Download - ALPS DISTRIBUTORS, INC
BrokerCheck Report
ALPS DISTRIBUTORS, INC.
Section Title
Report Summary
Firm History
CRD# 16853
1
7
Firm Profile 2 - 6
Page(s)
Firm Operations 8 - 17
Disclosure Events 18
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ALPS DISTRIBUTORS, INC.
CRD# 16853
SEC# 8-34626
Main Office Location
1290 BROADWAY, SUITE 1000DENVER, CO 80203Regulated by FINRA Denver Office
Mailing Address
PO BOX 328DENVER, CO 80201-0328
Business Telephone Number
303-623-2577
Report Summary for this Firm
This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.
Disclosure Events
Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.
Are there events disclosed about this firm? Yes
The following types of disclosures have beenreported:
Type Count
Regulatory Event 4
Firm Profile
This firm is classified as a corporation.
This firm was formed in Colorado on 07/01/1985.
Its fiscal year ends in December.
Firm History
Information relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.
Firm Operations
Is this brokerage firm currently suspended with anyregulator? No
This firm conducts 3 types of businesses.
This firm is affiliated with financial or investmentinstitutions.
This firm does not have referral or financialarrangements with other brokers or dealers.
This firm is registered with:
• the SEC• 1 Self-Regulatory Organization• 53 U.S. states and territories
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This firm is classified as a corporation.
This firm was formed in Colorado on 07/01/1985.
CRD#
This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.
Firm Profile
Firm Names and Locations
Its fiscal year ends in December.
ALPS DISTRIBUTORS, INC.
SEC#
16853
8-34626
Main Office Location
Mailing Address
Business Telephone Number
Doing business as ALPS DISTRIBUTORS, INC.
303-623-2577
Regulated by FINRA Denver Office
1290 BROADWAY, SUITE 1000DENVER, CO 80203
PO BOX 328DENVER, CO 80201-0328
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This section provides information relating to all direct owners and executive officers of the brokerage firm.
Direct Owners and Executive Officers
Firm Profile
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
ALPS HOLDINGS, INC.
PARENT
75% or more
No
Domestic Entity
09/2005
Yes
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
KYLLO, STEPHEN JOHN
SVP; PRESIDENT; DIRECTOR; CHIEF COMPLIANCE OFFICER; PRINCIPALOPERATIONS OFFICER
Less than 5%
No
Individual
04/2020
Yes
3204474
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
Position
Position Start Date
PARSONS, ERIC T
FINOP, PRINCIPAL FINANCIAL OFFICER
Individual
06/2021
5215115
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
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Direct Owners and Executive Officers (continued)
Firm Profile
Percentage of Ownership
Is this a public reportingcompany?
Does this owner direct themanagement or policies ofthe firm?
Less than 5%
No
No
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This section provides information relating to any indirect owners of the brokerage firm.
Indirect Owners
Firm Profile
DST SYSTEMS, INC.
OWNER
ALPS HOLDINGS, INC.
75% or more
Yes
Domestic Entity
11/2011
Yes
Legal Name & CRD# (if any):
Is this a domestic or foreignentity or an individual?
Company through whichindirect ownership isestablished
Relationship to Direct Owner
Relationship Established
Percentage of Ownership
Does this owner direct themanagement or policies ofthe firm?
Is this a public reportingcompany?
SS&C TECHNOLOGIES HOLDINGS, INC.
OWNER
SS&C TECHNOLOGIES, INC.
75% or more
Yes
Domestic Entity
11/2005
Yes
Legal Name & CRD# (if any):
Is this a domestic or foreignentity or an individual?
Company through whichindirect ownership isestablished
Relationship to Direct Owner
Relationship Established
Percentage of Ownership
Does this owner direct themanagement or policies ofthe firm?
Is this a public reportingcompany?
SS&C TECHNOLOGIES, INC.
DST SYSTEMS, INC.
Domestic Entity
Legal Name & CRD# (if any):
Is this a domestic or foreignentity or an individual?
Company through whichindirect ownership isestablished
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Indirect Owners (continued)
Firm Profile
OWNER
DST SYSTEMS, INC.
75% or more
No
04/2018
Yes
Company through whichindirect ownership isestablished
Relationship to Direct Owner
Relationship Established
Percentage of Ownership
Does this owner direct themanagement or policies ofthe firm?
Is this a public reportingcompany?
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Firm History
This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.
No information reported.
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Firm Operations
RegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.
This firm is currently registered with the SEC, 1 SRO and 53 U.S. states and territories.
SEC Registration Questions
This firm is registered with the SEC as:
A broker-dealer:
A broker-dealer and government securities broker or dealer:
A government securities broker or dealer only:
This firm has ceased activity as a government securities broker or dealer:
Yes
No
No
No
Federal Regulator Status Date Effective
SEC Approved 09/25/1985
Self-Regulatory Organization Status Date Effective
FINRA Approved 12/02/1985
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Firm Operations
Registrations (continued)
U.S. States &Territories
Status Date Effective
Alabama Approved 10/04/1989
Alaska Approved 04/28/1989
Arizona Approved 05/18/1988
Arkansas Approved 09/14/1993
California Approved 04/21/1988
Colorado Approved 12/09/1985
Connecticut Limited 06/08/1989
Delaware Approved 06/06/1989
District of Columbia Approved 04/17/1993
Florida Approved 03/07/1988
Georgia Approved 04/14/1989
Hawaii Approved 04/05/1993
Idaho Approved 07/19/1988
Illinois Approved 01/15/1988
Indiana Approved 04/22/1988
Iowa Approved 04/07/1988
Kansas Approved 03/08/1989
Kentucky Approved 04/04/1989
Louisiana Approved 05/16/1994
Maine Approved 06/15/1993
Maryland Approved 04/30/1990
Massachusetts Approved 05/31/1989
Michigan Approved 03/30/1988
Minnesota Approved 02/24/1988
Mississippi Approved 06/07/1989
Missouri Approved 02/05/1993
Montana Approved 06/29/1988
Nebraska Limited 05/22/1989
Nevada Limited 11/03/1988
New Hampshire Limited 04/18/1989
New Jersey Approved 03/25/1993
New Mexico Approved 01/06/1989
New York Approved 03/16/1989
U.S. States &Territories
Status Date Effective
North Carolina Approved 04/04/1989
North Dakota Limited 05/22/1989
Ohio Approved 04/01/1988
Oklahoma Approved 09/29/1988
Oregon Approved 02/18/1987
Pennsylvania Approved 05/11/1989
Puerto Rico Approved 07/19/1995
Rhode Island Approved 04/06/1993
South Carolina Approved 04/18/1989
South Dakota Approved 04/11/1989
Tennessee Approved 03/02/1989
Texas Limited 07/13/1988
Utah Approved 08/11/1988
Vermont Approved 05/13/1993
Virgin Islands Approved 08/22/2005
Virginia Approved 02/04/1993
Washington Limited 04/15/1988
West Virginia Approved 03/19/1993
Wisconsin Approved 01/08/1988
Wyoming Approved 10/13/1988
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Firm Operations
Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.
