m holdings securities, inc. · 2020-06-30 · m holdings securities, inc. crd# 43285 sec# 8-50214...
TRANSCRIPT
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BrokerCheck Report
M HOLDINGS SECURITIES, INC.
Section Title
Report Summary
Firm History
CRD# 43285
1
9
Firm Profile 2 - 8
Page(s)
Firm Operations 10 - 21
Disclosure Events 22
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M HOLDINGS SECURITIES, INC.
CRD# 43285
SEC# 8-50214
Main Office Location
1125 N.W. COUCH STREETSUITE 900PORTLAND, OR 97209Regulated by FINRA Denver Office
Mailing Address
P.O. BOX 2207PORTLAND, OR 97208-2207
This firm is a brokerage firm and an investmentadviser firm. For more information aboutinvestment adviser firms, visit the SEC'sInvestment Adviser Public Disclosure website at:
Business Telephone Number
800-656-6960
https://www.adviserinfo.sec.gov
Report Summary for this Firm
This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.
Disclosure Events
Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.
Are there events disclosed about this firm? Yes
The following types of disclosures have beenreported:
Type Count
Regulatory Event 4
Firm Profile
This firm is classified as a corporation.
This firm was formed in Oregon on 03/21/1997.
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 9 types of businesses.
This firm is affiliated with financial or investmentinstitutions.
This firm has referral or financial arrangements withother brokers or dealers.
This firm is registered with:
• the SEC• 1 Self-Regulatory Organization• 53 U.S. states and territories
www.finra.org/brokercheck User Guidance
1©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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This firm is classified as a corporation.
This firm was formed in Oregon on 03/21/1997.
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.
M HOLDINGS SECURITIES, INC.
SEC#
43285
8-50214
Main Office Location
Mailing Address
Business Telephone Number
Doing business as M HOLDINGS SECURITIES, INC.
800-656-6960
Regulated by FINRA Denver Office
1125 N.W. COUCH STREETSUITE 900PORTLAND, OR 97209
P.O. BOX 2207PORTLAND, OR 97208-2207
2©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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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?
M FINANCIAL HOLDINGS INCORPORATED
EQUITY OWNER
75% or more
No
Domestic Entity
03/1997
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?
BECKLEY, DEAN JAMES
CHIEF INFORMATION SECURITY OFFICER
Less than 5%
No
Individual
03/2019
No
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
Position
Percentage of Ownership
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
DOUGHERTY, CASEY WILLIAM
CHIEF COMPLIANCE OFFICER
Less than 5%
Individual
05/2020
Yes
4031339
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
3©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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Direct Owners and Executive Officers (continued)
Firm Profile
Is this a public reportingcompany?
Does this owner direct themanagement or policies ofthe firm?
No
Yes
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
KRAMER, ANDREW JOHN
DIRECTOR
Less than 5%
No
Individual
02/2020
No
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?
KUKAR, KEVIN BRUCE
TREASURER
Less than 5%
No
Individual
06/2006
Yes
4605225
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
Position
LUNDIN, STEPHEN ALEXANDER
DIRECTOR
IndividualIs this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
4©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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Direct Owners and Executive Officers (continued)
Firm Profile
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
DIRECTOR
Less than 5%
No
02/2020
No
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
MCNAMARA-FENESY, BRIDGET MARY
PRESIDENT AND CHIEF EXECUTIVE OFFICER
Less than 5%
No
Individual
04/2017
Yes
2233939
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?
PIMENTA, VALERIE RACHELLE BOLCH
VP, COO
Less than 5%
No
Individual
06/2017
Yes
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
5©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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Direct Owners and Executive Officers (continued)
Firm Profile
Position
Percentage of Ownership
Is this a public reportingcompany?
Position Start Date
Does this owner direct themanagement or policies ofthe firm?
ROGERS, MARIA RENEE
FINANCIAL PRINCIPAL
Less than 5%
No
Individual
09/2007
No
2442526
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?
SCHUTT, DAVID WALTER
SECRETARY
Less than 5%
No
Individual
02/2004
No
2736264
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
Position
Percentage of Ownership
Position Start Date
STRUTHERS, JEFF P
VICE PRESIDENT
Less than 5%
Individual
02/2020
4705114
Is this a domestic or foreignentity or an individual?
Legal Name & CRD# (if any):
6©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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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
7©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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This section provides information relating to any indirect owners of the brokerage firm.
Indirect Owners
Firm Profile
No information reported.
8©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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Firm History
This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.
No information reported.
