Scottrade, Inc. Crd# 8206

BrokerCheck Report SCOTTRADE, INC. CRD# 8206

Section Title Page(s) Report Summary 1

Registration and Withdrawal 2

Firm Profile 3 - 8

Firm History 9

Firm Operations 10 - 26

Disclosure Events 27

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©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 1 www.finra.org/brokercheck User Guidance Registration Withdrawal Information This section provides information relating to the date the brokerage firm ceased doing business and the firm's financial obligations to customers or other brokerage firms.

This firm terminated or 07/09/2018 withdrew registration on:

Does this brokerage firm owe No any money or securities to any customer or brokerage firm?

This firm is classified as a corporation. This firm was formed in Arizona on 05/01/1980. Its fiscal year ends in September.

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.

SCOTTRADE, INC. Doing business as SCOTTRADE, INC. CRD# 8206 SEC# 8-24760

Main Office Location 700 MARYVILLE CENTRE DRIVE ST. LOUIS, MO 63141-5824

Mailing Address PO BOX 31759 ST. LOUIS, MO 63131-0759

Business Telephone Number 314 965-1555

©2021 FINRA. All rights reserved. Report about SCOTTRADE, 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): TD AMERITRADE ONLINE HOLDINGS CORP. Is this a domestic or foreign Domestic Entity entity or an individual?

Position OWNER Position Start Date 09/2017 Percentage of Ownership 75% or more Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): BOUDROT, SUSAN M 2472538 Is this a domestic or foreign Individual entity or an individual?

Position CHIEF COMPLIANCE OFFICER Position Start Date 09/2017 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): BOYLE, STEPHEN JOHN 6501238 Is this a domestic or foreign Individual entity or an individual?

Position CHIEF FINANCIAL OFFICER Position Start Date 09/2017 Percentage of Ownership Less than 5% ©2021 FINRA. All rights reserved. Report about SCOTTRADE, 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 company?

Legal Name & CRD# (if any): DESILVA, PETER JAMES 1740057 Is this a domestic or foreign Individual entity or an individual?

Position PRESIDENT, DIRECTOR Position Start Date 09/2017 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): KIMM, DAVID ROBERT 722941 Is this a domestic or foreign Individual entity or an individual?

Position CHIEF RISK OFFICER Position Start Date 09/2017 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): NALLY, THOMAS ANDREW

Direct Owners and Executive Officers (continued) 2479301 Is this a domestic or foreign Individual entity or an individual?

Position EVP, INSTITUTIONAL SERVICES Position Start Date 09/2017 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): QUIRK, STEVEN MARK 2728768 Is this a domestic or foreign Individual entity or an individual?

Position SVP, TRADER GROUP Position Start Date 09/2017 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): RICKETTS, JUDITH K 2758924 Is this a domestic or foreign Individual entity or an individual?

Position VP, MD OPERATIONS Position Start Date 09/2017 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the©2021 firm? FINRA. All rights reserved. Report about SCOTTRADE, INC. 6 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): YATES, WILLIAM THOMAS 2749545 Is this a domestic or foreign Individual entity or an individual?

Position TREASURER, FINOP Position Start Date 09/2017 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 SCOTTRADE, INC. 7 www.finra.org/brokercheck User Guidance Firm Profile This section provides information relating to any indirect owners of the brokerage firm. Indirect Owners

Legal Name & CRD# (if any): TD AMERITRADE HOLDING CORPORATION Is this a domestic or foreign Domestic Entity entity or an individual?

Company through which TD AMERITRADE ONLINE HOLDINGS CORP indirect ownership is established Relationship to Direct Owner PARENT CORPORATION Relationship Established 09/2017 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?

©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 8 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.

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 no longer registered. The firm's registration was from 05/23/1980 to 10/04/2018.

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 6 types of businesses. Types of Business

Exchange member engaged in exchange commission business other than floor activities Broker or dealer retailing corporate equity securities over-the-counter Broker or dealer selling corporate debt securities Mutual fund retailer Municipal securities broker Put and call broker or dealer or option writer

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: INTERACTIVE BROKERS Business Address: ONE PICKWICK PLAZA GREENWICH, CT 06830 Effective Date: 01/20/2015 Description: SCOTTRADE IS AN INTRODUCING BROKER DEALER TO INTERACTIVE BROKERS ON A FULLY DISCLOSED BASIS.

This firm does have books or records maintained by a third party. Name: IRON MOUNTAIN STORAGE FACILITY Business Address: 2270 SCHUETZ ROAD SAINT LOUIS, MO 63146 Effective Date: 08/31/2008 Description: VENDOR THAT PROVIDES SECURE STORAGE FACILITY TO SCOTTRADE TO STORE ITS BUSINESS AND REGULATORY RECORDS THAT ARE IN A PHYSICAL FORMAT. Name: GLOBAL RELAY COMMUNICATIONS INC. Business Address: 220 CAMBIE STREET, 2ND FLOOR VANCOUVER, BRITISH, CANADA V6B 2M9 Effective Date: 02/01/2015 Description: GLOBAL RELAY PROVIDES SCOTTRADE WITH ELECTRONIC CORRESPONDENCE (EMAIL, CHAT, LINC, TEXT, SOCIAL MEDIA, ETC.) MONITORING AND ARCHIVING FUNCTIONALITY USING THEIR HOSTED CLOUD BASED SOLUTION. This firm does have accounts, funds, or securities maintained by a third party. Name: INTERACTIVE BROKERS Business Address: ONE PICKWICK PLAZA GREENWICH, CT 06830 Effective Date: 01/20/2015 Description: SCOTTRADE IS AN INTRODUCING BROKER DEALER TO INTERACTIVE BROKERS ON A FULLY DISCLOSED BASIS. This firm does have customer accounts, funds, or securities maintained by a third party. Name: INTERACTIVE BROKERS Business Address: ONE PICKWICK PLAZA GREENWICH, CT 06830 Effective Date: 01/20/2015 Description: SCOTTRADE IS AN INTRODUCING BROKER DEALER TO INTERACTIVE BROKERS ON A FULLY DISCLOSED BASIS.

Control Persons/Financing This firm does not have individuals who control its management or policies through agreement. ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 13 www.finra.org/brokercheck User Guidance Firm Operations Industry Arrangements (continued) 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.

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. EPOCH INVESTMENT PARTNERS, INC. is under common control with the firm. CRD #: 131556 Business Address: 399 PARK AVENUE 31ST FLOOR NEW YORK, NY 10022 Effective Date: 03/27/2013 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT OF EPOCH INVESTMENT PARTNERS, INC. THE TORONTO-DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORP. WHICH, IN TURN, IS THE PARENT COMPANY OF THE APPLICANT.

TD PRIME SERVICES LLC is under common control with the firm. CRD #: 1914 Business Address: 45 BRAODWAY 24TH FLOOR NEW YORK, NY 10006 Effective Date: 01/01/2017 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities:©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 15 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Investment Advisory No Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT FOR TD PRIME SERVICES LLC. THE TORONTO-DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

TD AMERITRADE FUTURES & FOREX LLC is under common control with the firm. Business Address: 600 WEST CHICAGO AVE. SUITE 100 CHICAGO, IL 60654 Effective Date: 03/30/2015 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: TD AMERITRADE FUTURES & FOREX, LLC. & SCOTTRADE INC. ARE SUBSIDIARIES OF THE SAME PARENT COMPANY, TD AMERITRADE HOLDING CORPORATION

TD WEALTH HOLDING (UK) LIMITED is under common control with the firm. Business Address: TRITON COURT 14/18 FINSBURY SQUARE LONDON, UK Effective Date: 04/05/2003 Foreign Entity: Yes Country: UK Securities Activities: Yes Investment Advisory No Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT OF BOTH THE APPLICANT AND TD WEALTH HOLDING (UK) LIMITED, A U.K. BASED DISCOUNT BROKER. THE TORONTO-DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT. ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 16 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

TD WATERHOUSE PRIVATE INVESTMENT COUNSEL INC is under common control with the firm. Business Address: TD TOWER, 12 FLOOR TORONTO DOMINION CENTRE TORONTO, CANADA M5K 1G8 Effective Date: 04/05/2013 Foreign Entity: Yes Country: CANANDA Securities Activities: No Investment Advisory Yes Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT OF BOTH THE APPLICANT AND TD WATERHOUSE PRIVATE INVESTMENT COUNSEL INC. THE TORONTO-DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

TORONTO DOMINION AUSTRALIA LIMITED is under common control with the firm. Business Address: L 24 9 CASTLEREAGH ST SYDNEY, AUSTRALIA NSW 2000 Effective Date: 04/05/2013 Foreign Entity: Yes Country: AUSTRALIA Securities Activities: Yes Investment Advisory No Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT OF BOTH THE APPLICANT AND TORONTO DOMINION AUSTRALIA LIMITED. THE TORONTO- DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

TD PRIVATE CLIENT WEALTH LLC is under common control with the firm. CRD #: 164484 Business Address: 444 MADISON AVENUE 11TH FLOOR ©2021 FINRA. All rights reserved. Report aboutNEW SCOTTRADE, YORK, NY INC. 10022 17 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Business Address: 444 MADISON AVENUE 11TH FLOOR NEW YORK, NY 10022 Effective Date: 02/28/2013 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory Yes Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT OF BOTH THE APPLICANT AND TD PRIVATE CLIENT WEALTH LLC. THE TORONTO- DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

THE INSURANCE AGENCY OF TD AMERITRADE LLC is under common control with the firm. Business Address: 4600 ALLIANCE GATEWAY FREEWAY FORT WORTH, TX 76177 Effective Date: 11/30/2011 Foreign Entity: No Country: Securities Activities: No Investment Advisory No Activities: Description: THE INSURANCE AGENCY OF TD AMERITRADE LLC AND THE APPLICANT ARE SUBSIDIARIES OF THE SAME PARENT COMPANY, TD AMERITRADE HOLDING CORPORATION.

TD AMERITRADE ASIA PTE. LTD. is under common control with the firm. Business Address: 1 TEMASEK AVENUE #15-02 MILLENIA TOWER SINGAPORE, SOUTHEAST ASIA 039192 Effective Date: 10/22/2010 Foreign Entity: Yes Country: SOUTHEAST ASIA Securities Activities: Yes ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 18 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Securities Activities: Yes Investment Advisory No Activities: Description: TD AMERITRADE ASIA PTE. LTD. AND SCOTTRADE INC. ARE SUBSIDIARIES OF THE SAME PARENT COMPANY, TD AMERITRADE HOLDING CORPORATION

TRADEWISE ADVISORS, INC. is under common control with the firm. CRD #: 153744 Business Address: 600 WEST CHICAGO AVENUE, SUITE100 CHICAGO, IL 60654 Effective Date: 04/26/2010 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: TRADEWISE ADVISORS, INC. AND SCOTTRADE, INC. ARE SUBSIDIARIES OF THE SAME PARENT COMPANY, TD AMERITRADE HOLDING CORPORATION

TDAM USA INC. is under common control with the firm. Business Address: 161 BAY STREET, 35TH FLOOR TORONTO ONTARIO, CANADA M5J 2T2 Effective Date: 05/31/2005 Foreign Entity: No Country: CANADA Securities Activities: No Investment Advisory Yes Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT OF TD ASSET MANAGEMENT USA INC, A REGISTERED INVESTMENT ADVISOR UNDER THE 40 ACT. THE TORONTO-DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

Organization Affiliates (continued)

TD BANK INTERNATIONAL S.A. is under common control with the firm. Business Address: 46A AVENUE JF KENNEDY L-2958 LUXEMBOURG, LUXEMBOURG Effective Date: 01/10/2006 Foreign Entity: Yes Country: LUXEMBOURG Securities Activities: Yes Investment Advisory No Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT OF TD BANK INTERNATIONAL S.A. FORMERLY KNOWN AS THE BANK OF TDW, BGL (LUXEMBOURG) AND INTERNAXX BANK S.A.. THE TORONTO-DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

TD INVESTMENT SERVICES INC is under common control with the firm. Business Address: 66 WELLINGTON STREET WEST TD TOWER, 27TH FLOOR TORONTO, CANADA Effective Date: 04/24/2006 Foreign Entity: Yes Country: CANADA Securities Activities: Yes Investment Advisory No Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT FOR TD INVESTMENT SERVICES INC, A CANADIAN MUTUAL FUND DEALER. THE TORONTO-DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

TD BANK EUROPE LIMITED is under common control with the firm. Business Address: TRITON COURT 14/18 FINSBURY SQUARE ©2021 FINRA. All rights reserved. Report aboutLONDON, SCOTTRADE, UK INC. 20 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Business Address: TRITON COURT 14/18 FINSBURY SQUARE LONDON, UK Effective Date: 04/24/2006 Foreign Entity: Yes Country: UK Securities Activities: Yes Investment Advisory No Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT FOR TD BANK EUROPE LIMITED, A EUROPEAN INVESTMENT BANK. THE TORONTO- DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

TD WATERHOUSE (CANADA) INC. is under common control with the firm. Business Address: TORONTO DOMINION TOWER TD CENTER TORONTO, CANANA M5K1A2 Effective Date: 04/24/2006 Foreign Entity: Yes Country: CANADA Securities Activities: Yes Investment Advisory No Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT FOR TD WATERHOUSE (CANADA) INC., A CANADIAN BASED DISCOUNT BROKER. THE TORONTO-DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

TD AMERITRADE, INC. is under common control with the firm. CRD #: 7870 Business Address: 200 S 108TH AVE OMAHA, NE 68154 Effective Date: 01/24/2006

Organization Affiliates (continued)

Foreign Entity: No Country: Securities Activities: Yes Investment Advisory Yes Activities: Description: TD AMERITRADE, INC. AND SCOTTRADE, INC. ARE SUBSIDIARIES OF THE SAME PARENT COMPANY, TD AMERITRADE HOLDING CORPORATION

TD AMERITRADE CLEARING, INC. is under common control with the firm. CRD #: 5633 Business Address: 200 S 108TH AVE OMAHA, NE 68154 Effective Date: 01/24/2006 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: TD AMERITRADE CLEARING, INC. AND SCOTTRADE, INC. ARE SUBSIDIARIES OF THE SAME PARENT COMPANY, TD AMERITRADE HOLDING CORPORATION

TD AMERITRADE INVESTMENT MANAGEMENT, LLC is under common control with the firm. CRD #: 111514 Business Address: 200 S 108TH AVE OMAHA, NE 68154 Effective Date: 01/24/2006 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: TD AMERITRADE INVESTMENT MANAGEMENT, LLC AND SCOTTRADE INC. ARE SUBSIDIARIES OF THE SAME PARENT COMPANY, TD AMERITRADE ©2021 FINRA. All rights reserved. Report aboutHOLDING SCOTTRADE, CORPORATION. INC. 22 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Description: TD AMERITRADE INVESTMENT MANAGEMENT, LLC AND SCOTTRADE INC. ARE SUBSIDIARIES OF THE SAME PARENT COMPANY, TD AMERITRADE HOLDING CORPORATION.

TD GLOBAL FINANCE is under common control with the firm. Business Address: LEVEL 2, PLAZA 2, CUSTOM HOUSE PLAZA DUBLING, IRELAND Effective Date: 01/24/2006 Foreign Entity: Yes Country: IRELAND Securities Activities: Yes Investment Advisory No Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT FOR TD GLOBAL FINANCE, AN IRELAND BASED SECURITIES FIRM. THE TORONTO- DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

TD ASSET ADMINISTRATION UK LIMITED is under common control with the firm. Business Address: 55 MANSELL STREET LONDON, UK E1 8AN Effective Date: 01/24/2006 Foreign Entity: Yes Country: UK Securities Activities: Yes Investment Advisory No Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT FOR TD ASSET ADMINISTRATION UK LIMITED, A EUROPEAN BASED BROKER-DEALER. THE TORONTO-DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

TD SECURITIES LIMITED is under common control with the firm. Business Address: 909 FANNIN STREET SUITE 1700 HOUSTON, TX ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 23 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Effective Date: 01/24/2006 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT FOR TD SECURITIES LIMITED, A U.K. BASED BROKERDEALER. THE TORONTO- DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

TD ASSET MANAGEMENT INC. is under common control with the firm. Business Address: TORONTO-DOMINION TOWER, 18TH FLOOR TORONTO-DOMINION CENTR TORONTO, CANADA M5K 1G8 Effective Date: 01/24/2006 Foreign Entity: Yes Country: CANADA Securities Activities: Yes Investment Advisory Yes Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT FOR TD ASSET MANAGEMENT INC, A CANADIAN PORTFOLIO MANAGER AND INVESTMENT COUNSELOR. THE TORONTO-DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

TD SECURITIES INC. is under common control with the firm. Business Address: TORONTO-DOMINION TOWER 18TH FLOOR TORONTO, CANADA M5K 1G8 Effective Date: 01/24/2006 Foreign Entity: Yes Country: CANADA Securities Activities: Yes ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 24 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Securities Activities: Yes Investment Advisory No Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT FOR TD SECURITIES INC, A FULL SERVICE CANADIAN BROKER-DEALER. THE TORONTO-DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

TD SECURITIES (USA) LLC is under common control with the firm. CRD #: 18476 Business Address: 31 WEST 52ND STREET NEW YORK, NY 10019 Effective Date: 01/24/2006 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: THE TORONTO-DOMINION BANK IS THE ULTIMATE PARENT FOR TD SECURITIES (USA) LLC. THE TORONTO-DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

SCOTTRADE INVESTMENT MANAGEMENT is under common control with the firm. CRD #: 169988 Business Address: 700 MARYVILLE CENTRE DRIVE SAINT LOUIS, MO 63131 Effective Date: 02/22/2014 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory Yes Activities: ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 25 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Investment Advisory Yes Activities: Description: SCOTTRADE INVESTMENT MANAGEMENT, INC. AND SCOTTRADE, INC. ARE SUBSIDIARIES OF THE SAME PARENT COMPANY, TD AMERITRADE HOLDING CORPORATION.

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

TORONTO DOMINION (SOUTH EAST ASIA) LIMITED is a Foreign Bank and controls the firm. Business Address: #15-02 MILLENIA TOWER SINGAPORE, REBUPLIC OF SINGAPORE 039192 Effective Date: 09/18/2017 Description: TORONTO DOMINION (SOUTH EAST ASIA) LIMITED IS A LICENSED MERCHANT BANK AND WHOLLY OWNED SUBSIDIARY OF THE TORONTO- DOMINION BANK. THE TORONTO-DOMINION BANK OWNS AT LEAST 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN IS THE PARENT COMPANY OF THE APPLICANT.

THE TORONTO-DOMINION BANK is a Foreign Bank and controls the firm. Business Address: TORONTO-DOMINION CENTRE TORONTO, CANADA M5K 1G8 Effective Date: 09/18/2017 Description: THE TORONTO DOMINION BANK ULTIMATELY OWNS 40% OF THE COMMON STOCK OF TD AMERITRADE HOLDING CORPORATION WHICH, IN TURN, IS THE PARENT COMPANY OF THE APPLICANT

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 51 0 Arbitration N/A 33 N/A Bond N/A 1 N/A

Disclosure Event Details What you should know about reported disclosure events:

1. BrokerCheck provides details for any disclosure event that was reported in CRD. It also 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 51 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED ©2021 FINRA. All rights reserved. Report aboutTO THE SCOTTRADE, SANCTIONS INC. AND TO THE ENTRY OF FINDINGS THAT IT REPORTED 28 POSITIONS TO THE LARGE OPTIONS POSITION REPORTING (LOPR) SYSTEM INACCURATELY OR FAILED TO REPORT POSITIONS IN APPROXIMATELY 2,075 INSTANCES. THE FINDINGS STATED THAT THESE REPORTING DEFICIENCIES RESULTED FROM CODE CHANGES THAT HAD BEEN IMPLEMENTED BY THE FIRM, SYSTEM ISSUES IN REPORTING MOVEMENT OF CUSTOMERS' ACCOUNTS FROM ONE BRANCH TO ANOTHER, MANUAL ERRORS, AND OTHER MISCELLANEOUS ERRORS. BETWEEN AUGUST 2013 AND MAY 2014, THE FIRM FAILED TO REPORT REPORTABLE OPTIONS POSITIONS OR REPORTED THEM WITH AN INCORRECT EFFECTIVE DATE IN 312 INSTANCES, NEARLY ALL OF WHICH HAD RESULTED FROM A FIRM EMPLOYEE'S FAILURE TO INITIATE THE SYSTEMATIC REPORTING OF THE FIRM'S LOPR POSITIONS ON AUGUST 14, 2013. BETWEEN JULY 1, 2013, AND JUNE 6, 2014, THE FIRM FAILED TO REPORT POSITIONS IN A TOTAL OF 16,908 INSTANCES FOR ACCOUNTS ACTING IN CONCERT BECAUSE OF THE FIRM'S FAILURE TO UPDATE ACCOUNTS THAT CLEARED THROUGH ONE OF ITS CLEARING FIRMS AS ACTING IN CONCERT. IN 16 INSTANCES IN SEPTEMBER AND OCTOBER 2014, SCOTTRADE FAILED TO PROPERLY RESUBMIT REJECTED RECORDS TO THE LOPR SYSTEM OR RESUBMITTED THEM IMPROPERLY. THE EFFECTIVE DATE THAT HAD BEEN ENTERED BY THE FIRM WAS A HOLIDAY. BETWEEN JUNE 12, 2015, AND JULY 29, 2015, THE FIRM FAILED TO REPORT AN UNKNOWN NUMBER OF POSITIONS BECAUSE OF AN ISSUE WITH ITS LOGIC FOR MODIFICATIONS AND DELETIONS. IF THE FIRM WAS ADDING A NEW SERIES AND MODIFYING THE SAME UNDERLYING, THE FIRM'S LOPR DATABASE RETAINED THE POSITION AS HAVING BEEN PREVIOUSLY REPORTED WHEN IT HAD NOT ACTUALLY BEEN REPORTED BECAUSE THE POSITIONS WERE LESS THAN 200 CONTRACTS. THE DATABASE FAILED TO RECOGNIZE THE ADDITIONS. THE FIRM'S SYSTEM THEN SUBMITTED MODIFICATIONS AND DELETIONS THAT WERE REJECTED BECAUSE NO POSITIONS HAD BEEN REPORTED IN THE FIRST PLACE. IN AN UNKNOWN NUMBER OF INSTANCES, THE FIRM FAILED TO REPORT POSITIONS WHERE CUSTOMERS HAD ACQUIRED THE POSITIONS ON EXPIRATION DAY AND PLACED DO-NOT-EXERCISE INSTRUCTIONS ON THE POSITIONS. THE FIRM'S PRACTICE WAS TO ACCEPT DO-NOT-EXERCISE INSTRUCTIONS ONLY ON EXPIRATION DAY AND TO CONSIDER POSITIONS WITH DO-NOT- EXERCISE INSTRUCTIONS AS CLOSED. AS A RESULT, IT DID NOT REPORT THE POSITIONS TO THE LOPR SYSTEM. ALTHOUGH THE FIRM CONTENDED THAT THESE SITUATIONS ONLY HAPPENED RARELY, THE FIRM IMPLEMENTED A FIX TO ENSURE THAT IT NOW PROPERLY REPORTS POSITIONS ESTABLISHED ON EXPIRATION WITH DO-NOT-EXERCISE INSTRUCTIONS. IN AN UNKNOWN NUMBER OF INSTANCES, THE FIRM FAILED TO MODIFY POSITIONS THAT HAD BEEN LIQUIDATED ON EXPIRATION DAY, OPERATING UNDER THE INCORRECT BELIEF THAT NO MODIFICATION WAS NECESSARY BECAUSE EXPIRING OPTIONS WERE AUTOMATICALLY PURGED FROM THE LOPR SYSTEM AFTER THEY EXPIRED. THE FIRM'S OBLIGATION, HOWEVER, WAS TO REPORT POSITIONS EFFECTIVE AS OF THE END OF THE DAY ON EXPIRATION, WHICH MEANT THAT IT HAD TO REPORT THE POSITION AS ZERO. FROM JANUARY 2012 THROUGH MAY 2016, ALTHOUGH THE FIRM HAD WRITTEN SUPERVISORY PROCEDURES AND REVIEWS WITH RESPECT TO LOPR REPORTING, IT FAILED TO HAVE AN ADEQUATE SYSTEM TO ASSURE COMPLIANCE WITH BZX RULE 18.10. 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 REPORTED POSITIONS TO THE LARGE OPTIONS POSITION REPORTING (LOPR) SYSTEM INACCURATELY OR FAILED TO REPORT POSITIONS IN APPROXIMATELY 2,075 INSTANCES. THE FINDINGS STATED THAT THESE REPORTING DEFICIENCIES RESULTED FROM CODE CHANGES THAT HAD BEEN IMPLEMENTED BY THE FIRM, SYSTEM ISSUES IN REPORTING MOVEMENT OF CUSTOMERS' ACCOUNTS FROM ONE BRANCH TO ANOTHER, MANUAL ERRORS, AND OTHER MISCELLANEOUS ERRORS. BETWEEN AUGUST 2013 AND MAY 2014, THE FIRM FAILED TO REPORT REPORTABLE OPTIONS POSITIONS OR REPORTED THEM WITH AN INCORRECT EFFECTIVE DATE IN 312 INSTANCES, NEARLY ALL OF WHICH HAD RESULTED FROM A FIRM EMPLOYEE'S FAILURE TO INITIATE THE SYSTEMATIC REPORTING OF THE FIRM'S LOPR POSITIONS ON AUGUST 14, 2013. BETWEEN JULY 1, 2013, AND JUNE 6, 2014, THE FIRM FAILED TO REPORT POSITIONS IN A TOTAL OF 16,908 INSTANCES FOR ACCOUNTS ACTING IN CONCERT BECAUSE OF THE FIRM'S FAILURE TO UPDATE ACCOUNTS THAT CLEARED THROUGH ONE OF ITS CLEARING FIRMS AS ACTING IN CONCERT. IN 16 INSTANCES IN SEPTEMBER AND OCTOBER 2014, SCOTTRADE FAILED TO PROPERLY RESUBMIT REJECTED RECORDS TO THE LOPR SYSTEM OR RESUBMITTED THEM IMPROPERLY. THE EFFECTIVE DATE THAT HAD BEEN ENTERED BY THE FIRM WAS A HOLIDAY. BETWEEN JUNE 12, 2015, AND JULY 29, 2015, THE FIRM FAILED TO REPORT AN UNKNOWN NUMBER OF POSITIONS BECAUSE OF AN ISSUE WITH ITS LOGIC FOR MODIFICATIONS AND DELETIONS. IF THE FIRM WAS ADDING A NEW SERIES AND MODIFYING THE SAME UNDERLYING, THE FIRM'S LOPR DATABASE RETAINED THE POSITION AS HAVING BEEN PREVIOUSLY REPORTED WHEN IT HAD NOT ACTUALLY BEEN REPORTED BECAUSE THE POSITIONS WERE LESS THAN 200 CONTRACTS. THE DATABASE FAILED TO RECOGNIZE THE ADDITIONS. THE FIRM'S SYSTEM THEN SUBMITTED MODIFICATIONS AND DELETIONS THAT WERE REJECTED BECAUSE NO POSITIONS HAD BEEN REPORTED IN THE FIRST PLACE. IN AN UNKNOWN NUMBER OF INSTANCES, THE FIRM FAILED TO REPORT POSITIONS WHERE CUSTOMERS HAD ACQUIRED THE POSITIONS ON EXPIRATION DAY AND PLACED DO-NOT-EXERCISE INSTRUCTIONS ON THE POSITIONS. THE FIRM'S PRACTICE WAS TO ACCEPT DO-NOT-EXERCISE INSTRUCTIONS ONLY ON EXPIRATION DAY AND TO CONSIDER POSITIONS WITH DO-NOT- EXERCISE INSTRUCTIONS AS CLOSED. AS A RESULT, IT DID NOT REPORT THE POSITIONS TO THE LOPR SYSTEM. ALTHOUGH THE FIRM CONTENDED THAT THESE SITUATIONS ONLY HAPPENED RARELY, THE FIRM IMPLEMENTED A FIX TO ENSURE THAT IT NOW PROPERLY REPORTS POSITIONS ESTABLISHED ON EXPIRATION WITH DO-NOT-EXERCISE INSTRUCTIONS. IN AN UNKNOWN NUMBER OF INSTANCES, THE FIRM FAILED TO MODIFY POSITIONS THAT HAD BEEN LIQUIDATED ON EXPIRATION DAY, OPERATING UNDER THE INCORRECT BELIEF THAT NO MODIFICATION WAS NECESSARY BECAUSE EXPIRING OPTIONS WERE ©2021 FINRA. All rights reserved. Report aboutAUTOMATICALLY SCOTTRADE, INC. PURGED FROM THE LOPR SYSTEM AFTER THEY 29 EXPIRED. THE FIRM'S OBLIGATION, HOWEVER, WAS TO REPORT POSITIONS EFFECTIVE AS OF THE END OF THE DAY ON EXPIRATION, WHICH MEANT THAT IT HAD TO REPORT THE POSITION AS ZERO. FROM JANUARY 2012 THROUGH MAY 2016, ALTHOUGH THE FIRM HAD WRITTEN SUPERVISORY PROCEDURES AND REVIEWS WITH RESPECT TO LOPR REPORTING, IT FAILED TO HAVE AN ADEQUATE SYSTEM TO ASSURE COMPLIANCE WITH BZX RULE 18.10. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT REPORTED POSITIONS TO THE LARGE OPTIONS POSITION REPORTING (LOPR) SYSTEM INACCURATELY OR FAILED TO REPORT POSITIONS IN APPROXIMATELY 2,075 INSTANCES. THE FINDINGS STATED THAT THESE REPORTING DEFICIENCIES RESULTED FROM CODE CHANGES THAT HAD BEEN IMPLEMENTED BY THE FIRM, SYSTEM ISSUES IN REPORTING MOVEMENT OF CUSTOMERS' ACCOUNTS FROM ONE BRANCH TO ANOTHER, MANUAL ERRORS, AND OTHER MISCELLANEOUS ERRORS. BETWEEN AUGUST 2013 AND MAY 2014, THE FIRM FAILED TO REPORT REPORTABLE OPTIONS POSITIONS OR REPORTED THEM WITH AN INCORRECT EFFECTIVE DATE IN 312 INSTANCES, NEARLY ALL OF WHICH HAD RESULTED FROM A FIRM EMPLOYEE'S FAILURE TO INITIATE THE SYSTEMATIC REPORTING OF THE FIRM'S LOPR POSITIONS ON AUGUST 14, 2013. BETWEEN JULY 1, 2013, AND JUNE 6, 2014, THE FIRM FAILED TO REPORT POSITIONS IN A TOTAL OF 16,908 INSTANCES FOR ACCOUNTS ACTING IN CONCERT BECAUSE OF THE FIRM'S FAILURE TO UPDATE ACCOUNTS THAT CLEARED THROUGH ONE OF ITS CLEARING FIRMS AS ACTING IN CONCERT. IN 16 INSTANCES IN SEPTEMBER AND OCTOBER 2014, SCOTTRADE FAILED TO PROPERLY RESUBMIT REJECTED RECORDS TO THE LOPR SYSTEM OR RESUBMITTED THEM IMPROPERLY. THE EFFECTIVE DATE THAT HAD BEEN ENTERED BY THE FIRM WAS A HOLIDAY. BETWEEN JUNE 12, 2015, AND JULY 29, 2015, THE FIRM FAILED TO REPORT AN UNKNOWN NUMBER OF POSITIONS BECAUSE OF AN ISSUE WITH ITS LOGIC FOR MODIFICATIONS AND DELETIONS. IF THE FIRM WAS ADDING A NEW SERIES AND MODIFYING THE SAME UNDERLYING, THE FIRM'S LOPR DATABASE RETAINED THE POSITION AS HAVING BEEN PREVIOUSLY REPORTED WHEN IT HAD NOT ACTUALLY BEEN REPORTED BECAUSE THE POSITIONS WERE LESS THAN 200 CONTRACTS. THE DATABASE FAILED TO RECOGNIZE THE ADDITIONS. THE FIRM'S SYSTEM THEN SUBMITTED MODIFICATIONS AND DELETIONS THAT WERE REJECTED BECAUSE NO POSITIONS HAD BEEN REPORTED IN THE FIRST PLACE. IN AN UNKNOWN NUMBER OF INSTANCES, THE FIRM FAILED TO REPORT POSITIONS WHERE CUSTOMERS HAD ACQUIRED THE POSITIONS ON EXPIRATION DAY AND PLACED DO-NOT-EXERCISE INSTRUCTIONS ON THE POSITIONS. THE FIRM'S PRACTICE WAS TO ACCEPT DO-NOT-EXERCISE INSTRUCTIONS ONLY ON EXPIRATION DAY AND TO CONSIDER POSITIONS WITH DO-NOT- EXERCISE INSTRUCTIONS AS CLOSED. AS A RESULT, IT DID NOT REPORT THE POSITIONS TO THE LOPR SYSTEM. ALTHOUGH THE FIRM CONTENDED THAT THESE SITUATIONS ONLY HAPPENED RARELY, THE FIRM IMPLEMENTED A FIX TO ENSURE THAT IT NOW PROPERLY REPORTS www.finra.org/brokercheck POSITIONS ESTABLISHED ON EXPIRATION WITH DO-NOT-EXERCISE User Guidance INSTRUCTIONS. IN AN UNKNOWN NUMBER OF INSTANCES, THE FIRM FAILED TO MODIFY POSITIONS THAT HAD BEEN LIQUIDATED ON EXPIRATION DAY, OPERATING UNDER THE INCORRECT BELIEF THAT NO MODIFICATION WAS NECESSARY BECAUSE EXPIRING OPTIONS WERE AUTOMATICALLY PURGED FROM THE LOPR SYSTEM AFTER THEY EXPIRED. THE FIRM'S OBLIGATION, HOWEVER, WAS TO REPORT POSITIONS EFFECTIVE AS OF THE END OF THE DAY ON EXPIRATION, WHICH MEANT THAT IT HAD TO REPORT THE POSITION AS ZERO. FROM JANUARY 2012 THROUGH MAY 2016, ALTHOUGH THE FIRM HAD WRITTEN SUPERVISORY PROCEDURES AND REVIEWS WITH RESPECT TO LOPR REPORTING, IT FAILED TO HAVE AN ADEQUATE SYSTEM TO ASSURE COMPLIANCE WITH BZX RULE 18.10. Initiated By: CBOE BZX EXCHANGE, INC. Date Initiated: 04/23/2018 Docket/Case Number: 2014042367101

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: 05/21/2018 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 $90,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $90,000. Regulator Statement IN DETERMINING TO RESOLVE THIS MATTER ON THE BASIS SET FORTH HEREIN, THE DEPARTMENT OF ENFORCEMENT CONSIDERED THAT THE FIRM HAD TAKEN PROMPT CORRECTIVE ACTION TO FIX CERTAIN ISSUES PRIOR TO THE STAFF'S NOTICE AND THAT IT HAD SELF-REPORTED ITS VIOLATIONS. i Reporting Source: ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 30 www.finra.org/brokercheck User Guidance

Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT REPORTED POSITIONS TO THE LARGE OPTIONS POSITION REPORTING (LOPR) SYSTEM INACCURATELY OR FAILED TO REPORT POSITIONS IN APPROXIMATELY 2,075 INSTANCES. THE FINDINGS STATED THAT THESE REPORTING DEFICIENCIES RESULTED FROM CODE CHANGES THAT HAD BEEN IMPLEMENTED BY THE FIRM, SYSTEM ISSUES IN REPORTING MOVEMENT OF CUSTOMERS' ACCOUNTS FROM ONE BRANCH TO ANOTHER, MANUAL ERRORS, AND OTHER MISCELLANEOUS ERRORS. BETWEEN AUGUST 2013 AND MAY 2014, THE FIRM FAILED TO REPORT REPORTABLE OPTIONS POSITIONS OR REPORTED THEM WITH AN INCORRECT EFFECTIVE DATE IN 312 INSTANCES, NEARLY ALL OF WHICH HAD RESULTED FROM A FIRM EMPLOYEE'S FAILURE TO INITIATE THE SYSTEMATIC REPORTING OF THE FIRM'S LOPR POSITIONS ON AUGUST 14, 2013. BETWEEN JULY 1, 2013, AND JUNE 6, 2014, THE FIRM FAILED TO REPORT POSITIONS IN A TOTAL OF 16,908 INSTANCES FOR ACCOUNTS ACTING IN CONCERT BECAUSE OF THE FIRM'S FAILURE TO UPDATE ACCOUNTS THAT CLEARED THROUGH ONE OF ITS CLEARING FIRMS AS ACTING IN CONCERT. IN 16 INSTANCES IN SEPTEMBER AND OCTOBER 2014, SCOTTRADE FAILED TO PROPERLY RESUBMIT REJECTED RECORDS TO THE LOPR SYSTEM OR RESUBMITTED THEM IMPROPERLY. THE EFFECTIVE DATE THAT HAD BEEN ENTERED BY THE FIRM WAS A HOLIDAY. BETWEEN JUNE 12, 2015, AND JULY 29, 2015, THE FIRM FAILED TO REPORT AN UNKNOWN NUMBER OF POSITIONS BECAUSE OF AN ISSUE WITH ITS LOGIC FOR MODIFICATIONS AND DELETIONS. IF THE FIRM WAS ADDING A NEW SERIES AND MODIFYING THE SAME UNDERLYING, THE FIRM'S LOPR DATABASE RETAINED THE POSITION AS HAVING BEEN PREVIOUSLY REPORTED WHEN IT HAD NOT ACTUALLY BEEN REPORTED BECAUSE THE POSITIONS WERE LESS THAN 200 CONTRACTS. THE DATABASE FAILED TO RECOGNIZE THE ADDITIONS. THE FIRM'S SYSTEM THEN SUBMITTED MODIFICATIONS AND DELETIONS THAT WERE REJECTED BECAUSE NO POSITIONS HAD BEEN REPORTED IN THE FIRST PLACE. IN AN UNKNOWN NUMBER OF INSTANCES, THE FIRM FAILED TO REPORT POSITIONS WHERE CUSTOMERS HAD ACQUIRED THE POSITIONS ON EXPIRATION DAY AND PLACED DO-NOT-EXERCISE INSTRUCTIONS ON THE POSITIONS. THE FIRM'S PRACTICE WAS TO ACCEPT DO-NOT-EXERCISE INSTRUCTIONS ONLY ON EXPIRATION DAY AND TO CONSIDER POSITIONS WITH DO-NOT- EXERCISE INSTRUCTIONS AS CLOSED. AS A RESULT, IT DID NOT REPORT THE POSITIONS TO THE LOPR SYSTEM. ALTHOUGH THE FIRM CONTENDED THAT THESE SITUATIONS ONLY HAPPENED RARELY, THE FIRM IMPLEMENTED A FIX TO ENSURE THAT IT NOW PROPERLY REPORTS POSITIONS ESTABLISHED ON EXPIRATION WITH DO-NOT-EXERCISE INSTRUCTIONS. IN AN UNKNOWN NUMBER OF INSTANCES, THE FIRM ©2021 FINRA. All rights reserved. Report aboutFAILED SCOTTRADE, TO MODIFY INC. POSITIONS THAT HAD BEEN LIQUIDATED ON 31 EXPIRATION DAY, OPERATING UNDER THE INCORRECT BELIEF THAT NO MODIFICATION WAS NECESSARY BECAUSE EXPIRING OPTIONS WERE AUTOMATICALLY PURGED FROM THE LOPR SYSTEM AFTER THEY EXPIRED. THE FIRM'S OBLIGATION, HOWEVER, WAS TO REPORT POSITIONS EFFECTIVE AS OF THE END OF THE DAY ON EXPIRATION, WHICH MEANT THAT IT HAD TO REPORT THE POSITION AS ZERO. FROM JANUARY 2012 THROUGH MAY 2016, ALTHOUGH THE FIRM HAD WRITTEN SUPERVISORY PROCEDURES AND REVIEWS WITH RESPECT TO LOPR REPORTING, IT FAILED TO HAVE AN ADEQUATE SYSTEM TO ASSURE COMPLIANCE WITH BZX RULE 18.10. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT REPORTED POSITIONS TO THE LARGE OPTIONS POSITION REPORTING (LOPR) SYSTEM INACCURATELY OR FAILED TO REPORT POSITIONS IN APPROXIMATELY 2,075 INSTANCES. THE FINDINGS STATED THAT THESE REPORTING DEFICIENCIES RESULTED FROM CODE CHANGES THAT HAD BEEN IMPLEMENTED BY THE FIRM, SYSTEM ISSUES IN REPORTING MOVEMENT OF CUSTOMERS' ACCOUNTS FROM ONE BRANCH TO ANOTHER, MANUAL ERRORS, AND OTHER MISCELLANEOUS ERRORS. BETWEEN AUGUST 2013 AND MAY 2014, THE FIRM FAILED TO REPORT REPORTABLE OPTIONS POSITIONS OR REPORTED THEM WITH AN INCORRECT EFFECTIVE DATE IN 312 INSTANCES, NEARLY ALL OF WHICH HAD RESULTED FROM A FIRM EMPLOYEE'S FAILURE TO INITIATE THE SYSTEMATIC REPORTING OF THE FIRM'S LOPR POSITIONS ON AUGUST 14, 2013. BETWEEN JULY 1, 2013, AND JUNE 6, 2014, THE FIRM FAILED TO REPORT POSITIONS IN A TOTAL OF 16,908 INSTANCES FOR ACCOUNTS ACTING IN CONCERT BECAUSE OF THE FIRM'S FAILURE TO UPDATE ACCOUNTS THAT CLEARED THROUGH ONE OF ITS CLEARING FIRMS AS ACTING IN CONCERT. IN 16 INSTANCES IN SEPTEMBER AND OCTOBER 2014, SCOTTRADE FAILED TO PROPERLY RESUBMIT REJECTED RECORDS TO THE LOPR SYSTEM OR RESUBMITTED THEM IMPROPERLY. THE EFFECTIVE DATE THAT HAD BEEN ENTERED BY THE FIRM WAS A HOLIDAY. BETWEEN JUNE 12, 2015, AND JULY 29, 2015, THE FIRM FAILED TO REPORT AN UNKNOWN NUMBER OF POSITIONS BECAUSE OF AN ISSUE WITH ITS LOGIC FOR MODIFICATIONS AND DELETIONS. IF THE FIRM WAS ADDING A NEW SERIES AND MODIFYING THE SAME UNDERLYING, THE FIRM'S LOPR DATABASE RETAINED THE POSITION AS HAVING BEEN PREVIOUSLY REPORTED WHEN IT HAD NOT ACTUALLY BEEN REPORTED BECAUSE THE POSITIONS WERE LESS THAN 200 CONTRACTS. THE DATABASE FAILED TO RECOGNIZE THE ADDITIONS. THE FIRM'S SYSTEM THEN SUBMITTED MODIFICATIONS AND DELETIONS THAT WERE REJECTED BECAUSE NO POSITIONS HAD BEEN REPORTED IN THE FIRST PLACE. IN AN UNKNOWN NUMBER OF INSTANCES, THE FIRM FAILED TO REPORT POSITIONS WHERE CUSTOMERS HAD ACQUIRED THE POSITIONS ON EXPIRATION DAY AND PLACED DO-NOT-EXERCISE INSTRUCTIONS ON THE POSITIONS. THE FIRM'S PRACTICE WAS TO ACCEPT DO-NOT-EXERCISE INSTRUCTIONS ONLY ON EXPIRATION DAY AND TO CONSIDER POSITIONS WITH DO-NOT- EXERCISE INSTRUCTIONS AS CLOSED. AS A RESULT, IT DID NOT REPORT www.finra.org/brokercheck THE POSITIONS TO THE LOPR SYSTEM. ALTHOUGH THE FIRM CONTENDED User Guidance THAT THESE SITUATIONS ONLY HAPPENED RARELY, THE FIRM IMPLEMENTED A FIX TO ENSURE THAT IT NOW PROPERLY REPORTS POSITIONS ESTABLISHED ON EXPIRATION WITH DO-NOT-EXERCISE INSTRUCTIONS. IN AN UNKNOWN NUMBER OF INSTANCES, THE FIRM FAILED TO MODIFY POSITIONS THAT HAD BEEN LIQUIDATED ON EXPIRATION DAY, OPERATING UNDER THE INCORRECT BELIEF THAT NO MODIFICATION WAS NECESSARY BECAUSE EXPIRING OPTIONS WERE AUTOMATICALLY PURGED FROM THE LOPR SYSTEM AFTER THEY EXPIRED. THE FIRM'S OBLIGATION, HOWEVER, WAS TO REPORT POSITIONS EFFECTIVE AS OF THE END OF THE DAY ON EXPIRATION, WHICH MEANT THAT IT HAD TO REPORT THE POSITION AS ZERO. FROM JANUARY 2012 THROUGH MAY 2016, ALTHOUGH THE FIRM HAD WRITTEN SUPERVISORY PROCEDURES AND REVIEWS WITH RESPECT TO LOPR REPORTING, IT FAILED TO HAVE AN ADEQUATE SYSTEM TO ASSURE COMPLIANCE WITH BZX RULE 18.10. Initiated By: CBOE BZX EXCHANGE, INC. Date Initiated: 04/23/2018 Docket/Case Number: 2014042367101

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: 05/21/2018 Sanctions Ordered: Censure Monetary/Fine $90,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $90,000. Firm Statement IN DETERMINING TO RESOLVE THIS MATTER ON THE BASIS SET FORTH HEREIN, THE DEPARTMENT OF ENFORCEMENT CONSIDERED THAT THE FIRM HAD TAKEN PROMPT CORRECTIVE ACTION TO FIX CERTAIN ISSUES PRIOR TO THE STAFF'S NOTICE AND THAT IT HAD SELF-REPORTED ITS VIOLATIONS. i Disclosure 2 of 51 Reporting Source: Regulator Current Status: Final

©2021Allegations: FINRA. All rights reserved. Report aboutSCOTTRADE, SCOTTRADE, INC. INC. RAN SALES CONTESTS IN VIOLATION OF ITS OWN 32 INTERNAL POLICIES DESIGNED TO ENSURE COMPLIANCE WITH THE U.S. DEPARTMENT OF LABOR FIDUCIARY RULE www.finra.org/brokercheck User Guidance

Allegations: SCOTTRADE, INC. RAN SALES CONTESTS IN VIOLATION OF ITS OWN INTERNAL POLICIES DESIGNED TO ENSURE COMPLIANCE WITH THE U.S. DEPARTMENT OF LABOR FIDUCIARY RULE Initiated By: MASSACHUSETTS SECURITIES DIVISION Date Initiated: 02/15/2018 Docket/Case Number: E-2017-0045 URL for Regulatory Action: HTTP://SEC.STATE.MA.US/SCT/CURRENT/SCTSCOTTRADE/SCOTTRADEIDX. HTM Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief CENSURE, REVIEW OF SUPERVISORY PROCEDURES, VERIFIED Sought: ACCOUNTING, DISGORGEMENT, ADMINISTRATIVE FINE

Resolution: Consent Resolution Date: 06/30/2020 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 $250,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: RESPONDENT PAID AN ADMINISTRATIVE FINE OF $250,000 ON JULY 9, 2020. i Reporting Source: Firm Current Status: Pending Allegations: SCOTTRADE, INC. ALLEGEDLY RAN SALES CONTESTS IN VIOLATION OF ITS OWN INTERNAL POLICIES DESIGNED TO COMPLY WITH THE U.S. DEPARTMENT OF LABOR FIDUCIARY RULE. Initiated By: MASSACHUSETTS SECURITIES DIVISION Date Initiated: 02/15/2018 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 33 www.finra.org/brokercheck User Guidance

Date Initiated: 02/15/2018 Docket/Case Number: E-2017-0045

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief CENSURE, REVIEW OF SUPERVISORY PROCEDURES, VERIFIED Sought: ACCOUNTING, DISGORGEMENT, ADMINISTRATIVE FINE i Disclosure 3 of 51 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 AS A RESULT OF THE FIRM'S FAILURE TO ESTABLISH AND MAINTAIN A RISK MANAGEMENT CONTROL REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, THE FIRM, DURING THE PERIOD FROM MAY 2, 2014 THROUGH JUNE 30, 2016, WHEN IT SUBSEQUENTLY IMPLEMENTED NEW ERRONEOUS ORDER CONTROLS, VIOLATED SECTION 15(C)(3) OF THE SECURITIES EXCHANGE ACT OF 1934 (THE EXCHANGE ACT) AND RULE 15C3-5(C)(1)(II) THEREUNDER, AND EDGX RULES 5.1 AND 3.1. THE FINDINGS STATED THAT AS PART OF ITS ERRONEOUS ORDER CONTROLS, THE FIRM HAD IMPLEMENTED A LIMIT ORDER PRICE CONTROL FOR STOCKS PRICED LESS THAN $10 PER SHARE. IN CERTAIN INSTANCES, THE LIMIT PRICE CONTROL FOR STOCKS PRICED LESS THAN $10 WOULD ALLOW A CUSTOMER TO ENTER A LIMIT ORDER UP TO ALMOST 400 PERCENT OF THE STOCK'S QUOTED OR LAST SALE PRICE WITHOUT THE ORDER BEING REJECTED. A PRICE LIMIT THAT ALLOWED FOR ORDERS TO BE PRICED AT NEARLY 400 PERCENT OF A STOCK'S QUOTED OR LAST SALE PRICE WAS TOO HIGH TO BE REASONABLY EXPECTED TO PREVENT ERRONEOUS ORDERS WITHOUT ADDITIONAL, REASONABLY DESIGNED PRICE LIMIT CONTROLS IN PLACE TO SUPPLEMENT THE CONTROL ESTABLISHED BY THE FIRM. THE FIRM ALSO IMPOSED A PRICE LIMIT CONTROL OF FIVE PERCENT OR MORE THROUGH THE STOCK'S LAST SALE PRICE FOR ALL STOCKS. THIS CONTROL, HOWEVER, DID NOT OPERATE AS A HARD BLOCK. WHEN TRIGGERED, IT ONLY WARNED THE CUSTOMER THAT THE LIMIT PRICE EXCEEDED THE FIVE PERCENT LIMIT. CUSTOMERS COULD OVERRIDE THE CONTROL'S WARNING, AND CHOOSE TO CONTINUE WITH THE ORDER AS ORIGINALLY PRICED. AN ERRONEOUS ORDER CONTROL THAT COULD BE ©2021 FINRA. All rights reserved. Report aboutOVERRIDDEN SCOTTRADE, BY INC. THE CUSTOMER COULD NOT REASONABLY BE 34 EXPECTED TO PREVENT THE ENTRY OF AN ERRONEOUS ORDER ABSENT OTHER REASONABLY DESIGNED CONTROLS. THE FINDINGS ALSO STATED THAT AS PART OF ITS ERRONEOUS ORDER CONTROLS, THE FIRM ALSO HAD IMPLEMENTED A SINGLE ORDER QUANTITY (SOQ) LIMIT OF 999,999 SHARES. PURSUANT TO ITS SOQ CONTROL, ONLY AN EQUITY ORDER OF ONE MILLION SHARES OR MORE WOULD BE REJECTED BY THE FIRM. THE USE OF A SINGLE PARAMETER THAT APPLIED TO ALL SECURITIES, AND THAT WAS SET AT 999,999 SHARES, COULD NOT REASONABLY BE EXPECTED TO PREVENT ERRONEOUS-SIZED ORDERS WITHOUT ADDITIONAL, REASONABLY DESIGNED SHARE SIZE CONTROLS IN PLACE TO SUPPLEMENT THE CONTROL ESTABLISHED BY THE FIRM. SUCH PARAMETER DID NOT ADEQUATELY TAKE INTO ACCOUNT THE RETAIL NATURE OF THE FIRM'S CLIENT BASE, AND, GIVEN THE BROAD SPECTRUM OF SECURITIES THAT TRADE IN U.S. MARKETS, DID NOT ADEQUATELY TAKE INTO ACCOUNT THE TRADING CHARACTERISTICS OF THE SPECIFIC SECURITY UNDERLYING AN ORDER. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT AS A RESULT OF THE FIRM'S FAILURE TO ESTABLISH AND MAINTAIN A RISK MANAGEMENT CONTROL REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, THE FIRM, DURING THE PERIOD FROM MAY 2, 2014 THROUGH JUNE 30, 2016, WHEN IT SUBSEQUENTLY IMPLEMENTED NEW ERRONEOUS ORDER CONTROLS, VIOLATED SECTION 15(C)(3) OF THE SECURITIES EXCHANGE ACT OF 1934 (THE EXCHANGE ACT) AND RULE 15C3-5(C)(1)(II) THEREUNDER, AND EDGX RULES 5.1 AND 3.1. THE FINDINGS STATED THAT AS PART OF ITS ERRONEOUS ORDER CONTROLS, THE FIRM HAD IMPLEMENTED A LIMIT ORDER PRICE CONTROL FOR STOCKS PRICED LESS THAN $10 PER SHARE. IN CERTAIN INSTANCES, THE LIMIT PRICE CONTROL FOR STOCKS PRICED LESS THAN $10 WOULD ALLOW A CUSTOMER TO ENTER A LIMIT ORDER UP TO ALMOST 400 PERCENT OF THE STOCK'S QUOTED OR LAST SALE PRICE WITHOUT THE ORDER BEING REJECTED. A PRICE LIMIT THAT ALLOWED FOR ORDERS TO BE PRICED AT NEARLY 400 PERCENT OF A STOCK'S QUOTED OR LAST SALE PRICE WAS TOO HIGH TO BE REASONABLY EXPECTED TO PREVENT ERRONEOUS ORDERS WITHOUT ADDITIONAL, REASONABLY DESIGNED PRICE LIMIT CONTROLS IN PLACE TO SUPPLEMENT THE CONTROL ESTABLISHED BY THE FIRM. THE FIRM ALSO IMPOSED A PRICE LIMIT CONTROL OF FIVE PERCENT OR MORE THROUGH THE STOCK'S LAST SALE PRICE FOR ALL STOCKS. THIS www.finra.org/brokercheck CONTROL, HOWEVER, DID NOT OPERATE AS A HARD BLOCK. WHEN User Guidance TRIGGERED, IT ONLY WARNED THE CUSTOMER THAT THE LIMIT PRICE EXCEEDED THE FIVE PERCENT LIMIT. CUSTOMERS COULD OVERRIDE THE CONTROL'S WARNING, AND CHOOSE TO CONTINUE WITH THE ORDER AS ORIGINALLY PRICED. AN ERRONEOUS ORDER CONTROL THAT COULD BE OVERRIDDEN BY THE CUSTOMER COULD NOT REASONABLY BE EXPECTED TO PREVENT THE ENTRY OF AN ERRONEOUS ORDER ABSENT OTHER REASONABLY DESIGNED CONTROLS. THE FINDINGS ALSO STATED THAT AS PART OF ITS ERRONEOUS ORDER CONTROLS, THE FIRM ALSO HAD IMPLEMENTED A SINGLE ORDER QUANTITY (SOQ) LIMIT OF 999,999 SHARES. PURSUANT TO ITS SOQ CONTROL, ONLY AN EQUITY ORDER OF ONE MILLION SHARES OR MORE WOULD BE REJECTED BY THE FIRM. THE USE OF A SINGLE PARAMETER THAT APPLIED TO ALL SECURITIES, AND THAT WAS SET AT 999,999 SHARES, COULD NOT REASONABLY BE EXPECTED TO PREVENT ERRONEOUS-SIZED ORDERS WITHOUT ADDITIONAL, REASONABLY DESIGNED SHARE SIZE CONTROLS IN PLACE TO SUPPLEMENT THE CONTROL ESTABLISHED BY THE FIRM. SUCH PARAMETER DID NOT ADEQUATELY TAKE INTO ACCOUNT THE RETAIL NATURE OF THE FIRM'S CLIENT BASE, AND, GIVEN THE BROAD SPECTRUM OF SECURITIES THAT TRADE IN U.S. MARKETS, DID NOT ADEQUATELY TAKE INTO ACCOUNT THE TRADING CHARACTERISTICS OF THE SPECIFIC SECURITY UNDERLYING AN ORDER. Initiated By: BATS EDGX EXCHANGE, INC. Date Initiated: 02/07/2018 Docket/Case Number: 2014041113203

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: 03/08/2018 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 $7,500.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $7,500, AND UNDERTAKES TO REVISE ©2021 FINRA. All rights reserved. Report aboutITS WRITTENSCOTTRADE, SUPERVISORY INC. PROCEDURES (WSPS) AND/OR RISK 35 MANAGEMENT CONTROLS WITH RESPECT TO THE AREAS DESCRIBED IN THE MATTER. THE DECISION BECAME FINAL ON MARCH 8, 2018. www.finra.org/brokercheck User Guidance

Sanction Details: THE FIRM WAS CENSURED, FINED $7,500, AND UNDERTAKES TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES (WSPS) AND/OR RISK MANAGEMENT CONTROLS WITH RESPECT TO THE AREAS DESCRIBED IN THE MATTER. THE DECISION BECAME FINAL ON MARCH 8, 2018. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT AS A RESULT OF THE FIRM'S FAILURE TO ESTABLISH AND MAINTAIN A RISK MANAGEMENT CONTROL REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, THE FIRM, DURING THE PERIOD FROM MAY 2, 2014 THROUGH JUNE 30, 2016, WHEN IT SUBSEQUENTLY IMPLEMENTED NEW ERRONEOUS ORDER CONTROLS, VIOLATED SECTION 15(C)(3) OF THE SECURITIES EXCHANGE ACT OF 1934 (THE EXCHANGE ACT) AND RULE 15C3-5(C)(1)(II) THEREUNDER, AND EDGX RULES 5.1 AND 3.1. THE FINDINGS STATED THAT AS PART OF ITS ERRONEOUS ORDER CONTROLS, THE FIRM HAD IMPLEMENTED A LIMIT ORDER PRICE CONTROL FOR STOCKS PRICED LESS THAN $10 PER SHARE. IN CERTAIN INSTANCES, THE LIMIT PRICE CONTROL FOR STOCKS PRICED LESS THAN $10 WOULD ALLOW A CUSTOMER TO ENTER A LIMIT ORDER UP TO ALMOST 400 PERCENT OF THE STOCK'S QUOTED OR LAST SALE PRICE WITHOUT THE ORDER BEING REJECTED. A PRICE LIMIT THAT ALLOWED FOR ORDERS TO BE PRICED AT NEARLY 400 PERCENT OF A STOCK'S QUOTED OR LAST SALE PRICE WAS TOO HIGH TO BE REASONABLY EXPECTED TO PREVENT ERRONEOUS ORDERS WITHOUT ADDITIONAL, REASONABLY DESIGNED PRICE LIMIT CONTROLS IN PLACE TO SUPPLEMENT THE CONTROL ESTABLISHED BY THE FIRM. THE FIRM ALSO IMPOSED A PRICE LIMIT CONTROL OF FIVE PERCENT OR MORE THROUGH THE STOCK'S LAST SALE PRICE FOR ALL STOCKS. THIS CONTROL, HOWEVER, DID NOT OPERATE AS A HARD BLOCK. WHEN TRIGGERED, IT ONLY WARNED THE CUSTOMER THAT THE LIMIT PRICE EXCEEDED THE FIVE PERCENT LIMIT. CUSTOMERS COULD OVERRIDE THE CONTROL'S WARNING, AND CHOOSE TO CONTINUE WITH THE ORDER AS ORIGINALLY PRICED. AN ERRONEOUS ORDER CONTROL THAT COULD BE OVERRIDDEN BY THE CUSTOMER COULD NOT REASONABLY BE EXPECTED TO PREVENT THE ENTRY OF AN ERRONEOUS ORDER ABSENT OTHER REASONABLY DESIGNED CONTROLS. THE FINDINGS ALSO STATED THAT AS PART OF ITS ERRONEOUS ORDER CONTROLS, THE FIRM ALSO HAD IMPLEMENTED A SINGLE ORDER QUANTITY (SOQ) LIMIT OF 999,999 SHARES. PURSUANT TO ITS SOQ CONTROL, ONLY AN EQUITY ORDER OF ONE MILLION SHARES OR MORE WOULD BE REJECTED BY THE FIRM. THE USE OF A SINGLE PARAMETER THAT APPLIED TO ALL SECURITIES, AND ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 36 THAT WAS SET AT 999,999 SHARES, COULD NOT REASONABLY BE EXPECTED TO PREVENT ERRONEOUS-SIZED ORDERS WITHOUT ADDITIONAL, REASONABLY DESIGNED SHARE SIZE CONTROLS IN PLACE TO SUPPLEMENT THE CONTROL ESTABLISHED BY THE FIRM. SUCH PARAMETER DID NOT ADEQUATELY TAKE INTO ACCOUNT THE RETAIL NATURE OF THE FIRM'S CLIENT BASE, AND, GIVEN THE BROAD SPECTRUM OF SECURITIES THAT TRADE IN U.S. MARKETS, DID NOT ADEQUATELY TAKE INTO ACCOUNT THE TRADING CHARACTERISTICS OF THE SPECIFIC SECURITY UNDERLYING AN ORDER. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT AS A RESULT OF THE FIRM'S FAILURE TO ESTABLISH AND MAINTAIN A RISK MANAGEMENT CONTROL REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS, THE FIRM, DURING THE PERIOD FROM MAY 2, 2014 THROUGH JUNE 30, 2016, WHEN IT SUBSEQUENTLY IMPLEMENTED NEW ERRONEOUS ORDER CONTROLS, VIOLATED SECTION 15(C)(3) OF THE SECURITIES EXCHANGE ACT OF 1934 (THE EXCHANGE ACT) AND RULE 15C3-5(C)(1)(II) THEREUNDER, AND EDGX RULES 5.1 AND 3.1. THE FINDINGS STATED THAT AS PART OF ITS ERRONEOUS ORDER CONTROLS, THE FIRM HAD IMPLEMENTED A LIMIT ORDER PRICE CONTROL FOR STOCKS PRICED LESS THAN $10 PER SHARE. IN CERTAIN INSTANCES, THE LIMIT PRICE CONTROL FOR STOCKS PRICED LESS THAN $10 WOULD ALLOW A CUSTOMER TO ENTER A LIMIT ORDER UP TO ALMOST 400 PERCENT OF THE STOCK'S QUOTED OR LAST SALE PRICE WITHOUT THE ORDER BEING REJECTED. A PRICE LIMIT THAT ALLOWED FOR ORDERS TO BE PRICED AT NEARLY 400 PERCENT OF A STOCK'S QUOTED OR LAST SALE PRICE WAS TOO HIGH TO BE REASONABLY EXPECTED TO PREVENT ERRONEOUS ORDERS WITHOUT ADDITIONAL, REASONABLY DESIGNED PRICE LIMIT CONTROLS IN PLACE TO SUPPLEMENT THE CONTROL ESTABLISHED BY THE FIRM. THE FIRM ALSO IMPOSED A PRICE LIMIT CONTROL OF FIVE PERCENT OR MORE THROUGH THE STOCK'S LAST SALE PRICE FOR ALL STOCKS. THIS CONTROL, HOWEVER, DID NOT OPERATE AS A HARD BLOCK. WHEN TRIGGERED, IT ONLY WARNED THE CUSTOMER THAT THE LIMIT PRICE EXCEEDED THE FIVE PERCENT LIMIT. CUSTOMERS COULD OVERRIDE THE CONTROL'S WARNING, AND CHOOSE TO CONTINUE WITH THE ORDER AS ORIGINALLY PRICED. AN ERRONEOUS ORDER CONTROL THAT COULD BE OVERRIDDEN BY THE CUSTOMER COULD NOT REASONABLY BE EXPECTED TO PREVENT THE ENTRY OF AN ERRONEOUS ORDER ABSENT OTHER REASONABLY DESIGNED CONTROLS. THE FINDINGS ALSO STATED www.finra.org/brokercheck THAT AS PART OF ITS ERRONEOUS ORDER CONTROLS, THE FIRM ALSO User Guidance HAD IMPLEMENTED A SINGLE ORDER QUANTITY (SOQ) LIMIT OF 999,999 SHARES. PURSUANT TO ITS SOQ CONTROL, ONLY AN EQUITY ORDER OF ONE MILLION SHARES OR MORE WOULD BE REJECTED BY THE FIRM. THE USE OF A SINGLE PARAMETER THAT APPLIED TO ALL SECURITIES, AND THAT WAS SET AT 999,999 SHARES, COULD NOT REASONABLY BE EXPECTED TO PREVENT ERRONEOUS-SIZED ORDERS WITHOUT ADDITIONAL, REASONABLY DESIGNED SHARE SIZE CONTROLS IN PLACE TO SUPPLEMENT THE CONTROL ESTABLISHED BY THE FIRM. SUCH PARAMETER DID NOT ADEQUATELY TAKE INTO ACCOUNT THE RETAIL NATURE OF THE FIRM'S CLIENT BASE, AND, GIVEN THE BROAD SPECTRUM OF SECURITIES THAT TRADE IN U.S. MARKETS, DID NOT ADEQUATELY TAKE INTO ACCOUNT THE TRADING CHARACTERISTICS OF THE SPECIFIC SECURITY UNDERLYING AN ORDER. Initiated By: BATS EDGX EXCHANGE, INC. Date Initiated: 02/07/2018 Docket/Case Number: 2014041113203

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: 03/08/2018 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $7,500, AND UNDERTAKES TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES (WSPS) AND/OR RISK MANAGEMENT CONTROLS WITH RESPECT TO THE AREAS DESCRIBED IN THE MATTER. THE DECISION BECAME FINAL ON MARCH 8, 2018. i Disclosure 4 of 51 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 IN MAY 2014, TWO ORDERS ENTERED BY A FIRM CUSTOMER TRIGGERED A TRADING PAUSE IN THE SECURITY THAT WAS THE SUBJECT OF THE ORDERS. BECAUSE OF THE TRADING PAUSE, THE MARKET ANALYSIS SECTION OF ©2021 FINRA. All rights reserved. Report aboutFINRA'S SCOTTRADE, DEPARTMENT INC. OF MARKET REGULATION, ON BEHALF OF NASDAQ, 37 REVIEWED THE FIRM'S COMPLIANCE WITH RULE 15C3-5 OF THE SECURITIES EXCHANGE ACT OF 1934 AND DETERMINED THAT THE FIRM'S LIMIT PRICE CONTROLS FOR STOCKS PRICED LESS THAN $10, AND ITS SINGLE ORDER QUANTITY CONTROLS, WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS. THE FINDINGS STATED THAT THE FIRM SET ITS ERRONEOUS ORDER CONTROLS FOR STOCKS LESS THAN $10 PER SHARE AT 400%, WHICH WAS TOO HIGH. THE FIRM ALSO IMPOSED A PRICE LIMIT CONTROL OF 5% OR MORE THROUGH THE STOCK'S LAST SALE PRICE FOR ALL STOCKS. THIS CONTROL, HOWEVER, WAS NOT A HARD BLOCK; IT ONLY WARNED THE CUSTOMER THAT THE LIMIT PRICE EXCEEDED THE 5% LIMIT. CUSTOMERS COULD OVERRIDE THE CONTROL'S WARNING, AND CHOOSE TO CONTINUE WITH THE ORDER AS ORIGINALLY PRICED. FINALLY, THE FIRM IMPLEMENTED SINGLE ORDER QUANTITY (SOQ) LIMITS THAT APPLIED TO ALL SECURITIES, WITHOUT TAKING INTO ACCOUNT THE RETAIL NATURE OF THE FIRM'S CLIENT BASE, THE BROAD SPECTRUM OF SECURITIES TRADED ON THE UNITED STATES MARKETS AND THE TRADING CHARACTERISTICS OF THE SPECIFIC SECURITY UNDERLYING AN ORDER. www.finra.org/brokercheck WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED User Guidance TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN MAY 2014, TWO ORDERS ENTERED BY A FIRM CUSTOMER TRIGGERED A TRADING PAUSE IN THE SECURITY THAT WAS THE SUBJECT OF THE ORDERS. BECAUSE OF THE TRADING PAUSE, THE MARKET ANALYSIS SECTION OF FINRA'S DEPARTMENT OF MARKET REGULATION, ON BEHALF OF NASDAQ, REVIEWED THE FIRM'S COMPLIANCE WITH RULE 15C3-5 OF THE SECURITIES EXCHANGE ACT OF 1934 AND DETERMINED THAT THE FIRM'S LIMIT PRICE CONTROLS FOR STOCKS PRICED LESS THAN $10, AND ITS SINGLE ORDER QUANTITY CONTROLS, WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS. THE FINDINGS STATED THAT THE FIRM SET ITS ERRONEOUS ORDER CONTROLS FOR STOCKS LESS THAN $10 PER SHARE AT 400%, WHICH WAS TOO HIGH. THE FIRM ALSO IMPOSED A PRICE LIMIT CONTROL OF 5% OR MORE THROUGH THE STOCK'S LAST SALE PRICE FOR ALL STOCKS. THIS CONTROL, HOWEVER, WAS NOT A HARD BLOCK; IT ONLY WARNED THE CUSTOMER THAT THE LIMIT PRICE EXCEEDED THE 5% LIMIT. CUSTOMERS COULD OVERRIDE THE CONTROL'S WARNING, AND CHOOSE TO CONTINUE WITH THE ORDER AS ORIGINALLY PRICED. FINALLY, THE FIRM IMPLEMENTED SINGLE ORDER QUANTITY (SOQ) LIMITS THAT APPLIED TO ALL SECURITIES, WITHOUT TAKING INTO ACCOUNT THE RETAIL NATURE OF THE FIRM'S CLIENT BASE, THE BROAD SPECTRUM OF SECURITIES TRADED ON THE UNITED STATES MARKETS AND THE TRADING CHARACTERISTICS OF THE SPECIFIC SECURITY UNDERLYING AN ORDER. Initiated By: NASDAQ STOCK MARKET Date Initiated: 01/09/2018 Docket/Case Number: 2014041113201

Principal Product Type: Other Other Product Type(s): UNSPECIFIED SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $7,500, AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES AND/OR RISK MANAGEMENT CONTROLS WITH RESPECT TO PREVENTING THE ENTRY OF ERRONEOUS ORDERS. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN MAY 2014, TWO ORDERS ENTERED BY A FIRM CUSTOMER TRIGGERED A TRADING PAUSE IN THE SECURITY THAT WAS THE SUBJECT OF THE ORDERS. BECAUSE OF THE TRADING PAUSE, THE MARKET ANALYSIS SECTION OF FINRA'S DEPARTMENT OF MARKET REGULATION, ON BEHALF OF NASDAQ, REVIEWED THE FIRM'S COMPLIANCE WITH RULE 15C3-5 OF THE SECURITIES EXCHANGE ACT OF 1934 AND DETERMINED THAT THE FIRM'S LIMIT PRICE CONTROLS FOR STOCKS PRICED LESS THAN $10, AND ITS SINGLE ORDER QUANTITY CONTROLS, WERE NOT REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS. THE FINDINGS STATED THAT THE FIRM SET ITS ERRONEOUS ORDER CONTROLS FOR STOCKS LESS THAN $10 PER SHARE AT 400%, WHICH WAS TOO HIGH. THE FIRM ALSO IMPOSED A PRICE LIMIT CONTROL OF 5% OR MORE THROUGH THE STOCK'S LAST SALE PRICE FOR ALL STOCKS. THIS CONTROL, HOWEVER, WAS NOT A HARD BLOCK; IT ONLY WARNED THE CUSTOMER THAT THE LIMIT PRICE EXCEEDED THE 5% LIMIT. CUSTOMERS COULD OVERRIDE THE CONTROL'S WARNING, AND CHOOSE TO CONTINUE WITH THE ORDER AS ORIGINALLY PRICED. FINALLY, THE FIRM IMPLEMENTED SINGLE ORDER QUANTITY (SOQ) LIMITS THAT APPLIED TO ALL SECURITIES, WITHOUT TAKING INTO ACCOUNT THE RETAIL NATURE OF THE FIRM'S CLIENT BASE, THE BROAD SPECTRUM OF SECURITIES TRADED ON THE UNITED STATES MARKETS AND THE TRADING CHARACTERISTICS OF THE SPECIFIC SECURITY UNDERLYING AN ORDER. Initiated By: NASDAQ STOCK MARKET Date Initiated: 01/09/2018 Docket/Case Number: 2014041113201

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: 01/09/2018 Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $7,500, AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES AND/OR RISK MANAGEMENT CONTROLS WITH RESPECT TO PREVENTING THE ENTRY OF ERRONEOUS ORDERS. i Disclosure 5 of 51 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 AND MAINTAIN RISK MANAGEMENT CONTROLS REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS. THE FINDINGS STATED THAT TWO ORDERS ENTERED BY A FIRM CUSTOMER TRIGGERED A TRADING PAUSE IN THE SECURITY THAT WAS THE SUBJECT OF THE ORDERS. BECAUSE OF THE TRADING PAUSE, FINRA REVIEWED THE FIRM'S COMPLIANCE WITH RULE 15C3-5 OF THE SECURITIES EXCHANGE ACT OF 1934 AND DETERMINED THAT THE FIRM DID NOT DESIGN REASONABLY ITS LIMIT PRICE CONTROLS FOR STOCKS PRICED LESS THAN $10, AND ITS SINGLE ORDER QUANTITY CONTROLS, TO PREVENT THE ENTRY OF ERRONEOUS ORDERS. THE FIRM SET ITS ERRONEOUS ORDER CONTROLS FOR STOCKS LESS THAN $10 PER SHARE AT 400 PERCENT, WHICH WAS TOO HIGH. THE FIRM ALSO IMPOSED A PRICE LIMIT CONTROL OF 5 PERCENT OR MORE THROUGH THE STOCK'S LAST SALE PRICE FOR ALL STOCKS. THIS CONTROL, HOWEVER, WAS NOT A HARD BLOCK. IT ONLY WARNED THE CUSTOMER THAT THE LIMIT PRICE EXCEEDED THE 5 PERCENT LIMIT. CUSTOMERS COULD OVERRIDE THE CONTROL'S WARNING, AND CHOOSE TO CONTINUE WITH THE ORDER AS ORIGINALLY PRICED. AN ERRONEOUS ORDER CONTROL THAT THE CUSTOMER COULD OVERRIDE WILL NOT PREVENT THE ENTRY OF AN ERRONEOUS ORDER ABSENT OTHER REASONABLY DESIGNED ©2021 FINRA. All rights reserved. Report aboutCONTROLS. SCOTTRADE, FINALLY, INC. THE FIRM IMPLEMENTED SINGLE ORDER QUANTITY 40 (SOQ) LIMITS THAT APPLIED TO ALL SECURITIES, WITHOUT TAKING INTO ACCOUNT THE RETAIL NATURE OF THE FIRM'S CLIENT BASE, THE BROAD SPECTRUM OF SECURITIES TRADED ON THE UNITED STATES MARKETS AND THE TRADING CHARACTERISTICS OF THE SPECIFIC SECURITY UNDERLYING AN ORDER. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN RISK MANAGEMENT CONTROLS REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS. THE FINDINGS STATED THAT TWO ORDERS ENTERED BY A FIRM CUSTOMER TRIGGERED A TRADING PAUSE IN THE SECURITY THAT WAS THE SUBJECT OF THE ORDERS. BECAUSE OF THE TRADING PAUSE, FINRA REVIEWED THE FIRM'S COMPLIANCE WITH RULE 15C3-5 OF THE SECURITIES EXCHANGE ACT OF 1934 AND DETERMINED THAT THE FIRM DID NOT DESIGN REASONABLY ITS LIMIT PRICE CONTROLS FOR STOCKS PRICED LESS THAN $10, AND ITS SINGLE ORDER QUANTITY CONTROLS, TO PREVENT THE ENTRY OF ERRONEOUS ORDERS. THE FIRM SET ITS ERRONEOUS ORDER CONTROLS FOR STOCKS LESS THAN $10 PER SHARE AT 400 PERCENT, WHICH WAS TOO HIGH. THE FIRM ALSO IMPOSED A PRICE LIMIT CONTROL OF 5 PERCENT OR MORE THROUGH THE STOCK'S LAST SALE PRICE FOR ALL STOCKS. THIS CONTROL, HOWEVER, WAS NOT A HARD BLOCK. IT ONLY WARNED THE CUSTOMER THAT THE LIMIT PRICE www.finra.org/brokercheck EXCEEDED THE 5 PERCENT LIMIT. CUSTOMERS COULD OVERRIDE THE User Guidance CONTROL'S WARNING, AND CHOOSE TO CONTINUE WITH THE ORDER AS ORIGINALLY PRICED. AN ERRONEOUS ORDER CONTROL THAT THE CUSTOMER COULD OVERRIDE WILL NOT PREVENT THE ENTRY OF AN ERRONEOUS ORDER ABSENT OTHER REASONABLY DESIGNED CONTROLS. FINALLY, THE FIRM IMPLEMENTED SINGLE ORDER QUANTITY (SOQ) LIMITS THAT APPLIED TO ALL SECURITIES, WITHOUT TAKING INTO ACCOUNT THE RETAIL NATURE OF THE FIRM'S CLIENT BASE, THE BROAD SPECTRUM OF SECURITIES TRADED ON THE UNITED STATES MARKETS AND THE TRADING CHARACTERISTICS OF THE SPECIFIC SECURITY UNDERLYING AN ORDER. Initiated By: FINRA Date Initiated: 01/09/2018 Docket/Case Number: 2014041113202