Other Types of Business
This firm does not effect transactions in commodities, commodity futures, or commodity options.This firm does not engage in other non-securities business.
Non-Securities Business Description:
This firm currently conducts 3 types of businesses.
Types of Business
Mutual fund underwriter or sponsor
Private placements of securities
Other - ACT AS WHOLESALER AND/OR MARKETING AGENT FOR EXCHANGE-TRADED SECURITIESREGISTERED UNDER THE SECURITIES ACT'S OF 1933, 1934, 1940 AND THE PHILANTHROPY PROTECTIONACT.
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Firm Operations
Clearing Arrangements
This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).
Introducing Arrangements
This firm does not refer or introduce customers to other brokers and dealers.
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Firm Operations
Industry Arrangements
This firm does have books or records maintained by a third party.
Name: QUEST CE
Business Address: 10850 WEST PARK PLACESUITE 1000MILWAUKEE, WI 53224
Effective Date: 01/01/2015
Description: QUEST CE'S ONLINE SOFTWARE IS USED TO MANAGE AND RETAINSTHE FIRMS RECORDS IN RELATION TO REGISTRATION AND LICENSING,AML TRAINING, FIRM ELEMENT, AND ANNUAL COMPLIANCEINTERVIEWS.
Name: SCHWAB COMPLIANCE TECHNOLOGIES, INC.
Business Address: 125 S. WACKER DRIVESUITE 1150CHICAGO, IL 60606
Effective Date: 03/24/2010
Description: SCHWAB COMPLIANCE TECHNOLOGIES, INC. IS A REGULATORYCOMPLIANCE SOFTWARE PRODUCT THAT OFFERS SOFTWARE TOMAINTAIN AND TRACK PERSONAL TRADING ACCOUNTS OF ACCESSPERSONS TO COMPLY WITH THE FIRMS CODE OF ETHICS POLICY.
Name: IRON MOUNTAIN
Business Address: 5050 MOLINE STREETDENVER, CO 80239
Effective Date: 09/25/1992
Description: IRON MOUNTAIN OFFERS OFF-SITE STORAGE OF BROKER-DEALERRECORDS AT THEIR SECURE FACILITY.
Name: GLOBAL RELAY COMMUNICATIONS INC.
Business Address: 410 PARK AVENUE15TH FLOORNEW YORK, NY 10022
Effective Date: 04/22/2005
Description: GLOBAL RELAY COMMUNICATIONS, INC. WILL SERVE AS ADI'SCOMPLIANCE MESSAGE ARCHIVING AND MONITORING SERVICEPROVIDER. GLOBAL RELAY WILL IMPLEMENT ELECTRONIC STORAGEMEDIA TO STORE CERTAIN BOOKS AND RECORDS AS REQUIRED BYSEC RULE 17A-3 AND/OR 17A-4. 12©2021 FINRA. All rights reserved. Report about ALPS DISTRIBUTORS, INC.
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Firm Operations
Industry Arrangements (continued)
This firm does not have accounts, funds, or securities maintained by a third party.
This firm does not have customer accounts, funds, or securities maintained by a third party.
This firm does not have individuals who control its management or policies through agreement.
This firm does not have individuals who wholly or partly finance the firm's business.
Control Persons/Financing
GLOBAL RELAY COMMUNICATIONS, INC. WILL SERVE AS ADI'SCOMPLIANCE MESSAGE ARCHIVING AND MONITORING SERVICEPROVIDER. GLOBAL RELAY WILL IMPLEMENT ELECTRONIC STORAGEMEDIA TO STORE CERTAIN BOOKS AND RECORDS AS REQUIRED BYSEC RULE 17A-3 AND/OR 17A-4.
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Firm Operations
Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.
This firm is, directly or indirectly:
· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.
No
Yes
AUSTRALIA
Yes
10/01/2018
LEVEL 179 CASTLEREAGH STREETSYDNEY, AUSTRALIA NSW 2000
EZE SOFTWARE GROUP PTY LIMITED is under common control with the firm.
EZE SOFTWARE GROUP PTY LIMITED IS UNDER COMMON CONTROL OFTHE FIRMS INDIRECT OWNER, SS&C TECHNOLOGIES HOLDINGS, INC.
Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
No
Yes
No
10/01/2018
12 FARNSWORTH STREET6TH FLOORBOSTON, MA 02210
132246
EZE CASTLE TRANSACTION SERVICES LLC is under common control with the firm.
EZE CASTLE TRANSACTION SERVICES LLC IS UNDER COMMON CONTROLOF THE FIRMS INDIRECT OWNER, SS&C TECHNOLOGIES HOLDINGS, INC.
Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
CRD #:
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Firm Operations
Organization Affiliates (continued)
No
Yes
No
04/01/2018
21860 BURBANK BLVDSUITE 150WOODLAND HILLS, CA 91367
42404
SECOND STREET SECURITIES, INC. is under common control with the firm.