9©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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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
Yes
No
No
Federal Regulator Status Date Effective
SEC Approved 10/30/1997
Self-Regulatory Organization Status Date Effective
FINRA Approved 10/30/1997
10©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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Firm Operations
Registrations (continued)
U.S. States &Territories
Status Date Effective
Alabama Approved 08/17/1998
Alaska Approved 07/23/1998
Arizona Approved 05/29/1998
Arkansas Approved 11/10/1998
California Approved 05/19/1998
Colorado Approved 05/29/1998
Connecticut Approved 06/12/1998
Delaware Approved 02/25/1999
District of Columbia Approved 08/31/1998
Florida Approved 07/01/1998
Georgia Approved 07/31/1998
Hawaii Approved 08/31/1998
Idaho Approved 05/21/1998
Illinois Approved 06/10/1998
Indiana Approved 04/07/1999
Iowa Approved 08/03/1998
Kansas Approved 09/09/1998
Kentucky Approved 07/14/1998
Louisiana Approved 02/26/1999
Maine Approved 10/16/1998
Maryland Approved 06/17/1998
Massachusetts Approved 06/26/1998
Michigan Approved 09/25/1998
Minnesota Approved 11/02/1999
Mississippi Approved 09/30/1998
Missouri Approved 04/23/1999
Montana Approved 05/20/1998
Nebraska Approved 07/14/1998
Nevada Approved 06/08/1998
New Hampshire Approved 07/30/1999
New Jersey Approved 10/21/1998
New Mexico Approved 05/28/1998
New York Approved 08/14/1998
U.S. States &Territories
Status Date Effective
North Carolina Approved 07/31/1998
North Dakota Approved 08/20/1998
Ohio Approved 08/13/1998
Oklahoma Approved 08/04/1998
Oregon Approved 10/30/1997
Pennsylvania Approved 07/14/1998
Puerto Rico Approved 04/12/2011
Rhode Island Approved 08/18/1998
South Carolina Approved 08/10/1998
South Dakota Approved 08/04/1998
Tennessee Approved 09/02/1998
Texas Approved 09/09/1998
Utah Approved 05/26/1998
Vermont Approved 09/02/1998
Virgin Islands Approved 06/15/2009
Virginia Approved 07/17/1998
Washington Approved 05/20/1998
West Virginia Approved 07/31/1998
Wisconsin Approved 08/05/1998
Wyoming Approved 08/04/1998
11©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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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 engage in other non-securities business.
Non-Securities Business Description: INVESTMENT ADVISORY BUSINESS APPLICANT IS ALSO REGISTEREDWITH SEC AS AN INVESTMENT ADVISOR AND PROVIDES ADVISORYSERVICES TO CLIENTS.
This firm currently conducts 9 types of businesses.
Types of Business
Broker or dealer retailing corporate equity securities over-the-counter
Broker or dealer selling corporate debt securities
Mutual fund retailer
U S. government securities broker
Municipal securities broker
Broker or dealer selling variable life insurance or annuities
Put and call broker or dealer or option writer
Investment advisory services
Private placements of securities
12©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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Firm Operations
Clearing Arrangements
This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).
Introducing Arrangements
This firm does refer or introduce customers to other brokers and dealers.
Name: PERSHING LLC
Business Address: 1 PERSHING PLAZAJERSEY CITY, NJ 07399
CRD #: 7560
Effective Date: 09/06/1999
Description: APPLICANT INTRODUCES ITS GENERAL SECURITIES CUSTOMERACCOUNTS TO PERSHING, LLC ("PERSHING") ON A FULLY DISCLOSEDBASIS FOR EXECUTIION, SETTLEMENT AND CLEARANCE OFTRANSACTIONS. ALL CUSTOMER FUNDS AND SECURITIES ARE HELDBY PERSHING. ANY CUSTOMER FUNDS OR SECURITIES DELIVERED TOAPPLICANT ARE PROMPTLY DELIVERED TO PERSHING.
13©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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Firm Operations
Industry Arrangements
This firm does have books or records maintained by a third party.
Name: WORLD SOFTWARE CORPORATION
Business Address: 266 HARRISTOWN ROADSUITE 201GLEN ROCK, NJ 07452
Effective Date: 02/01/2016
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH WORLDSOFTWARE CORPORATION TO PROVIDE A DOCUMENT MANAGMENTSOLUTION.
Name: RED TAIL TECHNOLOGY
Business Address: 11285 PYRITES WAYGOLD RIVER, CA 95670
Effective Date: 09/15/2015
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH RED TAILTECHNOLOGY TO PROVIDE A CRM TO HOUSE RELATED BOOKS ANDRECORDS.
Name: ONE SOURCE DOCUMENT SOLUTIONS
Business Address: 311-D POMONA DRIVEGREENSBORO, NC 27407
Effective Date: 06/19/2012
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH ONESOURCE DOCUMENT SOLUTIONS TO PROVIDE A DOCUMENTMANAGMENT SOLUTION.
Name: NETDOCUMENTS.COM
Business Address: 2500 EXECUTIVE PARKWAYSUITE 300LEHI, UT 84043
Effective Date: 02/01/2012
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITHNETDOCUMENTS.COM TO PROVIDE A DOCUMENT MANAGMENTSOLUTION.
Name: MUNIMETRIX
Business Address: 1575 DELUCCHI AVENUESUITE 223RENO, NV 89502-6582
14©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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Firm Operations
Industry Arrangements (continued)
Business Address: 1575 DELUCCHI AVENUESUITE 223RENO, NV 89502-6582
Effective Date: 03/14/2016
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITHMUNIMETRIX TO PROVIDE A DOCUMENT MANAGMENT SOLUTION.
Name: MOSAIC
Business Address: 3250-H PEACHTREE CORNERS CIRCLENORCROSS, GA 30092
Effective Date: 05/31/2011
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH MOSAIC TOPROVIDE A DOCUMENT MANAGMENT SOLUTION.
Name: KNOWLEDGELAKE
Business Address: 6 CITY PLACESUITE 500SAINT LOUIS, MO 63141
Effective Date: 11/11/2013
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITHKNOWLEDGELAKE TO PROVIDE A DOCUMENT MANAGMENT SOLUTION.
