TRACE 533 TRANSACTIONS IN TRACE- ELIGIBLE SECURITIES EXECUTED ON A BUSINESS DAY DURING TRACE SYSTEM HOURS WITHIN 45 MINUTES OF THE TIME OF EXECUTION AND STIS ALSO FAILED TO REPORT TO TRACE 20 TRANSACTIONS IN TRACE- ELIGIBLE SECURITIES EXECUTED ON A BUSINESS DAY AT OR AFTER 12:00 AM EST THROUGH 7:59:59 AM EST WITHIN 45 MINIUTES AFTER THE TRACE SYSTEM OPENS THE SAME BUSINESS DAY Initiated By: NASD Date Initiated: 06/29/2005 Docket/Case Number: AWC 20042000229
Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE OF $15,000 (CONSISTING OF A $10,000 FINE FOR THE TRACE Sought: VIOLATIONS AND A $5,000 FINE FOR THE SUPERVISION VIOLATIONS) AND AN UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO TRADE REPORTING IN THE TRACE SYSTEM. ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 55 www.finra.org/brokercheck User Guidance
Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/09/2005 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: ON OCTOBER 4, 2005, STIS PAID A FINE OF $15,000.00 FOR THE TRACE AND SUPERVISORY VIOLATIONS AND AGREED TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO TRADE REPORTING IN THE TRACE SYSTEM. Firm Statement STIS FAILED TO REPORT TO TRACE IN A TIMELY MANNER TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES IN TWO SEPARATE INSTANCES WHICH CONSITUTED DISTINCT VIOLATIONS OF NASD MARKETPLACE RULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD CONDUCT RULE 2110. i Disclosure 12 of 12 Reporting Source: Firm Current Status: Final Allegations: BETWEEN 2001 AND 2002, THE FIRM SOLD A SHARE MUTUAL FUND WITHOUT PROVIDING CERTAIN CUSTOMERS WITH THE REDUCTIONS IN FRONT-END LOADS OR SALES CHARGES. Initiated By: SECURITIES AND EXCHANGE COMMISSION ADMINISTRATIVE PROCEEDING FILE NO. 3-11924 Date Initiated: 05/17/2005 Docket/Case Number: 3-11924
Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:
Resolution: Order Resolution Date: 05/17/2005 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 56 Disgorgement/Restitution Cease and Desist/Injunction www.finra.org/brokercheck User Guidance
Sanctions Ordered: Censure Disgorgement/Restitution Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: FIRM SHALL PAY DISGORGEMENT AND PREJUDGMENT INTEREST: (1) FIRM SHALL MAKE A REFUND WITHIN 30 DAYS OF THE ENTRY OF ORDER TO EACH CUSTOMER IT IDENTIFIED IN THE SELF-ASSESSMENT AS HAVING NOT RECEIVED BREAKPOINT DISCOUNT TO WHICH THE CUSTOMER WAS ENTITLED; (2) FIRM TO PROVIDE WRITTEN NOTIFICATION WITHIN 30 DAYS OF THE ENTRY OF THE ORDER TO EACH CUSTOMER WHO PURCHASED CLASS A MUTUAL FUND SHARES THROUGH SUNTRUST FROM JANUARY 1, 1999 THROUGH DECEMBER 31, 2003; (3) FIRM SHALL MAKE REFUND WITHIN 30 DAYS AFTER RECEIVING REPLY FROM CUSTOMER WHO DID NOT RECEIVE DISCOUNT; (4)FIRM SHALL PAY PREJUDGMENT INTEREST ON ALL REFUNDS PAID TO CUSTOMER. Firm Statement THIS MATTER RESULTS FROM AN INDUSTRY WIDE BREAKPOINT SELF ASSESSMENT.