SECOND STREET SECURITIES, INC. IS UNDER COMMON CONTROL OF THEFIRMS INDIRECT OWNER, SS&C TECHNOLOGIES.
Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
CRD #:
Yes
No
No
07/31/2015
25188 GENESEE TRAIL ROADSUITE 250GOLDEN, CO 80401
135117
RED ROCKS CAPITAL LLC is under common control with the firm.
RED ROCKS CAPITAL, LLC IS UNDER COMMON CONTROL THROUGH ALPSADVISORS, INC AND DST SYSTEMS, INC.
Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
CRD #:
10/31/2011
920 2ND AVENUE SOUTHSUITE 700MINNEAPOLIS, MN 55402
23568
SS&C MARKET SERVICES, LLC is under common control with the firm.
Effective Date:
Business Address:
CRD #:
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Firm Operations
Organization Affiliates (continued)
No
Yes
No
10/31/2011
SS&C MARKET SERVICES, LLC IS UNDER COMMON CONTROL OF THEFIRMS INDIRECT OWNER, SS&C TECHNOLOGIES.
Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
No
Yes
No
03/19/2007
1290 BROADWAY, SUITE 1100DENVER, CO 80203
144464
ALPS PORTFOLIO SOLUTIONS DISTRIBUTOR, INC. is under common control with the firm.
ALPS PORTFOLIO SOLUTIONS DISTRIBUTOR, INC. IS A SUBSIDIARY OFALPS HOLDINGS, INC. ALPS HOLDINGS INC. IS ALSO THE PARENTCOMPANY TO ALPS DISTRIBUTORS, INC.
Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
CRD #:
Yes
No
No
12/18/2006
1290 BROADWAY, SUITE 1100DENVER, CO 80203
134340
ALPS ADVISORS, INC. is under common control with the firm.
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
CRD #:
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Firm Operations
Organization Affiliates (continued)
ALPS ADVISORS, INC. IS A SUBSIDIARY OF ALPS HOLDINGS, INC. ALPSHOLDINGS INC. IS ALSO THE PARENT COMPANY TO ALPS DISTRIBUTORS,INC.
Description:
This firm is not directly or indirectly, controlled by the following:
· bank holding company· national bank· state member bank of the Federal Reserve System· state non-member bank· savings bank or association· credit union· or foreign bank
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Disclosure Events
All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.
Final On AppealPending
Regulatory Event 0 4 0
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Disclosure Event Details
What you should know about reported disclosure events:
1. BrokerCheck provides details for any disclosure event that was reported in CRD. It also includessummary information regarding FINRA arbitration awards in cases where the brokerage firm wasnamed as a respondent.
2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a brokerage firm is required to disclose a
particular criminal event.3. Disclosure events in BrokerCheck reports come from different sources:
o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firmand a regulator report information for the same event, both versions of the event will appear in theBrokerCheck report. The different versions will be separated by a solid line with the reporting sourcelabeled.
4. There are different statuses and dispositions for disclosure events: o A disclosure event may have a status of pending, on appeal, or final.
§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently
being appealed.§ A "final" event has been concluded and its resolution is not subject to change.
o A final event generally has a disposition of adjudicated, settled or otherwise resolved.§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter,
or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.
§ A "settled" matter generally involves an agreement by the parties to resolve the matter.Please note that firms may choose to settle customer disputes or regulatory matters forbusiness or other reasons.
§ A "resolved" matter usually involves no payment to the customer and no finding ofwrongdoing on the part of the individual broker. Such matters generally involve customerdisputes.
5. You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure events contained in this BrokerCheck report.
Regulatory - Final
This type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission,foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation orsuspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federalcontractor.
Disclosure 1 of 4
Reporting Source: Regulator