Name: VERTAFORTE
Business Address: 999 18TH STREETDENVER, CO 80202
Effective Date: 01/15/2007
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITHVERTAFORTE TO PROVIDE A DOCUMENT MANAGMENT SOLUTION.
Name: DOCUWARE CORPORATION
Business Address: 4 CROTTY LANESUITE 200NEW WINDSOR, NY 12553
Effective Date: 04/22/2009
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH DOCUWARECORPORATION TO PROVIDE A DOCUMENT MANAGMENT SOLUTION.
Name: EGNYTE
Business Address: 1350 WEST MIDDLEFIELD ROADMOUNTAIN VIEW, CA 94043 15©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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Firm Operations
Industry Arrangements (continued)
Business Address: 1350 WEST MIDDLEFIELD ROADMOUNTAIN VIEW, CA 94043
Effective Date: 09/13/2015
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH EGNYTE TOPROVIDE A DOCUMENT MANAGMENT AND GOVERNANCE SOLUTION.
Name: EFILE CABINET, INC.
Business Address: 2989 WEST MAPLE LOOP DRIVESUITE 300LEHI, UT 84043
Effective Date: 02/19/2014
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH EFILECABINET, INC., TO PROVIDE A DOCUMENT MANAGMENT SOLUTION.
Name: DOCUPACE TECHNOLOGIES, INC.
Business Address: 2001 SOUTH BARRINGTON AVENUESUITE 215LOS ANGELES, CA 90025
Effective Date: 07/23/2014
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH DOCUPACETECHNOLOGIES, INC., TO PROVIDE A DOCUMENT MANAGMENTSOLUTION.
Name: DOCS IMAGING, LLC
Business Address: 7547 MENTOR DRIVESUITE 302MENTOR, OH 44060
Effective Date: 09/17/2013
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH DOCSIMAGING, LLC TO PROVIDE A DOCUMENT MANAGEMENT SOLUTION.
Name: COMPETITIVE ADVANTAGE SYSTEMS, LLC
Business Address: 740 ALFRED NOBEL DRIVEHERCULES, CA 94547
Effective Date: 05/10/2011
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITHCOMPETITIVE ADVANTAGE SYSTEMS, LLC TO PROVIDE INFORMATIONTECHOLOGY SERVICES.
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Firm Operations
Industry Arrangements (continued)
Name: CITRIX
Business Address: 701 CORPORATE CENTERSUITE 300RALEIGH, NC 27607
Effective Date: 06/01/2015
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH CITRIX TOPROVIDE SHAREFILE SOLUTION.
Name: CABINET, INC.
Business Address: 500 LANIER ROADSUITE BMADISON, AL 35758
Effective Date: 07/09/2007
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH CABINET,INC., TO PROVIDE DOCUMENT MANAGEMENT SYSTEMS.
Name: BOX, INC.
Business Address: 900 JEFFERSON AVENUEREDWOOD CITY, CA 94063
Effective Date: 01/03/2019
Description: M HOLDINGS SECURITIES, INC., HAS AN AGREEMENT WITH BOX, INC.,TO PROVIDE GOVERNANCE DOCUMENT MANAGEMENT SOFTWARE.
Name: REGED, INC.
Business Address: 2100 GATEWAY CENTRE BLVD., SUITE 200MORRISVILLE, NC 27560
Effective Date: 10/01/2018
Description: REGED, INC. IS A COMPLIANCE SUPPORT SYSTEM VENDOR WHO ALSOPROVIDES STORAGE FOR RELATED M HOLDINGS SECURITIES, INC.BOOKS AND RECORDS.
Name: GLOBAL RELAY COMMUNICATIONS, INC.
Business Address: 220 CAMBIE STREET2ND FLOORVANCOUVER, BC V6B 2M9, CANADA V6B 2M9
Effective Date: 08/31/2016
Description: ELECTRONIC CORRESPONDENCE IS MAINTAINED BY GLOBAL RELAYCOMMUNICATIONS, INC. IN ACCORDANCE WITH APPLICABLE BOOKS &RECORDS RULES.
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Firm Operations
Industry Arrangements (continued)
This firm does have accounts, funds, or securities maintained by a third party.
This firm does have customer accounts, funds, or securities maintained by a third party.
ELECTRONIC CORRESPONDENCE IS MAINTAINED BY GLOBAL RELAYCOMMUNICATIONS, INC. IN ACCORDANCE WITH APPLICABLE BOOKS &RECORDS RULES.
Name: FINANCIAL DATABASE SERVICES
Business Address: 9920 PACIFIC HEIGHTS BLVD#430SAN DIEGO, CA 92121
Effective Date: 01/01/2000
Description: FINANCIAL DATABASE SERVICES (FDS) IS THE VENDOR THATPROVIDES THE SOFTWARE AND STORAGE FOR M HOLDINGSSECURITIES BOOKS AND RECORDS.