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: 01/09/2018 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 $7,500.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $7,500, AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES AND/OR RISK MANAGEMENT CONTROLS WITH RESPECT TO PREVENTING THE ENTRY OF ERRONEOUS ORDERS. FINES PAID IN FULL ON FEBRUARY 5, 2018. FINES PAID IN FULL ON MARCH 16, 2018. i Reporting Source: Firm 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 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 41 ESTABLISH AND MAINTAIN RISK MANAGEMENT CONTROLS REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS. THE FINDINGS STATED THAT TWO ORDERS ENTERED BY A FIRM CUSTOMER TRIGGERED A TRADING PAUSE IN THE SECURITY THAT WAS THE SUBJECT OF THE ORDERS. BECAUSE OF THE TRADING PAUSE, FINRA REVIEWED THE FIRM'S COMPLIANCE WITH RULE 15C3-5 OF THE SECURITIES EXCHANGE ACT OF 1934 AND DETERMINED THAT THE FIRM DID NOT DESIGN REASONABLY ITS LIMIT PRICE CONTROLS FOR STOCKS PRICED LESS THAN $10, AND ITS SINGLE ORDER QUANTITY CONTROLS, TO PREVENT THE ENTRY OF ERRONEOUS ORDERS. THE FIRM SET ITS ERRONEOUS ORDER CONTROLS FOR STOCKS LESS THAN $10 PER SHARE AT 400 PERCENT, WHICH WAS TOO HIGH. THE FIRM ALSO IMPOSED A PRICE LIMIT CONTROL OF 5 PERCENT OR MORE THROUGH THE STOCK'S LAST SALE PRICE FOR ALL STOCKS. THIS CONTROL, HOWEVER, WAS NOT A HARD BLOCK. IT ONLY WARNED THE CUSTOMER THAT THE LIMIT PRICE EXCEEDED THE 5 PERCENT LIMIT. CUSTOMERS COULD OVERRIDE THE CONTROL'S WARNING, AND CHOOSE TO CONTINUE WITH THE ORDER AS ORIGINALLY PRICED. AN ERRONEOUS ORDER CONTROL THAT THE CUSTOMER COULD OVERRIDE WILL NOT PREVENT THE ENTRY OF AN ERRONEOUS ORDER ABSENT OTHER REASONABLY DESIGNED CONTROLS. FINALLY, THE FIRM IMPLEMENTED SINGLE ORDER QUANTITY (SOQ) LIMITS THAT APPLIED TO ALL SECURITIES, WITHOUT TAKING INTO ACCOUNT THE RETAIL NATURE OF THE FIRM'S CLIENT BASE, THE BROAD SPECTRUM OF SECURITIES TRADED ON THE UNITED STATES MARKETS AND THE TRADING CHARACTERISTICS OF THE SPECIFIC SECURITY UNDERLYING AN ORDER. 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 AND MAINTAIN RISK MANAGEMENT CONTROLS REASONABLY DESIGNED TO PREVENT THE ENTRY OF ERRONEOUS ORDERS BY REJECTING ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS. THE FINDINGS STATED THAT TWO ORDERS ENTERED BY A FIRM CUSTOMER TRIGGERED A TRADING PAUSE IN THE SECURITY THAT WAS THE SUBJECT OF THE ORDERS. BECAUSE OF THE TRADING PAUSE, FINRA REVIEWED THE FIRM'S COMPLIANCE WITH RULE 15C3-5 OF THE SECURITIES EXCHANGE ACT OF 1934 AND DETERMINED THAT THE FIRM DID NOT DESIGN REASONABLY ITS LIMIT PRICE CONTROLS FOR STOCKS PRICED LESS THAN $10, AND ITS SINGLE ORDER QUANTITY CONTROLS, TO PREVENT THE ENTRY OF ERRONEOUS ORDERS. THE FIRM SET ITS ERRONEOUS ORDER CONTROLS FOR STOCKS LESS THAN $10 PER SHARE AT 400 PERCENT, WHICH WAS TOO HIGH. THE FIRM ALSO IMPOSED A PRICE LIMIT CONTROL OF 5 PERCENT OR MORE THROUGH THE STOCK'S LAST SALE PRICE FOR ALL STOCKS. THIS CONTROL, HOWEVER, WAS NOT A HARD BLOCK. IT ONLY WARNED THE CUSTOMER THAT THE LIMIT PRICE EXCEEDED THE 5 PERCENT LIMIT. CUSTOMERS COULD OVERRIDE THE CONTROL'S WARNING, AND CHOOSE TO CONTINUE WITH THE ORDER AS ORIGINALLY PRICED. AN ERRONEOUS ORDER CONTROL THAT THE CUSTOMER COULD OVERRIDE WILL NOT PREVENT THE ENTRY OF AN ERRONEOUS ORDER ABSENT OTHER REASONABLY DESIGNED CONTROLS. FINALLY, THE FIRM IMPLEMENTED SINGLE ORDER QUANTITY (SOQ) LIMITS THAT APPLIED TO ALL SECURITIES, WITHOUT TAKING INTO ACCOUNT THE RETAIL NATURE OF THE FIRM'S CLIENT BASE, THE BROAD SPECTRUM OF SECURITIES TRADED ON THE UNITED STATES MARKETS AND THE TRADING CHARACTERISTICS OF THE SPECIFIC SECURITY UNDERLYING AN ORDER. Initiated By: FINRA Date Initiated: 01/09/2018 Docket/Case Number: 2014041113202

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: 01/09/2018 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine SCOTTRADE, $7,500.00 INC. 42 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $7,500.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $7,500, AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES AND/OR RISK MANAGEMENT CONTROLS WITH RESPECT TO PREVENTING THE ENTRY OF ERRONEOUS ORDERS. i Disclosure 6 of 51 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 TRANSMITTED 25 ORDERS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA. THE FINDINGS STATED THAT IN 25 INSTANCES OUT OF 25 SAMPLED ITEMS, THE FIRM FAILED TO PROVIDE DETAILS REQUIRED TO BE DISCLOSED ON CONFIRMATIONS TO CUSTOMERS FOR TRANSACTIONS EFFECTED BY A BROKER/DEALER. THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES (WSPS) WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS AND TO FINRA RULES. THE FIRM'S WSPS FAILED TO PROVIDE FOR ONE OR MORE OF THE REQUIREMENTS FOR ADEQUATE WSPS RELATED TO OATS REPORTING REQUIREMENTS AND ACCURACY OF CUSTOMER CONFIRMATIONS FOR TRADES BEING REPORTED BY A THIRD PARTY ON THE FIRM'S BEHALF. THE FIRM'S WSPS DID NOT PROVIDE FOR PROCEDURES AND SUPERVISION REASONABLY DESIGNED TO ENSURE AND REVIEW FOR COMPLIANCE WITH THE REQUIREMENTS TO LOCATE (OR ARRANGE TO BORROW) SECURITIES BEING SOLD PRIOR TO EXECUTION AS PRESCRIBED BY SEC RULE 203(B) OF REGULATION SHO. Initiated By: FINRA Date Initiated: 11/01/2017 Docket/Case Number: 2016048608401

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought: ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 43 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/01/2017 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 $42,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $42,500. FINES PAID IN FULL ON NOVEMBER 13, 2017. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT TRANSMITTED 25 ORDERS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA. THE FINDINGS STATED THAT IN 25 INSTANCES OUT OF 25 SAMPLED ITEMS, THE FIRM FAILED TO PROVIDE DETAILS REQUIRED TO BE DISCLOSED ON CONFIRMATIONS TO CUSTOMERS FOR TRANSACTIONS EFFECTED BY A BROKER/DEALER. THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES (WSPS) WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS AND TO FINRA RULES. THE FIRM'S WSPS FAILED TO PROVIDE FOR ONE OR MORE OF THE REQUIREMENTS FOR ADEQUATE WSPS RELATED TO OATS REPORTING REQUIREMENTS AND ACCURACY OF CUSTOMER CONFIRMATIONS FOR TRADES BEING REPORTED BY A THIRD PARTY ON THE FIRM'S BEHALF. THE FIRM'S WSPS DID NOT PROVIDE FOR PROCEDURES AND SUPERVISION REASONABLY DESIGNED TO ENSURE AND REVIEW FOR COMPLIANCE WITH THE REQUIREMENTS TO LOCATE (OR ARRANGE TO BORROW) SECURITIES BEING SOLD PRIOR TO EXECUTION AS PRESCRIBED BY SEC RULE 203(B) OF REGULATION SHO. Initiated By: FINRA

Date Initiated: 11/01/2017 Docket/Case Number: 2016048608401

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: 11/01/2017 Sanctions Ordered: Censure Monetary/Fine $42,500.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $42,500 i Disclosure 7 of 51 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 DID NOT MEDIA REPORT 1,130,000 TRANSACTIONS TO THE OTC REPORTING FACILITY (OTCRF). THE FINDINGS STATED THAT THE FIRM ROUTED 1,130,000 ORDERS IN OTC EQUITY SECURITIES TO A CANADIAN BROKER- DEALER FOR EXECUTION. IN 1,070,000 INSTANCES, THE CANADIAN BROKER-DEALER ROUTED THE ORDERS TO THE TORONTO STOCK EXCHANGE (TSX), WHERE THE ORDERS WERE EXECUTED, AND THE TRANSACTIONS REPORTED TO THE TSX. THE CANADIAN BROKER-DEALER THEN CONVERTED THE PRICE RECEIVED ON THE TSX INTO U.S. DOLLARS, AND ADDED AN ADDITIONAL AMOUNT AS COMPENSATION. THE CANADIAN BROKER-DEALER THEN CONVEYED THE SHARES TO THE FIRM AT THE NEW, MARKED-UP PRICE BY SUBMITTING A NON-MEDIA, CLEARING-ONLY REPORT TO THE OTCRF. THE FINDINGS ALSO STATED THAT BECAUSE THE TRADES WITH THE FIRM WERE REPORTED AT A DIFFERENT PRICE THAN THE PRICE PAID OR RECEIVED ON THE TSX, THE TRANSACTIONS BETWEEN THE FIRM AND THE CANADIAN BROKER-DEALER WERE NET TRADES, AND THUS WERE REQUIRED TO BE MEDIA REPORTED BY THE FIRM. THE FINDINGS ALSO INCLUDED THAT IN 60,000 INSTANCES, THE CANADIAN BROKER-DEALER EXECUTED THE TRADES ON A PRINCIPAL ©2021 FINRA. All rights reserved. Report aboutBASIS SCOTTRADE, RATHER INC. THAN ON THE TSX. THE CANADIAN BROKER-DEALER THEN 45 CONVEYED THE SHARES TO THE FIRM BY SUBMITTING A NON-MEDIA, CLEARING-ONLY REPORT TO THE OTCRF. THESE TRADES ALSO WERE REQUIRED TO BE MEDIA REPORTED BY THE FIRM TO THE OTCRF. THE FIRM DID NOT MEDIA REPORT 1,130,000 TRANSACTIONS TO THE OTCRF AND AS A RESULT, THE QUALITY AND USABILITY OF INFORMATION RECEIVED AND EMPLOYED BY FINRA IN ITS OVERALL SURVEILLANCE OF MARKET ACTIVITY IN OTC EQUITY SECURITIES WAS NEGATIVELY IMPACTED. IN ADDITION, INFORMATION MADE AVAILABLE TO THE PUBLIC AS PART OF FINRA'S REGULAR DISSEMINATION OF INFORMATION REGARDING MEDIA REPORTED TRANSACTIONS WAS NOT MADE AVAILABLE WITH RESPECT TO THESE 1,130,000 TRANSACTIONS. FINRA FOUND THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA'S EQUITY TRADE REPORTING RULES RELATED TO MEDIA REPORTING. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DID NOT MEDIA REPORT 1,130,000 TRANSACTIONS TO THE OTC REPORTING FACILITY (OTCRF). THE FINDINGS STATED THAT THE FIRM ROUTED 1,130,000 ORDERS IN OTC EQUITY SECURITIES TO A CANADIAN BROKER- DEALER FOR EXECUTION. IN 1,070,000 INSTANCES, THE CANADIAN BROKER-DEALER ROUTED THE ORDERS TO THE TORONTO STOCK EXCHANGE (TSX), WHERE THE ORDERS WERE EXECUTED, AND THE TRANSACTIONS REPORTED TO THE TSX. THE CANADIAN BROKER-DEALER THEN CONVERTED THE PRICE RECEIVED ON THE TSX INTO U.S. DOLLARS, AND ADDED AN ADDITIONAL AMOUNT AS COMPENSATION. THE CANADIAN BROKER-DEALER THEN CONVEYED THE SHARES TO THE FIRM AT THE NEW, MARKED-UP PRICE BY SUBMITTING A NON-MEDIA, CLEARING-ONLY REPORT TO THE OTCRF. THE FINDINGS ALSO STATED THAT BECAUSE THE TRADES WITH THE FIRM WERE REPORTED AT A DIFFERENT PRICE THAN www.finra.org/brokercheck THE PRICE PAID OR RECEIVED ON THE TSX, THE TRANSACTIONS User Guidance BETWEEN THE FIRM AND THE CANADIAN BROKER-DEALER WERE NET TRADES, AND THUS WERE REQUIRED TO BE MEDIA REPORTED BY THE FIRM. THE FINDINGS ALSO INCLUDED THAT IN 60,000 INSTANCES, THE CANADIAN BROKER-DEALER EXECUTED THE TRADES ON A PRINCIPAL BASIS RATHER THAN ON THE TSX. THE CANADIAN BROKER-DEALER THEN CONVEYED THE SHARES TO THE FIRM BY SUBMITTING A NON-MEDIA, CLEARING-ONLY REPORT TO THE OTCRF. THESE TRADES ALSO WERE REQUIRED TO BE MEDIA REPORTED BY THE FIRM TO THE OTCRF. THE FIRM DID NOT MEDIA REPORT 1,130,000 TRANSACTIONS TO THE OTCRF AND AS A RESULT, THE QUALITY AND USABILITY OF INFORMATION RECEIVED AND EMPLOYED BY FINRA IN ITS OVERALL SURVEILLANCE OF MARKET ACTIVITY IN OTC EQUITY SECURITIES WAS NEGATIVELY IMPACTED. IN ADDITION, INFORMATION MADE AVAILABLE TO THE PUBLIC AS PART OF FINRA'S REGULAR DISSEMINATION OF INFORMATION REGARDING MEDIA REPORTED TRANSACTIONS WAS NOT MADE AVAILABLE WITH RESPECT TO THESE 1,130,000 TRANSACTIONS. FINRA FOUND THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA'S EQUITY TRADE REPORTING RULES RELATED TO MEDIA REPORTING. Initiated By: FINRA Date Initiated: 09/22/2017 Docket/Case Number: 2015044085201

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/22/2017 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 $170,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $170,000, AND UNDERTAKES TO REVISE THE FIRM'S SUPERVISORY SYSTEM, INCLUDING, BUT NOT LIMITED TO, ITS ©2021 FINRA. All rights reserved. Report aboutWRITTEN SCOTTRADE, SUPERVISORY INC. PROCEDURES (WSPS), WITH RESPECT TO THE 46 AREA DESCRIBED IN THE AWC. FINES PAID IN FULL ON OCTOBER 4, 2017. www.finra.org/brokercheck User Guidance

Sanction Details: THE FIRM WAS CENSURED, FINED $170,000, AND UNDERTAKES TO REVISE THE FIRM'S SUPERVISORY SYSTEM, INCLUDING, BUT NOT LIMITED TO, ITS WRITTEN SUPERVISORY PROCEDURES (WSPS), WITH RESPECT TO THE AREA DESCRIBED IN THE AWC. FINES PAID IN FULL ON OCTOBER 4, 2017. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DID NOT MEDIA REPORT 1,130,000 TRANSACTIONS TO THE OTC REPORTING FACILITY (OTCRF). THE FINDINGS STATED THAT THE FIRM ROUTED 1,130,000 ORDERS IN OTC EQUITY SECURITIES TO A CANADIAN BROKER- DEALER FOR EXECUTION. IN 1,070,000 INSTANCES, THE CANADIAN BROKER-DEALER ROUTED THE ORDERS TO THE TORONTO STOCK EXCHANGE (TSX), WHERE THE ORDERS WERE EXECUTED, AND THE TRANSACTIONS REPORTED TO THE TSX. THE CANADIAN BROKER-DEALER THEN CONVERTED THE PRICE RECEIVED ON THE TSX INTO U.S. DOLLARS, AND ADDED AN ADDITIONAL AMOUNT AS COMPENSATION. THE CANADIAN BROKER-DEALER THEN CONVEYED THE SHARES TO THE FIRM AT THE NEW, MARKED-UP PRICE BY SUBMITTING A NON-MEDIA, CLEARING-ONLY REPORT TO THE OTCRF. THE FINDINGS ALSO STATED THAT BECAUSE THE TRADES WITH THE FIRM WERE REPORTED AT A DIFFERENT PRICE THAN THE PRICE PAID OR RECEIVED ON THE TSX, THE TRANSACTIONS BETWEEN THE FIRM AND THE CANADIAN BROKER-DEALER WERE NET TRADES, AND THUS WERE REQUIRED TO BE MEDIA REPORTED BY THE FIRM. THE FINDINGS ALSO INCLUDED THAT IN 60,000 INSTANCES, THE CANADIAN BROKER-DEALER EXECUTED THE TRADES ON A PRINCIPAL BASIS RATHER THAN ON THE TSX. THE CANADIAN BROKER-DEALER THEN CONVEYED THE SHARES TO THE FIRM BY SUBMITTING A NON-MEDIA, CLEARING-ONLY REPORT TO THE OTCRF. THESE TRADES ALSO WERE REQUIRED TO BE MEDIA REPORTED BY THE FIRM TO THE OTCRF. THE FIRM DID NOT MEDIA REPORT 1,130,000 TRANSACTIONS TO THE OTCRF AND AS A RESULT, THE QUALITY AND USABILITY OF INFORMATION RECEIVED AND EMPLOYED BY FINRA IN ITS OVERALL SURVEILLANCE OF MARKET ACTIVITY IN OTC EQUITY SECURITIES WAS NEGATIVELY IMPACTED. IN ADDITION, INFORMATION MADE AVAILABLE TO THE PUBLIC AS PART OF FINRA'S REGULAR DISSEMINATION OF INFORMATION REGARDING MEDIA REPORTED TRANSACTIONS WAS NOT MADE AVAILABLE WITH RESPECT TO THESE 1,130,000 TRANSACTIONS. FINRA FOUND THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA'S EQUITY TRADE REPORTING RULES RELATED TO MEDIA REPORTING. Initiated By: FINRA ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 47 www.finra.org/brokercheck User Guidance

Initiated By: FINRA Date Initiated: 09/22/2017 Docket/Case Number: 2015044085201

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/22/2017 Sanctions Ordered: Censure Monetary/Fine $170,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $170,000, AND UNDERTAKES TO REVISE THE FIRM'S SUPERVISORY SYSTEM, INCLUDING, BUT NOT LIMITED TO, ITS WRITTEN SUPERVISORY PROCEDURES (WSPS), WITH RESPECT TO THE AREA DESCRIBED IN THE AWC. i Disclosure 8 of 51 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 FOR SETTLEMENT DATES BETWEEN JANUARY 13, 2006 AND NOVEMBER 28, 2008, THE FIRM FAILED TO REPORT 126 SHORT INTEREST POSITIONS TOTALING 114,911 SHARES. THE FINDINGS STATED THAT THE FIRM FAILED TO REPORT 22 OF THE 126 SHORT INTEREST POSITIONS DUE TO AN ERROR BY THE FIRM'S STOCK RECORD DEPARTMENT. AS A RESULT OF THE ERROR, THE FIRM OMITTED OR DROPPED SECURITIES FROM ITS SHORT INTEREST REPORT. THE REMAINING FAILURES WERE THE RESULT OF THE FIRM'S MISPLACED RELIANCE ON A THIRD-PARTY WEBSITE THAT INDICATED CERTAIN SECURITIES WERE NOT ACTIVE AND THUS NOT REPORTABLE (NON-LISTED). FOR SETTLEMENT DATES BETWEEN DECEMBER 15, 2008 AND NOVEMBER 15, 2013, THE FIRM FAILED TO REPORT 339 SHORT INTEREST POSITIONS TOTALING 960,362 SHARES. THE FIRM FAILED TO REPORT 217 OF THE 339 SHORT INTEREST ©2021 FINRA. All rights reserved. Report aboutPOSITIONS SCOTTRADE, DUE INC. TO THE ERROR BY THE STOCK RECORD DEPARTMENT 48 DISCUSSED ABOVE. TWENTY-TWO FAILURES WERE DUE TO THE FIRM'S INCORRECT BELIEF THAT WARRANTS WERE NOT REPORTABLE AND THE REMAINING FAILURES WERE DUE TO THE NON-LISTED ISSUE DISCUSSED ABOVE. FOR SETTLEMENT DATES BETWEEN DECEMBER 15, 2009 AND DECEMBER 14, 2012, THE FIRM REPORTED 149 SHORT INTEREST POSITIONS TOTALING 58,972 SHARES WHEN IT SHOULD HAVE REPORTED 24 SHORT INTEREST POSITIONS TOTALING 23,596 SHARES. THESE INACCURATE SHORT INTEREST REPORTS OCCURRED AS A RESULT OF A SOFTWARE CODING ISSUE THAT RECLASSIFIED LONG POSITIONS IN CERTAIN ACCOUNTS AS SHORT. THE FINDINGS ALSO STATED THAT BETWEEN JANUARY 13, 2006 AND NOVEMBER 13, 2013, THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD RULE 3360 AND FINRA RULE 4560. SPECIFICALLY, THE FIRM'S WRITTEN SUPERVISORY PROCEDURES INCLUDED A SPOT CHECKING PROCESS THAT DID NOT ADEQUATELY ASSESS THE ACCURACY AND COMPLETENESS OF THE FIRM'S REPORTED SHORT INTEREST POSITIONS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT FOR SETTLEMENT DATES BETWEEN JANUARY 13, 2006 AND NOVEMBER 28, 2008, THE FIRM FAILED TO REPORT 126 SHORT INTEREST POSITIONS TOTALING 114,911 SHARES. THE FINDINGS STATED THAT THE FIRM FAILED TO REPORT 22 OF THE 126 SHORT INTEREST POSITIONS DUE TO AN ERROR BY THE FIRM'S STOCK RECORD DEPARTMENT. AS A RESULT OF THE ERROR, THE FIRM OMITTED OR DROPPED SECURITIES FROM ITS SHORT INTEREST REPORT. THE REMAINING FAILURES WERE THE RESULT OF THE FIRM'S MISPLACED RELIANCE ON A THIRD-PARTY WEBSITE THAT www.finra.org/brokercheck INDICATED CERTAIN SECURITIES WERE NOT ACTIVE AND THUS NOT User Guidance REPORTABLE (NON-LISTED). FOR SETTLEMENT DATES BETWEEN DECEMBER 15, 2008 AND NOVEMBER 15, 2013, THE FIRM FAILED TO REPORT 339 SHORT INTEREST POSITIONS TOTALING 960,362 SHARES. THE FIRM FAILED TO REPORT 217 OF THE 339 SHORT INTEREST POSITIONS DUE TO THE ERROR BY THE STOCK RECORD DEPARTMENT DISCUSSED ABOVE. TWENTY-TWO FAILURES WERE DUE TO THE FIRM'S INCORRECT BELIEF THAT WARRANTS WERE NOT REPORTABLE AND THE REMAINING FAILURES WERE DUE TO THE NON-LISTED ISSUE DISCUSSED ABOVE. FOR SETTLEMENT DATES BETWEEN DECEMBER 15, 2009 AND DECEMBER 14, 2012, THE FIRM REPORTED 149 SHORT INTEREST POSITIONS TOTALING 58,972 SHARES WHEN IT SHOULD HAVE REPORTED 24 SHORT INTEREST POSITIONS TOTALING 23,596 SHARES. THESE INACCURATE SHORT INTEREST REPORTS OCCURRED AS A RESULT OF A SOFTWARE CODING ISSUE THAT RECLASSIFIED LONG POSITIONS IN CERTAIN ACCOUNTS AS SHORT. THE FINDINGS ALSO STATED THAT BETWEEN JANUARY 13, 2006 AND NOVEMBER 13, 2013, THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD RULE 3360 AND FINRA RULE 4560. SPECIFICALLY, THE FIRM'S WRITTEN SUPERVISORY PROCEDURES INCLUDED A SPOT CHECKING PROCESS THAT DID NOT ADEQUATELY ASSESS THE ACCURACY AND COMPLETENESS OF THE FIRM'S REPORTED SHORT INTEREST POSITIONS. Initiated By: FINRA Date Initiated: 07/28/2017 Docket/Case Number: 2014039741201

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: 07/28/2017 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 $110,000.00 Other Sanctions Ordered: ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 49 www.finra.org/brokercheck User Guidance

Sanction Details: THE FIRM WAS CENSURED AND FINED $110,000. FINES PAID IN FULL ON AUGUST 9, 2017. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT FOR SETTLEMENT DATES BETWEEN JANUARY 13, 2006 AND NOVEMBER 28, 2008, THE FIRM FAILED TO REPORT 126 SHORT INTEREST POSITIONS TOTALING 114,911 SHARES. THE FINDINGS STATED THAT THE FIRM FAILED TO REPORT 22 OF THE 126 SHORT INTEREST POSITIONS DUE TO AN ERROR BY THE FIRM'S STOCK RECORD DEPARTMENT. AS A RESULT OF THE ERROR, THE FIRM OMITTED OR DROPPED SECURITIES FROM ITS SHORT INTEREST REPORT. THE REMAINING FAILURES WERE THE RESULT OF THE FIRM'S MISPLACED RELIANCE ON A THIRD-PARTY WEBSITE THAT INDICATED CERTAIN SECURITIES WERE NOT ACTIVE AND THUS NOT REPORTABLE (NON-LISTED). FOR SETTLEMENT DATES BETWEEN DECEMBER 15, 2008 AND NOVEMBER 15, 2013, THE FIRM FAILED TO REPORT 339 SHORT INTEREST POSITIONS TOTALING 960,362 SHARES. THE FIRM FAILED TO REPORT 217 OF THE 339 SHORT INTEREST POSITIONS DUE TO THE ERROR BY THE STOCK RECORD DEPARTMENT DISCUSSED ABOVE. TWENTY-TWO FAILURES WERE DUE TO THE FIRM'S INCORRECT BELIEF THAT WARRANTS WERE NOT REPORTABLE AND THE REMAINING FAILURES WERE DUE TO THE NON-LISTED ISSUE DISCUSSED ABOVE. FOR SETTLEMENT DATES BETWEEN DECEMBER 15, 2009 AND DECEMBER 14, 2012, THE FIRM REPORTED 149 SHORT INTEREST POSITIONS TOTALING 58,972 SHARES WHEN IT SHOULD HAVE REPORTED 24 SHORT INTEREST POSITIONS TOTALING 23,596 SHARES. THESE INACCURATE SHORT INTEREST REPORTS OCCURRED AS A RESULT OF A SOFTWARE CODING ISSUE THAT RECLASSIFIED LONG POSITIONS IN CERTAIN ACCOUNTS AS SHORT. THE FINDINGS ALSO STATED THAT BETWEEN JANUARY 13, 2006 AND NOVEMBER 13, 2013, THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD RULE 3360 AND FINRA RULE 4560. SPECIFICALLY, THE FIRM'S WRITTEN SUPERVISORY PROCEDURES INCLUDED A SPOT CHECKING PROCESS THAT DID NOT ADEQUATELY ASSESS THE ACCURACY AND COMPLETENESS OF THE FIRM'S REPORTED SHORT INTEREST POSITIONS. Initiated By: FINRA Date Initiated: 07/28/2017 Docket/Case Number: 20140397412-01

Principal Product Type: Other Other Product Type(s): SHORT INTEREST REPORTING Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/28/2017 Sanctions Ordered: Censure Monetary/Fine $110,000.00 Other Sanctions Ordered: Sanction Details: THE FULL AMOUNT OF THE FINE $110,000 WAS PAID BY CHECK DATED 8/2/17. i Disclosure 9 of 51 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 ITS CONFIRMATION STATEMENTS FOR SALES OF MUNICIPAL BONDS WITH OPTIONAL OR SPECIAL REDEMPTION FEATURES DID NOT IDENTIFY THE BONDS AS CALLABLE. THE FINDINGS STATED THAT THE FIRM ALSO DID NOT HAVE A SYSTEM TO ENSURE THAT THE CONFIRMATION STATEMENTS CONTAINED THAT INFORMATION. Initiated By: FINRA Date Initiated: 10/10/2016 Docket/Case Number: 2013038369901

Principal Product Type: Debt - Municipal Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/10/2016 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: THE FIRM WAS CENSURED AND FINED $150,000. FINE PAID IN FULL ON OCTOBER 26, 2016. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT'S CONFIRMATION STATEMENTS FOR SALES OF MUNICIPAL BONDS WITH OPTIONAL OR SPECIAL REDEMPTION FEATURES DID NOT IDENTIFY THE BONDS AS CALLABLE. THE FINDINGS STATED THAT THE FIRM ALSO DID NOT HAVE A SYSTEM TO ENSURE THAT THE CONFIRMATION STATEMENTS CONTAINED THAT INFORMATION. Initiated By: FINRA Date Initiated: 10/10/2016 Docket/Case Number: 2013038369901

Principal Product Type: Debt - Municipal Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/10/2016 Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine SCOTTRADE, $150,000.00 INC. 52 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $150,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $150,000.00. i Disclosure 10 of 51 Reporting Source: Regulator Current Status: Final Allegations: RESPONDENT'S FAILURE TO ESTABLISH WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS IN CONNECTION WITH THE WIRE TRANSFER OF FUNDS TO THE ACCOUNT OF A THIRD-PARTY IS A VIOLATION OF §115.10(B)(1) OF THE RULES AND REGULATIONS OF THE TEXAS STATE SECURITIES BOARD RULES Initiated By: TEXAS Date Initiated: 03/04/2016 Docket/Case Number: IC16-CAF-04 URL for Regulatory Action: 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: Order Resolution Date: 03/04/2016 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: Monetary/Fine $50,000.00 Other Sanctions Ordered: Sanction Details: RESPONDENT FURTHER AGREES TO CONTRIBUTE FIFTY THOUSAND DOLLARS ($50,000) WITHIN TEN (10) DAYS TO THE TEXAS TO THE ©2021 FINRA. All rights reserved. Report aboutINVESTOR SCOTTRADE, EDUCATION INC. FUND OF THE INVESTOR PROTECTION TRUST. 53 www.finra.org/brokercheck User Guidance

Sanction Details: RESPONDENT FURTHER AGREES TO CONTRIBUTE FIFTY THOUSAND DOLLARS ($50,000) WITHIN TEN (10) DAYS TO THE TEXAS TO THE INVESTOR EDUCATION FUND OF THE INVESTOR PROTECTION TRUST. i Reporting Source: Firm Current Status: Final Allegations: STATE REGULATORY AUTHORITY ALLEGES FROM JANUARY 2011 TO OCTOBER 2013, APPLICANT'S WRITTEN SUPERVISORY PROCEDURES WERE NOT IN COMPLIANCE WITH APPLICABLE STATE SECURITIES BOARD RULE RELATING TO CONFIRMATION NOTICES SENT TO THE CUSTOMER AFTER FUNDS TRANSFERRED FROM A CUSTOMER'S ACCOUNT TO THE ACCOUNT OF A THIRD PARTY. Initiated By: TEXAS SECURITIES BOARD Date Initiated: 03/07/2016 Docket/Case Number: IC16-CAF-04

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief APPLICANT PAID A FINE OF $50,000.00. APPLICANT ALSO AGREED TO Sought: CONTRIBUTE AN ADDITIONAL AMOUNT TO BE USED FOR INVESTOR EDUCATION IN TEXAS.

Resolution: Order Resolution Date: 03/07/2016 Sanctions Ordered: Monetary/Fine $50,000.00 Other Sanctions Ordered: APPLICANT FURTHER AGREED TO CONTRIBUTE AN ADDITIONAL AMOUNT TO BE USED FOR INVESTOR EDUCATION EFFORTS IN TEXAS. Sanction Details: AGREED TO CONTRIBUTE 50,000.00 TO THE INVESTOR EDUCATION EFFORTS IN TEXAS. i Disclosure 11 of 51 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 ©2021 FINRA. All rights reserved. Report aboutRETAIN SCOTTRADE, A SIGNIFICANT INC. NUMBER OF BUSINESS-RELATED ELECTRONIC 54 RECORDS IN NON-REWRITABLE, NON-ERASABLE FORMAT (ALSO REFERRED TO AS "WRITE-ONCE, READ-MANY" OR "WORM" FORMAT), WHICH INCLUDED KEY RECORDS SUCH AS SUSPICIOUS ACTIVITY REPORTS, WRITTEN SUPERVISORY PROCEDURES (WSPS), AND CUSTOMER ACCOUNT STATEMENTS, AS REQUIRED BY SEC RULE 17A-4. THE FINDINGS STATED THAT FIRM PERSONNEL IN DIFFERENT DEPARTMENTS SAVED CERTAIN DOCUMENTS IN A RESTRICTED SHARE DRIVE, WHICH WAS NOT WORM COMPLIANT. EACH DEPARTMENT WAS RESPONSIBLE FOR THE RETENTION OF ITS OWN DOCUMENTS, AND THERE WAS NO CENTRALIZED DOCUMENT RETENTION PROCESS OR PROCEDURE IN PLACE FOR ALL OF THE DEPARTMENTS TO FOLLOW. THE FIRM ALSO DID NOT HAVE A CENTRALIZED DEPARTMENT, TEAM, OR INDIVIDUAL RESPONSIBLE FOR ENSURING THAT THE VARIOUS FIRM DEPARTMENTS FOLLOWED A CONSISTENT DOCUMENT RETENTION PROCESS FULLY COMPLIANT WITH THE RECORD RETENTION RULES INCLUDING THE REQUIREMENT THAT ALL RECORDS BE RETAINED IN WORM FORMAT AS REQUIRED BY SEC RULE 17A-4. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO RETAIN OVER 168 MILLION AUTOMATICALLY GENERATED NOTIFICATIONS AND MASS MARKETING EMAILS SENT ON ITS BEHALF BY THIRD PARTIES. CERTAIN OUTGOING MAILS GENERATED BY THE FIRM'S AUTOMATED INTERNAL SYSTEMS, AND CERTAIN OUTGOING EMAILS AND CORRESPONDENCE GENERATED BY THIRD-PARTY VENDORS ON BEHALF OF THE FIRM, WERE NOT COPIED TO THE FIRM'S WORM STORAGE DEVICE OR RETAINED IN HARD COPY FORMAT. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WSPS REASONABLY DESIGNED TO ENSURE A CONSISTENT AND CENTRALIZED DOCUMENT RETENTION AND PRESERVATION PROGRAM AND ACHIEVE COMPLIANCE WITH SEC RULE 17A-4, WHICH CONTRIBUTED TO THE FIRM'S FAILURE TO MAINTAIN ITS BOOKS AND RECORDS IN WORM FORMAT. FURTHER, THE FIRM DID NOT "VERIFY AUTOMATICALLY THE QUALITY AND ACCURACY OF THE STORAGE MEDIA RECORDING PROCESS" FOR ALL DOCUMENTS THE FIRM WAS REQUIRED TO PRESERVE. FINRA FOUND THAT THE FIRM FAILED TO DISCLOSE TO FINRA THE FIRM'S SETTLEMENT OF NINE CUSTOMER COMPLAINTS. THESE COMPLAINTS WERE REPORTED BY THE FIRM IN THE QUARTERLY REPORTS FILED BY THE FIRM PURSUANT TO FINRA RULE 4530(D), BUT THE FIRM DID NOT REPORT THE CUSTOMER SETTLEMENTS TO FINRA UNTIL ALERTED BY FINRA STAFF. THE FIRM FAILED TO ESTABLISH AND MAINTAIN WSPS DESIGNED TO ENSURE THE REPORTING OF SETTLEMENTS WITH CUSTOMERS TO FINRA. THE FIRM'S WSPS FAILED TO SET FORTH A PROCESS FOR WHEN AND HOW THE FIRM WOULD REPORT SUCH CUSTOMER SETTLEMENTS TO FINRA. www.finra.org/brokercheck User Guidance

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO RETAIN A SIGNIFICANT NUMBER OF BUSINESS-RELATED ELECTRONIC RECORDS IN NON-REWRITABLE, NON-ERASABLE FORMAT (ALSO REFERRED TO AS "WRITE-ONCE, READ-MANY" OR "WORM" FORMAT), WHICH INCLUDED KEY RECORDS SUCH AS SUSPICIOUS ACTIVITY REPORTS, WRITTEN SUPERVISORY PROCEDURES (WSPS), AND CUSTOMER ACCOUNT STATEMENTS, AS REQUIRED BY SEC RULE 17A-4. THE FINDINGS STATED THAT FIRM PERSONNEL IN DIFFERENT DEPARTMENTS SAVED CERTAIN DOCUMENTS IN A RESTRICTED SHARE DRIVE, WHICH WAS NOT WORM COMPLIANT. EACH DEPARTMENT WAS RESPONSIBLE FOR THE RETENTION OF ITS OWN DOCUMENTS, AND THERE WAS NO CENTRALIZED DOCUMENT RETENTION PROCESS OR PROCEDURE IN PLACE FOR ALL OF THE DEPARTMENTS TO FOLLOW. THE FIRM ALSO DID NOT HAVE A CENTRALIZED DEPARTMENT, TEAM, OR INDIVIDUAL RESPONSIBLE FOR ENSURING THAT THE VARIOUS FIRM DEPARTMENTS FOLLOWED A CONSISTENT DOCUMENT RETENTION PROCESS FULLY COMPLIANT WITH THE RECORD RETENTION RULES INCLUDING THE REQUIREMENT THAT ALL RECORDS BE RETAINED IN WORM FORMAT AS REQUIRED BY SEC RULE 17A-4. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO RETAIN OVER 168 MILLION AUTOMATICALLY GENERATED NOTIFICATIONS AND MASS MARKETING EMAILS SENT ON ITS BEHALF BY THIRD PARTIES. CERTAIN OUTGOING MAILS GENERATED BY THE FIRM'S AUTOMATED INTERNAL SYSTEMS, AND CERTAIN OUTGOING EMAILS AND CORRESPONDENCE GENERATED BY THIRD-PARTY VENDORS ON BEHALF OF THE FIRM, WERE NOT COPIED TO THE FIRM'S WORM STORAGE DEVICE OR RETAINED IN HARD COPY FORMAT. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WSPS REASONABLY DESIGNED TO ENSURE A CONSISTENT AND CENTRALIZED DOCUMENT RETENTION AND PRESERVATION PROGRAM AND ACHIEVE COMPLIANCE WITH SEC RULE 17A-4, WHICH CONTRIBUTED TO THE FIRM'S FAILURE TO MAINTAIN ITS BOOKS AND RECORDS IN WORM FORMAT. FURTHER, THE FIRM DID NOT "VERIFY AUTOMATICALLY THE QUALITY AND ACCURACY OF THE STORAGE MEDIA RECORDING PROCESS" FOR ALL DOCUMENTS THE FIRM WAS REQUIRED TO PRESERVE. FINRA FOUND THAT THE FIRM FAILED TO DISCLOSE TO FINRA THE FIRM'S SETTLEMENT OF NINE CUSTOMER COMPLAINTS. THESE COMPLAINTS WERE REPORTED BY THE FIRM IN THE QUARTERLY REPORTS FILED BY THE FIRM PURSUANT TO FINRA RULE 4530(D), BUT THE FIRM DID NOT REPORT THE CUSTOMER SETTLEMENTS TO FINRA UNTIL ALERTED BY FINRA STAFF. THE FIRM FAILED TO ESTABLISH AND MAINTAIN WSPS DESIGNED TO ENSURE THE REPORTING OF SETTLEMENTS WITH CUSTOMERS TO FINRA. THE FIRM'S WSPS FAILED TO SET FORTH A PROCESS FOR WHEN AND HOW THE FIRM WOULD REPORT SUCH CUSTOMER SETTLEMENTS TO FINRA. Initiated By: FINRA Date Initiated: 11/16/2015 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 55 www.finra.org/brokercheck User Guidance

Date Initiated: 11/16/2015 Docket/Case Number: 2014039991001

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: 11/16/2015 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 $2,600,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $2.6 MILLION. FINE PAID IN FULL ON DECEMBER 4, 2015. Regulator Statement IN RESOLVING THIS MATTER, FINRA RECOGNIZED THE FIRM'S COOPERATION IN HAVING SELF-REPORTED THE DOCUMENT RETENTION AND PRESERVATION ISSUES DESCRIBED HEREIN, AND UNDERTAKING AN INTERNAL REVIEW OF THE FIRM'S SUPERVISORY POLICIES, PROCEDURES AND SYSTEMS RELATING TO THESE ISSUES. THE SANCTIONS BELOW REFLECT THE CREDIT THAT THE FIRM HAS BEEN GIVEN FOR SELF- REPORTING THESE ISSUES, AND FOR THE SUBSTANTIAL ASSISTANCE THE FIRM PROVIDED TO FINRA DURING ITS INVESTIGATION BY, AMONG OTHER THINGS, PROVIDING INFORMATION OBTAINED AS A RESULT OF THE FIRM'S INTERNAL INVESTIGATION. THE FIRM ALSO PROMPTLY TOOK REMEDIAL STEPS TO CORRECT THE FIRM'S DOCUMENT RETENTION AND RECORD PRESERVATION SYSTEM, AND BEGAN EMPLOYING CORRECTIVE MEASURES, PRIOR TO INTERVENTION BY A REGULATOR, TO AVOID RECURRENCE OF THE MISCONDUCT. i Reporting Source: Firm

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 RETAIN A SIGNIFICANT NUMBER OF BUSINESS-RELATED ELECTRONIC RECORDS IN NON-REWRITABLE, NON-ERASABLE FORMAT (ALSO REFERRED TO AS "WRITE-ONCE, READ-MANY" OR "WORM" FORMAT), AS REQUIRED BY SEC RULE 17A-4.