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN ITS ROLEAS DISTRIBUTOR FOR FIVE EXCHANGE TRADED PRODUCTS (ETPS)REGISTERED UNDER THE INVESTMENT COMPANY ACT OF 1940, THE FIRMAPPROVED FIVE CREATION REQUESTS THAT DID NOT COMPLY WITH THEREQUIREMENTS FOR MANUAL ORDERS SET FORTH IN THE RELEVANTGOVERNING DOCUMENTS. THE FINDINGS STATED THAT ALTHOUGH THEAUTHORIZED PARTICIPANTS (APS) PLACING THE ORDERS PROPERLYINITIATED THE ORDER PROCESS BY TELEPHONE PRIOR TO THERELEVANT ORDER CUTOFF TIMES, THE APS DID NOT SUBMIT THEIRCOMPLETED ORDER FORMS TO THE TRANSFER AGENT VIA FACSIMILEWITHIN THE REQUIRED TIMEFRAMES. THE FIRM NONETHELESSIMPROPERLY APPROVED THESE ORDERS FOR PROCESSING, INSTEAD OFTREATING THEM AS INVALID AS WAS REQUIRED BY THE RELEVANTGOVERNING DOCUMENTS. IN ITS ROLE AS MARKETING AGENT FOR THREEETPS REGISTERED UNDER THE SECURITIES ACT OF 1933, THE FIRMAPPROVED ONE CREATION REQUEST AND TWO REDEMPTION REQUESTSTHAT DID NOT COMPLY WITH THE REQUIREMENTS FOR MANUAL ORDERSSET FORTH IN THE RELEVANT GOVERNING DOCUMENTS. THE FIRMNONETHELESS IMPROPERLY APPROVED THESE ORDERS FORPROCESSING, INSTEAD OF TREATING THEM AS INVALID AS REQUIRED BYTHE RELEVANT GOVERNING DOCUMENTS. IN ITS ROLE AS MARKETINGAGENT FOR AN ETP REGISTERED UNDER THE SECURITIES ACT OF 1933,THE FIRM APPROVED A MANUAL REDEMPTION ORDER THAT DID NOTCOMPLY WITH THE REQUIREMENTS SET FORTH IN THE RELEVANTGOVERNING DOCUMENTS. AFTER RECEIVING THE ORDER FORM NINEMINUTES LATER, THE FIRM NONETHELESS IMPROPERLY APPROVED THISORDER, INSTEAD OF TREATING THE ORDER AS INVALID AS REQUIRED BYTHE RELEVANT GOVERNING DOCUMENTS. THE FINDINGS ALSO STATEDTHAT FOR 219 ADDITIONAL MANUAL ORDERS FOR CREATIONS ORREDEMPTIONS THAT WERE PROCESSED BY THE FIRM, THE FIRM FAILEDTO MAKE AND PRESERVE ACCURATE BOOKS AND RECORDS OF SUCHORDERS AS THE ORDERS CONTAINED MISSING, UNINTELLIGIBLE ORERRONEOUS INFORMATION, INCLUDING MISSING OR INACCURATEFACSIMILE TIME STAMPS OR TIME STAMPS THAT WERE PRIOR TO ORAFTER THE TIMES THE ORDERS WERE ACTUALLY PLACED. DUE TO THESEERRORS, FINRA WAS UNABLE TO DETERMINE WHETHER ADDITIONALORDERS FOR THE CREATION OR REDEMPTION OF ETPS SHARES WEREPROCESSED WITHIN THE REQUIRED TIMEFRAMES. THE FINDINGS ALSOINCLUDED THAT THE FIRM'S SUPERVISORY SYSTEM, INCLUDING ITSWRITTEN SUPERVISORY PROCEDURES (WSPS), DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE RULES AND REGULATIONS CONCERNING THE CREATION ORREDEMPTION APPROVAL PROCESS FOR ETPS. IN PARTICULAR, THE FIRMDID NOT HAVE ADEQUATE PROCEDURES TO ENSURE THAT ORDERS FORTHE CREATION AND REDEMPTION OF ETPS ADHERED TO THE RELEVANTCUTOFF TIMES AND THAT SUCH ORDERS WERE COMPLETED WITHIN THEREQUIRED TIMEFRAMES SET FORTH IN THE RELEVANT GOVERNINGDOCUMENTS, BEFORE THEY WERE APPROVED. THE FIRM FAILED TO HAVEIN PLACE AN ADEQUATE SUPERVISORY PROCESS AND REVIEW FORCOMPARISONS BETWEEN ELECTRONIC FAX SERVER RECORDS AND THEHANDWRITTEN ORDER DOCUMENTS MAINTAINED BY ITS TRADEPROCESSING DEPARTMENT, AS WELL AS FOR REVIEW OF ANY MATERIALINCONSISTENCIES IN RECORDS OR ANY INSTANCES IN WHICH FAXORDERS WERE RECEIVED OUTSIDE OF THE STATED CUTOFF TIMES ORTIMEFRAMES OUTLINED IN THE GOVERNING DOCUMENTS. MOREOVER,THE FIRM'S WSPS REFERENCED CHECKLISTS THAT FIRM EMPLOYEESWERE REQUIRED TO COMPLETE FOR THE AUTHORIZATION OF CREATIONOR REDEMPTION REQUESTS. THE FIRM'S WSPS FAILED TO REFERENCEANY SUPERVISORY REVIEW OF THE CREATION OR REDEMPTION ORDERTAKING AND APPROVAL PROCESS FOR ETPS, AND THE FIRM DID NOTPRODUCE ADEQUATE EVIDENCE OF SUCH SUPERVISORY REVIEWS.
Current Status: Final
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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN ITS ROLEAS DISTRIBUTOR FOR FIVE EXCHANGE TRADED PRODUCTS (ETPS)REGISTERED UNDER THE INVESTMENT COMPANY ACT OF 1940, THE FIRMAPPROVED FIVE CREATION REQUESTS THAT DID NOT COMPLY WITH THEREQUIREMENTS FOR MANUAL ORDERS SET FORTH IN THE RELEVANTGOVERNING DOCUMENTS. THE FINDINGS STATED THAT ALTHOUGH THEAUTHORIZED PARTICIPANTS (APS) PLACING THE ORDERS PROPERLYINITIATED THE ORDER PROCESS BY TELEPHONE PRIOR TO THERELEVANT ORDER CUTOFF TIMES, THE APS DID NOT SUBMIT THEIRCOMPLETED ORDER FORMS TO THE TRANSFER AGENT VIA FACSIMILEWITHIN THE REQUIRED TIMEFRAMES. THE FIRM NONETHELESSIMPROPERLY APPROVED THESE ORDERS FOR PROCESSING, INSTEAD OFTREATING THEM AS INVALID AS WAS REQUIRED BY THE RELEVANTGOVERNING DOCUMENTS. IN ITS ROLE AS MARKETING AGENT