Name: PERSHING LLC
Business Address: 1 PERSHING PLAZAJERSEY CITY, NJ 07399
CRD #: 7560
Effective Date: 09/06/1999
Description: PURSUANT TO THE FULLY DISCLOSED CLEARING AGMT PERSHINGMAINTAINS STOCK RECORDS & OTHER PRESCRIBED BOOKS &RECORDS OF ALL TRANSACTIONS EXECUTED OR CLEARED THROUGHIT. ALSO APPLICANT HAS AGMTS WITH FIRMS THAT ARE "MEMBERFIRMS" OF APPLICANT'S PARENT CO TO MAINTAIN CERTAIN OFAPPLICANT'S BOOKS & RECORDS, INCLUDING CUSTOMER FILES, INSUCH FORM AS REQUIRED BY APPLICANT. THE LOCATIONS OF SUCHMEMBER FIRMS AT WHICH APPLICANT'S BOOKS AND RECORDS AREMAINTAINED AT EITHER APPLICANT'S BRANCH OR NON-BRANCHLOCATION.
Name: PERSHING LLC
Business Address: 1 PERSHING PLAZAJERSEY CITY, NJ 07399
CRD #: 7560
Effective Date: 09/06/1999
Description: PERSHING MAINTAINS APPLICANT'S COMMISSION ACCOUNT IN WHICHCOMMISSIONS PAID BY CUSTOMERS ARE HELD UNTIL PAID TOAPPLICANT BY PERSHING.
Name: PERSHING LLC
CRD #: 756018©2020 FINRA. All rights reserved. Report about M HOLDINGS SECURITIES, INC.
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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.
Control Persons/Financing
Business Address: 1 PERSHING PLAZAJERSEY CITY, NJ 07399
CRD #: 7560
Effective Date: 09/06/1999
Description: ACCOUNTS, FUNDS AND SECURITIES OF CUSTOMERS OF APPLICANTARE HELD BY PERSHING PURSUANT TO THE FULLY DISCLOSEDCLEARING AGREEMENT.
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Firm Operations
Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.
This firm is, directly or indirectly:
· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.
Yes
No
No
06/20/2005
1125 NW COUCH ST., STE. 900PORTLAND, OR 97209
136694
M FINANCIAL ASSET MANAGEMENT, INC. is under common control with the firm.
BOTH M FINANCIAL ASSET MANAGEMENT, INC. AND M HOLDINGSSECURITIES, INC. ARE EACH WHOLLY OWNED SUBSIDIARIES OF MFINANCIAL HOLDINGS INCORPORATED.
Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
CRD #:
No
Yes
No
06/20/2005
1125 N.W. COUCH ST., STE. 900PORTLAND, OR 97209
139304
M FINANCIAL SECURITIES MARKETING, INC. is under common control with the firm.
BOTH M FINANCIAL SECURITIES MARKETING, INC. AND M HOLDINGSSECURITIES, INC. ARE EACH WHOLLY OWNED SUBSIDIARIES OF MFINANCIAL HOLDINGS INCORPORATED.
Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
CRD #:
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Firm Operations
Organization Affiliates (continued)BOTH M FINANCIAL SECURITIES MARKETING, INC. AND M HOLDINGSSECURITIES, INC. ARE EACH WHOLLY OWNED SUBSIDIARIES OF MFINANCIAL HOLDINGS INCORPORATED.
Description:
Yes
No
No
03/21/1997
1125 NW COUCH ST., STE. 900PORTLAND, OR 97209
M FINANCIAL INVESTMENT ADVISERS, INC. is under common control with the firm.
M HOLDINGS SECURITIES, INC. AND M FINANCIAL INVESTMENT ADVISERS,INC. ARE EACH WHOLLY OWNED SUBSIDIARIES OF M FINANCIALHOLDINGS INCORPORATED.
Description:
Investment AdvisoryActivities:
Securities Activities:
Country:
Foreign Entity:
Effective Date:
Business Address:
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: IA RELEASE 5193, MARCH 11, 2019: THE SECURITIES AND EXCHANGECOMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THATPUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BEINSTITUTED AGAINST M HOLDINGS SECURITIES, INC. ("RESPONDENT"). ONTHE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THECOMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OFBREACHES OF FIDUCIARY DUTY AND INADEQUATE DISCLOSURES BY THERESPONDENT IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASSSELECTION PRACTICES AND THE FEES IT RECEIVED. AT TIMES DURINGTHE RELEVANT PERIOD, RESPONDENT PURCHASED, RECOMMENDED, ORHELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THATCHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THESAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. RESPONDENTRECEIVED 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS.RESPONDENT FAILED TO DISCLOSE IN ITS FORM ADV OR OTHERWISE THECONFLICTS OF INTEREST RELATED TO (A) ITS RECEIPT OF 12B-1 FEES,AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAYSUCH FEES. DURING THE RELEVANT PERIOD, RESPONDENT RECEIVED12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH MUTUALFUND SHARE CLASSES. AS A RESULT OF THE CONDUCT, RESPONDENTWILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT.