THE FIRM ALSO CONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED TO DISCLOSE TO FINRA THE FIRM'S SETTLEMENT OF NINE CUSTOMER COMPLAINTS PURSUANT TO FINRA RULE 4530(D) IN A TIMELY MANNER. Initiated By: FINRA Date Initiated: 11/16/2015 Docket/Case Number: 2014039991001

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/16/2015 Sanctions Ordered: Censure Monetary/Fine $2,600,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $2,600,000.00 i Disclosure 12 of 51 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 TRANSMITTED REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT CONTAINED INACCURATE TIME-IN-FORCE CODES, INACCURATE SPECIAL HANDLING CODES, INACCURATE ORDER RECEIVED TIMESTAMPS, ©2021 FINRA. All rights reserved. Report aboutAND SCOTTRADE, INACCURATE INC. ORDER CANCEL TIMESTAMPS. 57 www.finra.org/brokercheck WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED User Guidance TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT TRANSMITTED REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT CONTAINED INACCURATE TIME-IN-FORCE CODES, INACCURATE SPECIAL HANDLING CODES, INACCURATE ORDER RECEIVED TIMESTAMPS, AND INACCURATE ORDER CANCEL TIMESTAMPS. Initiated By: FINRA Date Initiated: 09/28/2015 Docket/Case Number: 2014040029101

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: 09/28/2015 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: Sanction Details: THE FIRM WAS CENSURED AND FINED $15,000. FINE PAID IN FULL OCTOBER 31, 2015. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT TRANSMITTED REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT CONTAINED INACCURATE TIME-IN-FORCE CODES, INACCURATE SPECIAL HANDLING CODES, INACCURATE ORDER RECEIVED TIME STAMPS, AND INACCURATE ORDER CANCEL TIME STAMPS. Initiated By: FINRA Date Initiated: 09/28/2015 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 58 www.finra.org/brokercheck User Guidance

Docket/Case Number: 2014040029101

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/28/2015 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $15,000.00. i Disclosure 13 of 51 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 THAT WAS REASONABLY DESIGNED TO CONFIRM WITH CUSTOMERS ALL WIRE TRANSMITTALS FROM CUSTOMER ACCOUNTS TO THIRD PARTY ACCOUNTS. THE FINDINGS STATED THAT FINRA CAUTIONED THE FIRM THAT IT HAD NOT ESTABLISHED A SYSTEM REASONABLY DESIGNED TO NOTIFY CUSTOMERS OF THIRD PARTY WIRES OF $500,000 OR LESS, AND TO DOCUMENT SUCH NOTIFICATION. IN RESPONSE, THE FIRM COMMITTED TO IMPLEMENTING AN AUTOMATED SYSTEM TO NOTIFY CUSTOMERS OF WIRE TRANSFERS FROM CUSTOMERS' ACCOUNTS TO THIRD PARTY ACCOUNTS BY MEANS OF EMAILS GENERATED FROM ITS HOME OFFICE. PRIOR TO THE CHANGE OF ANY OF THE FIRM'S PROCEDURES OR PROCESSES, IT FAILED TO OBTAIN CUSTOMER CONFIRMATION IN ANY MANNER WITH RESPECT TO THIRD PARTY WIRES OF LESS THAN $200,000, AND WITH RESPECT TO THIRD PARTY WIRES IN AMOUNTS BETWEEN $200,000 AND $500,000, IT IMPROPERLY REQUIRED PRODUCING BRANCH OFFICE MANAGERS TO CONFIRM SUCH WIRE TRANSFERS WITH CUSTOMERS VIA TELEPHONE CALLS. AS A RESULT, THE FIRM EITHER FAILED TO OBTAIN CUSTOMER CONFIRMATION, OR FAILED TO OBTAIN CUSTOMER CONFIRMATION IN COMPLIANCE WITH NASD RULE ©2021 FINRA. All rights reserved. Report about3012. SCOTTRADE, THE FIRM INC. PROCESSED THIRD PARTY WIRES IN THE AGGREGATE 59 AMOUNT OF $883,944,371 DURING THIS PERIOD. 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 THAT WAS REASONABLY DESIGNED TO CONFIRM WITH CUSTOMERS ALL WIRE TRANSMITTALS FROM CUSTOMER ACCOUNTS TO THIRD PARTY ACCOUNTS. THE FINDINGS STATED THAT FINRA CAUTIONED THE FIRM THAT IT HAD NOT ESTABLISHED A SYSTEM REASONABLY DESIGNED TO NOTIFY CUSTOMERS OF THIRD PARTY WIRES OF $500,000 OR LESS, AND TO DOCUMENT SUCH NOTIFICATION. IN RESPONSE, THE FIRM COMMITTED TO IMPLEMENTING AN AUTOMATED SYSTEM TO NOTIFY CUSTOMERS OF WIRE TRANSFERS FROM CUSTOMERS' ACCOUNTS TO THIRD PARTY ACCOUNTS BY MEANS OF EMAILS GENERATED FROM ITS HOME OFFICE. PRIOR TO THE CHANGE OF ANY OF THE FIRM'S PROCEDURES OR PROCESSES, IT FAILED TO OBTAIN CUSTOMER CONFIRMATION IN ANY MANNER WITH RESPECT TO THIRD PARTY WIRES OF LESS THAN $200,000, AND WITH RESPECT TO THIRD PARTY WIRES IN www.finra.org/brokercheck AMOUNTS BETWEEN $200,000 AND $500,000, IT IMPROPERLY REQUIRED User Guidance PRODUCING BRANCH OFFICE MANAGERS TO CONFIRM SUCH WIRE TRANSFERS WITH CUSTOMERS VIA TELEPHONE CALLS. AS A RESULT, THE FIRM EITHER FAILED TO OBTAIN CUSTOMER CONFIRMATION, OR FAILED TO OBTAIN CUSTOMER CONFIRMATION IN COMPLIANCE WITH NASD RULE 3012. THE FIRM PROCESSED THIRD PARTY WIRES IN THE AGGREGATE AMOUNT OF $883,944,371 DURING THIS PERIOD. Initiated By: FINRA Date Initiated: 06/22/2015 Docket/Case Number: 2013035000501

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: 06/22/2015 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 $300,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $300,000. FINE PAID IN FULL JULY 9, 2015. i Reporting Source: Firm 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 THAT WAS REASONABLY DESIGNED TO CONFIRM WITH CUSTOMERS ALL WIRE TRANSMITTALS FROM CUSTOMER ACCOUNTS TO THIRD PARTY ACCOUNTS. THE FINDINGS STATED THAT FINRA CAUTIONED THE FIRM THAT IT HAD NOT ESTABLISHED A SYSTEM REASONABLY DESIGNED TO NOTIFY CUSTOMERS OF THIRD PARTY WIRES OF $500,000 OR LESS, AND TO DOCUMENT SUCH NOTIFICATION. IN RESPONSE, THE FIRM ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 60 COMMITTED TO IMPLEMENTING AN AUTOMATED SYSTEM TO NOTIFY CUSTOMERS OF WIRE TRANSFERS FROM CUSTOMERS' ACCOUNTS TO THIRD PARTY ACCOUNTS BY MEANS OF EMAILS GENERATED FROM ITS HOME OFFICE. PRIOR TO THE CHANGE OF ANY OF THE FIRM'S PROCEDURES OR PROCESSES, IT FAILED TO OBTAIN CUSTOMER CONFIRMATION IN ANY MANNER WITH RESPECT TO THIRD PARTY WIRES OF LESS THAN $200,000 AND WITH RESPECT TO THIRD PARTY WIRES IN AMOUNTS BETWEEN $200,000 AND $500,000, IT IMPROPERLY REQUIRED PRODUCING BRANCH OFFICE MANAGERS TO CONFIRM SUCH WIRE TRANSFERS WITH CUSTOMERS VIA TELEPHONE CALLS. AS A RESULT, THE FIRM EITHER FAILED TO OBTAIN CUSTOMER CONFIRMATION, OR FAILED TO OBTAIN CUSTOMER CONFIRMATION IN COMPLIANCE WITH NASD RULE 3012. THE FIRM PROCESSED THIRD PARTY WIRES IN THE AGGREGATE AMOUNT OF $883,944,371 DURING THIS PERIOD. 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 THAT WAS REASONABLY DESIGNED TO CONFIRM WITH CUSTOMERS ALL WIRE www.finra.org/brokercheck TRANSMITTALS FROM CUSTOMER ACCOUNTS TO THIRD PARTY User Guidance ACCOUNTS. THE FINDINGS STATED THAT FINRA CAUTIONED THE FIRM THAT IT HAD NOT ESTABLISHED A SYSTEM REASONABLY DESIGNED TO NOTIFY CUSTOMERS OF THIRD PARTY WIRES OF $500,000 OR LESS, AND TO DOCUMENT SUCH NOTIFICATION. IN RESPONSE, THE FIRM COMMITTED TO IMPLEMENTING AN AUTOMATED SYSTEM TO NOTIFY CUSTOMERS OF WIRE TRANSFERS FROM CUSTOMERS' ACCOUNTS TO THIRD PARTY ACCOUNTS BY MEANS OF EMAILS GENERATED FROM ITS HOME OFFICE. PRIOR TO THE CHANGE OF ANY OF THE FIRM'S PROCEDURES OR PROCESSES, IT FAILED TO OBTAIN CUSTOMER CONFIRMATION IN ANY MANNER WITH RESPECT TO THIRD PARTY WIRES OF LESS THAN $200,000 AND WITH RESPECT TO THIRD PARTY WIRES IN AMOUNTS BETWEEN $200,000 AND $500,000, IT IMPROPERLY REQUIRED PRODUCING BRANCH OFFICE MANAGERS TO CONFIRM SUCH WIRE TRANSFERS WITH CUSTOMERS VIA TELEPHONE CALLS. AS A RESULT, THE FIRM EITHER FAILED TO OBTAIN CUSTOMER CONFIRMATION, OR FAILED TO OBTAIN CUSTOMER CONFIRMATION IN COMPLIANCE WITH NASD RULE 3012. THE FIRM PROCESSED THIRD PARTY WIRES IN THE AGGREGATE AMOUNT OF $883,944,371 DURING THIS PERIOD. Initiated By: FINRA Date Initiated: 06/22/2015 Docket/Case Number: 2013035000501

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/22/2015 Sanctions Ordered: Censure Monetary/Fine $300,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $300,000. i Disclosure 14 of 51 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 IMPLEMENT WRITTEN SUPERVISORY POLICIES AND PROCEDURES ©2021 FINRA. All rights reserved. Report aboutREASONABLY SCOTTRADE, DESIGNED INC. TO INSURE THE SECURITY AND 61 CONFIDENTIALITY OF CUSTOMER RECORDS AND INFORMATION. THE FINDINGS STATED THAT THE FIRM DISCLOSED TO A CLASS ACTION CLAIMS ADMINISTRATOR OR A PRIVATE LAW FIRM NONPUBLIC, PERSONAL INFORMATION CONCERNING CUSTOMERS INCLUDING NAME AND ADDRESS, AND THE FACT THAT THE CUSTOMER PURCHASED A SECURITY INVOLVED IN THE CLASS ACTION. www.finra.org/brokercheck User Guidance

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO IMPLEMENT WRITTEN SUPERVISORY POLICIES AND PROCEDURES REASONABLY DESIGNED TO INSURE THE SECURITY AND CONFIDENTIALITY OF CUSTOMER RECORDS AND INFORMATION. THE FINDINGS STATED THAT THE FIRM DISCLOSED TO A CLASS ACTION CLAIMS ADMINISTRATOR OR A PRIVATE LAW FIRM NONPUBLIC, PERSONAL INFORMATION CONCERNING CUSTOMERS INCLUDING NAME AND ADDRESS, AND THE FACT THAT THE CUSTOMER PURCHASED A SECURITY INVOLVED IN THE CLASS ACTION. Initiated By: FINRA Date Initiated: 01/21/2015 Docket/Case Number: 2012031796401

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: 01/21/2015 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 $200,000.00 Other Sanctions Ordered: THE FIRM IS REQUIRED TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF ITS POLICIES, SYSTEMS, PROCEDURES (WRITTEN OR OTHERWISE), AND TRAINING WITH RESPECT TO RESPONDING TO REQUESTS FOR NONPUBLIC PERSONAL INFORMATION RELATING TO CLASS ACTIONS. Sanction Details: THE FIRM IS CENSURED, FINED $200,000, AND REQUIRED TO COMPLY WITH AN UNDERTAKING.

Reporting Source: Firm 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 IMPLEMENT WRITTEN SUPERVISORY POLICIES AND PROCEDURES REASONABLY DESIGNED TO INSURE THE SECURITY AND CONFIDENTIALITY OF CUSTOMER RECORDS AND INFORMATION IN CONNECTION WITH CERTAIN CLASS-ACTION RELATED REQUESTS. THE FINDINGS STATED THAT THE FIRM DISCLOSED TO A CLASS ACTION ADMINISTRATOR OR A PRIVATE LAW FIRM NON PUBLIC, PERSONAL INFORMATION CONCERNING CUSTOMERS INCLUDING NAME AND ADDRESS, AND THE FACT THAT THE CUSTOMER PURCHASED A SECURITY INVOLVED IN THE CLASS ACTION. Initiated By: FINRA Date Initiated: 01/21/2015 Docket/Case Number: 2012031796401

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/21/2015 Sanctions Ordered: Censure Monetary/Fine $200,000.00 Other Sanctions Ordered: THE FIRM IS REQUIRED TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF ITS POLICIES, SYSTEMS, PROCEDURES (WRITTEN OR OTHERWISE), AND TRAINING WITH RESPECT TO RESPONDING TO REQUESTS FOR NON-PUBLIC PERSONAL INFORMATION RELATING TO CLASS ACTIONS. Sanction Details: THE FIRM IS CENSURED, FINED $200,000.00, AND REQUIRED TO COMPLY WITH AN UNDERTAKING. i Disclosure 15 of 51 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 TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA. SPECIFICALLY, THE FIRM INCORRECTLY REPORTED TIME-IN-FORCE (TIF) CODES, MARKING ORDERS ENTERED DURING POST- MARKET HOURS AS DAY (DAY) INSTEAD OF GOOD-TIL-CROSSING (GTX); FILED ERRONEOUS DESK (DS) REPORTS TO OATS; FAILED TO SUBMIT THE CORRECT CANCELLED-BY-FLAG (CNCL FL) TO OATS; AND FAILED TO SUBMIT A ROUTE (RT) REPORT TO OATS. Initiated By: FINRA Date Initiated: 03/12/2014 Docket/Case Number: 2012031643301

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: 03/12/2014 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 $10,000.00 Other Sanctions Ordered: Sanction Details: SEE ABOVE i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 64 TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA. SPECIFICALLY, THE FIRM INCORRECTLY REPORTED TIME-IN-FORCE (TIF) CODES, MARKING ORDERS ENTERED DURING POST- MARKET HOURS AS DAY (DAY) INSTEAD OF GOOD TILL CROSSING (GTX); FILED ERRONEOUS DESK(DS) REPORTS TO OATS; FAILED TO SUBMIT THE CORRECT CANCELLED-BY-FLAG (CNCL FL) TO OATS; AND FAILED TO SUMBIT A ROUTE (RT0 REPORT TO OATS. 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 TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA. SPECIFICALLY, THE FIRM INCORRECTLY REPORTED TIME-IN-FORCE (TIF) CODES, MARKING ORDERS ENTERED DURING POST- MARKET HOURS AS DAY (DAY) INSTEAD OF GOOD TILL CROSSING (GTX); FILED ERRONEOUS DESK(DS) REPORTS TO OATS; FAILED TO SUBMIT THE CORRECT CANCELLED-BY-FLAG (CNCL FL) TO OATS; AND FAILED TO SUMBIT A ROUTE (RT0 REPORT TO OATS. Initiated By: FINRA Date Initiated: 03/12/2014 Docket/Case Number: 2012031643301

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 03/12/2014 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM CONSENTED TO A CENSURE AND FINE OF $10,000 AND THE ENTRY OF FINDINGS AGAINST THE FIRM. i Disclosure 16 of 51 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMIN RELEASE 34-71435, JANUARY 29, 2014: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND- DESIST PROCEEDINGS BE INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), AGAINST SCOTTRADE, INC. ("SCOTTRADE" OR "RESPONDENT").

©2021 FINRA. All rights reserved. Report aboutTHE SCOTTRADE, COMMISSION INC. FOUND THAT THE ACTION RESULTS FROM 65 SCOTTRADE'S VIOLATION OF THE RECORDKEEPING REQUIREMENTS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULES 17A-4(J), 17A-25 AND 17A-4(F)(3)(V) THEREUNDER. FROM MARCH 2006 THROUGH APRIL 2012 (THE "RELEVANT PERIOD"), SCOTTRADE FAILED TO PROVIDE REQUIRED ACCURATE AND COMPLETE BLUE SHEET SUBMISSIONS TO THE COMMISSION, AND ALSO FAILED TO HAVE AN AUDIT SYSTEM THAT PROVIDED ACCOUNTABILITY REGARDING THE INPUTTING OF RECORDS REQUIRED TO BE MAINTAINED AND PRESERVED.

IT IS A FUNDAMENTAL OBLIGATION OF BROKER-DEALERS TO PROVIDE COMPLETE AND ACCURATE BLUE SHEET DATA WHEN REQUESTED BY REPRESENTATIVES OF THE COMMISSION TO DO SO. BLUE SHEET DATA IS CRITICAL TO MANY ASPECTS OF THE COMMISSION'S OPERATIONS AND ITS ABILITY TO DISCHARGE ITS ENFORCEMENT AND REGULATORY MANDATES. THE FAILURE OF A BROKER-DEALER TO PROVIDE COMPLETE AND ACCURATE BLUE SHEET INFORMATION IN RESPONSE TO A COMMISSION REQUEST CAN IMPACT THE COMMISSION'S ABILITY TO DISCHARGE ITS STATUTORY OBLIGATIONS, UNDERMINE THE INTEGRITY OF ITS INVESTIGATIONS AND EXAMINATIONS, AND ULTIMATELY INTERFERE WITH THE COMMISSION'S ABILITY TO PROTECT INVESTORS.

AS A RESULT OF THE CONDUCT, SCOTTRADE WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND EXCHANGE ACT RULE 17A-4(J) BY FAILING TO "FURNISH PROMPTLY TO A REPRESENTATIVE OF THE COMMISSION LEGIBLE, TRUE, COMPLETE, AND CURRENT COPIES OF THOSE RECORDS OF THE [BROKER-DEALER] THAT ARE REQUIRED TO BE PRESERVED UNDER [RULE 17A-4], OR ANY OTHER RECORDS OF THE [BROKER-DEALER] SUBJECT TO EXAMINATION UNDER SECTION 17(B) OF THE [EXCHANGE ACT] THAT ARE REQUESTED BY THE REPRESENTATIVE OF THE COMMISSION."

AS A RESULT OF THE CONDUCT, SCOTTRADE WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND EXCHANGE ACT RULE 17A-25 BY FAILING TO PRODUCE REQUESTED BLUE SHEET DATA TO THE COMMISSION STAFF, AND BY NOT PROPERLY MAINTAINING AND PRESERVING THE BLUE SHEET DATA INFORMATION.

AS A RESULT OF THE CONDUCT, SCOTTRADE WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND EXCHANGE ACT RULE 17A- 4(F)(3)(V) BY FAILING TO HAVE "IN PLACE AN AUDIT SYSTEM PROVIDING FOR ACCOUNTABILITY REGARDING INPUTTING OF RECORDS REQUIRED TO BE MAINTAINED AND PRESERVED PURSUANT TO RULES 17A-3 AND 17A-4 TO ELECTRONIC STORAGE MEDIA AND INPUTTING OF ANY CHANGES MADE TO EVERY ORIGINAL AND DUPLICATE RECORD MAINTAINED AND PRESERVED THEREBY." SEC ADMIN RELEASE 34-71435, JANUARY 29, 2014: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED IT APPROPRIATE AND www.finra.org/brokercheck IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND- User Guidance DESIST PROCEEDINGS BE INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), AGAINST SCOTTRADE, INC. ("SCOTTRADE" OR "RESPONDENT").

THE COMMISSION FOUND THAT THE ACTION RESULTS FROM SCOTTRADE'S VIOLATION OF THE RECORDKEEPING REQUIREMENTS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULES 17A-4(J), 17A-25 AND 17A-4(F)(3)(V) THEREUNDER. FROM MARCH 2006 THROUGH APRIL 2012 (THE "RELEVANT PERIOD"), SCOTTRADE FAILED TO PROVIDE REQUIRED ACCURATE AND COMPLETE BLUE SHEET SUBMISSIONS TO THE COMMISSION, AND ALSO FAILED TO HAVE AN AUDIT SYSTEM THAT PROVIDED ACCOUNTABILITY REGARDING THE INPUTTING OF RECORDS REQUIRED TO BE MAINTAINED AND PRESERVED.

AS A RESULT OF THE CONDUCT, SCOTTRADE WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND EXCHANGE ACT RULE 17A-4(J) BY FAILING TO "FURNISH PROMPTLY TO A REPRESENTATIVE OF THE COMMISSION LEGIBLE, TRUE, COMPLETE, AND CURRENT COPIES OF THOSE RECORDS OF THE [BROKER-DEALER] THAT ARE REQUIRED TO BE ©2021 FINRA. All rights reserved. Report aboutPRESERVED SCOTTRADE, UNDER INC. [RULE 17A-4], OR ANY OTHER RECORDS OF 66 THE [BROKER-DEALER] SUBJECT TO EXAMINATION UNDER SECTION 17(B) OF THE [EXCHANGE ACT] THAT ARE REQUESTED BY THE REPRESENTATIVE OF THE COMMISSION."

AS A RESULT OF THE CONDUCT, SCOTTRADE WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND EXCHANGE ACT RULE 17A- 4(F)(3)(V) BY FAILING TO HAVE "IN PLACE AN AUDIT SYSTEM PROVIDING FOR ACCOUNTABILITY REGARDING INPUTTING OF RECORDS REQUIRED TO BE MAINTAINED AND PRESERVED PURSUANT TO RULES 17A-3 AND 17A-4 TO ELECTRONIC STORAGE MEDIA AND INPUTTING OF ANY CHANGES MADE TO EVERY ORIGINAL AND DUPLICATE RECORD MAINTAINED AND PRESERVED THEREBY." SEC ADMIN RELEASE 34-71435, JANUARY 29, 2014: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND- DESIST PROCEEDINGS BE INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), AGAINST SCOTTRADE, INC. ("SCOTTRADE" OR "RESPONDENT").

SECTION 17 OF THE EXCHANGE ACT IMPOSES ON BROKER-DEALERS RECORDKEEPING REQUIREMENTS THAT ARE ESSENTIAL TO THE COMMISSION'S ABILITY TO ENFORCE THE FEDERAL SECURITIES LAWS AND TO PROTECT INVESTORS. TO ENSURE THE CONTINUED EFFECTIVENESS OF THE COMMISSION'S ENFORCEMENT AND REGULATORY PROGRAMS, BROKER-DEALERS MUST COMPLY WITH, AMONG OTHER THINGS: RULE 17A-25, REQUIRING THAT BROKER-DEALERS SUBMIT ELECTRONICALLY SECURITIES TRANSACTION INFORMATION UPON REQUEST BY THE COMMISSION'S STAFF; RULE 17A-4(J), REQUIRING BROKER-DEALERS TO FURNISH PROMPTLY TRUE, COMPLETE, AND CURRENT COPIES OF THOSE RECORDS UPON REQUEST BY THE COMMISSION'S STAFF; AND RULE 17A-4(F)(3)(V), REQUIRING BROKER- DEALERS TO HAVE AN AUDIT SYSTEM THAT PROVIDES FOR ACCOUNTABILITY REGARDING THE INPUTTING OF RECORDS REQUIRED TO BE MAINTAINED AND PRESERVED. SCOTTRADE FAILED TO COMPLY WITH THESE REQUIREMENTS. www.finra.org/brokercheck AS A RESULT OF THE CONDUCT, SCOTTRADE WILLFULLY VIOLATED User Guidance SECTION 17(A) OF THE EXCHANGE ACT AND EXCHANGE ACT RULE 17A-4(J) BY FAILING TO "FURNISH PROMPTLY TO A REPRESENTATIVE OF THE COMMISSION LEGIBLE, TRUE, COMPLETE, AND CURRENT COPIES OF THOSE RECORDS OF THE [BROKER-DEALER] THAT ARE REQUIRED TO BE PRESERVED UNDER [RULE 17A-4], OR ANY OTHER RECORDS OF THE [BROKER-DEALER] SUBJECT TO EXAMINATION UNDER SECTION 17(B) OF THE [EXCHANGE ACT] THAT ARE REQUESTED BY THE REPRESENTATIVE OF THE COMMISSION."

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 01/29/2014 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 $2,500,000.00 Cease and Desist/Injunction ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 67 www.finra.org/brokercheck User Guidance

Censure Monetary/Fine $2,500,000.00 Cease and Desist/Injunction Other Sanctions Ordered: UNDERTAKINGS Sanction Details: THE COMMISSION DEEMED IT APPROPRIATE, AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN SCOTTRADE'S OFFER. ACCORDINGLY, PURSUANT TO SECTIONS 15(B) AND 21C OF THE EXCHANGE ACT, IT IS HEREBY ORDERED THAT SCOTTRADE SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULES 17A-4(J), 17A-25, AND 17A-4(F)(3)(V) THEREUNDER.

SCOTTRADE IS CENSURED.

SCOTTRADE SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $2,500,000.

SCOTTRADE SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER. Regulator Statement IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS, RESPONDENT SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION DETERMINED TO ACCEPT. SCOTTRADE ADMITS THE FINDINGS SET FORTH IN THE ORDER, ADMITS THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THE PROCEEDINGS, AND CONSENTED TO THE ENTRY OF THE ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ("ORDER").

IN DETERMINING TO ACCEPT THE OFFER, THE COMMISSION CONSIDERED REMEDIAL ACTS PROMPTLY UNDERTAKEN BY SCOTTRADE AND COOPERATION AFFORDED THE COMMISSION STAFF. i Reporting Source: Firm Current Status: Final Allegations: ON JANUARY 29, 2014, THE SECURITIES AND EXCHANGE COMMISSION (SEC) ENTERED AN ORDER RELATING TO SCOTTRADE'S PRODUCTION OF TRADE INFORMATION IN RESPONSE TO SEC REQUESTS. THE ORDER RESULTED FROM A SETTLEMENT THAT SCOTTRADE ENTERED INTO WITH THE SEC. THE ALLEGATIONS INVOLVED AN INADVERTENT COMPUTER CODING ERROR THAT CAUSED CERTAIN TRADES TO BE EXCLUDED FROM SCOTTRADE'S RESPONSES TO SEC "BLUE SHEET" REQUESTS FROM 2006 - 2012. ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 68 ON JANUARY 29, 2014, THE SECURITIES AND EXCHANGE COMMISSION (SEC) ENTERED AN ORDER RELATING TO SCOTTRADE'S PRODUCTION OF TRADE INFORMATION IN RESPONSE TO SEC REQUESTS. THE ORDER www.finra.org/brokercheck RESULTED FROM A SETTLEMENT THAT SCOTTRADE ENTERED INTO WITH User Guidance THE SEC. THE ALLEGATIONS INVOLVED AN INADVERTENT COMPUTER CODING ERROR THAT CAUSED CERTAIN TRADES TO BE EXCLUDED FROM SCOTTRADE'S RESPONSES TO SEC "BLUE SHEET" REQUESTS FROM 2006 - 2012. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 01/29/2014 Docket/Case Number: 3-15702

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 01/29/2014 Sanctions Ordered: Censure Monetary/Fine $2,500,000.00 Other Sanctions Ordered: UNDERTAKINGS Sanction Details: PURSUANT TO THE ORDER, SCOTTRADE SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACT AND RULES 17A-4(J), 17A-25, AND 17A-4(F)(3)(V) THEREUNDER. ALSO, SCOTTRADE AGREED TO PAY A CIVIL PENALTY OF $2.5 MILLION TO THE UNITED STATES TREASURY. i Disclosure 17 of 51 Reporting Source: Regulator Current Status: Final Allegations: FINRA RULES 2010, 4560, NASD RULES 2110, 3010, 3360 - SCOTTRADE, INC. INACCURATELY REPORTED SHORT INTEREST POSITIONS AND FAILED TO REPORT SHORT INTEREST POSITIONS. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD AND FINRA RULES REGARDING SHORT INTEREST REPORTING. Initiated By: FINRA Date Initiated: 11/01/2013 Docket/Case Number: 2009018505901

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: 11/01/2013 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 $100,000.00 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 $100,000. FINE PAID IN FULL ON NOVEMBER 26, 2013. i Reporting Source: Firm Current Status: Final Allegations: FINRA RULES 2010, 4560, NASD RULES 2110, 3010, 3360 - SCOTTRADE, INC INACCURATELY REPORTED SHORT INTEREST POSITIONS AND FAILED TO REPORT SHORT INTEREST POSITIONS. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASD AND FINRA RULES REGARDING SHORT INTEREST REPORTING. Initiated By: FINRA Date Initiated: 11/01/2013 Docket/Case Number: 2009018505901

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 70 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief $100,000 MONETARY FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/01/2013 Sanctions Ordered: Censure Monetary/Fine $100,000.00 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 $100,000. Firm Statement 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 $100,000. i Disclosure 18 of 51 Reporting Source: Regulator Current Status: Final Allegations: SECTION 5 OF THE SECURITIES ACT OF 1933, NASD RULES 2110, 3010(A), 3010(B): THE FIRM FAILED TO CONDUCT AN INDEPENDENT INQUIRY TO DETERMINE WHETHER SHARES OF A COMPANY'S STOCK DEPOSITED BY AN INDIVIDUAL WERE FREELY TRADABLE. THE INDIVIDUAL WAS A CORPORATE INSIDER AND CONTROL PERSON OF THE COMPANY. HE SERVED AS THE COMPANY'S CHIEF FINANCIAL OFFICER, GENERAL COUNSEL, AND BOARD OF DIRECTORS MEMBER DURING THE PERIOD THAT HE SOLD THE STOCK THROUGH ACCOUNTS AT THE FIRM. THE INDIVIDUAL DEPOSITED 1,286,500 SHARES OF THE STOCK IN HIS THREE FAMILY ACCOUNTS, LIQUIDATED MOST OF THE SHARES SOON AFTER EACH TRANSFER, AND THEN WIRED OUT ALL OF THE SALES PROCEEDS. THE SHARES DEPOSITED AND CONTROLLED BY THE INDIVIDUAL ALONE CONSTITUTED OVER 16 PERCENT OF THE TOTAL SHARES OF THE STOCK THAT WERE OUTSTANDING AS OF SEPTEMBER 25, 2006. THE 1,259,600 SHARES DEPOSITED AND SOLD BY ACCOUNTS OF TWO ADDITIONAL CUSTOMERS CONSTITUTED AN ADDITIONAL 16 PERCENT OF THE COMPANY'S TOTAL SHARES OUTSTANDING AS OF SEPTEMBER 25, 2006. THE STOCK WAS NOT PROPERLY ISSUED PURSUANT TO SEC S-8 REGISTRATION AND AS A RESULT, THE SHARES WERE RESTRICTED FROM RESALE, ABSENT AN APPLICABLE EXEMPTION FROM REGISTRATION. NO EXEMPTIONS APPLIED TO THE RESALES. THE FIRM FAILED TO ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 71 UNDERTAKE SUFFICIENT EFFORTS TO ASCERTAIN WHETHER THE STOCK COULD BE PROPERLY SOLD. WITHOUT HAVING OBTAINED INFORMATION REGARDING THE FACTS AND CIRCUMSTANCES SURROUNDING THE INDIVIDUAL AND THE OTHER TWO CUSTOMERS' POSSESSION OF THE STOCK, THE FIRM DID NOT SATISFY ITS DUTY TO CONDUCT A REASONABLE INQUIRY THAT IS A CRUCIAL PART OF THE BROKERS' EXEMPTION. THE FIRM DID NOT ESTABLISH AND MAINTAIN ADEQUATE SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO COMPLY WITH SECTION 5 OF THE SECURITIES ACT OF 1933. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES FOR COMPLIANCE WITH SECTION 5 WERE LIMITED TO TWO SHORT PARAGRAPHS CONCERNING THE SALE OF CONTROL OR RESTRICTED STOCK. THE PROCEDURES IN PLACE DURING THE REVIEW PERIOD NOTED THAT, "SCOTTRADE DOES NOT ROUTINELY CLEAR AND SELL RESTRICTED STOCK. COMPLIANCE SHOULD BE CONSULTED DIRECTLY FOR ASSISTANCE REGARDING THE PROCESSING OF RULE 144 AND RULE 145 SALES." THE PROCEDURES ALSO NOTED THAT THE FIRM'S NEW CUSTOMER ACCOUNT DOCUMENTATION "INCLUDES AN INQUIRY WHETHER THE CUSTOMER IS AN OFFICER, DIRECTOR OR MAJOR STOCKHOLDER OF THE COMPANY. THE ACCOUNT WILL BE CODED TO REPRESENT THAT RELATIONSHIP." THE PROCEDURES BRIEFLY DESCRIBED THE BROAD PURPOSES OF RULES 144 AND 145, BUT PROVIDED FOR NO SUPERVISORY STRUCTURE TO ENSURE OVERALL COMPLIANCE WITH SECTION 5. THE FIRM'S PROCEDURES DID NOT ADDRESS COMPLIANCE GENERALLY WITH SECTION 5 AND WERE INADEQUATE IN SETTING FORTH THE CIRCUMSTANCES UNDER WHICH THE FIRM SHOULD INQUIRE INTO THE REGISTRATION OR EXEMPTION STATUS OF SECURITIES IN CUSTOMER ACCOUNTS. THE PROCEDURES IN PLACE DURING THE REVIEW PERIOD DID NOT SPECIFICALLY LIST THE FACTORS THAT THE FIRM WAS REQUIRED TO EVALUATE OR CONSIDER IN ORDER TO DETERMINE WHETHER IT NEEDED TO INQUIRE FURTHER BEFORE ALLOWING POTENTIALLY UNREGISTERED SECURITIES TO BE SOLD BY A CUSTOMER. FIRM CUSTOMERS ENGAGED IN THE UNREGISTERED DISTRIBUTION OF MORE THAN 2.4 MILLION SHARES OF THE COMPANY'S STOCK WHICH GENERATED PROCEEDS TO THEM OF OVER $8.3 MILLION. DURING THE UNREGISTERED DISTRIBUTION OF SHARES OF THE COMPANY, THE FIRM'S PERSONNEL INCORRECTLY ASSUMED THAT THE SHARES WERE FREELY TRADABLE, WITHOUT RESTRICTION, PRIMARILY BECAUSE THE SHARES WERE RECEIVED INTO THE CUSTOMERS' ACCOUNTS DIRECTLY FROM A TRANSFER AGENT AND THE CUSTOMERS DISCLOSED TO THE FIRM THAT THEY WERE NOT INSIDERS. IN ALLOWING THE CUSTOMERS TO SELL THEIR SHARES, THE FIRM DID NOT CONSIDER ALL OF THE FACTORS RELEVANT TO A DETERMINATION OF WHETHER THE SHARES WERE UNRESTRICTED AND ELIGIBLE FOR RESALE. SECTION 5 OF THE SECURITIES ACT OF 1933, NASD RULES 2110, 3010(A), 3010(B): THE FIRM FAILED TO CONDUCT AN INDEPENDENT INQUIRY TO DETERMINE WHETHER SHARES OF A COMPANY'S STOCK DEPOSITED BY AN INDIVIDUAL WERE FREELY TRADABLE. THE INDIVIDUAL WAS A CORPORATE INSIDER AND CONTROL PERSON OF THE COMPANY. HE SERVED AS THE COMPANY'S CHIEF FINANCIAL OFFICER, GENERAL COUNSEL, AND BOARD OF DIRECTORS MEMBER DURING THE PERIOD THAT HE SOLD THE STOCK THROUGH ACCOUNTS AT THE FIRM. THE INDIVIDUAL DEPOSITED 1,286,500 SHARES OF THE STOCK IN HIS THREE FAMILY ACCOUNTS, LIQUIDATED MOST OF THE SHARES SOON AFTER EACH TRANSFER, AND THEN WIRED OUT ALL OF THE SALES PROCEEDS. THE SHARES DEPOSITED AND CONTROLLED BY THE INDIVIDUAL ALONE CONSTITUTED OVER 16 PERCENT OF THE TOTAL SHARES OF THE STOCK THAT WERE OUTSTANDING AS OF SEPTEMBER 25, 2006. THE 1,259,600 SHARES DEPOSITED AND SOLD BY ACCOUNTS OF TWO ADDITIONAL CUSTOMERS CONSTITUTED AN ADDITIONAL 16 PERCENT OF THE www.finra.org/brokercheck COMPANY'S TOTAL SHARES OUTSTANDING AS OF SEPTEMBER 25, 2006. User Guidance THE STOCK WAS NOT PROPERLY ISSUED PURSUANT TO SEC S-8 REGISTRATION AND AS A RESULT, THE SHARES WERE RESTRICTED FROM RESALE, ABSENT AN APPLICABLE EXEMPTION FROM REGISTRATION. NO EXEMPTIONS APPLIED TO THE RESALES. THE FIRM FAILED TO UNDERTAKE SUFFICIENT EFFORTS TO ASCERTAIN WHETHER THE STOCK COULD BE PROPERLY SOLD. WITHOUT HAVING OBTAINED INFORMATION REGARDING THE FACTS AND CIRCUMSTANCES SURROUNDING THE INDIVIDUAL AND THE OTHER TWO CUSTOMERS' POSSESSION OF THE STOCK, THE FIRM DID NOT SATISFY ITS DUTY TO CONDUCT A REASONABLE INQUIRY THAT IS A CRUCIAL PART OF THE BROKERS' EXEMPTION. THE FIRM DID NOT ESTABLISH AND MAINTAIN ADEQUATE SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO COMPLY WITH SECTION 5 OF THE SECURITIES ACT OF 1933. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES FOR COMPLIANCE WITH SECTION 5 WERE LIMITED TO TWO SHORT PARAGRAPHS CONCERNING THE SALE OF CONTROL OR RESTRICTED STOCK. THE PROCEDURES IN PLACE DURING THE REVIEW PERIOD NOTED THAT, "SCOTTRADE DOES NOT ROUTINELY CLEAR AND SELL RESTRICTED STOCK. COMPLIANCE SHOULD BE CONSULTED DIRECTLY FOR ASSISTANCE REGARDING THE PROCESSING OF RULE 144 AND RULE 145 SALES." THE PROCEDURES ALSO NOTED THAT THE FIRM'S NEW CUSTOMER ACCOUNT DOCUMENTATION "INCLUDES AN INQUIRY WHETHER THE CUSTOMER IS AN OFFICER, DIRECTOR OR MAJOR STOCKHOLDER OF THE COMPANY. THE ACCOUNT WILL BE CODED TO REPRESENT THAT RELATIONSHIP." THE PROCEDURES BRIEFLY DESCRIBED THE BROAD PURPOSES OF RULES 144 AND 145, BUT PROVIDED FOR NO SUPERVISORY STRUCTURE TO ENSURE OVERALL COMPLIANCE WITH SECTION 5. THE FIRM'S PROCEDURES DID NOT ADDRESS COMPLIANCE GENERALLY WITH SECTION 5 AND WERE INADEQUATE IN SETTING FORTH THE CIRCUMSTANCES UNDER WHICH THE FIRM SHOULD INQUIRE INTO THE REGISTRATION OR EXEMPTION STATUS OF SECURITIES IN CUSTOMER ACCOUNTS. THE PROCEDURES IN PLACE DURING THE REVIEW PERIOD DID NOT SPECIFICALLY LIST THE FACTORS THAT THE FIRM WAS REQUIRED TO EVALUATE OR CONSIDER IN ORDER TO DETERMINE WHETHER IT NEEDED TO INQUIRE FURTHER BEFORE ALLOWING POTENTIALLY UNREGISTERED SECURITIES TO BE SOLD BY A CUSTOMER. FIRM CUSTOMERS ENGAGED IN THE UNREGISTERED DISTRIBUTION OF MORE THAN 2.4 MILLION SHARES OF THE COMPANY'S STOCK WHICH GENERATED PROCEEDS TO THEM OF OVER $8.3 MILLION. DURING THE UNREGISTERED DISTRIBUTION OF SHARES OF THE COMPANY, THE FIRM'S PERSONNEL INCORRECTLY ASSUMED THAT THE SHARES WERE FREELY TRADABLE, WITHOUT RESTRICTION, PRIMARILY BECAUSE THE SHARES WERE RECEIVED INTO THE CUSTOMERS' ACCOUNTS DIRECTLY FROM A TRANSFER AGENT AND THE CUSTOMERS DISCLOSED TO THE FIRM THAT THEY WERE NOT INSIDERS. IN ALLOWING THE CUSTOMERS TO SELL THEIR SHARES, THE FIRM DID NOT CONSIDER ALL OF THE FACTORS RELEVANT TO A DETERMINATION OF WHETHER THE SHARES WERE UNRESTRICTED AND ELIGIBLE FOR RESALE. Initiated By: FINRA ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 72 www.finra.org/brokercheck User Guidance