FOR THREEETPS REGISTERED UNDER THE SECURITIES ACT OF 1933, THE FIRMAPPROVED ONE CREATION REQUEST AND TWO REDEMPTION REQUESTSTHAT DID NOT COMPLY WITH THE REQUIREMENTS FOR MANUAL ORDERSSET FORTH IN THE RELEVANT GOVERNING DOCUMENTS. THE FIRMNONETHELESS IMPROPERLY APPROVED THESE ORDERS FORPROCESSING, INSTEAD OF TREATING THEM AS INVALID AS REQUIRED BYTHE RELEVANT GOVERNING DOCUMENTS. IN ITS ROLE AS MARKETINGAGENT FOR AN ETP REGISTERED UNDER THE SECURITIES ACT OF 1933,THE FIRM APPROVED A MANUAL REDEMPTION ORDER THAT DID NOTCOMPLY WITH THE REQUIREMENTS SET FORTH IN THE RELEVANTGOVERNING DOCUMENTS. AFTER RECEIVING THE ORDER FORM NINEMINUTES LATER, THE FIRM NONETHELESS IMPROPERLY APPROVED THISORDER, INSTEAD OF TREATING THE ORDER AS INVALID AS REQUIRED BYTHE RELEVANT GOVERNING DOCUMENTS. THE FINDINGS ALSO STATEDTHAT FOR 219 ADDITIONAL MANUAL ORDERS FOR CREATIONS ORREDEMPTIONS THAT WERE PROCESSED BY THE FIRM, THE FIRM FAILEDTO MAKE AND PRESERVE ACCURATE BOOKS AND RECORDS OF SUCHORDERS AS THE ORDERS CONTAINED MISSING, UNINTELLIGIBLE ORERRONEOUS INFORMATION, INCLUDING MISSING OR INACCURATEFACSIMILE TIME STAMPS OR TIME STAMPS THAT WERE PRIOR TO ORAFTER THE TIMES THE ORDERS WERE ACTUALLY PLACED. DUE TO THESEERRORS, FINRA WAS UNABLE TO DETERMINE WHETHER ADDITIONALORDERS FOR THE CREATION OR REDEMPTION OF ETPS SHARES WEREPROCESSED WITHIN THE REQUIRED TIMEFRAMES. THE FINDINGS ALSOINCLUDED THAT THE FIRM'S SUPERVISORY SYSTEM, INCLUDING ITSWRITTEN SUPERVISORY PROCEDURES (WSPS), DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE RULES AND REGULATIONS CONCERNING THE CREATION ORREDEMPTION APPROVAL PROCESS FOR ETPS. IN PARTICULAR, THE FIRMDID NOT HAVE ADEQUATE PROCEDURES TO ENSURE THAT ORDERS FORTHE CREATION AND REDEMPTION OF ETPS ADHERED TO THE RELEVANTCUTOFF TIMES AND THAT SUCH ORDERS WERE COMPLETED WITHIN THEREQUIRED TIMEFRAMES SET FORTH IN THE RELEVANT GOVERNINGDOCUMENTS, BEFORE THEY WERE APPROVED. THE FIRM FAILED TO HAVEIN PLACE AN ADEQUATE SUPERVISORY PROCESS AND REVIEW FORCOMPARISONS BETWEEN ELECTRONIC FAX SERVER RECORDS AND THEHANDWRITTEN ORDER DOCUMENTS MAINTAINED BY ITS TRADEPROCESSING DEPARTMENT, AS WELL AS FOR REVIEW OF ANY MATERIALINCONSISTENCIES IN RECORDS OR ANY INSTANCES IN WHICH FAXORDERS WERE RECEIVED OUTSIDE OF THE STATED CUTOFF TIMES ORTIMEFRAMES OUTLINED IN THE GOVERNING DOCUMENTS. MOREOVER,THE FIRM'S WSPS REFERENCED CHECKLISTS THAT FIRM EMPLOYEESWERE REQUIRED TO COMPLETE FOR THE AUTHORIZATION OF CREATIONOR REDEMPTION REQUESTS. THE FIRM'S WSPS FAILED TO REFERENCEANY SUPERVISORY REVIEW OF THE CREATION OR REDEMPTION ORDERTAKING AND APPROVAL PROCESS FOR ETPS, AND THE FIRM DID NOTPRODUCE ADEQUATE EVIDENCE OF SUCH SUPERVISORY REVIEWS.
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Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 10/14/2015
Docket/Case Number: 2011029728201
Principal Product Type: Other
Other Product Type(s): EXCHANGE TRADED PRODUCTS
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN ITS ROLEAS DISTRIBUTOR FOR FIVE EXCHANGE TRADED PRODUCTS (ETPS)REGISTERED UNDER THE INVESTMENT COMPANY ACT OF 1940, THE FIRMAPPROVED FIVE CREATION REQUESTS THAT DID NOT COMPLY WITH THEREQUIREMENTS FOR MANUAL ORDERS SET FORTH IN THE RELEVANTGOVERNING DOCUMENTS. THE FINDINGS STATED THAT ALTHOUGH THEAUTHORIZED PARTICIPANTS (APS) PLACING THE ORDERS PROPERLYINITIATED THE ORDER PROCESS BY TELEPHONE PRIOR TO THERELEVANT ORDER CUTOFF TIMES, THE APS DID NOT SUBMIT THEIRCOMPLETED ORDER FORMS TO THE TRANSFER AGENT VIA FACSIMILEWITHIN THE REQUIRED TIMEFRAMES. THE FIRM NONETHELESSIMPROPERLY APPROVED THESE ORDERS FOR PROCESSING, INSTEAD OFTREATING THEM AS INVALID AS WAS REQUIRED BY THE RELEVANTGOVERNING DOCUMENTS. IN ITS ROLE AS MARKETING AGENT FOR THREEETPS REGISTERED UNDER THE SECURITIES ACT OF 1933, THE FIRMAPPROVED ONE CREATION REQUEST AND TWO REDEMPTION REQUESTSTHAT DID NOT COMPLY WITH THE REQUIREMENTS FOR MANUAL ORDERSSET FORTH IN THE RELEVANT GOVERNING DOCUMENTS. THE FIRMNONETHELESS IMPROPERLY APPROVED THESE ORDERS FORPROCESSING, INSTEAD OF TREATING THEM AS INVALID AS REQUIRED BYTHE RELEVANT GOVERNING DOCUMENTS. IN ITS ROLE AS MARKETINGAGENT FOR AN ETP REGISTERED UNDER THE SECURITIES ACT OF 1933,THE FIRM APPROVED A MANUAL REDEMPTION ORDER THAT DID NOTCOMPLY WITH THE REQUIREMENTS SET FORTH IN THE