Current Status: Final
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Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
N/A
Date Initiated: 03/11/2019
Docket/Case Number: 3-19096
Principal Product Type: Mutual Fund(s)
Other Product Type(s):
Allegations: IA RELEASE 5193, MARCH 11, 2019: THE SECURITIES AND EXCHANGECOMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THATPUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BEINSTITUTED AGAINST M HOLDINGS SECURITIES, INC. ("RESPONDENT"). ONTHE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THECOMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OFBREACHES OF FIDUCIARY DUTY AND INADEQUATE DISCLOSURES BY THERESPONDENT IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASSSELECTION PRACTICES AND THE FEES IT RECEIVED. AT TIMES DURINGTHE RELEVANT PERIOD, RESPONDENT PURCHASED, RECOMMENDED, ORHELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THATCHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THESAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. RESPONDENTRECEIVED 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS.RESPONDENT FAILED TO DISCLOSE IN ITS FORM ADV OR OTHERWISE THECONFLICTS OF INTEREST RELATED TO (A) ITS RECEIPT OF 12B-1 FEES,AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAYSUCH FEES. DURING THE RELEVANT PERIOD, RESPONDENT RECEIVED12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH MUTUALFUND SHARE CLASSES. AS A RESULT OF THE CONDUCT, RESPONDENTWILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT.
Resolution Date: 03/11/2019
Resolution:
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
Yes
Sanctions Ordered: CensureDisgorgement/RestitutionCease and Desist/Injunction
Order
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Other Sanctions Ordered: UNDERTAKINGS AND PREJUDGMENT INTEREST
Sanction Details: THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED,SHALL PAY DISGORGEMENT OF $923,202.35 AND PREJUDGMENT INTERESTOF $98,846.14, AND SHALL COMPLY WITH THE UNDERTAKINGSENUMERATED IN THE OFFER OF SETTLEMENT.
Regulator Statement RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THECOMMISSION HAS DETERMINED TO ACCEPT. IN VIEW OF THE FOREGOING,THE COMMISSION DEEMS IT APPROPRIATE IN THE PUBLIC INTEREST TOIMPOSE THE SANCTIONS AGREED TO IN THE RESPONDENT'S OFFER.RESPONDENT SELF-REPORTED TO THE COMMISSION THE VIOLATIONSDISCUSSED IN THIS ORDER PURSUANT TO THE DIVISION OFENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE("SCSD INITIATIVE"). ACCORDINGLY, THIS ORDER AND RESPONDENT'SOFFER ARE BASED ON THE INFORMATION SELF-REPORTED BYRESPONDENT.
Sanctions Ordered: CensureDisgorgement/RestitutionCease and Desist/Injunction
iReporting Source: Firm
Initiated By: SECURITIES AND EXCHANGE COMMISSION
Allegations: ON MARCH 11, 2019, THE SECURITIES AND EXCHANGE COMMISSION (SEC)PUBLISHED IA RELEASE NO. 5193, AN ORDER INSTITUTINGADMINISTRATIVE AND CEASE AND DESIST PROCEEDINGS, PURSUANT TOSECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940(ADVISERS ACT), AGAINST M HOLDINGS SECURITIES, INC. (RESPONDENT).RESPONDENT SELF-REPORTED THE VIOLATIONS TO THE SEC. THEPROCEEDINGS ARISE OUT OF BREACHES OF FIDUCIARY DUTY ANDINADEQUATE DISCLOSURES BY RESPONDENT IN CONNECTION WITH ITSMUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE 12B-1FEES IT AND/OR ITS ASSOCIATED PERSONS RECEIVED. AT TIMES DURINGTHE RELEVANT PERIOD, RESPONDENT PURCHASED FOR, RECOMMENDEDTO, OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSESTHAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSESOF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE.RESPONDENT FAILED TO DISCLOSE IN ITS FORM ADV OR OTHERWISECONFLICTS OF INTEREST RELATED TO THE COLLECTION OF SUCH FEES.AS A RESULT OF THE CONDUCT, RESPONDENT WILLFULLY VIOLATEDSECTIONS 206(2) AND 207 OF THE ADVISERS ACT.
Current Status: Final
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Principal Sanction(s)/ReliefSought:
Cease and Desist
Other Sanction(s)/ReliefSought:
Date Initiated: 06/11/2018
Docket/Case Number: FILE NO. 3-19096
Principal Product Type: Mutual Fund(s)
Other Product Type(s):
Resolution Date: 03/11/2019
Resolution:
Other Sanctions Ordered:
Sanction Details: RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED,SHALL PAY DISGORGEMENT PLUS INTEREST OF $1,022,048.49 AND SHALLCOMPLY WITH THE UNDERTAKINGS DESCRIBED IN THE OFFER OFSETTLEMENT.
Firm Statement WITHIN 30 DAYS OF THE ORDER'S ISSUANCE, M SECURITIES IS REQUIREDTO: DEPOSIT THE MONEY IN AN ESCROW ACCOUNT, UPDATE ITSDISCLOSURES, UPDATE ITS POLICIES AND PROCEDURES, CONVERTELIGIBLE FUNDS TO A LOWER-COST SHARE CLASS AND PROVIDEAFFECTED CLIENTS WITH NOTIFICATION.