Initiated By: FINRA Date Initiated: 07/09/2013 Docket/Case Number: 2010025332401

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/09/2013 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 $100,000.00 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 IT IS CENSURED AND FINED $100,000. FINE PAID IN FULL ON JULY 31, 2013. i Reporting Source: Firm Current Status: Final Allegations: FINRA ALLEGES VIOLATIONS OF NASD RULE 2110 AND RULES 3010(A) AND (B). Initiated By: FINRA Date Initiated: 07/09/2013 Docket/Case Number: 2010025332401

Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE $100,000 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/09/2013 Sanctions Ordered: Monetary/Fine $100,000.00 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 IT IS CENSURED AND FINED $100,000 Firm Statement THE FIRM CONSENTED TO A CENSURE AND FINE OF $100,000 AND THE ENTRY OF FINDINGS AGAINST THE FIRM. i Disclosure 19 of 51 Reporting Source: Regulator Current Status: Final Allegations: SEC RULES 204T(A)(1), SEC RULES 200(G), 203(A)(1), 203(B)(3) OF REGULATION SHO, FINRA RULES 2010, 6730(A), 6730(D)(4)(D) - SCOTTRADE, INC. HAD A FAIL-TO-DELIVER POSITION AT A REGISTERED CLEARING AGENCY IN A THRESHOLD SECURITY FOR 13 CONSECUTIVE SETTLEMENT DAYS, AND FAILED TO IMMEDIATELY THEREAFTER CLOSE OUT THE FAIL-TO-DELIVER POSITION BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY. THE FIRM HAD FAIL-TO-DELIVER POSITIONS AT A REGISTERED CLEARING AGENCY IN AN EQUITY SECURITY THAT RESULTED FROM A LONG SALE, AND DID NOT CLOSE THE FAIL-TO- DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY WITHIN THE TIME FRAME PRESCRIBED BY SEC RULE 204T(A)(1). THE FIRM EXECUTED SHORT SALE ORDERS AND FAILED TO PROPERLY MARK THE ORDERS AS SHORT. THE FIRM KNEW OR HAD REASONABLE GROUNDS TO BELIEVE THAT THE SALE OF AN EQUITY SECURITY WAS OR WOULD BE EFFECTED PURSUANT TO AN ORDER MARKED LONG, AND FAILED TO DELIVER THE SECURITY ON THE DATE DELIVERY WAS DUE. THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) S1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE EXECUTION TIME. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 6730(A) AND A PATTERN OR PRACTICE OF LATE REPORTING ©2021 FINRA. All rights reserved. Report aboutWITHOUT SCOTTRADE, EXCEPTIONAL INC. CIRCUMSTANCES IN VIOLATION OF FINRA RULE 74 2010. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT MARKET IDENTIFIER FOR SOME P1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. SEC RULES 204T(A)(1), SEC RULES 200(G), 203(A)(1), 203(B)(3) OF REGULATION SHO, FINRA RULES 2010, 6730(A), 6730(D)(4)(D) - SCOTTRADE, INC. HAD A FAIL-TO-DELIVER POSITION AT A REGISTERED CLEARING AGENCY IN A THRESHOLD SECURITY FOR 13 CONSECUTIVE SETTLEMENT DAYS, AND FAILED TO IMMEDIATELY THEREAFTER CLOSE OUT THE FAIL-TO-DELIVER POSITION BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY. THE FIRM HAD FAIL-TO-DELIVER POSITIONS AT A REGISTERED CLEARING AGENCY IN AN EQUITY SECURITY THAT RESULTED FROM A LONG SALE, AND DID NOT CLOSE THE FAIL-TO- DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY WITHIN THE TIME FRAME PRESCRIBED BY SEC RULE 204T(A)(1). THE FIRM EXECUTED SHORT SALE ORDERS AND FAILED TO PROPERLY MARK THE ORDERS AS SHORT. THE FIRM KNEW OR HAD REASONABLE GROUNDS TO BELIEVE THAT THE SALE OF AN EQUITY SECURITY WAS OR WOULD BE EFFECTED PURSUANT TO AN ORDER MARKED LONG, AND FAILED TO DELIVER THE SECURITY ON THE DATE DELIVERY WAS DUE. www.finra.org/brokercheck THE FIRM FAILED TO REPORT TO THE TRADE REPORTING AND User Guidance COMPLIANCE ENGINE (TRACE) S1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE EXECUTION TIME. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 6730(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT MARKET IDENTIFIER FOR SOME P1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. Initiated By: FINRA Date Initiated: 06/19/2013 Docket/Case Number: 2009018255901

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): THRESHOLD SECURITIES, TRACE-ELIGIBLE SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/19/2013 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 $45,000.00 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 $45,000. FINE PAID IN FULL ON JULY 10, 2013. i Reporting Source: Firm Current Status: Final Allegations: FINRA ALLEGES VIOLATIONS OF SEC RULES 204T(A)(1), 200(G), 203 (A)(1), 203 (B)(3) OF REGULATION SHO, FINRA RULES 2010, AND 6730(A), 6730 (D)(4)(D) Initiated By: FINRA ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 75 www.finra.org/brokercheck User Guidance

Initiated By: FINRA Date Initiated: 06/19/2013 Docket/Case Number: 2009018255901

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): THRESHOLD SECURITIES - TRACE ELIGIBLE SECURITIES Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE $45,000 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/19/2013 Sanctions Ordered: Monetary/Fine $45,000.00 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 IT IS CENSURED AND FINED $45,000 Firm Statement A CENSURE AND FINE OF $45,000 (CONSISTING OF A $22,500 FINE FOR VIOLATION OF SEC RULES 203(B)?(3) AND 204T(A)(1) OF REG SHO IN 20090182559; A $10,000 FINE FOR VIOLATIONS OF SEC RULE 200(G) OF REG. SHO IN 20090182559; A $5,000 FINE FOR VIOLATION OF SEC RULE 203(A) OF REG. SHO IN 2009182559; AND A $7,500 FINE FOR TRACE REPORTING VIOLATIONS IN 201102780232. i Disclosure 20 of 51 Reporting Source: Regulator Current Status: Final Allegations: FINRA RULES 2010, 2360(B)(5), NASD RULES 2110, 2860(B)(5), 3010 - SCOTTRADE, INC. FAILED TO REPORT REPORTABLE OPTIONS POSITIONS IN STANDARD OPTIONS TO THE SECURITIES INDUSTRY AUTOMATION CORPORATION (SIAC) LARGE OPTION POSITIONS REPORTS (LOPR) AND FAILED TO REPORT AT LEAST ONE REPORTABLE OPTION POSITION IN STANDARD OPTIONS TO THE OPTIONS CLEARING CORPORATION (OCC) LOPR. THE FIRM FAILED TO REPORT NUMEROUS REPORTABLE POSITIONS IN STANDARD OPTIONS TO SIAC AND OCC FOR ACCOUNTS UNDER COMMON CONTROL OR ACTING-IN-CONCERT. THE FIRM FAILED TO REPORT APPROXIMATELY 8,000 OPTIONS POSITIONS TO THE LOPR OVER AN APPROXIMATE SIX MONTH PERIOD. THE FIRM FAILED TO REPORT THE ©2021 FINRA. All rights reserved. Report aboutAPPROPRIATE SCOTTRADE, INC.IN-CONCERT INFORMATION FOR NUMEROUS CUSTOMER 76 ACCOUNTS TO SIAC AND OCC AND FAILED TO REPORT APPROXIMATELY 9,300 OPTIONS POSITIONS TO THE LOPR WITH THE CORRECT IN- CONCERT INFORMATION FOR OVER 18 MONTHS. THE FIRM FAILED TO REPORT NUMEROUS REPORTABLE OPTIONS POSITIONS IN STANDARD OPTIONS TO SIAC AND OCC AS A RESULT OF THE FIRM INCORRECTLY NETTING OPTIONS POSITIONS AND CODING ERRORS IN THE FIRM'S INTERNAL REPORTING SYSTEMS. THE FIRM FAILED TO REPORT APPROXIMATELY 1,100 OPTIONS POSITIONS TO THE LOPR FOR APPROXIMATELY 18 MONTHS. THE FIRM FAILED TO ACCURATELY REPORT NUMEROUS REPORTABLE OPTIONS POSITIONS IN STANDARD OPTIONS TO SIAC AND THE OCC WITH THE CORRECT EFFECTIVE DATE. THE FIRM FAILED TO ACCURATELY REPORT APPROXIMATELY 789 OPTIONS POSITIONS TO THE LOPR WITH THE CORRECT EFFECTIVE DATE. FOR APPROXIMATELY THREE YEARS, THE FIRM FAILED TO HAVE AN ADEQUATE SYSTEM TO SUPERVISE REPORTING OF OPTIONS POSITIONS FOR ACCOUNTS UNDER COMMON CONTROL OR ACTING IN-CONCERT. FOR OVER FIVE YEARS, THE FIRM FAILED TO HAVE AN ADEQUATE SUPERVISORY SYSTEM TO REVIEW THE ACCURACY OF ITS DAILY LOPR SUBMISSIONS. FINRA RULES 2010, 2360(B)(5), NASD RULES 2110, 2860(B)(5), 3010 - SCOTTRADE, INC. FAILED TO REPORT REPORTABLE OPTIONS POSITIONS IN STANDARD OPTIONS TO THE SECURITIES INDUSTRY AUTOMATION CORPORATION (SIAC) LARGE OPTION POSITIONS REPORTS (LOPR) AND FAILED TO REPORT AT LEAST ONE REPORTABLE OPTION POSITION IN STANDARD OPTIONS TO THE OPTIONS CLEARING CORPORATION (OCC) www.finra.org/brokercheck LOPR. THE FIRM FAILED TO REPORT NUMEROUS REPORTABLE POSITIONS User Guidance IN STANDARD OPTIONS TO SIAC AND OCC FOR ACCOUNTS UNDER COMMON CONTROL OR ACTING-IN-CONCERT. THE FIRM FAILED TO REPORT APPROXIMATELY 8,000 OPTIONS POSITIONS TO THE LOPR OVER AN APPROXIMATE SIX MONTH PERIOD. THE FIRM FAILED TO REPORT THE APPROPRIATE IN-CONCERT INFORMATION FOR NUMEROUS CUSTOMER ACCOUNTS TO SIAC AND OCC AND FAILED TO REPORT APPROXIMATELY 9,300 OPTIONS POSITIONS TO THE LOPR WITH THE CORRECT IN- CONCERT INFORMATION FOR OVER 18 MONTHS. THE FIRM FAILED TO REPORT NUMEROUS REPORTABLE OPTIONS POSITIONS IN STANDARD OPTIONS TO SIAC AND OCC AS A RESULT OF THE FIRM INCORRECTLY NETTING OPTIONS POSITIONS AND CODING ERRORS IN THE FIRM'S INTERNAL REPORTING SYSTEMS. THE FIRM FAILED TO REPORT APPROXIMATELY 1,100 OPTIONS POSITIONS TO THE LOPR FOR APPROXIMATELY 18 MONTHS. THE FIRM FAILED TO ACCURATELY REPORT NUMEROUS REPORTABLE OPTIONS POSITIONS IN STANDARD OPTIONS TO SIAC AND THE OCC WITH THE CORRECT EFFECTIVE DATE. THE FIRM FAILED TO ACCURATELY REPORT APPROXIMATELY 789 OPTIONS POSITIONS TO THE LOPR WITH THE CORRECT EFFECTIVE DATE. FOR APPROXIMATELY THREE YEARS, THE FIRM FAILED TO HAVE AN ADEQUATE SYSTEM TO SUPERVISE REPORTING OF OPTIONS POSITIONS FOR ACCOUNTS UNDER COMMON CONTROL OR ACTING IN-CONCERT. FOR OVER FIVE YEARS, THE FIRM FAILED TO HAVE AN ADEQUATE SUPERVISORY SYSTEM TO REVIEW THE ACCURACY OF ITS DAILY LOPR SUBMISSIONS. Initiated By: FINRA Date Initiated: 01/15/2013 Docket/Case Number: 2009019913601

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/15/2013 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 $125,000.00 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 77 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $125,000.00 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 $125,000. FINE PAID IN FULL ON 1/30/2013. i Reporting Source: Firm Current Status: Final Allegations: FINRA RULES 2010, 2360(B)(5), NASD RULES 2110, 2860 (B)(5), 3010 - SCOTTRADE, INC. FAILED TO REPORT REPORTABLE OPTIONS POSITIONS IN STANDARD OPTIONS TO THE SECURITIES INDUSTRY AUTOMATION CORPORATION (SIAC) LARGE OPTION PORISTIONS REPORTS (LOPR) AND FAILED TO REPORT AT LEAST ONE REPORTABLE OPTION POSITION IN STANDARD OPTIONS TO THE OPTIONS CLEARING CORPRATION (OCC) LOPR. THE FIRM FAILED TO REPORT NUMEROUS REPORTABLE POSITIONS IN STANDARD OPTIONS IN SIAC AND OCC FOR ACCOUNTS UNDER COMMON CONTROL OR ACTING-IN-CONCERT. THE FIRM FAILED TO REPORT APPROXIMATELY 8,000 OPTIONS POSITIONS TO THE LOPR OVER AN APPROXIMATE SIX MONTH PERIOD. THE FIRM FAILED TO REPORT THE APPROPRIATE INCONCERT INFORMATION FOR NUMEROUS CUSTOMER ACCOUNTS TO SIAC AND OCC AND FAILED TO REPORT APPROXIMATELY 9,300 OPTIONS POSITIONS TO THE LOPR WITH THE CORRECT IN-CONCERT INFORMATION FOR OVER 18 MONTHS. THE FIRM FAILED TO REPORT NUMEROUS REPORTABLE OPTIONS IN STANDARD OPTIONS TO SIAC AND OCC AS A RESULT OF THE FIRM INCORRECTLY NETTING OPTIONS AND CODING ERRORS IN THE FIRM'S INTERNAL REPORTING SYSTEMS. THE FIRM FAILED TO REPORT APPROXIMATELY 1,100 OPETIONS POSITIONS TO THE LOPR FOR APPROXIMATELY 18 MONTHS. THE FIRM FAILED TO ACCURATEL REPORT NUMEROUS REPORTABLE OPTIONS POSITIONS IN STANDARD OPTIONS TO SIAC AND THE OCC WITH THE CORRECT EFFECTIVE DATE. THE FIRM FAILED TO ACCURATELY REPORT APPROXIMATELY 789 OPTIONS POSITIONS TO THE LOPR WITH THE CORRECT EFFECTIVE DATE. FOR APPROXIMATELY THREE YEARS, THE FIRM FAILED TO HAVE AN ADEQUATE SYSTEM TO SUPERVISE REPORTING OF OUR OPTIONS POSITIONS FOR ACCOUNTS UNDER COMMON CONTROL OR ACTING IN-CONCERT. FOR OVER FIVE YEARS THE FIRM FAILED TO HAVE AN ADEQUATE SUPERVISORY SYSTEM TO REVIEW THE ACCURACY OF ITS DAILY LOPR SUBMISSION. Initiated By: FINRA Date Initiated: 01/15/2013 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 78 www.finra.org/brokercheck User Guidance

Date Initiated: 01/15/2013 Docket/Case Number: 2009019913601

Principal Product Type: Options Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/15/2013 Sanctions Ordered: Censure Monetary/Fine $125,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFOR, THE FIRM IS CENSURED AND FINED $125,000. PAYMENT IN THE AMOUNT OF $125,000 WAS SENT OUT ON 01/30/2013 i Disclosure 21 of 51 Reporting Source: Regulator Current Status: Final Allegations: ACTED IN CONTRAVENTION OF SECTION 5(B)(2) OF THE SECURITIES ACT, VIOLATED FINRA RULE 2010, NASD RULES 3010(A)(1) AND (B)(1): THE FIRM FAILED TO DELIVER PROSPECTUSES TO MUTUAL FUND CUSTOMERS ON A TIMELY BASIS DURING A REVIEW PERIOD. DURING THE PERIOD, THE FIRM CONTRACTED WITH A THIRD-PARTY SERVICE PROVIDER FOR THE DELIVERY OF MUTUAL FUND PROSPECTUSES. THE FIRM FAILED TO DELIVER ON TIME, OR FAILED TO ENSURE THAT THE SERVICE PROVIDER DELIVERED ON TIME, PROSPECTUSES TO CERTAIN CUSTOMERS WHO PURCHASED MUTUAL FUNDS. IN NUMEROUS INSTANCES, THE FIRM'S CUSTOMERS WHO SHOULD HAVE RECEIVED A PROSPECTUS WITHIN THREE BUSINESS DAYS OF THE TRANSACTION DID NOT. THE FIRM DID NOT TAKE ACTIONS TO ENSURE THAT ALL OF ITS CUSTOMERS WERE RECEIVING PROSPECTUSES ON TIME. BECAUSE OF THE FIRM'S FAILURE TO DELIVER PROSPECTUSES ON TIME TO A SIGNIFICANT NUMBER OF CUSTOMERS WHO PURCHASED MUTUAL FUNDS, THESE CUSTOMERS WERE NOT PROVIDED WITH IMPORTANT DISCLOSURES ABOUT THESE PRODUCTS BY SETTLEMENT DATE. CONSEQUENTLY, SCOTTRADE ACTED ©2021 FINRA. All rights reserved. Report aboutIN CONTRAVENTION SCOTTRADE, INC. OF SECTION 5(B)(2) OF THE SECURITIES ACT. DURING 79 THE PERIOD, THE FIRM EXECUTED MULTIPLE MUTUAL FUND PURCHASE TRANSACTIONS THAT REQUIRED IT TO DELIVER A MUTUAL FUND PROSPECTUS, OR A SUMMARY PROSPECTUS, TO THE PURCHASING CUSTOMER. AS SUCH, DURING THE PERIOD, THE FIRM WAS REQUIRED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES THAT WERE REASONABLY DESIGNED TO MONITOR AND ENSURE THE TIMELY DELIVERY OF MUTUAL FUND PROSPECTUSES. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES DID NOT REQUIRE REVIEW OF THE SERVICE PROVIDER'S PERFORMANCE OF ITS PROSPECTUS DELIVERY OBLIGATIONS. EVEN FOLLOWING AN INTERNAL AUDIT OF ITS PROCEDURES IN A PARTICULAR YEAR, IN WHICH THE AUDITOR RECOMMENDED THAT THE FIRM IMPLEMENT SUCH A REVIEW, IT DID NOT REVIEW THE SERVICE PROVIDER'S PERFORMANCE. INSTEAD, THE FIRM'S SYSTEM FOR SUPERVISING THE TIMELY DELIVERY OF MUTUAL FUND PROSPECTUSES INVOLVED ALMOST COMPLETE RELIANCE ON THE SERVICE PROVIDER. THE FIRM HAD NO SYSTEM OR PROCEDURES IN PLACE REASONABLY DESIGNED TO ENSURE THAT MUTUAL FUND PROSPECTUSES WERE BEING DELIVERED ON A TIMELY BASIS CONSISTENT WITH SECTION 5(B)(2) OF THE SECURITIES ACT, AND IT FAILED TO IMPLEMENT AND MAINTAIN SUCH A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES. ACTED IN CONTRAVENTION OF SECTION 5(B)(2) OF THE SECURITIES ACT, VIOLATED FINRA RULE 2010, NASD RULES 3010(A)(1) AND (B)(1): THE FIRM FAILED TO DELIVER PROSPECTUSES TO MUTUAL FUND CUSTOMERS ON A TIMELY BASIS DURING A REVIEW PERIOD. DURING THE PERIOD, THE FIRM CONTRACTED WITH A THIRD-PARTY SERVICE PROVIDER FOR THE DELIVERY OF MUTUAL FUND PROSPECTUSES. THE FIRM FAILED TO DELIVER ON TIME, OR FAILED TO ENSURE THAT THE SERVICE PROVIDER DELIVERED ON TIME, PROSPECTUSES TO CERTAIN CUSTOMERS WHO PURCHASED MUTUAL FUNDS. IN NUMEROUS INSTANCES, THE FIRM'S CUSTOMERS WHO SHOULD HAVE RECEIVED A PROSPECTUS WITHIN THREE BUSINESS DAYS OF THE TRANSACTION DID NOT. THE FIRM DID NOT TAKE ACTIONS TO ENSURE THAT ALL OF ITS CUSTOMERS WERE www.finra.org/brokercheck RECEIVING PROSPECTUSES ON TIME. BECAUSE OF THE FIRM'S FAILURE User Guidance TO DELIVER PROSPECTUSES ON TIME TO A SIGNIFICANT NUMBER OF CUSTOMERS WHO PURCHASED MUTUAL FUNDS, THESE CUSTOMERS WERE NOT PROVIDED WITH IMPORTANT DISCLOSURES ABOUT THESE PRODUCTS BY SETTLEMENT DATE. CONSEQUENTLY, SCOTTRADE ACTED IN CONTRAVENTION OF SECTION 5(B)(2) OF THE SECURITIES ACT. DURING THE PERIOD, THE FIRM EXECUTED MULTIPLE MUTUAL FUND PURCHASE TRANSACTIONS THAT REQUIRED IT TO DELIVER A MUTUAL FUND PROSPECTUS, OR A SUMMARY PROSPECTUS, TO THE PURCHASING CUSTOMER. AS SUCH, DURING THE PERIOD, THE FIRM WAS REQUIRED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES THAT WERE REASONABLY DESIGNED TO MONITOR AND ENSURE THE TIMELY DELIVERY OF MUTUAL FUND PROSPECTUSES. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES DID NOT REQUIRE REVIEW OF THE SERVICE PROVIDER'S PERFORMANCE OF ITS PROSPECTUS DELIVERY OBLIGATIONS. EVEN FOLLOWING AN INTERNAL AUDIT OF ITS PROCEDURES IN A PARTICULAR YEAR, IN WHICH THE AUDITOR RECOMMENDED THAT THE FIRM IMPLEMENT SUCH A REVIEW, IT DID NOT REVIEW THE SERVICE PROVIDER'S PERFORMANCE. INSTEAD, THE FIRM'S SYSTEM FOR SUPERVISING THE TIMELY DELIVERY OF MUTUAL FUND PROSPECTUSES INVOLVED ALMOST COMPLETE RELIANCE ON THE SERVICE PROVIDER. THE FIRM HAD NO SYSTEM OR PROCEDURES IN PLACE REASONABLY DESIGNED TO ENSURE THAT MUTUAL FUND PROSPECTUSES WERE BEING DELIVERED ON A TIMELY BASIS CONSISTENT WITH SECTION 5(B)(2) OF THE SECURITIES ACT, AND IT FAILED TO IMPLEMENT AND MAINTAIN SUCH A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES. Initiated By: FINRA Date Initiated: 12/31/2012 Docket/Case Number: 2011029102701

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/31/2012 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 80 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $50,000.00 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 $50,000. FINE PAID IN FULL ON 1/9/2013. i Reporting Source: Firm Current Status: Final Allegations: ACTED IN CONTRAVENTION OF SECTION 5(B(2)OF THE SECURITIES ACT. VIOLATED FINRA RULE 2010, NASD RULES 3010(A(1) AND (B)(1): THE FIRM FAILED TO DELIVER PROSPECTUSES TO MUTUAL FUND CUSTOMERS ON A TIMELY BASIS DURING A REVIEW PERIOD. DURING THE PERIOD, THE FIRM CONTRACTED WITH A THIRD-PARTY SERVICE PROVIDER FOR THE DELIVERY OF MUTUAL FUND PROSPECTUSES. THE FIRM FAILED TO DELIVER ON TIME, OR FAILED TO ENSURE THAT THE SERVICE PROVIDER DELIVERED ON TIME, PROSPECTUSES TO CERTAIN CUSTOMERS WHO PURCHASED MUTUAL FUNDS. IN NUMEROUS INSTANCES, THE FIRM'S CUSTOMERS WHO SHOULD HAVE RECEIVED A PROSPECTUS WITHIN THREE BUSINESS DAYS OF THE TRANSACTION DID NOT. THE FIRM DID NOT TAKE ACTIONS TO ENSURE THAT ALL OF ITS CUSTOMERS WERE RECEIVING PROSPECTUSES ON TIME. BECAUSE OF THE FIRM'S FAILURE TO DELIVER PROSPECTUSES ON TIME TO A SIGNIGICANT NUMBER OF CUSTOMERS WHO PURCHASED MUTUAL FUNDS, THESE CUSTOMERS WERE NOT PROVIDED WITH IMPORTANT DISCLOSURES ABOUT THESE PRODUCTS BY SETTLEMENT DATE. CONSEQUENTLY, SCOTTRADE ACTED IN CONTRAVENTION OF SECTION 5(B(2) OF THE SECURITIES ACT. DURING THE PERIOD, THE FIRM EXCUTED MULTIPLE MUTUAL FUND PURCHASE TRANSACTIONS THAT REQUIRED IT TO DELIVER A MUTUAL FUND PROSPECTUS, OR A SUMMARY PROSPECTUS, TO THE PURCHASING CUSTOMER. AS SUCH, DURING THE PERIOD, THE FIRM WAS REQUIRED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES THAT WERE REASONABLY DESIGNED TO MONITOR AND ENSURE THE TIMELY DELIVERY OF MUTUAL FUND PROSPECTUSES. THE FIRM'S WRITTEN SUPERVISORY PROCEDURED DID NOT REQUIRE REVIEW OF THE SERVICE PROVIDER'S PERFORMANCE OF ITS PROSPECTUS DELIVERY OBLIGATIONS. EVEN FOLLOWING AN INTERNAL AUDIT OF ITS PROCEDURES IN A PARTICULAR YEAR, IN WHICH THE AUDITOR RECOMMENDED THAT THE FIRM IMPLEMENT SUCH A REVIEW, IT DID NOT REVIEW THE SERVICE PROVIDER'S PERFORMANCE. INSTEAD, THE FIRM'S SYSTEM FOR SUPERVISING THE TIMELY DELIVERY ©2021 FINRA. All rights reserved. Report aboutOF MUTUAL SCOTTRADE, FUND INC. PROSPECTUSES INVOLVED ALMOST COMPLETE 81 RELIANCE ON THE SERVICE PROVIDER. THE FIRM HAD NO SYSTEM OR PROCEDURES IN PLACE REASONABLE DESIGNED TO ENSURE THAT MUTUAL FUND PROSPECTUSES WERE BEING DELIVERED ON A TIMELY BASIS CONSISTENT WITH SECTIO 5(B)(2) OF THE SECURITIESACT, AND IT FAILED TO IMPLEMENT AND MAINTAIN SUCH A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES. ACTED IN CONTRAVENTION OF SECTION 5(B(2)OF THE SECURITIES ACT. VIOLATED FINRA RULE 2010, NASD RULES 3010(A(1) AND (B)(1): THE FIRM FAILED TO DELIVER PROSPECTUSES TO MUTUAL FUND CUSTOMERS ON A TIMELY BASIS DURING A REVIEW PERIOD. DURING THE PERIOD, THE FIRM CONTRACTED WITH A THIRD-PARTY SERVICE PROVIDER FOR THE DELIVERY OF MUTUAL FUND PROSPECTUSES. THE FIRM FAILED TO DELIVER ON TIME, OR FAILED TO ENSURE THAT THE SERVICE PROVIDER DELIVERED ON TIME, PROSPECTUSES TO CERTAIN CUSTOMERS WHO PURCHASED MUTUAL FUNDS. IN NUMEROUS INSTANCES, THE FIRM'S CUSTOMERS WHO SHOULD HAVE RECEIVED A PROSPECTUS WITHIN THREE BUSINESS DAYS OF THE TRANSACTION DID NOT. THE FIRM DID NOT TAKE ACTIONS TO ENSURE THAT ALL OF ITS CUSTOMERS WERE RECEIVING PROSPECTUSES ON TIME. BECAUSE OF THE FIRM'S FAILURE TO DELIVER PROSPECTUSES ON TIME TO A SIGNIGICANT NUMBER OF CUSTOMERS WHO PURCHASED MUTUAL FUNDS, THESE CUSTOMERS WERE NOT PROVIDED WITH IMPORTANT DISCLOSURES ABOUT THESE PRODUCTS BY SETTLEMENT DATE. CONSEQUENTLY, SCOTTRADE ACTED IN CONTRAVENTION OF SECTION 5(B(2) OF THE SECURITIES ACT. DURING THE PERIOD, THE FIRM EXCUTED MULTIPLE MUTUAL FUND PURCHASE TRANSACTIONS THAT REQUIRED IT TO DELIVER A MUTUAL FUND PROSPECTUS, OR A SUMMARY PROSPECTUS, TO THE PURCHASING CUSTOMER. AS SUCH, DURING THE PERIOD, THE FIRM WAS REQUIRED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES THAT WERE REASONABLY DESIGNED TO MONITOR AND ENSURE THE TIMELY DELIVERY OF MUTUAL FUND PROSPECTUSES. THE FIRM'S WRITTEN SUPERVISORY PROCEDURED DID NOT REQUIRE REVIEW OF THE SERVICE PROVIDER'S PERFORMANCE OF ITS PROSPECTUS DELIVERY OBLIGATIONS. EVEN FOLLOWING AN www.finra.org/brokercheck INTERNAL AUDIT OF ITS PROCEDURES IN A PARTICULAR YEAR, IN WHICH User Guidance THE AUDITOR RECOMMENDED THAT THE FIRM IMPLEMENT SUCH A REVIEW, IT DID NOT REVIEW THE SERVICE PROVIDER'S PERFORMANCE. INSTEAD, THE FIRM'S SYSTEM FOR SUPERVISING THE TIMELY DELIVERY OF MUTUAL FUND PROSPECTUSES INVOLVED ALMOST COMPLETE RELIANCE ON THE SERVICE PROVIDER. THE FIRM HAD NO SYSTEM OR PROCEDURES IN PLACE REASONABLE DESIGNED TO ENSURE THAT MUTUAL FUND PROSPECTUSES WERE BEING DELIVERED ON A TIMELY BASIS CONSISTENT WITH SECTIO 5(B)(2) OF THE SECURITIESACT, AND IT FAILED TO IMPLEMENT AND MAINTAIN SUCH A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES. Initiated By: FINRA Date Initiated: 12/31/2012 Docket/Case Number: 2011029102701

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/31/2012 Sanctions Ordered: Censure Monetary/Fine $50,000.00 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 &50,000. PAYMENT WAS MADE IN THE AMOUNT OF $50.000 ON 01/08/2013. i Disclosure 22 of 51 Reporting Source: Regulator Current Status: Final Allegations: FINRA RULE 7450 - SCOTTRADE, INC. TRANSMITTED REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE BUT THE FIRM FAILED TO REPAIR SOME OF THE REJECTED ROES SO THE FIRM FAILED TO SUBMIT THEM DURING THE REVIEW PERIOD. THE FIRM ALSO FAILED TO REPAIR SOME OF THE REJECTED ROES WITHIN THE REQUIRED FIVE BUSINESS DAYS AND FAILED TO POPULATE THE CORRECT ROE RECONCILIATION ID ON SOME ©2021 FINRA. All rights reserved. Report aboutRESUBMISSIONS. SCOTTRADE, INC. 82 FINRA RULE 7450 - SCOTTRADE, INC. TRANSMITTED REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND WERE www.finra.org/brokercheck REPAIRABLE BUT THE FIRM FAILED TO REPAIR SOME OF THE REJECTED User Guidance ROES SO THE FIRM FAILED TO SUBMIT THEM DURING THE REVIEW PERIOD. THE FIRM ALSO FAILED TO REPAIR SOME OF THE REJECTED ROES WITHIN THE REQUIRED FIVE BUSINESS DAYS AND FAILED TO POPULATE THE CORRECT ROE RECONCILIATION ID ON SOME RESUBMISSIONS. Initiated By: FINRA Date Initiated: 12/12/2012 Docket/Case Number: 2011028358701

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: 12/12/2012 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 $10,000.00 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 $10,000. FINE PAID IN FULL ON 12/24/12. i Reporting Source: Firm Current Status: Final Allegations: FINRA RULE 7450 - SCOTTRADE,INC. TRANSMITTED REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE BUT THE FIRM FAILED TO REPAIR SOME OF THE REJECTED ROES SO THE FIRM FAILED TO SUBMIT THEM DURING THE REVIEW PERIOD. THE FIRM ALSO FAILED TO REPAIR SOME OF THE REJECTED ROES WITHIN THE REQUIRED FIVE BUSINESS DAYS AND FAILED TO POPULATE THE CORRECT ROE RECONCILIATION ID ON SOME ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 83 RESUBMISSIONS. FINRA RULE 7450 - SCOTTRADE,INC. TRANSMITTED REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND WERE www.finra.org/brokercheck REPAIRABLE BUT THE FIRM FAILED TO REPAIR SOME OF THE REJECTED User Guidance ROES SO THE FIRM FAILED TO SUBMIT THEM DURING THE REVIEW PERIOD. THE FIRM ALSO FAILED TO REPAIR SOME OF THE REJECTED ROES WITHIN THE REQUIRED FIVE BUSINESS DAYS AND FAILED TO POPULATE THE CORRECT ROE RECONCILIATION ID ON SOME RESUBMISSIONS. Initiated By: FINRA Date Initiated: 12/12/2012 Docket/Case Number: 2011028358701