RELEVANTGOVERNING DOCUMENTS. AFTER RECEIVING THE ORDER FORM NINEMINUTES LATER, THE FIRM NONETHELESS IMPROPERLY APPROVED THISORDER, INSTEAD OF TREATING THE ORDER AS INVALID AS REQUIRED BYTHE RELEVANT GOVERNING DOCUMENTS. THE FINDINGS ALSO STATEDTHAT FOR 219 ADDITIONAL MANUAL ORDERS FOR CREATIONS ORREDEMPTIONS THAT WERE PROCESSED BY THE FIRM, THE FIRM FAILEDTO MAKE AND PRESERVE ACCURATE BOOKS AND RECORDS OF SUCHORDERS AS THE ORDERS CONTAINED MISSING, UNINTELLIGIBLE ORERRONEOUS INFORMATION, INCLUDING MISSING OR INACCURATEFACSIMILE TIME STAMPS OR TIME STAMPS THAT WERE PRIOR TO ORAFTER THE TIMES THE ORDERS WERE ACTUALLY PLACED. DUE TO THESEERRORS, FINRA WAS UNABLE TO DETERMINE WHETHER ADDITIONALORDERS FOR THE CREATION OR REDEMPTION OF ETPS SHARES WEREPROCESSED WITHIN THE REQUIRED TIMEFRAMES. THE FINDINGS ALSOINCLUDED THAT THE FIRM'S SUPERVISORY SYSTEM, INCLUDING ITSWRITTEN SUPERVISORY PROCEDURES (WSPS), DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE RULES AND REGULATIONS CONCERNING THE CREATION ORREDEMPTION APPROVAL PROCESS FOR ETPS. IN PARTICULAR, THE FIRMDID NOT HAVE ADEQUATE PROCEDURES TO ENSURE THAT ORDERS FORTHE CREATION AND REDEMPTION OF ETPS ADHERED TO THE RELEVANTCUTOFF TIMES AND THAT SUCH ORDERS WERE COMPLETED WITHIN THEREQUIRED TIMEFRAMES SET FORTH IN THE RELEVANT GOVERNINGDOCUMENTS, BEFORE THEY WERE APPROVED. THE FIRM FAILED TO HAVEIN PLACE AN ADEQUATE SUPERVISORY PROCESS AND REVIEW FORCOMPARISONS BETWEEN ELECTRONIC FAX SERVER RECORDS AND THEHANDWRITTEN ORDER DOCUMENTS MAINTAINED BY ITS TRADEPROCESSING DEPARTMENT, AS WELL AS FOR REVIEW OF ANY MATERIALINCONSISTENCIES IN RECORDS OR ANY INSTANCES IN WHICH FAXORDERS WERE RECEIVED OUTSIDE OF THE STATED CUTOFF TIMES ORTIMEFRAMES OUTLINED IN THE GOVERNING DOCUMENTS. MOREOVER,THE FIRM'S WSPS REFERENCED CHECKLISTS THAT FIRM EMPLOYEESWERE REQUIRED TO COMPLETE FOR THE AUTHORIZATION OF CREATIONOR REDEMPTION REQUESTS. THE FIRM'S WSPS FAILED TO REFERENCEANY SUPERVISORY REVIEW OF THE CREATION OR REDEMPTION ORDERTAKING AND APPROVAL PROCESS FOR ETPS, AND THE FIRM DID NOTPRODUCE ADEQUATE EVIDENCE OF SUCH SUPERVISORY REVIEWS.
Resolution Date: 10/14/2015
Resolution:
Other Sanctions Ordered: UNDERTAKING: ADDRESS THE DEFICIENCIES DESCRIBED ABOVE TOENSURE THAT THE FIRM HAS IMPLEMENTED PROCEDURES THAT AREREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THEAPPLICABLE RULES AND REGULATIONS.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $125,000.00
Acceptance, Waiver & Consent(AWC)
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UNDERTAKING: ADDRESS THE DEFICIENCIES DESCRIBED ABOVE TOENSURE THAT THE FIRM HAS IMPLEMENTED PROCEDURES THAT AREREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THEAPPLICABLE RULES AND REGULATIONS.
Sanction Details: THE FIRM WAS CENSURED, FINED $125,000 AND UNDERTAKES TOADDRESS THE DEFICIENCIES DESCRIBED ABOVE TO ENSURE THAT THEFIRM HAS IMPLEMENTED PROCEDURES THAT ARE REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE RULES ANDREGULATIONS. FINE PAID IN FULL OCTOBER 27, 2015.
iReporting Source: Firm
Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA")
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CENSURE AND AN UNDERTAKING REQUIRING ALPS DISTRIBUTORS, INC.TO SUBMIT A LETTER TO FINRA REPRESENTING THAT THE FIRM HASADDRESSED THE DEFICIENCIES SET FORTH IN THE LETTER OFACCEPTANCE, WAIVER AND CONSENT.
Date Initiated: 10/14/2015
Docket/Case Number: 20110297282-01
Principal Product Type: Other
Other Product Type(s): EXCHANGE-TRADED PRODUCT
Allegations: FINRA FOUND THAT ALPS DISTRIBUTORS, INC. ("ADI") APPROVED CERTAINMANUAL ETP ORDERS THAT DID NOT COMPLY WITH THE REQUIREMENTSFOR MANUAL ORDERS OUTLINED IN RELEVANT DOCUMENTS; ADI FAILEDTO MAKE AND PRESERVE ACCURATE BOOKS AND RECORDS REGARDINGCERTAIN MANUAL ETP ORDERS; AND ADI DID NOT HAVE ADEQUATESUPERVISORY PROCEDURES TO ENSURE THAT MANUAL ORDERS FORTHE CREATION AND REDEMPTION OF ETPS ADHERED TO AND WERECOMPLETED WITHIN THE REQUIRED TIMEFRAMES SET FORTH IN THERELEVANT DOCUMENTS.
Current Status: Final
Resolution Date: 10/14/2015
Resolution:
Other Sanctions Ordered: UNDERTAKING REQUIRING ALPS DISTRIBUTORS, INC. TO SUBMIT ALETTER TO FINRA REPRESENTING THAT THE FIRM HAS ADDRESSED THEDEFICIENCIES SET FORTH IN THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT.