Sanctions Ordered: CensureDisgorgement/RestitutionCease and Desist/Injunction
Order
Disclosure 2 of 4
i
Reporting Source: Regulator
Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM,INCLUDING WRITTEN SUPERVISORY PROCEDURES (WSPS), REASONABLYDESIGNED TO SUPERVISE REPRESENTATIVES' USE OF CONSOLIDATEDREPORTS. THE FINDINGS STATED THAT DURING A PERIOD, ASSOCIATEDPERSONS OF THE FIRM CREATED AND DISSEMINATED CONSOLIDATEDREPORTS TO CUSTOMERS, YET, IT HAD NO WSPS DIRECTLY ADDRESSINGTHE SUPERVISION OF CONSOLIDATED REPORTS. FURTHER, THE FIRM DIDNOT MAINTAIN OR REVIEW CONSOLIDATED REPORTS ASCOMMUNICATIONS WITH CUSTOMERS AND DID NOT MAINTAIN OR REVIEWTHE SUPPORTING DOCUMENTS RELATED TO ASSETS AND ASSET VALUESENTERED MANUALLY BY REGISTERED REPRESENTATIVES IN THECONSOLIDATED REPORTS. FOLLOWING FINRA'S EXAMINATION, THE FIRMCREATED WSPS ADDRESSING THE USE AND DISSEMINATION OFCONSOLIDATED REPORTS BY ITS REPRESENTATIVES. THE WSPSINCLUDED THE FIRM'S REQUIREMENTS FOR REVIEW AND APPROVALBEFORE SUBMITTING OF CONSOLIDATED REPORTS TO FIRM CUSTOMERSOR PROSPECTIVE CUSTOMERS, AND PROHIBITED THE DISSEMINATION OFCONSOLIDATED REPORTS UNLESS AND UNTIL APPROVAL WAS PROVIDEDBY THE FIRM. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TORECORD AND REVIEW SALES OF PRIVATE OFFERING TO INVESTORS BYITS REGISTERED REPRESENTATIVE, PRIOR TO FINRA'S DISCOVERY OFTHE ACTIVITY. ONE OF THE FIRM'S REGISTERED REPRESENTATIVESREQUESTED THE FIRM'S APPROVAL TO ENGAGE IN PRIVATE SECURITIESTRANSACTIONS INVOLVING A PRIVATE OFFERING OF LIMITEDPARTNERSHIP INTERESTS IN A COMMERCIAL REAL ESTATE PROJECT. THEFIRM APPROVED REPRESENTATIVE'S REQUEST AND THEN FAILED TOSUPERVISE TRANSACTIONS INVOLVING SALES OF THE PRIVATEOFFERING BY THE REPRESENTATIVE TO INVESTORS, TOTALING$18,755,000 IN INTERESTS IN THE COMMERCIAL REAL ESTATEINVESTMENT. ALSO, THE FIRM DID NOT RECORD ANY OF THESETRANSACTIONS ON ITS BOOKS AND RECORDS, AS REQUIRED. AS ARESULT OF FINRA'S INQUIRIES, THE FIRM EVENTUALLY CONDUCTED DUEDILIGENCE ON THE COMMERCIAL REAL ESTATE PROJECT, REVIEWED THETRANSACTIONS, AND LATER RECORDED THE TRANSACTIONS ON ITSBOOKS AND RECORDS.
Current Status: Final
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Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 07/09/2018
Docket/Case Number: 2017052293001
Principal Product Type: Other
Other Product Type(s): PRIVATE SECURITIES TRANSACTIONS
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM,INCLUDING WRITTEN SUPERVISORY PROCEDURES (WSPS), REASONABLYDESIGNED TO SUPERVISE REPRESENTATIVES' USE OF CONSOLIDATEDREPORTS. THE FINDINGS STATED THAT DURING A PERIOD, ASSOCIATEDPERSONS OF THE FIRM CREATED AND DISSEMINATED CONSOLIDATEDREPORTS TO CUSTOMERS, YET, IT HAD NO WSPS DIRECTLY ADDRESSINGTHE SUPERVISION OF CONSOLIDATED REPORTS. FURTHER, THE FIRM DIDNOT MAINTAIN OR REVIEW CONSOLIDATED REPORTS ASCOMMUNICATIONS WITH CUSTOMERS AND DID NOT MAINTAIN OR REVIEWTHE SUPPORTING DOCUMENTS RELATED TO ASSETS AND ASSET VALUESENTERED MANUALLY BY REGISTERED REPRESENTATIVES IN THECONSOLIDATED REPORTS. FOLLOWING FINRA'S EXAMINATION, THE FIRMCREATED WSPS ADDRESSING THE USE AND DISSEMINATION OFCONSOLIDATED REPORTS BY ITS REPRESENTATIVES. THE WSPSINCLUDED THE FIRM'S REQUIREMENTS FOR REVIEW AND APPROVALBEFORE SUBMITTING OF CONSOLIDATED REPORTS TO FIRM CUSTOMERSOR PROSPECTIVE CUSTOMERS, AND PROHIBITED THE DISSEMINATION OFCONSOLIDATED REPORTS UNLESS AND UNTIL APPROVAL WAS PROVIDEDBY THE FIRM. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TORECORD AND REVIEW SALES OF PRIVATE OFFERING TO INVESTORS BYITS REGISTERED REPRESENTATIVE, PRIOR TO FINRA'S DISCOVERY OFTHE ACTIVITY. ONE OF THE FIRM'S REGISTERED REPRESENTATIVESREQUESTED THE FIRM'S APPROVAL TO ENGAGE IN PRIVATE SECURITIESTRANSACTIONS INVOLVING A PRIVATE OFFERING OF LIMITEDPARTNERSHIP INTERESTS IN A COMMERCIAL REAL ESTATE PROJECT. THEFIRM APPROVED REPRESENTATIVE'S REQUEST AND THEN FAILED TOSUPERVISE TRANSACTIONS INVOLVING SALES OF THE PRIVATEOFFERING BY THE REPRESENTATIVE TO INVESTORS, TOTALING$18,755,000 IN INTERESTS IN THE COMMERCIAL REAL ESTATEINVESTMENT. ALSO, THE FIRM DID NOT RECORD ANY OF THESETRANSACTIONS ON ITS BOOKS AND RECORDS, AS REQUIRED. AS ARESULT OF FINRA'S INQUIRIES, THE FIRM EVENTUALLY CONDUCTED DUEDILIGENCE ON THE COMMERCIAL REAL ESTATE PROJECT, REVIEWED THETRANSACTIONS, AND LATER RECORDED THE TRANSACTIONS ON ITSBOOKS AND RECORDS.