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/12/2012 Sanctions Ordered: Censure Monetary/Fine $10,000.00 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 $10,000. PAYMENT WAS MADE ON 12/21/2012. i Disclosure 23 of 51 Reporting Source: Regulator Current Status: Final Allegations: SEC REGULATION SHO RULE 204(A), NASD RULES 2520(F)(8)(B)(IV), 3010(A) AND (B) - SCOTTRADE, INC. HAD AN AUTOMATED SYSTEM WHEREBY THE FIRM MONITORED DAY-TRADING BUYING POWER OF PATTERN DAY TRADERS ON A REAL-TIME BASIS. AS PATTERN DAY TRADERS PLACED ORDERS, THE FIRM'S TRADE EXECUTION PLATFORM CALCULATED THE EFFECT ON THE PATTERN DAY TRADER'S DAY TRADING BUYING POWER - PURCHASES REDUCED THE AVAILABLE DAY-TRADING POWER AND SALES RESTORED DAY-TRADING BUYING POWER. IF A PATTERN DAY TRADER'S PURCHASE TRANSACTION EXCEEDED AVAILABLE DAY TRADING BUYING POWER, THE FIRM'S SYSTEM AUTOMATICALLY BLOCKED THE ORDER. THE FIRM USED AN IMPROPER METHOD FOR CALCULATING THE REDUCTION IN DAY-TRADING BUYING POWER THAN PROVIDED FOR IN NASD RULE 2520. RATHER THAN USING THE COST OF THE TRANSACTION (THE EXECUTION ©2021 FINRA. All rights reserved. Report aboutPRICE), SCOTTRADE, THE FIRM INC. USED THE SECURITY'S PRICE AT THE CLOSE OF THE 84 PREVIOUS DAY SO THAT THE FIRM COULD NOT PROPERLY MONITOR WHETHER PATTERN DAY TRADERS WERE TRADING IN EXCESS OF THEIR BUYING POWER. THE FIRM FAILED TO HAVE IN PLACE SUPERVISORY PROCEDURES THAT EFFECTIVELY DETECTED PATTERN DAY TRADERS WHO EXCEEDED THEIR DAY-TRADING BUYING POWER SO THAT A MARGIN CALL COULD BE ISSUED. REGULATION SHO RULE 204(A) REQUIRES PARTICIPANTS OF REGISTERED CLEARING AGENCIES HAVING A FAIL-TO- DELIVER POSITION TO PURCHASE OR BORROW SECURITIES TO CLOSE OUT THE FAIL BY NO LATER THAN THE BEGINNING OF REGULAR TRADING HOURS ON THE SETTLEMENT DAY AFTER THE FAIL OCCURS (T+4). RULE 204(E) PROVIDES AN EXEMPTION IF THE BROKER-DEALER HAS PURCHASED THE LIKE SECURITIES IN AN AMOUNT SUFFICIENT TO CLOSE THE FAIL POSITION, IN A BONA-FIDE TRANSACTION EFFECTED ON T+1, T+2, AND T+3, THE BROKER-DEALER IS NOT REQUIRED TO EFFECT A BUY- IN TRANSACTION ON THE MORNING OF T+4 TO CLOSE OUT THE OPEN POSITION (PRE-FAIL CREDIT). THE FIRM IMPROPERLY COUNTED CUSTOMER PURCHASES OF SECURITIES TO TAKE ADVANTAGE OF THE PRE-FAIL CREDIT IN CALCULATING ITS CLOSE-OUT OBLIGATION ON THE MORNING OF T+4 SO THAT ON APPROXIMATELY 6,541 OCCASIONS, THE FIRM FAILED TO CLOSE OUT OPEN FAIL POSITIONS BY EFFECTING A BUY- IN TRANSACTION PRIOR TO THE OPENING OF TRADING HOURS ON THE MORNING OF T+4. THE FIRM FAILED TO HAVE IN PLACE SUPERVISORY PROCEDURES THAT ENSURED COMPLIANCE WITH RULE 204(A)'S CLOSE- OUT REQUIREMENT AND ITS USE OF THE PRE-FAIL CREDIT. SEC REGULATION SHO RULE 204(A), NASD RULES 2520(F)(8)(B)(IV), 3010(A) AND (B) - SCOTTRADE, INC. HAD AN AUTOMATED SYSTEM WHEREBY THE FIRM MONITORED DAY-TRADING BUYING POWER OF PATTERN DAY TRADERS ON A REAL-TIME BASIS. AS PATTERN DAY TRADERS PLACED ORDERS, THE FIRM'S TRADE EXECUTION PLATFORM CALCULATED THE EFFECT ON THE PATTERN DAY TRADER'S DAY TRADING BUYING POWER - PURCHASES REDUCED THE AVAILABLE DAY-TRADING POWER AND SALES RESTORED DAY-TRADING BUYING POWER. IF A PATTERN DAY TRADER'S www.finra.org/brokercheck PURCHASE TRANSACTION EXCEEDED AVAILABLE DAY TRADING BUYING User Guidance POWER, THE FIRM'S SYSTEM AUTOMATICALLY BLOCKED THE ORDER. THE FIRM USED AN IMPROPER METHOD FOR CALCULATING THE REDUCTION IN DAY-TRADING BUYING POWER THAN PROVIDED FOR IN NASD RULE 2520. RATHER THAN USING THE COST OF THE TRANSACTION (THE EXECUTION PRICE), THE FIRM USED THE SECURITY'S PRICE AT THE CLOSE OF THE PREVIOUS DAY SO THAT THE FIRM COULD NOT PROPERLY MONITOR WHETHER PATTERN DAY TRADERS WERE TRADING IN EXCESS OF THEIR BUYING POWER. THE FIRM FAILED TO HAVE IN PLACE SUPERVISORY PROCEDURES THAT EFFECTIVELY DETECTED PATTERN DAY TRADERS WHO EXCEEDED THEIR DAY-TRADING BUYING POWER SO THAT A MARGIN CALL COULD BE ISSUED. REGULATION SHO RULE 204(A) REQUIRES PARTICIPANTS OF REGISTERED CLEARING AGENCIES HAVING A FAIL-TO- DELIVER POSITION TO PURCHASE OR BORROW SECURITIES TO CLOSE OUT THE FAIL BY NO LATER THAN THE BEGINNING OF REGULAR TRADING HOURS ON THE SETTLEMENT DAY AFTER THE FAIL OCCURS (T+4). RULE 204(E) PROVIDES AN EXEMPTION IF THE BROKER-DEALER HAS PURCHASED THE LIKE SECURITIES IN AN AMOUNT SUFFICIENT TO CLOSE THE FAIL POSITION, IN A BONA-FIDE TRANSACTION EFFECTED ON T+1, T+2, AND T+3, THE BROKER-DEALER IS NOT REQUIRED TO EFFECT A BUY- IN TRANSACTION ON THE MORNING OF T+4 TO CLOSE OUT THE OPEN POSITION (PRE-FAIL CREDIT). THE FIRM IMPROPERLY COUNTED CUSTOMER PURCHASES OF SECURITIES TO TAKE ADVANTAGE OF THE PRE-FAIL CREDIT IN CALCULATING ITS CLOSE-OUT OBLIGATION ON THE MORNING OF T+4 SO THAT ON APPROXIMATELY 6,541 OCCASIONS, THE FIRM FAILED TO CLOSE OUT OPEN FAIL POSITIONS BY EFFECTING A BUY- IN TRANSACTION PRIOR TO THE OPENING OF TRADING HOURS ON THE MORNING OF T+4. THE FIRM FAILED TO HAVE IN PLACE SUPERVISORY PROCEDURES THAT ENSURED COMPLIANCE WITH RULE 204(A)'S CLOSE- OUT REQUIREMENT AND ITS USE OF THE PRE-FAIL CREDIT. Initiated By: FINRA Date Initiated: 06/18/2012 Docket/Case Number: 2010021776501

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: 06/18/2012 Does the order constitute a No final order based on violations of any laws or ©2021regulations FINRA. All that rights prohibit reserved. Report about SCOTTRADE, INC. 85 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 $250,000.00 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 $250,000. FINE PAID IN FULL ON JUNE 28, 2012. i Reporting Source: Firm Current Status: Final Allegations: SCOTTRADE, INC. UTILIZES AN AUTOMATED SYSTEM TO MONITOR PATTERN-DAY-TRADERS' DAY BUYING POWER ON A REAL-TIME BASIS. AS PATTERN DAY TRADERS PLACED ORDERS, THE FIRM'S TRADE EXECUTION PLATFORM CALCULATED THE EFFECT ON THE PATTERN-DAY-TRADERS' BUYING POWER; PURCHASES REDUCED THE AVAILABLE BUYING POWER AND SALES RESTORED THE BUYING POWER, BUT NEVER TO EXCEED THE BUYING POWER AT THE BEGINNING OF THE DAY. FINRA ALLEGED THAT, BETWEEN SEPTEMBER 2001 AND DECEMBER 2009, SCOTTRADE, INC. VIOLATED NASD RULES 2520 AND 3010 BY USING A METHOD TO CALCULATE THE REDUCTION IN PATTERN-DAY-TRADERS' BUYING POWER THAT DID NOT, IN ALL CASES, DETECT WHEN PATTERN-DAY-TRADERS EXCEEDED THEIR BUYING POWER. ALTHOUGH THE FIRM'S CALCULATION METHOD WAS MORE CONSERVATIVE THAN WHAT RULE 2520 ALLOWS IN THAT IT WAS DESIGNED TO BLOCK TRANSACTIONS THAT WOULD CAUSE A PATTERN-DAY-TRADER TO EXCEED THEIR BUYING POWER, FINRA ALLEGED THAT, IN CERTAIN INSTANCES, THE FIRM MAY HAVE FAILED TO ISSUE MARGIN CALLS BECAUSE ITS SYSTEM RELIED ON A SECURITY'S PRICE AT THE CLOSE OF BUSINESS THE PREVIOUS DAY TO CALCULATE PATTERN-DAY-TRADERS' BUYING POWER. FINRA ALSO ALLEGED THAT, BETWEEN DECEMBER 2008 AND NOVEMBER 2009, THE FIRM DID NOT COMPLY WITH RULES 204 AND 204T UNDER REGULATION SHO BECAUSE THE FIRM INTERPRETED THE RULES AS ALLOWING THE FIRM TO RELY ON CUSTOMER PURCHASES TO TAKE ADVANTAGE OF THE PRE-FAIL CREDIT IN CALCULATING ITS CLOSE OUT OBLIGATIONS. FINRA ALLEGED THAT, AS A RESULT OF THE FIRM'S INTERPRETATION, IT FAILED TO CLOSE OUT OPEN FAIL POSITIONS BY EFFECTING A BUY-IN TRANSACTION PRIOR TO ©2021 FINRA. All rights reserved. Report aboutTHE SCOTTRADE, OPENING OFINC. TRADING HOURS ON T+4. 86 SCOTTRADE, INC. UTILIZES AN AUTOMATED SYSTEM TO MONITOR PATTERN-DAY-TRADERS' DAY BUYING POWER ON A REAL-TIME BASIS. AS PATTERN DAY TRADERS PLACED ORDERS, THE FIRM'S TRADE EXECUTION PLATFORM CALCULATED THE EFFECT ON THE PATTERN-DAY-TRADERS' BUYING POWER; PURCHASES REDUCED THE AVAILABLE BUYING POWER AND SALES RESTORED THE BUYING POWER, BUT NEVER TO EXCEED THE BUYING POWER AT THE BEGINNING OF THE DAY. FINRA ALLEGED THAT, BETWEEN SEPTEMBER 2001 AND DECEMBER 2009, SCOTTRADE, INC. VIOLATED NASD RULES 2520 AND 3010 BY USING A METHOD TO CALCULATE THE REDUCTION IN PATTERN-DAY-TRADERS' BUYING POWER THAT DID NOT, IN ALL CASES, DETECT WHEN PATTERN-DAY-TRADERS EXCEEDED THEIR BUYING POWER. ALTHOUGH THE FIRM'S CALCULATION METHOD WAS MORE CONSERVATIVE THAN WHAT RULE 2520 ALLOWS IN THAT IT WAS DESIGNED TO BLOCK TRANSACTIONS THAT WOULD CAUSE A PATTERN-DAY-TRADER TO EXCEED THEIR BUYING POWER, FINRA ALLEGED THAT, IN CERTAIN INSTANCES, THE FIRM MAY HAVE FAILED TO ISSUE MARGIN CALLS BECAUSE ITS SYSTEM RELIED ON A SECURITY'S PRICE AT THE CLOSE OF BUSINESS THE PREVIOUS DAY TO CALCULATE PATTERN-DAY-TRADERS' BUYING POWER. FINRA ALSO ALLEGED THAT, BETWEEN DECEMBER 2008 AND NOVEMBER 2009, THE FIRM DID NOT COMPLY WITH RULES 204 AND 204T UNDER REGULATION SHO BECAUSE THE FIRM INTERPRETED THE RULES AS ALLOWING THE FIRM TO RELY ON www.finra.org/brokercheck CUSTOMER PURCHASES TO TAKE ADVANTAGE OF THE PRE-FAIL CREDIT User Guidance IN CALCULATING ITS CLOSE OUT OBLIGATIONS. FINRA ALLEGED THAT, AS A RESULT OF THE FIRM'S INTERPRETATION, IT FAILED TO CLOSE OUT OPEN FAIL POSITIONS BY EFFECTING A BUY-IN TRANSACTION PRIOR TO THE OPENING OF TRADING HOURS ON T+4. Initiated By: FINRA Date Initiated: 06/18/2012 Docket/Case Number: 2010021776501

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: 06/18/2012 Sanctions Ordered: Censure Monetary/Fine $250,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND FINE OF $250,000, WHICH WAS PAID ON 06/27/12. i Disclosure 24 of 51 Reporting Source: Regulator Current Status: Final Allegations: FINRA RULES 8211, 8213, NASD RULES 8211, 8213 - SCOTTRADE, INC. FAILED TO REPORT ACCURATE TRADING INFORMATION THROUGH THE SUBMISSION OF ELECTRONIC BLUE SHEETS IN RESPONSE TO REQUESTS FOR SUCH INFORMATION BY FINRA. Initiated By: FINRA Date Initiated: 02/08/2012 Docket/Case Number: 2009018137601

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/08/2012 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 $40,000.00 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 $40,000. FINE PAID IN FULL FEBRUARY 21, 2012. i Reporting Source: Firm Current Status: Final Allegations: FINRA ALLEGED THAT, DURING THE REVIEW PERIODS FROM DECEMBER 2007 THROUGH MARCH 2008 AND DECEMBER 2008 THROUGH MARCH 2009, SCOTTRADE, INC. VIOLATED FINRA AND NASD RULES 8211 AND 8213 BY FAILING TO REPORT ACCURATE TRADING INFORMATION THROUGH THE SUBMISSION OF ELECTRONIC BLUE SHEETS IN RESPONSE TO REQUESTS FOR SUCH INFORMATION BY FINRA. THE ALLEGED MISSING BLUE SHEETS REPRESENTED JUST THREE PERCENT AND FIVE PERCEN OF ALL ELECTRONIC BLUE SHEETS REQUIRED TO BE SUBMITTED DURING THE RESPECTIVE REVIEW PERIODS. Initiated By: FINRA Date Initiated: 02/08/2012 Docket/Case Number: 2009018137601

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought:

Other Sanction(s)/Relief FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 02/08/2012 Sanctions Ordered: Censure Monetary/Fine $40,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND FINE OF $40,000, WHICH WAS PAID ON 02/17/2012. Firm Statement THIS MATTER WAS DISPOSED OF VIA AN ACCEPTANCE, WAIVER AND CONSENT (AWC) IN WHICH, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND FINE OF $40,000. i Disclosure 25 of 51 Reporting Source: Regulator Current Status: Final Allegations: FINRA RULE 6730: THE FIRM: (A) FAILED TO REPORT TO TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) 268 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT WAS REQUIRED TO REPORT; (B) REPORTED THE INCORRECT CONTRA-PARTY FOR 21 TRANSACTIONS; AND (C) REPORTED INACCURATE INFORMATION TO TRACE FOR 10 TRANSACTIONS. THESE TRANSACTIONS CONSTITUTED SEVEN PERCENT OF THE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT THE FIRM WAS REQUIRED TO REPORT TO TRACE. THE FIRM FAILED TO REPORT TO TRACE THE CORRECT INFORMATION FOR 214 TRANSACTIONS IN TRACE- ELIGIBLE CORPORATE BONDS. SPECIFICALLY, THE FIRM INACCURATELY REPORTED THE STATED COMMISSION, EXECUTION DATE, PRICE, VOLUME, CONTRA-PARTY, OR BUY/SELL INDICATOR TO TRACE. IN ADDITION, THE FIRM OVER-REPORTED 72 TRANSACTIONS TO TRACE. THESE INACCURATE REPORTS CONSTITUTED SEVEN PERCENT OF THE INTER- DEALER REPORTS THAT THE FIRM SUBMITTED TO TRACE. Initiated By: FINRA Date Initiated: 01/25/2012 Docket/Case Number: 2010024119601

Other Product Type(s): TRACE-ELIGIBLE SECURITIES Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/25/2012 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 $11,000.00 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 IT IS CENSURED AND FINED $11,000. FINE PAID IN FULL FEBRUARY 6, 2012. i Reporting Source: Firm Current Status: Final Allegations: FINRA ALLEGED THAT DURING THE REVIEW PERIODS FROM JULY 2009 THROUGH DECEMBER 2009, SCOTTRADE, INC. VOILATED FINRA RULE 6730 BY: (1) FAILING TO REPORT TO TRACE CERTAIN TRACE-ELIGIBLE SECURITIES; (2) REPORTING THE INCORRECT CONTRA-PARTY FOR CERTAIN TRANSACTIONS; (3) REPORTED INACCURATE INFORAMTION TO TRACE FOR CERTAIN TRANSACTIONS; AND (4) REPORTED INACCURATE INFORMATION FOR CERTAIN TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE BONDS. Initiated By: FINRA Date Initiated: 01/25/2012 Docket/Case Number: 2010024119601

Other Product Type(s): TRACE-ELIGIBLE SECURITIES Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/25/2012 Sanctions Ordered: Censure Monetary/Fine $11,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND FINE OF $11,000 WHICH WAS PAID ON 02/03/2012. Firm Statement THIS MATTER WAS DISPOSED OF VIA AN ACCEPTANCE, WAIVER AND CONSENT (AWC)IN WHICH, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND FINE OF $11,000. i Disclosure 26 of 51 Reporting Source: Regulator Current Status: Final Allegations: FINRA RULE 7450 - SCOTTRADE, INC. TRANSMITTED REPORTABLE ORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE BUT THE FIRM FAILED TO REPAIR MANY OF THE REJECTED ROES SO THEY WERE NOT TRANSMITTED TO OATS DURING THE REVIEW PERIOD. THE FIRM TRANSMITTED ROES TO OATS LATE; TRANSMITTED NEW ORDER REPORTS WITH INACCURATE TIMESTAMPS; TRANSMITTED ROUTE OR COMBINED ORDER ROUTE REPORTS TO OATS THAT OATS WAS UNABLE TO LINK TO THE RELATED ORDER IN THE NASDAQ MARKET CENTER; AND TRANSMITTED ROUTE REPORTS OR COMBINED ORDER ROUTE REPORTS TO OATS THAT OATS WAS UNABLE TO MATCH TO THE RECEIVING FIRM'S RELATED NEW ORDER REPORT. Initiated By: FINRA Date Initiated: 12/16/2011 Docket/Case Number: 2010023301301

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: 12/16/2011 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 $15,000.00 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 $15,000. FINE PAID IN FULL DECEMBER 29, 2011. i Reporting Source: Firm Current Status: Final Allegations: FINRA ALLEGED THAT DURING THE REVIEW PERIODS FROM JANUARY 2010 THROUGH APRIL 2010, SCOTTRADE, INC. VIOLATED FINRA RULE 7450 BY: (1) SUBMITTING CERTAIN REPORTABLE EVENTS (ROES) TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT WERE REJECTED AND NOT REPAIRED; (2) TRANSMITTING CERTAIN ROES LATE OR WITH INACCURATE TIME STAMPS; (3) AND TRANSMITTING TO OATS ROUTE OR COMBINED ORDER ROUTE REPORTS THAT COULD NOT BE LINKED WITH THE RELATED ORDER IN THE NASDAQ MARKET CENTER OR COULD NOT BE MATCHED TO THE RECEIVING FIRM'S RELATED NEW ORDER REPORT. Initiated By: FINRA Date Initiated: 12/16/2011 Docket/Case Number: 20100233301301

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/16/2011 Sanctions Ordered: Censure Monetary/Fine $15,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND FINE OF $15,000, WHICH WAS PAID ON 12/29/2011. Firm Statement THIS MATTER WAS DISPOSED OF VIA AN ACCEPTANCE, WAIVER AND CONSENT (AWC) IN WHICH, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO A CENSURE AND FINE OF $15,000. i Disclosure 27 of 51 Reporting Source: Regulator Current Status: Final Allegations: MSRB RULE G-17 - SCOTTRADE, INC. FAILED TO DETERMINE IN ALL MUNICIPAL SECURITIES TRANSACTIONS WHETHER THE UNDERLYING CREDIT RATING OF THE ISSUER OF AN INSURED MUNICIPAL SECURITY CONSTITUTED MATERIAL INFORMATION THAT WAS REQUIRED TO BE DISCLOSED AT OR BEFORE THE TIME OF PURCHASE. THE FIRM FAILED TO DISCLOSE TO CUSTOMERS IN CONNECTION WITH MUNICIPAL SECURITIES TRANSACTIONS, ALL MATERIAL FACTS AT OR BEFORE THE TIME OF PURCHASE; THE FIRM FAILED TO DISCLOSE TO CUSTOMERS THE UNDERLYING CREDIT RATING OF INSURED MUNICIPAL BONDS AT OR PRIOR TO THE TIME OF PURCHASE. Initiated By: FINRA Date Initiated: 11/09/2010 Docket/Case Number: 2008016050101

Principal Product Type: Debt - Municipal Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/09/2010 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 $35,000.00 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 $35,000. i Reporting Source: Firm Current Status: Final Allegations: IN CERTAIN TRANSACTIONS IN 2008, SCOTTRADE ALLEGEDLY FAILED TO DETERMINE WHETHER THE UNDERLYING CREDIT RATING OF THE ISSUER OF AN INSURED MUNICIPAL SECURITY CONSTITUTED MATERIAL INFORMATION THAT WAS REQUIRED TO BE DISCLOSED AT OR BEFORE THE TIME OF PURCHASE. THE FIRM ALLEGEDLY FAILED TO DISCLOSE TO CUSTOMERS IN CONNECTION WITH THE MINICIPAL SECURITIES TRANSACTIONS, ALL MATERIAL FACTS AT OR BEFORE THE TIME OF PURCHASE; THE FIRM ALLEGEDLY FAILED TO DISCLOSE TO CUSTOMERS THE UNDERLYING CREDIT RATING OF INSURED MUNICIPAL BONDS AT OR PRIOR TO THE TIME OF PURCHASE. Initiated By: FINRA Date Initiated: 11/09/2010 Docket/Case Number: 2008016050101

Principal Product Type: Debt - Municipal Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/09/2010 Sanctions Ordered: Censure Monetary/Fine $35,000.00 Other Sanctions Ordered: Sanction Details: MONETARY FINE IN THE AMOUNT OF $35,000 Firm Statement THIS MATTER HAS BEEN RESOLVED. WITHOUT ADMITTING OR DENYING THE FINDINGS, SCOTTRADE CONSENTED TO A $35,000 FINE AND A CENSURE AND TO THE ENTRY OF FINDINGS. i Disclosure 28 of 51 Reporting Source: Regulator Current Status: Final Allegations: NASDAQ RULES 2110, 3010 - SCOTTRADE'S SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS (INCLUDING NASD NOTICE TO MEMBERS 04-66) AND NASDAQ RULES CONCERNING THE PREVENTION OF ERRONEOUS ORDERS AND TRANSACTIONS AND FRIVOLOUS CLEARLY ERRONEOUS TRANSACTION COMPLAINTS. Initiated By: NASDAQ STOCK MARKET Date Initiated: 06/29/2010 Docket/Case Number: 2009018387201

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 95 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/29/2010 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 $10,000.00 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, THE FIRM IS CENSURED, FINED $10,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING COMPLIANCE WITH NASD NOTICE TO MEMBERS 04-66 WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NASDAQ REVIEW COUNCIL. i Reporting Source: Firm Current Status: Final Allegations: ALLEGES THAT SCOTTRADE'S WRITTEN SUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITES LAWS AND REGULATIONS (INCLUDING NASD NOTICE TO MEMBERS 04-66) AND NASDAQ RULES CONCERNING THE PREVENTION OF ERRONEOUS ORDERS AND TRANACTIONS AND FRIVOLOUS CLEARLY ERRONEOUS TRANSACTION COMPLAINTS. Initiated By: NASDAQ Date Initiated: 06/29/2010 Docket/Case Number: 2009018387201

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought:

Other Sanction(s)/Relief MONETARY/FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/29/2010 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: SCOTTRADE IS REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING CLEARLY ERRONEOUS ORDERS AND TRANSACTIONS WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THE AWC BY THE COUNCIL. Sanction Details: THE TOTAL MONETARY FINE WAS FOR $10,000.00. A CHECK HAS BEEN ISSUED WITH A PAYMENT DATE OF 07/27/2010. Firm Statement WITHOUTH ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE OF $10,000.00 AND IS REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING CLEARLY ERRONEOUS ORDERS AND TRANSACTIONS WITHIN 30 DAYS OF ACCEPTANCE OF THE AWC BY THE COUNCIL. i Disclosure 29 of 51 Reporting Source: Regulator Current Status: Final Allegations: SECTION 220.8 OF FEDERAL RESERVE REGULATION T, SECTION 7 OF THE SECURITIES EXCHANGE ACT OF 1934, NASD RULES 2110, 2520(F)(8) - SCOTTRADE, INC. PERMITTED CUSTOMERS IN NUMEROUS MARGIN ACCOUNTS THAT MET THE DEFINITION OF PATTERN DAY TRADER, TO EXECUTE NUMEROUS DAY TRADES WHEN THE EQUITY IN THE ACCOUNT WAS LESS THAN $25,000. THE FIRM USED A PATTERN DAY TRADING REPORT (PDTR) TO IDENTIFY A MARGIN ACCOUNT CUSTOMER WHO MET THE DEFINITION OF PATTERN DAY TRADER AND WHOSE ACCOUNT FELL BELOW $25,000 IN EQUITY AND WOULD SEND THE CUSTOMER WRITTEN NOTIFICATION THAT THE CUSTOMER HAD TO RESULT THE EQUITY BACK TO THE MINIMUM BEFORE TRADING BY DEPOSITING CASH OR SECURITIES IN THE MARGIN ACCOUNT BUT THE FIRM DID NOT PRECLUDE OR RESTRICT DAY TRADING ACTIVITIES WHEN THE CUSTOMER FAILED TO PROMPTLY DEPOSIT CASH OR SECURITIES. IF THE CUSTOMER APPEARED ON THE PDTR A SECOND TIME, THE FIRM SENT THE CUSTOMER A SECOND WRITTEN NOTIFICATION INSTRUCTING THE CUSTOMER TO RESTORE THE MINIMUM WITHIN FIVE BUSINESS DAYS. PRIOR TO AUGUST 2006, IF THE CUSTOMER DID NOT COMPLY WITHIN FIVE BUSINESS DAYS, THE FIRM REMOVED MARGIN PRIVILEGES AND CONVERTED THE ACCOUNT TO A ©2021 FINRA. All rights reserved. Report aboutCASH SCOTTRADE, ACCOUNT INC. UNTIL EQUITY WAS RESTORED TO $25,000. IN AUGUST 97 2006, THE FIRM CHANGED ITS PROCESS AND THE CUSTOMER WAS RESTRICTED TO TRADING ON A CASH-ONLY BASIS FOR 90 DAYS. AFTER THE 90-DAY RESTRICTION PASSED, IF THE CUSTOMER WANTED MARGIN PRIVILEGES REINSTATED, THE CUSTOMER WAS REQUIRED TO SUBMIT WRITTEN COMMUNICATION REQUESTING REINSTATEMENT, DESCRIBING INTENDED FUTURE TRADING ACTIVITIES AND PROMISING NOT TO ENGAGE IN PATTERN DAY TRADING IF $25,000 EQUITY WAS NOT IN THE ACCOUNT. FOR A CUSTOMER WHO APPEARED ON THE PDTR A THIRD TIME AND DID NOT RESTORE EQUITY BACK IN FIVE BUSINESS DAYS, PRIOR TO AUGUST 2006, THE FIRM PERMANENTLY REMOVED MARGIN PRIVILEGES. AFTER AUGUST 2006, IF THE FIRM RESTORED MARGIN PRIVILEGES AFTER THE CUSTOMER SUBMITTED WRITTEN COMMUNICATION TO BE REINSTATED, THE MARGIN PRIVILEGES WERE REMOVED IMMEDIATELY AND THE FIRM CONSIDERED THE CUSTOMER'S ACTIVITIES AND CONDUCT IN THE EVENT THE CUSTOMER EVER REQUESTED TO BE REINSTATED. THE FIRM FAILED TO OBTAIN FROM CUSTOMERS SUFFICIENT CASH PAYMENT OR OTHERWISE PROMPTLY CANCEL OR LIQUIDATE TRANSACTIONS WITHIN THE PERIOD SPECIFIED BY FEDERAL RESERVE REGULATION T. THE FIRM'S PRACTICE WAS TO SEND THE CUSTOMERS SELLOUT LETTERS ADVISING THE CUSTOMERS THAT THEY WERE REQUIRED TO PROVIDE PAYMENT WITHIN TWO BUSINESS DAYS, DATES THAT WERE BEYOND THE REGULATION T DATE. THE FIRM'S ACTIONS HAD THE EFFECT OF ALLOWING CUSTOMERS ADDITIONAL DAYS BEYOND THOSE PERMITTED IN SECTION 220.8 OF REGULATION T. SECTION 220.8 OF FEDERAL RESERVE REGULATION T, SECTION 7 OF THE SECURITIES EXCHANGE ACT OF 1934, NASD RULES 2110, 2520(F)(8) - SCOTTRADE, INC. PERMITTED CUSTOMERS IN NUMEROUS MARGIN ACCOUNTS THAT MET THE DEFINITION OF PATTERN DAY TRADER, TO EXECUTE NUMEROUS DAY TRADES WHEN THE EQUITY IN THE ACCOUNT WAS LESS THAN $25,000. THE FIRM USED A PATTERN DAY TRADING REPORT (PDTR) TO IDENTIFY A MARGIN ACCOUNT CUSTOMER WHO MET THE DEFINITION OF PATTERN DAY TRADER AND WHOSE ACCOUNT FELL BELOW $25,000 IN EQUITY AND WOULD SEND THE CUSTOMER WRITTEN NOTIFICATION THAT THE CUSTOMER HAD TO RESULT THE EQUITY BACK TO THE MINIMUM BEFORE TRADING BY DEPOSITING CASH OR SECURITIES IN THE MARGIN ACCOUNT BUT THE FIRM DID NOT PRECLUDE OR RESTRICT DAY TRADING ACTIVITIES WHEN THE CUSTOMER FAILED TO PROMPTLY DEPOSIT CASH OR SECURITIES. IF THE CUSTOMER APPEARED www.finra.org/brokercheck ON THE PDTR A SECOND TIME, THE FIRM SENT THE CUSTOMER A SECOND User Guidance WRITTEN NOTIFICATION INSTRUCTING THE CUSTOMER TO RESTORE THE MINIMUM WITHIN FIVE BUSINESS DAYS. PRIOR TO AUGUST 2006, IF THE CUSTOMER DID NOT COMPLY WITHIN FIVE BUSINESS DAYS, THE FIRM REMOVED MARGIN PRIVILEGES AND CONVERTED THE ACCOUNT TO A CASH ACCOUNT UNTIL EQUITY WAS RESTORED TO $25,000. IN AUGUST 2006, THE FIRM CHANGED ITS PROCESS AND THE CUSTOMER WAS RESTRICTED TO TRADING ON A CASH-ONLY BASIS FOR 90 DAYS. AFTER THE 90-DAY RESTRICTION PASSED, IF THE CUSTOMER WANTED MARGIN PRIVILEGES REINSTATED, THE CUSTOMER WAS REQUIRED TO SUBMIT WRITTEN COMMUNICATION REQUESTING REINSTATEMENT, DESCRIBING INTENDED FUTURE TRADING ACTIVITIES AND PROMISING NOT TO ENGAGE IN PATTERN DAY TRADING IF $25,000 EQUITY WAS NOT IN THE ACCOUNT. FOR A CUSTOMER WHO APPEARED ON THE PDTR A THIRD TIME AND DID NOT RESTORE EQUITY BACK IN FIVE BUSINESS DAYS, PRIOR TO AUGUST 2006, THE FIRM PERMANENTLY REMOVED MARGIN PRIVILEGES. AFTER AUGUST 2006, IF THE FIRM RESTORED MARGIN PRIVILEGES AFTER THE CUSTOMER SUBMITTED WRITTEN COMMUNICATION TO BE REINSTATED, THE MARGIN PRIVILEGES WERE REMOVED IMMEDIATELY AND THE FIRM CONSIDERED THE CUSTOMER'S ACTIVITIES AND CONDUCT IN THE EVENT THE CUSTOMER EVER REQUESTED TO BE REINSTATED. THE FIRM FAILED TO OBTAIN FROM CUSTOMERS SUFFICIENT CASH PAYMENT OR OTHERWISE PROMPTLY CANCEL OR LIQUIDATE TRANSACTIONS WITHIN THE PERIOD SPECIFIED BY FEDERAL RESERVE REGULATION T. THE FIRM'S PRACTICE WAS TO SEND THE CUSTOMERS SELLOUT LETTERS ADVISING THE CUSTOMERS THAT THEY WERE REQUIRED TO PROVIDE PAYMENT WITHIN TWO BUSINESS DAYS, DATES THAT WERE BEYOND THE REGULATION T DATE. THE FIRM'S ACTIONS HAD THE EFFECT OF ALLOWING CUSTOMERS ADDITIONAL DAYS BEYOND THOSE PERMITTED IN SECTION 220.8 OF REGULATION T. Initiated By: FINRA Date Initiated: 04/01/2010 Docket/Case Number: 2007007126901

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/01/2010 Does the order constitute a No final order based on violations of any laws or ©2021regulations FINRA. All that rights prohibit reserved. Report about SCOTTRADE, INC. 98 fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) ©2021Sought: FINRA. All rights reserved. Report about SCOTTRADE, INC. 99 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/01/2010 Sanctions Ordered: Censure Monetary/Fine $200,000.00 Other Sanctions Ordered: Sanction Details: TOTAL AMOUNT OF FINE $200,000.00. i Disclosure 30 of 51 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010, 3360, 6955(A), 8211, 8213 - SCOTTRADE, INC. FAILED TO REPORT ACCURATE TRADING INFORMATION THROUGH THE SUBMISSION OF ELECTRONIC BLUE SHEETS IN RESPONSE TO FINRA REQUESTS FOR SUCH INFORMATION; THE FIRM FAILED TO INCLUDE THE SHORT SALE INDICATOR FOR THE BLUE SHEET RECORDS. THE FIRM TRANSMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS) THAT THE OATS SYSTEM WAS UNABLE TO LINK TO THE CORRESPONDING NEW ORDER TRANSMITTED BY THE DESTINATION MEMBER FIRM DUE TO INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA. THE FIRM FAILED TO TRANSMIT NUMEROUS REPORTABLE ORDER EVENTS (ROES) TO OATS AND TRANSMITTED ROES TO OATS THAT WERE REJECTED BY OATS FOR CONTENT OR SYNTAX ERRORS AND THE FIRM FAILED TO REPAIR MOST OF THEM. THE FIRM FAILED TO TIMELY REPORT ROES TO OATS; TRANSMITTED EXECUTION REPORTS TO OATS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA SO THAT THE OATS SYSTEM WAS UNABLE TO LINK THE EXECUTION REPORTS TO THE RELATED TRADE REPORTS IN AN NASD TRADE REPORTING SYSTEM. THE FIRM SUBMITTED TO NASD INACCURATE SHORT INTEREST POSITION REPORTS IN NASDAQ AND EXCHANGE-LISTED SECURITIES. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING ELECTRONIC BLUE SHEET SUBMISSION REQUIREMENTS AND SHORT INTEREST REPORTING.