Sanctions Ordered: CensureMonetary/Fine $125,000.00
Acceptance, Waiver & Consent(AWC)
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UNDERTAKING REQUIRING ALPS DISTRIBUTORS, INC. TO SUBMIT ALETTER TO FINRA REPRESENTING THAT THE FIRM HAS ADDRESSED THEDEFICIENCIES SET FORTH IN THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT.
Sanction Details: ALPS DISTRIBUTORS, INC. PAID A FINE OF $125,000 ON OCTOBER 27, 2015.NO PORTION OF THE PENALTY WAS WAIVED.
Firm Statement ON OCTOBER 14, 2015, FINRA ISSUED A NOTICE OF ACCEPTANCE OF ALETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") IN CONNECTIONWITH ITS REVIEW OF ADI'S ROLE IN THE CREATION AND REDEMPTION OFCERTAIN EXCHANGE TRADED PRODUCTS ("ETPS") DURING A 60 DAYPERIOD IN 2011. ADI CONSENTED TO THE ENTRY OF THE AWC WITHOUTADMITTING OR DENYING THE FINDINGS. AS SET FORTH IN THE AWC,FINRA FOUND THAT: ADI APPROVED CERTAIN MANUAL ETP ORDERS THATDID NOT COMPLY WITH THE REQUIREMENTS FOR MANUAL ORDERSOUTLINED IN RELEVANT DOCUMENTS; ADI FAILED TO MAKE ANDPRESERVE ACCURATE BOOKS AND RECORDS REGARDING CERTAINMANUAL ETP ORDERS; AND ADI DID NOT HAVE ADEQUATE SUPERVISORYPROCEDURES TO ENSURE THAT MANUAL ORDERS FOR THE CREATIONAND REDEMPTION OF ETPS ADHERED TO AND WERE COMPLETED WITHINTHE REQUIRED TIMEFRAMES SET FORTH IN THE RELEVANT DOCUMENTS.IN CONNECTION WITH THE SETTLEMENT, ADI AGREED TO A CENSURE, AFINE OF $125,000 AND AN UNDERTAKING REQUIRING ADI TO SUBMIT ALETTER TO FINRA REPRESENTING THAT THE FIRM HAS ADDRESSED THEDEFICIENCIES SET FORTH IN THE AWC.
Disclosure 2 of 4
i
Reporting Source: Regulator
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 04/16/1998
Docket/Case Number: C3A980014
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
Resolution Date: 04/16/1998
Resolution: Acceptance, Waiver & Consent(AWC)
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Resolution Date: 04/16/1998
Other Sanctions Ordered:
Sanction Details:
Regulator Statement ON APRIL 16, 1998, DISTRICT NO. 3 NOTIFIED RESPONDENTS ALPSMUTUAL FUNDS SERVICES AND THOMAS A. CARTER THAT THE LETTER OFACCEPTANCE, WAIVER AND CONSENT NO. C3A980014 WAS ACCEPTED;THEREFORE, THEY ARE CENSURED AND FINED $5,000, JOINTLY ANDSEVERALLY - (NASD RULE 2110 - RESPONDENT MEMBER, ACTINGTHROUGHRESPONDENT CARTER, CONDUCTED A SECURITIES BUSINESS WHILEFAILING TO MAINTAIN THE MINIMUM NET CAPITAL REQUIRED BY SECRULE 15c3-1).
**$5,000.00 PAID J&S ON 5/14/98, INVOICE #98-3A-388**
Sanctions Ordered: CensureMonetary/Fine $5,000.00
iReporting Source: Firm
Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
NONE
Date Initiated: 12/05/1997
Docket/Case Number: C3A980014
Principal Product Type: Mutual Fund(s)
Other Product Type(s):
Allegations: IT WAS ALLEGED ON JULY 31, AUG. 29, SEPT. 30, AND NOV. 30,1997,APPLICANT, ACTING THROUGH MR. CARTER, CONDUCTEDSECURITIES BUSINESS WHILE FAILING TO MAINTAIN MINIMUM NETCAPITAL REQUIREMENTS UNDER SEC RULE 15C3-1 AND NASD RULE 2110.
Current Status: Final
Resolution Date: 03/05/1998
Resolution:
Other Sanctions Ordered:
Sanctions Ordered: CensureMonetary/Fine $5,000.00
Acceptance, Waiver & Consent(AWC)
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Other Sanctions Ordered:
Sanction Details: ALPS AGREED TO THE FOLLOWING ACTIONS: 1) CFO WILL OBTAIN THESERIES 28 FINOP LICENSE; 2) A NEW ATTORNEY HAS BEEN HIRED TOASSIST WITH BD COMPLIANCE; 3) A NEW CPA HAS BEEN HIRED ASCONTROLLER; 4) NEW NET CAPITAL REVIEW PROCEDURE IS IN PLACE; 5)ALPS PRINCIPALS RE-EDUCATED ON CAPITAL IMPLICATIONS OFTRANSACTIONS AND HAVE COMMITTED TO CAPITAL INJECTIONS IFNECESSARY.
Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, ALPS SUBMITTEDTO THE NASD AN AWC FOR THE ALLEGED VIOLATIONS. ALPS AGREED TO ACENSURE, A $5,000 FINE AND TO TAKE CORRECTIVE ACTION DETAILEDABOVE.
Disclosure 3 of 4
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Reporting Source: Regulator
Initiated By: MT SECURITIES DEPT.
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 08/04/1992
Docket/Case Number: 4-7-92-8
URL for Regulatory Action:
Principal Product Type:
Other Product Type(s):
Allegations: VIOLATIONS OF SECURITIES REGISTRATIONPROVISIONS OF MT SECURITIES ACT.