Resolution Date: 07/09/2018
Resolution: Acceptance, Waiver & Consent(AWC)
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Resolution Date: 07/09/2018
Other Sanctions Ordered:
Sanction Details: THE FIRM WAS CENSURED AND FINED $135,000. FINES PAID IN FULL ONJULY 26, 2018.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $135,000.00
iReporting Source: Firm
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Censure
Other Sanction(s)/ReliefSought:
Date Initiated: 05/22/2017
Docket/Case Number: 2017052293001
Principal Product Type: Other
Other Product Type(s): CONSOLIDATED REPORTS, PRIVATE SECURITIES TRANSACTION
Allegations: FAILURE TO SUPERVISE
Current Status: Final
Resolution Date: 07/09/2018
Resolution:
Other Sanctions Ordered:
Sanction Details: $135,000 WAS PAID IN SANCTIONS IN JULY, 2018.
Firm Statement M SECURITIES WAS IMPOSED A CENSURE AND FINE IN THE AMOUNT OF$135,000 AS SANCTIONS.
Sanctions Ordered: CensureMonetary/Fine $135,000.00
Acceptance, Waiver & Consent(AWC)
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Disclosure 3 of 4
i
Reporting Source: Regulator
Initiated By: KENTUCKY DEPARTMENT OF FINANCIAL INSTITUTIONS
Principal Sanction(s)/ReliefSought:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanction(s)/ReliefSought:
Date Initiated: 06/06/2018
Docket/Case Number: 2018-AH-00003
URL for Regulatory Action:
Principal Product Type: No Product
Other Product Type(s):
Allegations: ON FEBRUARY 1-2, 2017, DFI CONDUCTED A ROUTINE COMPLIANCEEXAMINATION OF THE M HOLDINGS LOUISVILLE BRANCH. DURING THEEXAMINATION, DFI DISCOVERED THAT AN IAR OF M HOLDINGS HADALTERED CLIENT DOCUMENTS. SPECIFICALLY, THE IAR CUT AND TAPED ACLIENT'S SIGNATURE ON A 1035 EXCHANGE FORM. M HOLDINGSVIOLATED 808 KAR 10:030 SECTION 3 BY FAILING TO SUPERVISE THE IAR.
Current Status: Final
Resolution Date: 06/06/2018
Resolution:
Other Sanctions Ordered:
Sanction Details: $5,000 FINE WAS PAID 5/31/2018
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: Monetary/Fine $5,000.00
Order
iReporting Source: Firm
Current Status: Final
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Initiated By: STATE OF KENTUCKY, DEPARTMENT OF FINANCIAL INSTITUTIONS
Principal Sanction(s)/ReliefSought:
Other
Other Sanction(s)/ReliefSought:
AGREED ORDER
Date Initiated: 02/01/2017
Docket/Case Number: 2018-AH-0003
Principal Product Type: Insurance
Other Product Type(s):
Allegations: FAILURE TO SUPERVISE AN RR WHO ALTERED A CLIENT'S 1035 EXCHANGEFORM BY CUTTING AND TAPING CLIENT'S SIGNATURE ON THE FORM.CLIENT FILES CONTAINED MULTIPLE IMPROPERLY COMPLETED FORMS.
Resolution Date: 06/06/2018
Resolution:
Other Sanctions Ordered:
Sanction Details: M HOLDINGS SECURITIES, INC. AGREED TO MONETARY FINE AND REVIEWOF WRITTEN SUPERVISORY PROCEDURES TO ENSURE RELEVANCY ANDREASONABLENESS.
Firm Statement A PAYMENT WAS MADE TO THE STATE OF KENTUCKY BY M HOLDINGSSECURITIES, INC.
Sanctions Ordered: Monetary/Fine $5,000.00
Decision & Order of Offer of Settlement
Disclosure 4 of 4
i
Reporting Source: Regulator
Allegations: NASD RULES 2110, 2440, 3010, INTERPRETATIVE MATERIAL 2440 - MHOLDINGS SECURITIES, INC. SOLD CORPORATE BONDS TO A CUSTOMERAND FAILED TO SELL SUCH BONDS AT A PRICE THAT WAS FAIR, TAKINGINTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDINGMARKET CONDITIONS WITH RESPECT TO EACH BOND AT THE TIME OF THETRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WASENTITLED TO A PROFIT. IN EACH INSTANCE, THE BONDS WERE SOLD BYTHE SAME REGISTERED REPRESENTATIVE WHO WAS EMPLOYED IN ABRANCH OFFICE. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDEFOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITH APPLICABLE SECURITIES LAWS, REGULATIONS AND/OR NASD RULESADDRESSING QUALITY OF MARKET TOPICS. THE FIRM'S WRITTENSUPERVISORY PROCEDURES FAILED TO PROVIDE FOR MINIMUMREQUIREMENTS FOR ADEQUATE WRITTEN SUPERVISORY PROCEDURESIN FAIR PRICING REVIEWS OF FIXED INCOME TRANSACTIONS ANDQUALIFYING SUPERVISORY PERSONNEL.