Initiated By: FINRA Date Initiated: 01/06/2010 Docket/Case Number: 2005002507502

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: 01/06/2010 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 $90,000.00 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, THE FIRM IS CENSURED, FINED $90,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEEDINGS REGARDING ELECTRONIC BLUE SHEET SUBMISSION REQUIREMENTS WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. i Reporting Source: Firm Current Status: Final Allegations: SCOTTRADE ALLEGEDLY FAILED TO FILE ACCURATE AND TIMELY TRADING INFORMATION THROUGH THE SUBMISSIONS OF BLUE SHEETS AND THROUGH THE ORDER AUDIT TRAIL SYSTEM (OATS). ALSO, SCOTTRADE ALLEGEDLY FAILED TO HAVE ADEQUATE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE SECURITIES CAUSES AND REGULATIONS. Initiated By: FINRA ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 101 www.finra.org/brokercheck User Guidance

Date Initiated: 01/06/2010 Docket/Case Number: 2005002507502

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/06/2010 Sanctions Ordered: Censure Monetary/Fine $90,000.00 Other Sanctions Ordered: UNDERTAKING TO REVISE WRITTEN SUPERVISORY PROCEDURES REGARDING BLUE SHEET SUBMISSIONS. Sanction Details: MONETARY/FINE OF $90,000 WAS PAID ON 01/20/2010. i Disclosure 31 of 51 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3011(A), 3011(B) AND MSRB RULE G-41: RESPONDENT SCOTTRADE INC. FAILED TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES THAT COULD BE REASONABLY EXPECTED TO DETECT AND CAUSE THE REPORTING OF TRANSACTIONS REQUIRED UNDER 31 U.S.C. § 5318(G) AND THE IMPLEMENTING REGULATIONS THEREUNDER AND FAILED TO ESTABLISH AND IMPLEMENT POLICIES, PROCEDURES AND INTERNAL CONTROLS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE BANK SECRECY ACT AND THE IMPLEMENTING REGULATIONS THEREUNDER. THE FIRM FAILED TO ESTABLISH AND IMPLEMENT REASONABLE ANTI-MONEY LAUNDERING (AML) POLICIES, PROCEDURES AND INTERNAL CONTROLS TAILORED TO ITS BUSINESS MODEL. DESPITE THE HIGH VOLUME OF ON-LINE TRADING AT THE FIRM, IT DID NOT HAVE ANY SYSTEMATIC OR AUTOMATED SYSTEM DESIGNED TO DETECT POTENTIALLY SUSPICIOUS MONEY MOVEMENT OR SECURITIES TRANSACTIONS FOR FURTHER ANALYSIS AND REPORTING AS APPROPRIATE. INSTEAD, THE FIRM USED A MANUAL SYSTEM FOR MONITORING ITS ACCOUNTS FOR SUSPICIOUS ACTIVITIES, WHICH RELIED EXCLUSIVELY ON INTERNAL SOURCES, INCLUDING BRANCH, CASHIERING ©2021 FINRA. All rights reserved. Report aboutAND SCOTTRADE, MARGIN PERSONNEL, INC. AND EXTERNAL SOURCES, TO REFER 102 POTENTIALLY SUSPICIOUS ACTIVITY TO ITS RISK MANAGEMENT DEPARTMENT FOR FURTHER REVIEW. THE FIRM DID NOT PROVIDE ADEQUATE WRITTEN GUIDANCE TO ITS EMPLOYEES AS TO HOW TO DETECT OR REVIEW FOR POTENTIALLY SUSPICIOUS ACTIVITY. THE SHEER VOLUME OF ON-LINE TRADING RENDERED THE LACK OF AN AUTOMATED SYSTEM, ALONG WITH THE FIRM'S RELIANCE ON INADEQUATE INTERNAL RESOURCES TO DETECT SUSPICIOUS ACTIVITY, UNREASONABLE. NOTWITHSTANDING THE IMPLEMENTATION OF A PROPRIETARY, AUTOMATED FILTER-BASED SYSTEM TO MONITOR FOR SUSPICIOUS TRANSACTIONS, THE FIRM DID NOT HAVE ADEQUATE POLICIES, PROCEDURES AND INTERNAL CONTROLS TO DETECT AND CAUSE THE REPORTING OF SUSPICIOUS SECURITIES TRANSACTIONS. THE FIRM'S AML ANALYSTS ONLY REVIEWED THE SYSTEM FOR POTENTIALLY SUSPICIOUS TRADING ACTIVITY CAPTURED IN A FILTER IF THERE WAS MONEY MOVEMENT INTO OR OUT OF AN ACCOUNT THAT INDEPENDENTLY TRIGGERED ONE OF THE FILTERS. THE FIRM'S AML PROCEDURES FAILED TO PROVIDE ADEQUATE WRITTEN GUIDANCE TO ITS AML ANALYSTS AS TO WHEN AND HOW THEY SHOULD REVIEW ACCOUNTS FOR SUSPICIOUS TRADING ACTIVITY IN CONNECTION WITH MONEY MOVEMENTS. AS A RESULT, THE FIRM'S AML POLICIES, PROCEDURES AND INTERNAL CONTROLS WERE INADEQUATE TO ACHIEVE COMPLIANCE WITH THE BANK SECRECY ACT AND THE IMPLEMENTING REGULATIONS THEREUNDER BECAUSE THEY WERE NOT REASONABLY DESIGNED TO DETECT AND CAUSE THE REPORTING OF SUSPICIOUS SECURITIES TRANSACTIONS. NASD RULES 2110, 3011(A), 3011(B) AND MSRB RULE G-41: RESPONDENT SCOTTRADE INC. FAILED TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES THAT COULD BE REASONABLY EXPECTED TO DETECT AND CAUSE THE REPORTING OF TRANSACTIONS REQUIRED UNDER 31 U.S.C. § 5318(G) AND THE IMPLEMENTING REGULATIONS THEREUNDER AND FAILED TO ESTABLISH AND IMPLEMENT POLICIES, PROCEDURES AND INTERNAL CONTROLS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE BANK SECRECY ACT AND THE IMPLEMENTING REGULATIONS THEREUNDER. THE FIRM FAILED TO ESTABLISH AND IMPLEMENT REASONABLE ANTI-MONEY LAUNDERING (AML) POLICIES, PROCEDURES AND INTERNAL CONTROLS TAILORED TO ITS BUSINESS MODEL. DESPITE THE HIGH VOLUME OF ON-LINE TRADING AT THE FIRM, IT DID NOT HAVE ANY SYSTEMATIC OR AUTOMATED SYSTEM DESIGNED TO DETECT POTENTIALLY SUSPICIOUS MONEY MOVEMENT OR SECURITIES www.finra.org/brokercheck TRANSACTIONS FOR FURTHER ANALYSIS AND REPORTING AS User Guidance APPROPRIATE. INSTEAD, THE FIRM USED A MANUAL SYSTEM FOR MONITORING ITS ACCOUNTS FOR SUSPICIOUS ACTIVITIES, WHICH RELIED EXCLUSIVELY ON INTERNAL SOURCES, INCLUDING BRANCH, CASHIERING AND MARGIN PERSONNEL, AND EXTERNAL SOURCES, TO REFER POTENTIALLY SUSPICIOUS ACTIVITY TO ITS RISK MANAGEMENT DEPARTMENT FOR FURTHER REVIEW. THE FIRM DID NOT PROVIDE ADEQUATE WRITTEN GUIDANCE TO ITS EMPLOYEES AS TO HOW TO DETECT OR REVIEW FOR POTENTIALLY SUSPICIOUS ACTIVITY. THE SHEER VOLUME OF ON-LINE TRADING RENDERED THE LACK OF AN AUTOMATED SYSTEM, ALONG WITH THE FIRM'S RELIANCE ON INADEQUATE INTERNAL RESOURCES TO DETECT SUSPICIOUS ACTIVITY, UNREASONABLE. NOTWITHSTANDING THE IMPLEMENTATION OF A PROPRIETARY, AUTOMATED FILTER-BASED SYSTEM TO MONITOR FOR SUSPICIOUS TRANSACTIONS, THE FIRM DID NOT HAVE ADEQUATE POLICIES, PROCEDURES AND INTERNAL CONTROLS TO DETECT AND CAUSE THE REPORTING OF SUSPICIOUS SECURITIES TRANSACTIONS. THE FIRM'S AML ANALYSTS ONLY REVIEWED THE SYSTEM FOR POTENTIALLY SUSPICIOUS TRADING ACTIVITY CAPTURED IN A FILTER IF THERE WAS MONEY MOVEMENT INTO OR OUT OF AN ACCOUNT THAT INDEPENDENTLY TRIGGERED ONE OF THE FILTERS. THE FIRM'S AML PROCEDURES FAILED TO PROVIDE ADEQUATE WRITTEN GUIDANCE TO ITS AML ANALYSTS AS TO WHEN AND HOW THEY SHOULD REVIEW ACCOUNTS FOR SUSPICIOUS TRADING ACTIVITY IN CONNECTION WITH MONEY MOVEMENTS. AS A RESULT, THE FIRM'S AML POLICIES, PROCEDURES AND INTERNAL CONTROLS WERE INADEQUATE TO ACHIEVE COMPLIANCE WITH THE BANK SECRECY ACT AND THE IMPLEMENTING REGULATIONS THEREUNDER BECAUSE THEY WERE NOT REASONABLY DESIGNED TO DETECT AND CAUSE THE REPORTING OF SUSPICIOUS SECURITIES TRANSACTIONS. Initiated By: FINRA Date Initiated: 10/26/2009 Docket/Case Number: 2007009026302

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: 10/26/2009 Does the order constitute a No final order based on violations of any laws or ©2021regulations FINRA. All that rights prohibit reserved. Report about SCOTTRADE, INC. 103 fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance

Principal Product Type: No Product

Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE OF $600,000; AND Sought: AN UNDERTAKING THAT THE FIRM'S CHIEF COMPLIANCE OFFICER SHALL CERTIFY WITHIN 60 DAYS OF THE EFFECTIVE DATE OF THIS AWC THAT THE FIRM IS IN COMPLIANCE WITH FINRA RULE 3011(A) AND (B) AND MSRB RULE G-41 BY ESTABLISHING AND IMPLEMENTNG AML POLICIES, PROCEDURES, AND INTERNAL CONTROLS WITH RESPECT TO ITS MONITORING FOR SUSPICIOUS TRANSACTIONS THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE REQUIREMENTS OF THE BANK SECRECY ACT AND THE TREASURY'S IMPLEMENTING REGULATIONS.

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/26/2009 Sanctions Ordered: Censure Monetary/Fine $600,000.00 Other Sanctions Ordered: AN UNDERTAKING THAT THE FIRM'S CHIEF COMPLIANCE OFFICER SHALL CERTIFY WITHIN 60 DAYS OF THE EFFECTIVE DATE OF THIS AWC THAT THE FIRM IS IN COMPLIANCE WITH FINRA RULE 3011(A) AND (B) AND MSRB RULE G-41 BY ESTABLISHING AND IMPLEMENTING AML POLICIES, PROCEDURES, AND INTERNAL CONTROLS WITH RESPECT TO ITS MONITORING FOR SUSPICIOUS TRANSACTIONS THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE REQUIREMENTS OF THE BANK SECRECY ACT AND THE TRESURY'S IMPLEMENTING REGULATIONS. Sanction Details: AWC RESULTED IN A FINE OF $600,000 WHICH WAS PAID ON 10/30/2009, A CENSURE AND AN UNDERTAKING. Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DISCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $600,000 AND REQUIRED TO CERTIFY WITHIN 60 DAYS OF THE EFFECTIVE DATE OF THE AWC THAT THE FIRM IS IN COMPLIANCE WITH FINRA RULE 3011(A) AND (B) AND MSRB RULE G-41 BY ESTABLISHING AND IMPLEMENTING AML POLICIES, PROCEDURES AND INTERNAL CONTROLS WITH RESPECT TO ITS MONITORING FOR SUSPICIOUS TRANSACTIONS THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE REQUIREMENTS OF THE BANK SECRECY ACT AND THE TRESURY'S IMPLEMENTING REGULATIONS. i Disclosure 32 of 51 Reporting Source: Firm ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 105 www.finra.org/brokercheck User Guidance

Current Status: Final Allegations: THE ALLEGATIONS IN SUMMARY WERE THAT THE FIRM FAILED TO FOLLOW ITS WRITTEN SUPERVISORY PROCEDURES IN CONNECTION WITH A COMPLAINT THAT AN ORDER SHOULD HAVE EXECUTED IN VIOLATION ON NSX RULES 3.1, 3.2, 5.1, 11.9(U).01. Initiated By: NATIONAL STOCK EXCHANGE Date Initiated: 05/29/2008 Docket/Case Number: BCC 2008-001

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief MONETARY FINE OF $25,000 Sought:

Resolution: Consent Resolution Date: 05/29/2008 Sanctions Ordered: Monetary/Fine $25,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $25,000. Firm Statement THE FIRM CONSENTED, WITHOUT ADMITTING OR DENYING THAT IT FAILED TO FOLLOW ITS WRITTEN SUPERVISORY PROCEDURES IN CONNECTION WITH A COMPLAINT THAT AN ORDER SHOULD HAVE EXECUTED IN VOLIATION OF THE NSX RULES REFERENCED ABOVE. i Disclosure 33 of 51 Reporting Source: Regulator Current Status: Final Allegations: SEC RULE 203(B)(3) OF REGULATION SHO, NASD RULES 2110, 3010, 3370, 6130(B) - SCOTTRADE, INC. EFFECTED SHORT SALES IN A SECURITY FOR THE FIRM'S PROPRIETARY ACCOUNT(S) AND FAILED TO ANNOTATE AN AFFIRMATIVE DETERMINATION THAT THE FIRM COULD BORROW THE SECURITY OR OTHERWISE PROVIDE FOR DELIVERY OF THE SECURITY BY SETTLEMENT DATE. THE FIRM HAD FAIL-TO DELIVER POSITIONS AT A REGISTERED CLEARING AGENCY IN THRESHOLD SECURITIES FOR 13 CONSECUTIVE SETTLEMENT DAYS AND BECAUSE OF DISCREPANCIES ©2021 FINRA. All rights reserved. Report aboutBETWEEN SCOTTRADE, DATA INC. PROCESSING SYSTEMS, FAILED TO IMMEDIATELY 106 THEREAFTER CLOSE OUT THE FAIL-TO-DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY AND CONTINUED TO HAVE FAIL-TO DELIVER POSITIONS AT THE CLEARING AGENCY FOR CONSECUTIVE SETTLEMENT DAYS THROUGH FUTURE DATES. THE FIRM FAILED TO ACCEPT OR DECLINE IN THE NASDAQ MARKET CENTER (NMC)TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION THAT THE FIRM HAD AN OBLIGATION TO ACCEPT OR DECLINE IN THE NMC AS THE ORDER ENTRY IDENTIFIER. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING SEC RULES 203(A)(1), 203(B)(1), NASD RULES 3370, 6130(D)(6). SEC RULE 203(B)(3) OF REGULATION SHO, NASD RULES 2110, 3010, 3370, 6130(B) - SCOTTRADE, INC. EFFECTED SHORT SALES IN A SECURITY FOR THE FIRM'S PROPRIETARY ACCOUNT(S) AND FAILED TO ANNOTATE AN www.finra.org/brokercheck AFFIRMATIVE DETERMINATION THAT THE FIRM COULD BORROW THE User Guidance SECURITY OR OTHERWISE PROVIDE FOR DELIVERY OF THE SECURITY BY SETTLEMENT DATE. THE FIRM HAD FAIL-TO DELIVER POSITIONS AT A REGISTERED CLEARING AGENCY IN THRESHOLD SECURITIES FOR 13 CONSECUTIVE SETTLEMENT DAYS AND BECAUSE OF DISCREPANCIES BETWEEN DATA PROCESSING SYSTEMS, FAILED TO IMMEDIATELY THEREAFTER CLOSE OUT THE FAIL-TO-DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY AND CONTINUED TO HAVE FAIL-TO DELIVER POSITIONS AT THE CLEARING AGENCY FOR CONSECUTIVE SETTLEMENT DAYS THROUGH FUTURE DATES. THE FIRM FAILED TO ACCEPT OR DECLINE IN THE NASDAQ MARKET CENTER (NMC)TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION THAT THE FIRM HAD AN OBLIGATION TO ACCEPT OR DECLINE IN THE NMC AS THE ORDER ENTRY IDENTIFIER. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING SEC RULES 203(A)(1), 203(B)(1), NASD RULES 3370, 6130(D)(6). Initiated By: FINRA Date Initiated: 06/26/2008 Docket/Case Number: 2004100016401

Principal Product Type: Other Other Product Type(s): THRESHOLD SECURITIES, REPORTABLE SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/26/2008 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 $45,000.00 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, THE FIRM IS CENSURED, FINED $45,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING SEC RULES 203(A)(1), 203(B)(1) AND NASD RULE 6130(D)(6) WITHIN 30 BUSINESS ©2021 FINRA. All rights reserved. Report aboutDAYS SCOTTRADE, OF ACCEPTANCE INC. OF THIS AWC BY THE NAC. 107 www.finra.org/brokercheck WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED User Guidance TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $45,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING SEC RULES 203(A)(1), 203(B)(1) AND NASD RULE 6130(D)(6) WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS AND SOLELY FOR THE PURPOSE OF THIS PROCEEDING, THE FIRM ACCEPTED AND CONSENTED TO THE FINDINGS THAT IT FAILED TO; ANNOTATE 196 SHORT SALE ORDERS IN VIOLATION OF NASD RULES 3370, 2110, & 3010; CLOSE OUT FAIL POSITIONS IN THREE STOCKS IN VIOLATION OF RULE 203(B)(3) AND ACCEPT OR DECLINE IN ACT 165 TRANSACTIONS. Initiated By: FINANCIAL REGULATORY AUTHORITY (FINRA) Date Initiated: 06/26/2008 Docket/Case Number: AWC NO. 20011000164-01

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): EQUITY - OTC Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/26/2008 Sanctions Ordered: Censure Monetary/Fine $45,000.00 Other Sanctions Ordered: Sanction Details: FINE OF $45,000 Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS AND SOLELY FOR THE PURPOSE OF THIS PROCEEDING, THE FIRM ACCEPTED AND CONSENTED TO FINDINGS THAT IT FAILED TO: ANNOTATE 196 SHORT SALE ORDERS IN VIOLATION OF NASD 3370; HAVE WRITTEN SUPERVISORY PROCEDURES REGARDING THE AFOREMENTIONED IN VIOLATION OF NASD RULES, 2110 AND 3010; CLOSE OUT FAIL POSITIONS IN THREE STOCKS IN VOLIATION OF RULE 203 (B)(3) OF REGULATION SHO; HAVE WRITTEN SUPERVISORY PROCEDURES REGARDING THE AFOREMENTIONED IN VIOLATION OF NASD RULES 2110 AND 3010; ACCEPT OR DECLINE IN ACT 165 TRANSACTIONS WITHIN 20 MINUTES AS REQUIRED IN VIOLATION OF NASD ©2021 FINRA. All rights reserved. Report aboutMARKET SCOTTRADE, PLACE INC. RULE 6130(B) AND NASD CONDUCT RULE 2110. 108 WITHOUT ADMITTING OR DENYING THE FINDINGS AND SOLELY FOR THE PURPOSE OF THIS PROCEEDING, THE FIRM ACCEPTED AND CONSENTED TO FINDINGS THAT IT FAILED TO: ANNOTATE 196 SHORT SALE ORDERS IN VIOLATION OF NASD 3370; HAVE WRITTEN SUPERVISORY PROCEDURES REGARDING THE AFOREMENTIONED IN VIOLATION OF NASD RULES, 2110 www.finra.org/brokercheck AND 3010; CLOSE OUT FAIL POSITIONS IN THREE STOCKS IN VOLIATION User Guidance OF RULE 203 (B)(3) OF REGULATION SHO; HAVE WRITTEN SUPERVISORY PROCEDURES REGARDING THE AFOREMENTIONED IN VIOLATION OF NASD RULES 2110 AND 3010; ACCEPT OR DECLINE IN ACT 165 TRANSACTIONS WITHIN 20 MINUTES AS REQUIRED IN VIOLATION OF NASD MARKET PLACE RULE 6130(B) AND NASD CONDUCT RULE 2110. i Disclosure 34 of 51 Reporting Source: Regulator Current Status: Final Allegations: SEC ADMIN RELEASE 34-58012, JUNE 24, 2008: WILLFULLY VIOLATED SECTION 15(C)(1)(A) OF THE EXCHANGE ACT - 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 SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST SCOTTRADE, INC. ("SCOTTRADE" OR "RESPONDENT"). IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT.THIS MATTER ARISES FROM REPRESENTATIONS SCOTTRADE MADE TO ITS CUSTOMERS IN CONNECTION WITH THEIR NASDAQ PRE-OPEN ORDERS FROM JANUARY 1, 2001 THROUGH DECEMBER 31, 2004 (THE "RELEVANT TIME PERIOD").SCOTTRADE EXPRESSLY MISREPRESENTED IN THE CUSTOMER ACCOUNT OPENING DOCUMENTS AND ACCOUNT STATEMENTS IT SENT TO ITS CUSTOMERS THAT ONE OF ITS POLICIES WAS TO ROUTE ITS CUSTOMERS' ORDERS BASED ON FACTORS THAT INCLUDED "LIQUIDITY AT MARKET OPENING," AMONG OTHER THINGS, WHICH GAVE ITS CUSTOMERS THE OPPORTUNITY TO RECEIVE EXECUTIONS "THAT MAY BE SUPERIOR TO THE NATIONAL BEST BID OFFER ('NBBO') IN ANY ONE MARKET CENTER." DURING THE RELEVANT TIME PERIOD, SCOTTRADE HAD NO WRITTEN POLICIES AND PROCEDURES TO ASSESS LIQUIDITY AT THE MARKET OPENING PROVIDED BY MARKET CENTERS AND, AS A RESULT, DID NOT CONSIDER THE AVAILABILITY OF EXECUTIONS THAT MAY BE SUPERIOR TO THE NBBO, SUCH AS SINGLE OR MIDPOINT PRICING, FOR ITS NASDAQ PRE-OPEN ORDERS. AS A BROKER-DEALER, SCOTTRADE HAS A LEGAL DUTY TO SEEK TO OBTAIN FOR ITS CUSTOMERS' ORDERS THE MOST FAVORABLE TERMS REASONABLY AVAILABLE UNDER THE CIRCUMSTANCES, TAKING INTO ACCOUNT PRICE, ORDER SIZE, TRADING CHARACTERISTICS OF THE SECURITY, SPEED OF EXECUTION, CLEARING COSTS, AND THE COST AND DIFFICULTY OF EXECUTING AN ORDER IN A PARTICULAR MARKET, AS WELL AS THE POTENTIAL FOR PRICE IMPROVEMENT (I.E., BEST EXECUTION). [CONTINUED IN COMMENTS.] Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 06/24/2008 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 109 www.finra.org/brokercheck User Guidance

Date Initiated: 06/24/2008 Docket/Case Number: SEC FILE 3-13081

Principal Product Type: Other Other Product Type(s): NASDAQ SECURITIES Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 06/24/2008 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 $950,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: 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 IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND- DESIST PROCEEDINGS PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER (THE "ORDER"). SCOTTRADE WILLFULLY VIOLATED SECTION 15(C)(1)(A) OF THE EXCHANGE ACT IT IS HEREBY ORDERED THAT: SCOTTRADE IS CENSURED. SCOTTRADE SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 15(C)(1)(A) OF THE EXCHANGE ACT; IT IS FURTHER ORDERED THAT SCOTTRADE SHALL, WITHIN 30 DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $950,000 TO THE UNITED STATES TREASURY. Regulator Statement BY ACCEPTING CUSTOMERS' ORDERS, A BROKER-DEALER IMPLIEDLY ©2021 FINRA. All rights reserved. Report aboutREPRESENTS SCOTTRADE, TO INC. CUSTOMERS THAT IT WILL REGULARLY AND 110 RIGOROUSLY REVIEW THE QUALITY OF EXECUTION THAT IT RECEIVES ON ITS ORDERS, AND WHERE MATERIAL DIFFERENCES EXIST BETWEEN THE PRICE IMPROVEMENT OPPORTUNITIES OFFERED BY MARKET CENTERS, THESE DIFFERENCES WILL BE TAKEN INTO ACCOUNT BY THE BROKER- DEALER WHEN DECIDING WHERE TO ROUTE ITS ORDERS. JUST PRIOR TO THE RELEVANT TIME PERIOD, THE COMMISSION STATED THAT SOME MARKET CENTERS OFFERED INVESTORS AN OPPORTUNITY TO AVOID PAYING A LIQUIDITY PREMIUM AT THE OPENING. THE COMMISSION STATED THAT AN EXAMPLE OF THIS IS "MIDPOINT PRICING" FOR NASDAQ PRE- OPEN ORDERS AND THAT BROKER-DEALERS SHOULD TAKE THESE ALTERNATIVE PRICING OPTIONS INTO CONSIDERATION WHEN SEEKING TO OBTAIN BEST EXECUTION FOR THEIR CUSTOMERS' NASDAQ PRE- OPEN ORDERS. CONTRARY TO THESE IMPLIED REPRESENTATIONS, SCOTTRADE DID NOT CONDUCT A REGULAR AND RIGOROUS REVIEW OF THE EXECUTION QUALITY OF ITS NASDAQ PRE-OPEN ORDERS DURING THE RELEVANT TIME PERIOD BECAUSE ITS PROCEDURES DID NOT REQUIRE IT TO CONSIDER THE AVAILABILITY OF MARKET CENTERS THAT COULD HAVE PROVIDED EXECUTIONS SUPERIOR TO THE NBBO THROUGH SINGLE OR MIDPOINT PRICING WHEN ROUTING ITS CUSTOMERS' NASDAQ PRE-OPEN ORDERS TO MARKET CENTERS. www.finra.org/brokercheck User Guidance

Regulator Statement BY ACCEPTING CUSTOMERS' ORDERS, A BROKER-DEALER IMPLIEDLY REPRESENTS TO CUSTOMERS THAT IT WILL REGULARLY AND RIGOROUSLY REVIEW THE QUALITY OF EXECUTION THAT IT RECEIVES ON ITS ORDERS, AND WHERE MATERIAL DIFFERENCES EXIST BETWEEN THE PRICE IMPROVEMENT OPPORTUNITIES OFFERED BY MARKET CENTERS, THESE DIFFERENCES WILL BE TAKEN INTO ACCOUNT BY THE BROKER- DEALER WHEN DECIDING WHERE TO ROUTE ITS ORDERS. JUST PRIOR TO THE RELEVANT TIME PERIOD, THE COMMISSION STATED THAT SOME MARKET CENTERS OFFERED INVESTORS AN OPPORTUNITY TO AVOID PAYING A LIQUIDITY PREMIUM AT THE OPENING. THE COMMISSION STATED THAT AN EXAMPLE OF THIS IS "MIDPOINT PRICING" FOR NASDAQ PRE- OPEN ORDERS AND THAT BROKER-DEALERS SHOULD TAKE THESE ALTERNATIVE PRICING OPTIONS INTO CONSIDERATION WHEN SEEKING TO OBTAIN BEST EXECUTION FOR THEIR CUSTOMERS' NASDAQ PRE- OPEN ORDERS. CONTRARY TO THESE IMPLIED REPRESENTATIONS, SCOTTRADE DID NOT CONDUCT A REGULAR AND RIGOROUS REVIEW OF THE EXECUTION QUALITY OF ITS NASDAQ PRE-OPEN ORDERS DURING THE RELEVANT TIME PERIOD BECAUSE ITS PROCEDURES DID NOT REQUIRE IT TO CONSIDER THE AVAILABILITY OF MARKET CENTERS THAT COULD HAVE PROVIDED EXECUTIONS SUPERIOR TO THE NBBO THROUGH SINGLE OR MIDPOINT PRICING WHEN ROUTING ITS CUSTOMERS' NASDAQ PRE-OPEN ORDERS TO MARKET CENTERS. i Reporting Source: Firm Current Status: Final Allegations: SOLELY FOR PURPOSE OF THE PROCEEDING AND WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT CONSENTED TO THE ENTRY OF AN ORDER MAKING FINDINGS THAT SCOTTRADE MADE MISREPRESENTATIONS IN ACCOUNT OPENING DOCUMENTS AND ACCOUNT STATEMENTS REGARDING THE FACTORS USED TO DETERMINE THE ROUTING OF NASDAQ "PRE-OPEN" ORDERS FROM 2001 TO 2004 IN VIOLATION OF 15(C)(1) OF THE EXCHANGE ACT. Initiated By: U.S. SECURITIES & EXCHANGE COMMISSION Date Initiated: 06/24/2008 Docket/Case Number: FILE NO. 3-13081

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CEASE AND DESIST, CENSURE Sought: ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 111 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief CEASE AND DESIST, CENSURE Sought:

Resolution: Decision & Order of Offer of Settlement Resolution Date: 06/24/2008 Sanctions Ordered: Censure Monetary/Fine $950,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: FINE OF $950,000 Firm Statement SOLELY FOR THE PURPOSE OF THE PROCEEDING AND WITHOUT ADMITTING OR DENYING THE FINDINGS, THE RESPONDENT CONSENTED TO THE ENTRY OF AN ORDER MAKING FINDINGS THAT BETWEEN 2001 AND 2004 SCOTTRADE MADE MISREPRESENTATIONS IN ACCOUNT OPENING DOCUMENTS AND ACCOUNT STATEMENTS REGARDING THE FACTORS USED TO DETERMINE ROUTING OF NASDAQ PRE-OPEN ORDERS; HAD NO WRITTEN POLICIES AND PROCEDURES TO ACCESS LIQUIDITY AT MARKET OPEN; AND IMPLIEDLY REPRESENTED TO CUSTOMERS THAT IT WOULD REGULARLY REVIEW ITS CUSTOMERS NASDAQ PRE-OPEN ORDERS, WHEN IT DID NOT, IN VIOLATION OF SECTION 15(C)(1)(A) OF THE ACT. i Disclosure 35 of 51 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010 - SCOTTRADE, INC.'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING THE DUTY OF BEST EXECUTION, NASD CONDUCT RULE 2320, AND THE REQUIREMENT, UNDER THE DUTY OF BEST EXECUTION, TO CONDUCT A REGULAR AND RIGOROUS SYSTEM OF EXECUTION QUALITY. Initiated By: NASD Date Initiated: 11/03/2006 Docket/Case Number: 2004200003702

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 112 www.finra.org/brokercheck User Guidance

Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/03/2006 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 $20,000.00 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 $20,000. i Reporting Source: Firm Current Status: Final Allegations: THE FIRM DID NOT HAVE IN PLACE SUFFICIENT WRITTEN SUPERVISORY PROCEDURES. Initiated By: NASD Date Initiated: 11/03/2006 Docket/Case Number: 20042000037-02

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE OF $20,000 Sought:

Sanctions Ordered: Censure Monetary/Fine $20,000.00 Other Sanctions Ordered: Sanction Details: $20,000 Firm Statement FROM JULY 1, 2002 THROUGH SEPTEMBER 30, 2002, SCOTTRADE AGREED TO AN AWC, WITHOUT ADMITTING OR DENY THE FINDINGS, THAT ITS WRITTEN SUPERVISORY PROCEDURES REGARDING ITS REGULAR AND RIGOROUS REVIEW WERE INSUFFICIENT IN DETAIL. THE INSUFFICIENT WRITTEN SUPERVISORY PROCEDURES WERE DEEMED TO BE A VIOLATION OF NASD RULES 2110 AND 3010. i Disclosure 36 of 51 Reporting Source: Regulator Current Status: Final Allegations: SEC RULES 10B-5, 11AC1-6, NASD RULES 2110, 3010, 6955(A) - SCOTTRADE, INC. FAILED TO SUBMIT A COMBINED ORDER/ROUTE REPORT FOR ORDERS RECEIVED AND FULLY ROUTED IN THE SAME DAY; FAILED TO SUBMIT TO OATS ROUTE REPORTS FOLLOWING CUSTOMER MODIFICATION OF A PREVIOUSLY ELECTRONICALLY ROUTED ORDER; INCORRECTLY INCLUDED ON CUSTOMER CONFIRMATIONS A NOTATION DISCLOSING TO ITS CUSTOMERS THAT THE FIRM WAS A MARKET MAKER IN THE SUBJECT SECURITY; FAILED TO NOTIFY CUSTOMERS AT LEAST ANNUALLY IN WRITING THAT A WRITTEN COPY OF THE QUARTERLY REPORT ON THE FIRM'S ROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITIES WILL BE FURNISHED ON REQUEST; AND THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING THE ONE PERCENT RULE, ANTI-INTIMIDATION; OATS CLOCK SYNCHRONIZATION, AND BOOKS AND RECORDS. Initiated By: NASD Date Initiated: 08/30/2004 Docket/Case Number: 2005002324001

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief ©2021Sought: FINRA. All rights reserved. Report about SCOTTRADE, INC. 114 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/30/2006 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 $27,500.00 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, THE FIRM IS CENSURED, FINED $27,500 AND REQUIRED TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES REGARDING THE ONE PERCENT RULE, ANTI-INTIMIDATION; OATS CLOCK SYNCHRONIZATION, AND BOOKS AND RECORDS WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. i Reporting Source: Firm Current Status: Final Allegations: THE FIRM CONSENTED, WITHOUT ADMITTING OR DENYING, AND SOLELY FOR NASD PURPOSES, THAT IT FAILED TO SUBMIT CERTAIN OATS REPORTS (33 COMBINED ORDER REPORTS AND 9 ROUTE REPORTS) IN VIOLATION OF THE NASD OATS RULES; INCORRECTLY NOTED THAT THE FIRM WAS A MARKET MAKER ON 15 CUSTOMER CONFIRMATIONS IN VIOLATION OF SEC RULE 10B-10; FAILED TO NOTIFY ITS CUSTOMERS ON AT LEAST AN ANNUAL BASIS THAT A WRITTEN COPY OF THE FIRM'S ROUTING OF NON-DIRECTED ORDERS WOULD BE FURNISHED ON REQUEST IN VIOLATIONOF REGULATION NMS 606; AND ITS WRITTEN SUPERVISORY PROCEDURES WERE DEFICIENT WITH RESPECT TO THE ONE PERCENT RULE, ANTI-INTIMIDATION, OATS CLOCK SYNCHRONIZATION AND BOOKS AND RECORDS IN VIOLATION OF NASD RULE 2110 AND 3010. Initiated By: NASD Date Initiated: 08/30/2006 Docket/Case Number: 20050023240-01 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 115 www.finra.org/brokercheck User Guidance

Docket/Case Number: 20050023240-01

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief CENSURE AND FINE OF $27,500 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/30/2006 Sanctions Ordered: Censure Monetary/Fine $27,500.00 Other Sanctions Ordered: NONE Sanction Details: FINE OF $27,500 PAID ON 9/28/06. i Disclosure 37 of 51 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010, 6955(A), 6955(C) - SCOTTRADE, INC. FAILED TO SUBMIT TO THE ORDER AUDIT TRAIL SYSTEM (OATS) ROUTE REPORTS RELATED TO CANCEL/REPLACE REPORTS; SUBMITTED TO OATS REPORTS WITH RESPECT TO EQUITY SECURITIES TRADED ON THE NASDAQ STOCK MARKET THAT WERE NOT IN THE ELECTRONIC FORM PRESCRIBED BY NASD AND NOTICE OF SUCH REJECTION WAS MADE AVAILABLE TO THE FIRM ON THE OATS WEBSITE BUT THE FIRM DID NOT CORRECT OR REPLACE 20 PERCENT OF THE SUBJECT REPORTS; THE FIRM DID NOT MAINTAIN WRITTEN DOCUMENTS EVIDENCING ITS REPORTING AGENT AGREEMENT(S) IN EFFECT DURING SEVERAL MONTHS; AND THE FIRM FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES THAT SPECIFIED THAT THE FIRM WOULD MAINTAIN REPORTS OF EACH DAY'S REJECTIONS WITH NOTATIONS EXPLAINING WHAT WAS REPAIRED AND RESUBMITTED. Initiated By: NASD Date Initiated: 06/30/2006 Docket/Case Number: 2005000005701

Principal Product Type: Equity Listed (Common & Preferred Stock)

Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/30/2006 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 $30,000.00 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 $30,000. i Reporting Source: Firm Current Status: Final Allegations: OATS RULE VIOLATION ALLEGATIONS. TO WIT: THE FIRM FAILED TO: SUBMIT CERTAIN ROUTE REPORTS FROM JAN - SEPT 2004; REPAIR CERTAIN REPORTS; HAVE WRITTEN EVIDENCE OF ITS REPORTING AGENT AGREEMENT; AND ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES. Initiated By: NASD Date Initiated: 06/30/2006 Docket/Case Number: 20050000057-01

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE OF $30,000 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/30/2006 Sanctions Ordered: Censure Monetary/Fine $30,000.00 Other Sanctions Ordered: Sanction Details: FINE OF $30,000 PAID ON JULY 18, 2006. Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, SCOTTRADE CONSENTED TO FINDINGS THAT IT VIOLATED CERTAIN OATS RULES INCLUDING FAILURE TO: SUBMIT CERTAIN ROUTE REPORTS FROM JAN - SEPT 2004; REPAIR CERTAIN REPORTS; HAVE WRITTEN EVIDENCE OF ITS REPORTING AGENT AGREEMENT; AND ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES. i Disclosure 38 of 51 Reporting Source: Regulator Current Status: Final Allegations: NASD CONDUCT RULES 3070 AND 2110, MARKETPLACE RULE 6230, MSB RULES G-14 AND G-27; THE FIRM FAILED TO TIMELY FILE CUSTOMER COMPLAINTS, DID NOT FILE COMPLAINTS UNTIL THE STAFF BROUGHT THEM TO THE FIRM'S ATTENTION, AND FILED AN INCORRECT DATE OF RECEIPT FOR CUSTOMER COMPLAINTS; IT FAILED TO TIMELY REPORT TRACE ELIGIBLE TRANSACTIONS WITHIN 30 MINUTES OF THE TIME OF EXECUTION; IT FAILED TO TIMELY REPORT INTER-DEALER TRANSACTIONS; FAILED TO HAVE IN PLACE AN ADEQUATE SUPERVISORY SYSTEM REASONABLY DESIGNED TO ENSURE THE TIMELY REPORTING OF MSRB TRANSACTIONS. Initiated By: NASD Date Initiated: 01/05/2006 Docket/Case Number: E042005009301

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: 01/05/2006 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 $110,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE MEMBER FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $110,000. i Reporting Source: Firm Current Status: Final Allegations: NASD CONDUCT RULES 3070 AND 2110,MARKETPLACE RULE 6230, MSRB RULES G-14 AND G-27; THE FIRM FAILED TO: 1. FILE CUSTOMER COMPLAINTS AND FILED AN INCORRECT DATE OF RECEIPT FOR CUSTOMER COMPLAINTS; 2. TIMELY REPORT TRACE ELIGIBLE TRANSACTIONS WITHIN 30 MINUTES OF THE TIME OF EXECUTION; 3. TIMELY REPORT INTER-DEALER TRANSACTIONS IN MUNICIPAL SECURITIES AND HAVE IN PLACE AN ADEQUATE SUPERVISORY SYSTEM REASONABLY DESIGNED TO ENSURE THE TIMELY REPORTING OF MSRB TRANSACTIONS. Initiated By: NASD Date Initiated: 01/05/2006 Docket/Case Number: E042005093-01

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief $110,000 FINE Sought:

Resolution Date: 01/05/2006 Sanctions Ordered: Censure Monetary/Fine $110,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE MEMBER FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $110,000. i Disclosure 39 of 51 Reporting Source: Regulator Current Status: Final Allegations: NASD MARKETPLACE RULE 6955(A), NASD CONDUCT RULE 2110 - SCOTTRADE, INC. FAILED TO TIMELY REPORT TO OATS REPORTABLE ORDER EVENTS (ROES") AND SUBMITTED TO OATS REPORTS WITH RESPECT TO EQUITY SECURITIES TRADED ON THE NASDAQ STOCK MARKET (THE "SUBJECT REPORTS") THAT WERE NOT INCLUDED IN THE ELECTRONIC FORM PRESCRIBED BY NASD AND WERE REPAIRABLE. THE SUBJECT REPORT WERE REJECTED BY OATS SYSTEM AND NOTICE OF SUCH REJECTION WAS MADE AVAILABLE TO THE FIRM ON THE OATS WEBSITE. IN FACT, THE FIRM DID NOT REPLACE 99% OF THE SUBJECT REPORTS. Initiated By: NASD Date Initiated: 09/06/2005 Docket/Case Number: 2005000003201

Principal Product Type: Other Other Product Type(s): EQUITY SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/06/2005 Does the order constitute a No final order based on violations of any laws or regulations that prohibit ©2021fraudulent, FINRA. Allmanipulative, rights reserved. or Report about SCOTTRADE, INC. 120 deceptive conduct? www.finra.org/brokercheck User Guidance

Principal Product Type: Other Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief CENSURE AND FINE OF $20,000 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/06/2005 Sanctions Ordered: Censure Monetary/Fine $20,000.00 Other Sanctions Ordered: NONE Sanction Details: CENSURE AND FINE OF $20,000 Firm Statement THE FIRM CONSENTED, WITHOUT ADMITTING OR DENYING, AND SOLELY ©2021 FINRA. All rights reserved. Report aboutFOR SCOTTRADE, THE PURPOSE INC. OF THIS PROCEEDING OR OTHERS INVOLVING NASD, 121 THAT IT FAILED TO REPORT CERTAIN TRANSACTIONS TO OATS IN A TIMELY MANNER AND FAILED TO REPORT OTHER TRANSACTIONS TO OATS IN A FORM OTHER THAN THAT PRESCRIBED BY OATS. www.finra.org/brokercheck User Guidance

Firm Statement THE FIRM CONSENTED, WITHOUT ADMITTING OR DENYING, AND SOLELY FOR THE PURPOSE OF THIS PROCEEDING OR OTHERS INVOLVING NASD, THAT IT FAILED TO REPORT CERTAIN TRANSACTIONS TO OATS IN A TIMELY MANNER AND FAILED TO REPORT OTHER TRANSACTIONS TO OATS IN A FORM OTHER THAN THAT PRESCRIBED BY OATS. i Disclosure 40 of 51 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010, 6420(C)(4) - RESPONDENT MEMBER FAILED TO REPORT THROUGH ACT THE CORRECT SYMBOL INDICATING WHETHER THE TRANSACTION WAS A BUY, SELL OR CROSS IN TRANSACTIONS IN ELIGIBLE SECURITIES. THE FINDINGS STATED THAT 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 TRADE REPORTING. Initiated By: NASD Date Initiated: 07/07/2005 Docket/Case Number: CLG050096

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: 07/07/2005 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 $10,000.00 Other Sanctions Ordered: UNDERTAKING: REQUIRED TO REVISE THE FIRM'S WRITTEN ©2021 FINRA. All rights reserved. Report aboutSUPERVISORY SCOTTRADE, INC.PROCEDURES REGARDING TRADE REPORTING WITHIN 30 122 BUSINESS DAYS. www.finra.org/brokercheck User Guidance

Other Sanctions Ordered: UNDERTAKING: REQUIRED TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES REGARDING TRADE REPORTING WITHIN 30 BUSINESS DAYS. Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SSIC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED AND FINED $10,000. i Reporting Source: Firm Current Status: Final Allegations: THE ALLEGATIONS WERE THAT FROM JULY 1, 2002 THROUGH SEPT 30, 2002, THE FIRM FAILED TO REPORT THROUGH ACT THE CORRECT SYMBOL INDICATING WHETHER THE TRANSACTION WAS A BUY, SELL OR CROSS FOR 161 TRANSACTIONS. THE FIRM ALSO DID NOT HAVE THE APPROPRIATE WRITTEN SUPERVISORY PROCEDURES IN PLACE. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 07/07/2005 Docket/Case Number: CLG050096AWC

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief $10,000 FINE AND AN UNDERTAKING TO REVISE WRITTEN SUPERVISORY Sought: PROCEDURES.