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 57 www.finra.org/brokercheck User Guidance
Arbitration Award - Award / Judgment Brokerage firms are not required to report arbitration claims filed against them by customers; however, BrokerCheck provides summary information regarding FINRA arbitration awards involving securities and commodities disputes between 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 13 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/13/2000 Case Number: 00-03702 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $17,250.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/31/2001 Sum of All Relief Awarded: $8,950.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 2 of 13 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING Arbitration Forum: NASD Case Initiated: 11/26/2003 Case Number: 03-07628 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BOND FUNDS; ©2021 FINRA. All rights reserved. Report aboutMUTUAL TRUIST FUNDS INVESTMENT SERVICES, INC. 58 www.finra.org/brokercheck User Guidance
Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BOND FUNDS; MUTUAL FUNDS Sum of All Relief Requested: $150,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/02/2006 Sum of All Relief Awarded: $10,577.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 3 of 13 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 08/31/2004 Case Number: 04-06112 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS; OPTIONS Sum of All Relief Requested: $228,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/26/2005 Sum of All Relief Awarded: $200,300.02 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 4 of 13 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE
©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 59 www.finra.org/brokercheck User Guidance
Arbitration Forum: NASD Case Initiated: 12/05/2006 Case Number: 06-05145 Disputed Product Type: ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $41,028.19 Disposition: AWARD AGAINST PARTY Disposition Date: 11/16/2007 Sum of All Relief Awarded: $43,703.09 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 5 of 13 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 05/05/2008 Case Number: 08-01348 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $1,000,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/20/2009 Sum of All Relief Awarded: $464,296.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 6 of 13 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- ©2021 FINRA. All rights reserved. Report aboutMISREPRESENTATION; TRUIST INVESTMENT SERVICES, ACCOUNT INC. ACTIVITY-OMISSION OF FACTS; 60 ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE www.finra.org/brokercheck User Guidance
Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 07/28/2009 Case Number: 09-04354 Disputed Product Type: VARIABLE ANNUITIES Sum of All Relief Requested: Disposition: AWARD AGAINST PARTY Disposition Date: 10/15/2010 Sum of All Relief Awarded: There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 7 of 13 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 10/23/2009 Case Number: 09-05979 Disputed Product Type: VARIABLE ANNUITIES Sum of All Relief Requested: $105,072.59 Disposition: AWARD AGAINST PARTY Disposition Date: 07/15/2010 Sum of All Relief Awarded: $30,000.01 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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i Disclosure 8 of 13 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 12/28/2009 Case Number: 09-07088 Disputed Product Type: COLLATERALIZED DEBT OBLIGATIONS Sum of All Relief Requested: $230,125.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/27/2010 Sum of All Relief Awarded: $75,000.02 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 9 of 13 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MANIPULATION; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-EXCHANGES; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 08/21/2012 Case Number: 12-02948 Disputed Product Type: COLLATERALIZED DEBT OBLIGATIONS; COLLATERALIZED MORTGAGE OBLIGATIONS; CORPORATE BONDS; STRUCTURED PRODUCTS Sum of All Relief Requested: $150,000.00
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Disposition: AWARD AGAINST PARTY Disposition Date: 12/02/2013 Sum of All Relief Awarded: $27,000.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 10 of 13 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 07/11/2014 Case Number: 14-02072 Disputed Product Type: Sum of All Relief Requested: $65,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/18/2016 Sum of All Relief Awarded: $12,996.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 11 of 13 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: FINRA Case Initiated: 07/27/2015 Case Number: 15-01300
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Disputed Product Type: MUTUAL FUNDS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $51,335.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/29/2016 Sum of All Relief Awarded: $49,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 12 of 13 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-FRAUD; ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 07/10/2020 Case Number: 20-01957 Disputed Product Type: CERTIFICATE OF DEPOSIT; COMMON STOCK; CORPORATE BONDS; EXCHANGE-TRADED FUNDS; MUNICIPAL BONDS; MUTUAL FUNDS; OTHER TYPES OF SECURITIES Sum of All Relief Requested: $2,146,052.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/01/2021 Sum of All Relief Awarded: $200,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 13 of 13 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER ©2021 FINRA. All rights reserved. Report about TRUIST INVESTMENT SERVICES, INC. 64 CONTROVERSY INVOLVED www.finra.org/brokercheck User Guidance
Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/23/1991 Case Number: 90-03548 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $425.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/31/1991 Sum of All Relief Awarded: $517.74 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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Civil Bond This type of disclosure event involves a civil bond for the brokerage firm that has been denied, paid, or revoked by a bonding company. Disclosure 1 of 2 Reporting Source: Firm Policy Holder: SUNTRUST SECURITIES, INC. Bonding Company Name: ST. PAUL FIRE AND MARINE INSURANCE CO. Disposition: Payout Disposition Date: 05/10/2000 Payout Details: TWO PAYOUTS: 5/10/00 FOR $133,000 AND 4/28/00 FOR $10,869.11 Firm Statement WIRE TRANSFER FRAUD INVOLVING THE ACCOUNT OF PEDRO P. ANTONINI i Disclosure 2 of 2 Reporting Source: Firm Policy Holder: SUNTRUST SECURITIES, INC. Bonding Company Name: ST. PAUL INSURANCE COMPANY Disposition: Payout Disposition Date: 11/01/1998 Payout Details: $15,430.11 PAID IN NOVEMEBER 1998. THE MEMBER FIRM'S BONDING COMPANY PAID OUT $15,430.11 ARISING OUT OF AN INCIDENT INVOLVING OUR REGISTERED REPRESENTATIVE, WAYNE E. WARREN-YOUNG, WHO WAS CENSURED, FINED $85,000, AND BARRED FROM ASSOCIATION WITH ANY NASD MEMBER IN ANY CAPACITY. Firm Statement THE SANCTIONS WERE BASED ON FINDINGS THAT MR. WARREN-YOUNG ACCEPTED A $50K CHECK FROM A RETAIL CUSTOMER FOR INVESTMENT IN MUTUAL FUNDS, DEPOSITED THE CHECK IN A BANK ACCOUNT OF A PRIVATE COMPANY CONTRARY TO THE CUSTOMER'S INSTRUCTION AND, WITHOUT THE MEMBER FIRM'S KNOWLEDGE. HE SUBSEQUENTLY FAILED TO COMPLY WITH THE CUSOTMER'S DEMAND FOR RETURN OF MONEY. THE CUSTOMER WAS IMMEDIATELY MADE WHOLE BY THE MEMBER FIRM. COLLECTION EFFORTS RESULTED IN A TOTAL REIMBURSEMENT OF $28K FROM MR. WARREN-YOUNG.
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