Current Status: Final
Resolution Date: 08/04/1992
Resolution:
Other Sanctions Ordered:
Sanction Details: CONSENT AGREEMENT ENTERED. WITHOUT ADMITTING ORDENYING ALLEGATIONS, RESPONDENTS AGREED TO ABIDE BY THE MTSECURITES ACT IN THE FUTURE, OFFER RESCISSION TO MT INVESTORS,AND PAY FINE OF $5,000.00
Sanctions Ordered: Monetary/Fine $5,000.00
Consent
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CONSENT AGREEMENT ENTERED. WITHOUT ADMITTING ORDENYING ALLEGATIONS, RESPONDENTS AGREED TO ABIDE BY THE MTSECURITES ACT IN THE FUTURE, OFFER RESCISSION TO MT INVESTORS,AND PAY FINE OF $5,000.00
Regulator Statement Not Provided
iReporting Source: Firm
Initiated By: MONTANA STATE AUDITOR
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
CONSENT AGREEMENT WAS SIGNED BY ALL PARTIES. ALPS PAID ANADMINISTRATIVE FINE OF $5,000 AND AN OFFER OF RESCISSIONWASMADE TO ALL AFFECTED SHAREHOLDERS IN ACCORDANCE WITH STATEPROCEDURES.
Date Initiated: 01/30/1992
Docket/Case Number: UNKNOWN
Principal Product Type: Mutual Fund(s)
Other Product Type(s):
Allegations: AS ADMINISTRATOR OF THE WESTCORE TRUST MUTUAL FUNDS,APPLICANT WAS REPONSIBLE FOR ALL BLUE SKY RENEWALS. SHARES OFAN UNREGISTERED MUTUAL FUND WERE INADVERTENTLY SOLD DUE TO AFAILURE TO RENEW IN MONTANA ON A TIMELY BASIS. THE FAILURE TORENEW WAS THE RESULT OF AN INADVERTENT CLERICAL OVERSIGHTAND WAS BROUGHT TO THE ATTENTION OF THE STATE OF MONTANAUPON DISCOVERY.
Current Status: Final
Resolution Date: 08/04/1992
Resolution:
Other Sanctions Ordered: NONE.
Sanction Details: CONSENT AGREEMENT WAS SIGNED BY ALL PARTIES, ALPS PAID ANADMINISTRATIVE FINE OF $5,000 AND ALL AFFECTED SHAREHOLDERSWERE MADE WHOLE PLUS 10%. ALPS ALSO PAID WESTCORE'S LOSSES INCONNECTION WITH THE RESCISSION OFFER.
Sanctions Ordered: Monetary/Fine $5,000.00
Consent
Disclosure 4 of 4
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Reporting Source: Regulator
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Initiated By: MARYLAND
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 01/30/1990
Docket/Case Number: BD-90-0076
URL for Regulatory Action:
Principal Product Type:
Other Product Type(s):
Allegations:
Current Status: Final
Resolution Date: 03/14/1990
Resolution:
Other Sanctions Ordered:
Sanction Details:
Regulator Statement 4/4/90-FORM U6 (8036-07890) DISCLOSES: CRD ROSTER REFLECTS NOAGENT REGISTERED AS OF JANUARY 2, 1990. ORDER TO SHOW CAUSEANDSUMMARY SUSPENSION ISSUED ON JANUARY 30, 1990, VIOLATION OFSECTION 11-412(a)(2) OF THE ACT. ALPS SECURITIES, INC. DID NOTREQUEST A HEARING. FINAL ORDER OF REVOCATION ISSUED MARCH 14,1990. DOCKET/CASE NUMBER NOT APPLICABLE, DATED MARCH 14, 1990.
^5/17/90, AMENDED FORM U-6 (JDS #8048-12990) DISCLOSES: ALPSSECURITIES, INC., HAD AN ORDER TO SHOW CAUSE AND SUMMARYSUSPENSION ISSUED ON JANUARY 30, 1990, FOR FAILURE TO HAVE ANAGENT REGISTERED, VIOLATION OF SEC. 11-412(a)(2) OF THE ACT.ALPS SECURITIES, INC. DID NOT REGISTER AN AGENT OR REQUEST AHEARING. FINAL ORDER OF REVOCATION ISSUE MARCH 14, 1990. ALPSSECURITIES, INC. WAS FINED $1,000.00 FOR ADMINISTRATIVE COSTSAND THE BROKER-DEALER REGISTRATION WAS REINSTATED APRIL 34,1990. DOCKET/CASE NO. BD-90-0076, DATED APRIL 30, 1990, MARYLANDDIVISION OF SECURITIES.
Sanctions Ordered: Monetary/Fine $1,000.00Revocation/Expulsion/Denial
Decision
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iReporting Source: Firm
Initiated By: STATE OF MARYLAND, DIVISION OF SECURITIES
Principal Sanction(s)/ReliefSought:
Revocation
Other Sanction(s)/ReliefSought:
NONE.
Date Initiated: 01/30/1990
Docket/Case Number: N/A
Principal Product Type: Mutual Fund(s)
Other Product Type(s):
Allegations: FAILURE OF APPLICANT TO REGISTER AT LEAST ONE AGENT WITH THEDIVISION IN ASSOCIATION WITH APPLICANT'S REGISTRATION AS ABROKER-DEALER WITH THE DIVISION.
Current Status: Final
Resolution Date: 05/01/1990
Resolution:
Other Sanctions Ordered: NONE
Sanction Details: APPLICANT'S BROKER-DEALER REGISTRATION WAS REVOED INMARYLAND EFFECTIVE MARCH 14, 1990. REGISTRATION WAS REINSTATEDEFFECTIVE MAY 1,1990.`
Firm Statement APPLICANT SUBMITTED AN UNDERTAKING TO THE DIVISION CERTIFYINGTHAT IT WOULD COMPLY WITH PROCEDURES ENACTED TO PREVENTFUTURE VIOLATIONS OF THE MARYLAND SECURITIES ACT. INREPONSE,THE DIVISION OF SECURITIES ISSUED AN ORDER OF REINSTATEMENT OFAPPLICANT'S BROKER-DEALER REGISTRAION.
Sanctions Ordered: Revocation/Expulsion/Denial
Settled
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