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/07/2005 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: UNDERTAKING TO REVISE WSPS. Sanction Details: NOT APPLICABLE i Disclosure 41 of 51 Reporting Source: Regulator Current Status: Final Allegations: SECTION 7, SECTION 220.8 OF REGULATION T, NASD RULE 2110 - ©2021 FINRA. All rights reserved. Report aboutSCOTTRADE, SCOTTRADE, INC. INC. PERMITTED PUBLIC CUSTOMERS TO PURCHASE AND 123 SELL SECURITIES IN A SERIES OF TRADES WITHOUT REQUIRING FULL CASH PAYMENT FOR EACH SECURITIES PURCHASE AND WITHOUT ANY GOOD FAITH BASIS FOR BELIEVING THAT THE CUSTOMERS WOULD PROMPTLY MAKE FULL CASH PAYMENT BEFORE SELLING THE SECURITIES; PERMITTED THE IMPROPER TRADING BY ONE OF TWO MEANS: (I) SECURITIES WERE SOLD WITHOUT FULL CASH PAYMENT HAVING BEEN MADE BY THE CUSTOMER, AND/OR (II) PROCEEDS FROM UNSETTLED SALE TRANSACTIONS WERE APPLIED AS PAYMENT FOR SUBSEQUENT PURCHASES; CHARGED CASH ACCOUNT CUSTOMERS APPROXIMATELY $7 FOR A MARKET ORDER AND RECEIVED APPROXIMATELY $193,170 IN REVENUE DUE TO THE MISCONDUCT. www.finra.org/brokercheck User Guidance

Allegations: SECTION 7, SECTION 220.8 OF REGULATION T, NASD RULE 2110 - SCOTTRADE, INC. PERMITTED PUBLIC CUSTOMERS TO PURCHASE AND SELL SECURITIES IN A SERIES OF TRADES WITHOUT REQUIRING FULL CASH PAYMENT FOR EACH SECURITIES PURCHASE AND WITHOUT ANY GOOD FAITH BASIS FOR BELIEVING THAT THE CUSTOMERS WOULD PROMPTLY MAKE FULL CASH PAYMENT BEFORE SELLING THE SECURITIES; PERMITTED THE IMPROPER TRADING BY ONE OF TWO MEANS: (I) SECURITIES WERE SOLD WITHOUT FULL CASH PAYMENT HAVING BEEN MADE BY THE CUSTOMER, AND/OR (II) PROCEEDS FROM UNSETTLED SALE TRANSACTIONS WERE APPLIED AS PAYMENT FOR SUBSEQUENT PURCHASES; CHARGED CASH ACCOUNT CUSTOMERS APPROXIMATELY $7 FOR A MARKET ORDER AND RECEIVED APPROXIMATELY $193,170 IN REVENUE DUE TO THE MISCONDUCT. Initiated By: NASD Date Initiated: 01/21/2005 Docket/Case Number: C04040062

Principal Product Type: Other Other Product Type(s): UNKNOWN TYPE OF SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/21/2005 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 $250,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SCOTTRADE CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $250,000. THE FINE IS TO BE PAID WITHIN 10 DAYS OF NOTICE OF ACCEPTANCE OF THIS AWC.

i Reporting Source: Firm Current Status: Final Allegations: WITHOUT SCOTTRADE ADMITTING OR DENYING THE CHARGES, SCOTTRADE CONSENTED TO THE ENTRY OF FINDINGS THAT IT IMPROPERLY EXTENDED CREDIT IN VIOLATION OF REG T AND NASD CONDUCT RULE 2110 FOR THE PERIOD OF JAN-SEPT 2001 Initiated By: NATIONAL ASSOCIATION OF SECURITES DEALERS (NASD) Date Initiated: 01/21/2005 Docket/Case Number: C04040062

Principal Product Type: Equity - OTC Other Product Type(s): EQUITY-LISTED Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief FINE OF $250,000 Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/21/2005 Sanctions Ordered: Censure Monetary/Fine $250,000.00 Other Sanctions Ordered: N/A Sanction Details: THE FIRM WAS CENSURED AND FINED $250,000. THE FINE WAS PAID BY JANUARY 28TH, 2005. Firm Statement THIS MATTER IS FINAL i Disclosure 42 of 51 Reporting Source: Regulator Current Status: Final Allegations: NASD MARKETPLACE RULE 6955(A), NASD CONDUCT RULES 2110 AND 3010 - RESPONDENT MEMBER SCOTTRADE, INC. SUBMITTED TO OATS 56,671 REPORTS WITH RESPECT TO EQUITY SECURITIES TRADED ON THE NASDAQ STOCK MARKET THAT WERE NOT IN THE ELECTRONIC FORM PRESCRIBED BY NASD AND WERE REPAIRABLE. THE REPORTS WERE REJECTED BY THE OATS SYSTEM AND NOTICE WAS MADE AVAILABLE TO ©2021 FINRA. All rights reserved. Report aboutTHE SCOTTRADE, FIRM ON THE INC. OATS WEBSITE. THE FIRM DID NOT CORRECT OR 125 REPLACE 56,671 OF THE REPORTS, OR 100 PERCENT OF THE REPORTS. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR THE SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND RULES OF NASD, CONCERNING ACCURATE AND TIMELY OATS SUBMISSIONS. NASD MARKETPLACE RULE 6955(A), NASD CONDUCT RULES 2110 AND 3010 - RESPONDENT MEMBER SCOTTRADE, INC. SUBMITTED TO OATS www.finra.org/brokercheck 56,671 REPORTS WITH RESPECT TO EQUITY SECURITIES TRADED ON THE User Guidance NASDAQ STOCK MARKET THAT WERE NOT IN THE ELECTRONIC FORM PRESCRIBED BY NASD AND WERE REPAIRABLE. THE REPORTS WERE REJECTED BY THE OATS SYSTEM AND NOTICE WAS MADE AVAILABLE TO THE FIRM ON THE OATS WEBSITE. THE FIRM DID NOT CORRECT OR REPLACE 56,671 OF THE REPORTS, OR 100 PERCENT OF THE REPORTS. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR THE SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND RULES OF NASD, CONCERNING ACCURATE AND TIMELY OATS SUBMISSIONS. Initiated By: NASD Date Initiated: 08/19/2004 Docket/Case Number: CMS040125

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: 08/19/2004 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 $16,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENT MEMBER SCOTTRADE, INC. CONSENTED TO THE FINDING OF THE ALLEGATIONS AND TO THE FOLLOWING SANCTIONS: CENSURED AND FINED $16,000.00. WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC, A REGISTERED PRINCIPAL OF THE RESPONDENT MEMBER SHALL SUBMIT TO NASD, A SIGNED, DATED LETTER, PROVIDING (1) A REFERENCE TO THIS MATTER; (2) A REPRESENTATION THAT THE FIRM HAS REVISED ITS WRITTEN SUPERVISORY PROCEDURES TO ADDRESS THE DEFICIENCIES IN THIS MATTER; AND (3) THE DATE THE REVISED PROCEDURES WERE IMPLEMENTED.

i Reporting Source: Firm Current Status: Final Allegations: FIRM WAS REPORTED TO BE IN VIOLATION OF NASD MARKETPLACE RULE 6955(A) AND CONDUCT RULE 2110 THAT IT FAILED TO CORRECT 56,671 REPORTABLE OATS REPORTS. THE FIRM'S SUPERVISORY SYSTEM WAS ALLEGED TO BE DEFICIENT WITH REGARD TO OATS REPORTING. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 08/19/2004 Docket/Case Number: CMS 040125AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief FINED $16,000 AND UNDERTAKING TO REVISE SUPERVISORY Sought: PROCEDURES.

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 08/19/2004 Sanctions Ordered: Censure Monetary/Fine $16,000.00 Other Sanctions Ordered: UNDERTAKING TO REVISE SUPERVISORY PROCEDURES Sanction Details: THE FIRM'S SUPERVISORY SYSTEM HAS BEEN REDESIGNED TO ACHIEVE COMPLIANCE WITH NASD RULES CONCERNING OATS REPORTING. Firm Statement THE FIRM CONSENTED, WITHOUT ADMITTING OR DENYING THAT IT: 1) FAILED TO CORRECT 56,671 REPAIRABLE OATS REPORTS IN VIOLATION OF NASD MARKET PLACE RULE 6955(A) AND NASD CONDUCT RULE 2110; 2) DID NOT HAVE ADEQUATE SUPERVISORY PROCEDURES THAT PROVIDED FOR SUPERISION OF OATS REPORTING. i Disclosure 43 of 51 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110 AND 6230(A) - RESPONDENT MEMBER FAILED TO REPORT TO "TRACE" ELIGIBLE SECURITIES WITHIN 75 MINUTES AFTER ©2021 FINRA. All rights reserved. Report aboutEXECUTION. SCOTTRADE, INC. 127 www.finra.org/brokercheck User Guidance

NASD RULES 2110 AND 6230(A) - RESPONDENT MEMBER FAILED TO REPORT TO "TRACE" ELIGIBLE SECURITIES WITHIN 75 MINUTES AFTER EXECUTION. Initiated By: NASD Date Initiated: 12/23/2003 Docket/Case Number: CMS030300

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: 12/23/2003 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: Monetary/Fine $5,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM IS FINED $5,000. i Reporting Source: Firm Current Status: Final Allegations: SSIC FAILED TO REPORT TO TRACE 300 TRANSACTIOS IN TRACE-ELIGIBLE SECURITIES WITHIN 75 MINUTES AFTER EXECUTION DURING A PERIOD AUGUST 1 THROUGH SEPTEMBER 30, 2002. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS (NASD) Date Initiated: 11/25/2003 Docket/Case Number: MRD200238466

Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief FINE OF $5000 PAID Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/23/2003 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: NO OTHER SANCTIONS ORDERED Sanction Details: $5000 PAID 12/25/2003 Firm Statement THE FIRM SETTLED WITH NASD THROUGH AN ACCEPTANCE WAIVER AND CONSENT (AWC)WITHOUT ADMITTING OR DENYING TRHE ALLEGATIONS OR FINDINGS SET FORTH IN THE AWC, THAT IT FAILED TO REPORT 399 TRANSACTIONS IN TRACE ELIGIBLE SECURITIES TO TRACE WITHIN 90 MINUTES AS REQUIRED, WHICH CONSTITUTED VIOLATIONS OF NASD MARKETPLACE RULE 6230(A) AND NASD RULE 2110. i Disclosure 44 of 51 Reporting Source: Firm Current Status: Final Allegations: SSIC REPORTED THROUGH ACT 60 LAST SALE REPORTS OF TRANSACTIONS IN ELIGIBLE SECURITIES IT WAS NOT REQUIRED TO REPORT. THIS CONDUCT IS IN VIOLATION OF NASD MARKETPLACE RULES 6420(B)(1) AND 6420(E)(1). Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS (NASD) Date Initiated: 01/28/2002 Docket/Case Number: CMS030007

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief WITHOUT ACCEPTING OR DENYING THE ALLEGATIONS SSIC CONSENTS Sought: TO THE IMPOSITION OF A $5000 FINE.

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/30/2003 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: NO OTHER SANCTIONS ORDERED Sanction Details: FINE OF $5000 PAID THROUGH NASD. Firm Statement SCOTTRADE(SSIC)USED AN ORDER MGMNT. SYSTEM LOCATED NEXT TO WORLD TRADE CENTER. AT TIME OF VIOLATIONS, THE SERVICE BUREAU WAS USING BACK UP SOFTWARE TO REPLACE 9-11 DAMAGED SOFTWARE. THERE WAS NO INTENTIONAL MANIPULATION OF MKTS. ALL CUST. ORDERS RECVD. BEST EXECUTIONS. SERVICE BUREAU TOOK FULL RESPONSIBILITY & CORRECTED PROBLEM IMMEDIATELY. i Disclosure 45 of 51 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110 AND 6955(A)- WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE FINDINGS THAT IT SUBMITTED TO OATS REPORTS THAT WERE NOT IN THE ELECTRONIC FORM PRESCRIBED BY THE NASD; AND REPORTED TO OATS EXECUTION REPORTS THAT CONTAINED EITHER INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA THEREBY CAUSING THE OATS SYSTEM TO BE UNABLE TO LINK THE EXECUTION REPORTS TO THE RELATED TRADE REPORTS IN ACT. Initiated By: NATIONAL ASSOCIATION OF SECURITES DEALERS Date Initiated: 11/07/2001 Docket/Case Number: CMS010180

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/07/2001 Sanctions Ordered: Monetary/Fine $5,000.00

Other Sanctions Ordered: Sanction Details: UNDERTAKE TO REVIEW ITS WRITTEN SUPERVISORY PROCEDURES TO ENSURE THAT THEY ARE ADEQUATE INCLUDING A DAILY REVIEW OF OATS DATE SUBMITTED TO THE OATS SYSTEM. Regulator Statement 04/18/02AC FINES & COST PAID IN FULL $5,000.00 12/12/01 INVOICE # 00- 9B- 315 i Reporting Source: Firm Current Status: Final Allegations: DURING THE PERIOD 9/1/99-1/21/2000, THE FIRM SUBMITTED TO OATS REPORTS THAT WERE NOT IN THE ELECTRONIC FORM PRESCRIBED BY THE ASSOCIATION. DURING THE PERIOD 10/18/99-11/12/99 THE FIRM REPORTED TO OATS EXECUTION REPORTS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA. Initiated By: NASD REGULATION, INC. Date Initiated: 02/09/2001 Docket/Case Number: CMS010180

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief LETTER OF ACCEPTANCE, WAIVER AND CONSENT Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/07/2001 Sanctions Ordered: Monetary/Fine $5,000.00 Other Sanctions Ordered: THE FIRM MUST REVIEW IT'S WRITTEN SUPERVISORY PROCEDURES TO ENSURE THAT THEY ARE ADEQUATE. Sanction Details: THE FIRM PAID $5000.00 ON 11/07/2001. Firm Statement AS SOON AS THE FIRM WAS MADE AWARE OF IT'S ERROR, IT COMPLIED IMMEDIATELY WITH THE REPORTING RULES. SCOTTRADE ACCEPTS THE $5,000 FINE AND HAS CORRECTED THE SUPERVISORY MANUAL. i Disclosure 46 of 51 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 131 www.finra.org/brokercheck User Guidance

Disclosure 46 of 51 Reporting Source: Firm Current Status: Final Allegations: SCOTTRADE FAILED TO PROPERLY SUPERVISE ITS SPECIALIST OPERATION. SCOTTRADE VIOLATED CINCINNATI STOCK EXCHANGE RULES 5.1 AND 5.2. Initiated By: CINCINNATI STOCK EXCHANGE Date Initiated: 04/19/2001 Docket/Case Number: BCC2001-001

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/26/2001 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: Sanction Details: $10,000 FINE LEVIED AGINST SCOTTRADE AND KRISTOPHER WALLACE JOINTLY AND SEVERALLY WHICH WAS PAID ON 08/08/2001 Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, SCOTTRADE AND KRISTOPHER WALLACE SUBMITTED AN EXPEDITED PROCEEDING LETTER OF CONSENT IN WHICH WE AGREED TO CENSURE AND $10,000 FINE. THE BUSINESS CONDUCT COMMITTEE ACCEPTED THE CONSENT LETTER. THE $10,000 FINE WAS PAID ON 08/08/2001 i Disclosure 47 of 51 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 4632(A), 4642(A) - REPORTED TRANSACTIONS TO THE AUTOMATED CONFIRMATION TRANSACTION SERVICES IN VIOLATION OF APPLICABLE SECURITIES LAWS AND REGULATIONS REGARDING TRADE REPORTING. ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 132 www.finra.org/brokercheck User Guidance NASD RULES 2110, 4632(A), 4642(A) - REPORTED TRANSACTIONS TO THE AUTOMATED CONFIRMATION TRANSACTION SERVICES IN VIOLATION OF APPLICABLE SECURITIES LAWS AND REGULATIONS REGARDING TRADE REPORTING. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 05/10/2000 Docket/Case Number: CMS000089

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/10/2000 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: Monetary/Fine $7,500.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, FIRM IS FINED $7,500. i Reporting Source: Firm Current Status: Final Allegations: DURING THE PERIOD 10/1-12/31, 1998 AND 1/4-3/31, 1999 SCOTTRADE FAILED TO REPORT THROUGH ACT SOME LAST SALE REPORTS WITHIN THE ALLOTTED 90 SECOND PERMISSABLE TIME FRAME. THERE WERE ALSO TRADES FOR WHICH SCOTTRADE INCORRECTLY DESIGNATED WHETHER SOME TRADES TOOK PLACE DURING OR OUTSIDE OF NORMAL MARKET HOURS. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 12/06/1999 Docket/Case Number: CMS000089 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 133 www.finra.org/brokercheck User Guidance

Docket/Case Number: CMS000089

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief MONETARY SANCTIONS OF $7500.00 WERE IMPOSED. Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/06/1999 Sanctions Ordered: Monetary/Fine $7,500.00 Other Sanctions Ordered: NO OTHER SANCTIONS ORDERED Sanction Details: MONETARY FINE OF $7500 WAS PAID TO THE NATIONAL ASSOCIATION OF SECURITIES DEALERS ON 12/6/99. NO OTHER CONDITIONS WERE REQUIRED. Firm Statement SCOTTRADE VOLUNTARILY, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS SIGNED AN NASD LETTER OF ACCEPTANCE, WAIVER ANND CONSENT ON 12/6/99. THE COMPUTER ORDER ROUTING SYSTEM IN USE BY SCOTTRADE WAS RESPONSIBLE FOR THESE RULE VIOLATIONS AND PROGRAMMING FIXES HAVE BEEN ADDRESSED BY THE ROUTING SOFTWARE VENDOR. i Disclosure 48 of 51 Reporting Source: Firm Current Status: Final Allegations: VIOLATION OF SEC RULES 15C,3-3 AND 15C 3-1 Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 09/18/1987 Docket/Case Number: KC-473-AWC

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): EQUITY-OTC OPTIONS Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief VIOLATION Sought: ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 134 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief VIOLATION Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/29/1987 Sanctions Ordered: Monetary/Fine $3,000.00 Other Sanctions Ordered: NONE Sanction Details: SCOTTSDALE, MR. RINEY AND MS. MCCLURE SIGNED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT AGREEING TO TAKE CORRECTIVE ACTIONS AND PAYMENT OF A $3,000 FINE WAS PAID. Firm Statement WITHOUT ADMITTING OR DENYING THE VIOLATIONS, SCOTTSDALE, MR. RINEY AND MS. MCCLURE SIGNED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT AGREEING TO TAKE CORRECTIVE ACTIONS AND PAYMENT OF A $3,000 FINE. i Disclosure 49 of 51 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/02/1997 Docket/Case Number: CMS950220(A) AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/02/1997 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details:

ON JULY 2, 1997, SCOTTSDALE SECURITIES, INC. (SSIC) WAS NOTIFIED THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) IT SUBMITTED WAS ACCEPTED BY THE MARKET REGULATION AND THE NATIONAL BUSINESS CONDUCT COMMITTEES. THE AWC ALLEGES THAT SSIC VIOLATED MARKETPLACE RULES 4632, 4642 AND 6130 FOR THE FOLLOWING ACTIVITY:

SSIC REPORTED 20 RISKLESS PRINCIPAL TRANSACTIONS THAT SHOULD NOT HAVE BEEN REPORTED; FAILED TO ADD THE PROPER MODIFIER TO 6 TRANSACTIONS; REPORTED 8 TRANSACTIONS INCORRECTLY AS RISKLESS PRINCIPAL TRANSACTIONS WHEN THEY SHOULD HAVE BEEN REPORTED AS A BUY OR SELL; AND FAILED TO IDENTIFY 8 TRANSACTIONS AS SHORT SALES. SSIC WAS FINED $2,000.

***$2,000.00 PAID ON 8//14/97, INVOICE #97-MS-660** www.finra.org/brokercheck User Guidance

Regulator Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS950220(A) AWC.

***$2,000.00 PAID ON 8//14/97, INVOICE #97-MS-660** i Reporting Source: Firm Current Status: Final Allegations: 06/19/1999: NASD RULES 2110, 4632(A),4642(A) - REPORTED TRANSACTIONS TO THE AUTOMATED CONFIRMATION TRANSACTION SERVICES IN VIOLATION OF APPLICABLE SECURITIES LAWS AND REGULATIONS REGARDING TRADE REPORTING. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 07/02/1997 Docket/Case Number: CMS950220(A) AWC

Principal Product Type: Equity - OTC Other Product Type(s): Principal Sanction(s)/Relief Denial Sought: Other Sanction(s)/Relief Sought:

Resolution Date: 05/10/2000 Sanctions Ordered: Monetary/Fine $2,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, SCOTTRADE AGREED TO CENSURE AND $3000 FINE. Firm Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS950220(A)AWC ON JULY 2, 1997, SCOTTSDALE SECURITIES, INC. (SSIC) WAS NOTIFIED THAT THE LTTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) IT SUBMITTED WAS ACCEPTED BY THE MARKET REGULATION AND THE NATIONAL BUSINESS CONDUCT COMMITTEES. THE AWC ALLEGES THAT SSIC VIOLATED MARKETPLACE RULES 4632, 4642, AND 6130 FOR THE FOLLOWING ACTIVITY: SSIC REPORTED 20 RISKLESS PRINCIPAL TRANSACTIONS THAT SHOULD NOT HAVE BEEN REPORTED; FAILED TO ADD THE PROPER MODIFIDER TO 6 TRANSACTIONS; REPORTED 8 TRANSACTIONS INCORRECTLY AS RISKLESS PRINCIPAL TRANSACTIONS WHEN THEY SHOULD HAVE BEEN REPORTED AS A BUY OR SELL; AND FAILED TO IDENTIFY 8 TRANSACTIONS AS SHORT SALES. SSIC WAS FINED $2,000. ***$2,000 PAID ON 8/14/97, INVOICE #97-MS-660*** i Disclosure 50 of 51 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 04/16/1990 Docket/Case Number: KC-473-AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/16/1990 Sanctions Ordered: Censure Monetary/Fine $1,000.00

Other Sanctions Ordered: Sanction Details: Regulator Statement ON APRIL 16, 1990, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. KC-473-AWC (DISTRICT NO. 4) SUBMITTED BY RESPONDENTS SCOTTSDALE SECURITIES, INC. AND KAREN ANN MCCLURE WAS ACCEPTED; THEREFORE, THEY ARE CENSURED AND FINED $1,000, JOINTLY AND SEVERALLY (ARTICLE III, SECTION 1 OF THE RULES OF FAIR PRACTICE - THE FIRM, ACTING THROUGH RESPONDENT MCCLURE FAILED TO MAINTAIN THE REQUIRED BALANCE IN THE SPECIAL RESERVE ACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERS). ***$1,000.00 J&S PAID ON 5/8/90 INVOICE #90-04-507*** i Reporting Source: Firm Current Status: Final Allegations: VIOLATION OF ARTICLE III, SECTION1 OF THE RULES OF FAIR PRACTICE. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 09/30/1989 Docket/Case Number: KC-473-AWC

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): EQUITY-OTC OPTIONS Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 04/16/1989 Sanctions Ordered: Censure Monetary/Fine $1,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE COMPLAINT THE FIRM PAID A $1,000 FINE. Firm Statement ON 9/30/89 SCOTTSDALE FORGOT TO MAKE A RESERVE DEPOSIT AND PROMPTLY BROUGHT THE OVERSIGHT TO THE ATTENTION OF THE NASD. WITHOUT ADMITTING OR DENYING THE COMPLAINT ALLEGATIONS, THE ©2021 FINRA. All rights reserved. Report aboutFIRM SCOTTRADE, CONSENTED INC. TO THE FOLLOWING FINDINGS: THE FIRM FAILED TO 138 MAINTAIN THE REQUIRED BALANCE IN THE SPECIAL RESERVE ACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERS. www.finra.org/brokercheck User Guidance

ON 9/30/89 SCOTTSDALE FORGOT TO MAKE A RESERVE DEPOSIT AND PROMPTLY BROUGHT THE OVERSIGHT TO THE ATTENTION OF THE NASD. WITHOUT ADMITTING OR DENYING THE COMPLAINT ALLEGATIONS, THE FIRM CONSENTED TO THE FOLLOWING FINDINGS: THE FIRM FAILED TO MAINTAIN THE REQUIRED BALANCE IN THE SPECIAL RESERVE ACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERS. i Disclosure 51 of 51 Reporting Source: Regulator Current Status: Final Allegations: Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 12/21/1987 Docket/Case Number: KC-394-AWC

Principal Product Type: Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/21/1987 Sanctions Ordered: Censure Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: Regulator Statement ON DECEMBER 21, 1987, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. KC-394-AWC (DISTRICT NO. 4) SUBMITTED BY RESPONDENTS SCOTTSDALE SECURITIES, INC., RODGER O. RINEY AND KAREN A. MCCLURE WAS ACCEPTED; THEREFORE, THEY ARE CENSURED AND FINED $3,000.00, JOINTLY AND SEVERALLY (ARTICLE III, SECTIONS 1 AND 19(b) OF THE RULES OF FAIR PRACTICE - RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS RINEY AND MCCLURE, INCURRED DEFICIENCIES IN ITS SPECIAL RESERVE ACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERS; AND, CONDUCTED A SECURITIES BUSINESS WHILE FAILING TO MAINTAIN MINIMUM REQUIRED NET CAPITAL).

©2021 FINRA. All rights reserved. Report about***$3,000 SCOTTRADE, FINE PAID INC. J&S 12/21/87 139 ON DECEMBER 21, 1987, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. KC-394-AWC (DISTRICT NO. 4) SUBMITTED BY RESPONDENTS SCOTTSDALE SECURITIES, INC., RODGER O. RINEY AND KAREN A. MCCLURE WAS ACCEPTED; THEREFORE, THEY ARE CENSURED AND FINED $3,000.00, JOINTLY AND SEVERALLY (ARTICLE III, SECTIONS 1 AND 19(b) OF THE RULES OF FAIR PRACTICE - RESPONDENT MEMBER, www.finra.org/brokercheck ACTING THROUGH RESPONDENTS RINEY AND MCCLURE, INCURRED User Guidance DEFICIENCIES IN ITS SPECIAL RESERVE ACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERS; AND, CONDUCTED A SECURITIES BUSINESS WHILE FAILING TO MAINTAIN MINIMUM REQUIRED NET CAPITAL).

***$3,000 FINE PAID J&S 12/21/87 i Reporting Source: Firm Current Status: Final Allegations: RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS RINEY AND MCCLURE, INCURRED DEFICIENCIES IN ITS SPECIAL RESERVE ACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERS; AND, CONDUCTED A SECURITIES BUSINESS WHILE FAILING TO MAINTAIN MINIMUM REQUIRED NET CAPITAL. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. Date Initiated: 12/21/1987 Docket/Case Number: KC-394-AWC

Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Type(s): Principal Sanction(s)/Relief Censure Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/21/1987 Sanctions Ordered: Censure Monetary/Fine $3,000.00 Other Sanctions Ordered: Sanction Details: ON DECEMBER 21, 1987, THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. KC-394-AWC (DISTRICT NO. 4) SUBMITTED BY RESPONDENTS SCOTTSDALE SECURITIES, INC., RODGER O. RINEY, AND KAREN A. MCCLURE WAS ACCEPTED; THEREFORE, THEY ARE CENSURED AND FINED $3,000.00 JOINTLY AND SEVERALLY (ARTICLE III, SECTIONS 1 AND 19(B) OF THE RULES OF FAIR PRACTICE - RESPONDENT MEMBER, ACTING THROUGH RESPONDENTS RINEY AND MCCLURE, INCURRED DEFICIENCIES IN ITS SPECIAL RESERVE ACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERS; AND CONDUCTED A SECURITIES BUSINESS WHILE FAILING TO MAINTAIN MINIMUM REQUIRED NET CAPTIAL). ***$3,000 FINE PAID J&S 12/21/1987***

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 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-MARGIN CALLS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/27/2000 Case Number: 00-03961 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: Unspecified Damages Disposition: AWARD AGAINST PARTY Disposition Date: 10/01/2001 Sum of All Relief Awarded: $57,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 2 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE- EXECUTIONS-EXECUTION PRICE Arbitration Forum: NASD Case Initiated: 10/05/2000 Case Number: 00-04362 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 141 www.finra.org/brokercheck User Guidance

Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $50,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 07/18/2001 Sum of All Relief Awarded: $6,925.00 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 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 04/19/2001 Case Number: 01-01740 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,078.95 Disposition: AWARD AGAINST PARTY Disposition Date: 10/17/2001 Sum of All Relief Awarded: $1,153.96 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 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-EXECUTION PRICE; DO NOT USE-EXECUTIONS- LIMIT V MRKT ORDR; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/03/2001 Case Number: 01-03740 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 142 www.finra.org/brokercheck User Guidance

Case Number: 01-03740 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $2,553.04 Disposition: AWARD AGAINST PARTY Disposition Date: 02/05/2002 Sum of All Relief Awarded: $402.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 5 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-OTHER; ACCOUNT RELATED-TRANSFER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/25/2001 Case Number: 01-04474 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $5,637.12 Disposition: AWARD AGAINST PARTY Disposition Date: 03/05/2002 Sum of All Relief Awarded: $697.10 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 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

Arbitration Forum: NASD Case Initiated: 11/13/2001 Case Number: 01-04813 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $23,925.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/21/2002 Sum of All Relief Awarded: $1,225.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 7 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVED; TRADING DISPUTES-BUY IN; TRADING DISPUTES-SELL OUTS Arbitration Forum: NASD Case Initiated: 01/14/2002 Case Number: 01-06103 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $5,240.08 Disposition: AWARD AGAINST PARTY Disposition Date: 04/26/2002 Sum of All Relief Awarded: $4,567.09 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 8 of 33 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 12/21/2001 Case Number: 01-06259 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $300,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/03/2003 Sum of All Relief Awarded: $9,999.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 9 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-OTHER-ON-LINE TRADING DISPUTE Arbitration Forum: NASD Case Initiated: 06/27/2003 Case Number: 03-02929 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $22,201.15 Disposition: AWARD AGAINST PARTY Disposition Date: 03/18/2004 Sum of All Relief Awarded: $7,489.01 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 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; DO NOT USE-OTHER-ON-LINE TRADING DISPUTE Arbitration Forum: NASD Case Initiated: 12/09/2004 Case Number: 04-07802 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/10/2005 Sum of All Relief Awarded: $983.07 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 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-EXECUTION PRICE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: FINRA Case Initiated: 10/30/2007 Case Number: 07-02385 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $10,262.55 Disposition: AWARD AGAINST PARTY Disposition Date: 05/29/2008 Sum of All Relief Awarded: $10,262.55 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 146 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $10,262.55 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 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-NO OTHER CONTROVERSY INVOLVED; TRADING DISPUTES- OTHER Arbitration Forum: FINRA Case Initiated: 04/24/2008 Case Number: 08-01197 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $25,850.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/03/2008 Sum of All Relief Awarded: $3,963.00 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 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-EXCHANGES; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: FINRA Case Initiated: 12/10/2008 Case Number: 08-03878 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $2,575.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/13/2009 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 147 www.finra.org/brokercheck User Guidance

Disposition Date: 05/13/2009 Sum of All Relief Awarded: $2,537.50 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 14 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED-NEGLIGENCE; TRADING DISPUTES-OTHER Arbitration Forum: FINRA Case Initiated: 10/21/2009 Case Number: 09-05951 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $4,644.99 Disposition: AWARD AGAINST PARTY Disposition Date: 07/01/2010 Sum of All Relief Awarded: $377.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 15 of 33 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-UNAUTHORIZED TRADING; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; TRADING DISPUTES-TRANSFERS Arbitration Forum: FINRA Case Initiated: 01/21/2010 Case Number: 09-06773 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 148 www.finra.org/brokercheck User Guidance

Case Number: 09-06773 Disputed Product Type: COMMON STOCK; MUTUAL FUNDS Sum of All Relief Requested: $1,406,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/16/2011 Sum of All Relief Awarded: $45,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 16 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED- COLLECTION Arbitration Forum: FINRA Case Initiated: 02/09/2012 Case Number: 12-00035 Disputed Product Type: COMMON STOCK; OPTIONS Sum of All Relief Requested: $930,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/14/2013 Sum of All Relief Awarded: $116,603.55 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 17 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 149 www.finra.org/brokercheck User Guidance

Arbitration Forum: FINRA Case Initiated: 02/04/2013 Case Number: 13-00279 Disputed Product Type: Sum of All Relief Requested: $15,439.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/23/2013 Sum of All Relief Awarded: $3,837.50 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 18 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-TRANSFER; OTHER-CLEARING DISPUTES; TRADING DISPUTES-TRANSFERS Arbitration Forum: FINRA Case Initiated: 09/13/2013 Case Number: 13-02641 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $2,455.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/19/2014 Sum of All Relief Awarded: $37.50 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 19 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 150 www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT RELATED-BREACH OF CONTRACT Arbitration Forum: FINRA Case Initiated: 01/27/2014 Case Number: 14-00211 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $2,252.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/13/2014 Sum of All Relief Awarded: $75.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 20 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 11/30/2015 Case Number: 15-03156 Disputed Product Type: COMMON STOCK; EXCHANGE-TRADED FUNDS; MUTUAL FUNDS; OPTIONS Sum of All Relief Requested: $1,200,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/16/2018 Sum of All Relief Awarded: $78,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 21 of 33 Reporting Source: Regulator

Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-FRAUD; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE- EXECUTIONS-OTHER Arbitration Forum: FINRA Case Initiated: 01/25/2016 Case Number: 16-00131 Disputed Product Type: COLLATERALIZED MORTGAGE OBLIGATIONS Sum of All Relief Requested: $83,982.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/13/2017 Sum of All Relief Awarded: $3,225.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 22 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY- UNAUTHORIZED TRADING; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-MARGIN CALLS; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EMPLOYMENT-LIBEL OR SLANDER; DO NOT USE- EXECUTIONS-LIMIT V MRKT ORDR Arbitration Forum: FINRA Case Initiated: 07/20/2016 Case Number: 16-01449 Disputed Product Type: COMMON STOCK; OPTIONS Sum of All Relief Requested: $49,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/12/2016

Sum of All Relief Awarded: $914.27 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 23 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-ERRORS-CHARGES Arbitration Forum: FINRA Case Initiated: 07/11/2017 Case Number: 17-01795 Disputed Product Type: COMMON STOCK Sum of All Relief Requested: $3,038.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/29/2017 Sum of All Relief Awarded: $838.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 24 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: FINRA Case Initiated: 02/23/2018 Case Number: 18-00299 Disputed Product Type: Sum of All Relief Requested: $5,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 06/27/2018 Sum of All Relief Awarded: $5,175.00 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 153 www.finra.org/brokercheck User Guidance

Sum of All Relief Awarded: $5,175.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 25 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-EXECUTIONS-OTHER; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/03/1993 Case Number: 93-02799 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $311,158.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/11/1994 Sum of All Relief Awarded: $20,329.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 26 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED- NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/16/1993 Case Number: 93-03093 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $15,000.00 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 154 www.finra.org/brokercheck User Guidance

Sum of All Relief Requested: $15,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 05/09/1994 Sum of All Relief Awarded: $3,750.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 27 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-ERRORS- CHARGES; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 11/11/1993 Case Number: 93-03861 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $1,550.00 Disposition: AWARD AGAINST PARTY Disposition Date: 02/18/1994 Sum of All Relief Awarded: $220.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 28 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 12/02/1993 Case Number: 93-04210 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; PREFERRED STOCK ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 155 www.finra.org/brokercheck User Guidance

Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; PREFERRED STOCK Sum of All Relief Requested: $10,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/29/1994 Sum of All Relief Awarded: $10,021.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 29 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-EXECUTIONS-OTHER Arbitration Forum: NASD Case Initiated: 11/14/1994 Case Number: 94-04154 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $36,496.52 Disposition: AWARD AGAINST PARTY Disposition Date: 12/07/1995 Sum of All Relief Awarded: $446.60 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 30 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-ERRORS-CHARGES; DO NOT USE-NO OTHER CONTROVERSY INVOLVED; TRADING DISPUTES-OTHER Arbitration Forum: NASD Case Initiated: 03/07/1997 ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 156 www.finra.org/brokercheck User Guidance

Case Initiated: 03/07/1997 Case Number: 97-01017 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $9,884.00 Disposition: AWARD AGAINST PARTY Disposition Date: 09/15/1997 Sum of All Relief Awarded: $500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 31 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 03/12/1998 Case Number: 98-00599 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $4,350.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/23/1998 Sum of All Relief Awarded: $4,475.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 32 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about SCOTTRADE, INC. 157 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 02/04/1999 Case Number: 99-00028 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $4,227.00 Disposition: AWARD AGAINST PARTY Disposition Date: 01/24/2000 Sum of All Relief Awarded: $1,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 33 of 33 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-MARGIN CALLS; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 10/04/1999 Case Number: 99-04007 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $2,510,197.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/28/2000 Sum of All Relief Awarded: $40,317.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

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 1 Reporting Source: Firm Policy Holder: SCOTTSDALE SECURITIES, INC. Bonding Company Name: NATIONAL UNION FIRE INSURANCE CO. Disposition: Payout Disposition Date: 10/15/1987 Payout Details: $53,000 WAS PAID OUT TO SCOTTSDALE SECURITIES, INC. ON 10/15/1987 Firm Statement SCOTTSDALE SECURITIES, INC. WAS REIMBURSED BY NATIONAL UNION INSURANCE $53,000 DUE TO A CLAIM ARISING FROM TOTAL LOSSES OF $58,000 RESULTING FROM EITHER DISHONEST OR FRAUDULENT ACTS OF 2 FORMER EMPLOYEES.

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