Current Status: Final
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Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
Date Initiated: 09/06/2011
Docket/Case Number: 2006006455001
Principal Product Type: Debt - Corporate
Other Product Type(s):
NASD RULES 2110, 2440, 3010, INTERPRETATIVE MATERIAL 2440 - MHOLDINGS SECURITIES, INC. SOLD CORPORATE BONDS TO A CUSTOMERAND FAILED TO SELL SUCH BONDS AT A PRICE THAT WAS FAIR, TAKINGINTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDINGMARKET CONDITIONS WITH RESPECT TO EACH BOND AT THE TIME OF THETRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WASENTITLED TO A PROFIT. IN EACH INSTANCE, THE BONDS WERE SOLD BYTHE SAME REGISTERED REPRESENTATIVE WHO WAS EMPLOYED IN ABRANCH OFFICE. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDEFOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCEWITH APPLICABLE SECURITIES LAWS, REGULATIONS AND/OR NASD RULESADDRESSING QUALITY OF MARKET TOPICS. THE FIRM'S WRITTENSUPERVISORY PROCEDURES FAILED TO PROVIDE FOR MINIMUMREQUIREMENTS FOR ADEQUATE WRITTEN SUPERVISORY PROCEDURESIN FAIR PRICING REVIEWS OF FIXED INCOME TRANSACTIONS ANDQUALIFYING SUPERVISORY PERSONNEL.
Resolution Date: 09/06/2011
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $90,000, ORDERED TO PAY$30,963.26, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS ANDREQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURESREGARDING FAIR PRICING REVIEWS OF FIXED INCOME TRANSACTIONSAND QUALIFYING SUPERVISORY PERSONNEL WITHIN 30 BUSINESS DAYSOF ACCEPTANCE OF THIS AWC BY THE NAC. A REGISTERED PRINCIPAL OFTHE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THERESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTSUNDERTAKEN TO EFFECT RESTITUTION, TO FINRA NO LATER THAN 120DAYS AFTER ACCEPTANCE OF THIS AWC.
Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?
No
Sanctions Ordered: CensureMonetary/Fine $90,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
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WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $90,000, ORDERED TO PAY$30,963.26, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS ANDREQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURESREGARDING FAIR PRICING REVIEWS OF FIXED INCOME TRANSACTIONSAND QUALIFYING SUPERVISORY PERSONNEL WITHIN 30 BUSINESS DAYSOF ACCEPTANCE OF THIS AWC BY THE NAC. A REGISTERED PRINCIPAL OFTHE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THERESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTSUNDERTAKEN TO EFFECT RESTITUTION, TO FINRA NO LATER THAN 120DAYS AFTER ACCEPTANCE OF THIS AWC.
iReporting Source: Firm
Initiated By: FINRA
Principal Sanction(s)/ReliefSought:
Other Sanction(s)/ReliefSought:
OTHER SANCTIONS/RELIEF SOUGHT
Date Initiated: 09/06/2011
Docket/Case Number: 2006006455001
Principal Product Type: Debt - Corporate
Other Product Type(s):
Allegations: NASD RULES 2110, 2440, 3010, INTERPRETATIVE MATERIAL 2440 - FINRASTAFF ALLEGED M HOLDINGS SECURITIES, INC. SOLD CERTAINCORPORATE BONDS TO A CUSTOMER AND FAILED TO SELL SUCH BONDSAT A PRICE THAT WAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANTCIRCUMSTANCES. IN EACH INSTANCE, THE BONDS WERE SOLD BY THESAME REGISTERED REPRESENTATIVE WHO WAS EMPLOYED IN A BRANCHOFFICE. FURTHER, FINRA STAFF CLAIMED THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH CERTAIN SECURITIES LAWS,REGULATIONS AND/OR NASD RULES ADDRESSING QUALITY OF MARKETTOPICS AND THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WEREINADEQUATE IN THE FOLLOWING SUBJECT AREAS: FAIR PRICINGREVIEWS OF FIXED INCOME TRANSACTIONS AND QUALIFYINGSUPERVISORY PERSONNEL.
Current Status: Final
Resolution Date: 09/06/2011
Resolution:
Other Sanctions Ordered: UNDERTAKING
Sanction Details: WITHOUT ADMITTING OR DENYING FINRA'S CLAIMS, THE FIRM SUBMITTEDAN AWC WHEREBY IT WAS CENSURED, FINED $90,000, ORDERED TO PAY$30,963.26, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS ANDREQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURESREGARDING FAIR PRICING REVIEWS OF FIXED INCOME TRANSACTIONSAND QUALIFYING SUPERVISORY PERSONNEL WITHIN 30 BUSINESS DAYSOF ACCEPTANCE OF THIS AWC BY THE NAC. A REGISTERED PRINCIPAL OFTHE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THERESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTSUNDERTAKEN TO EFFECT RESTITUTION, TO FINRA NO LATER THAN 120DAYS AFTER ACCEPTANCE OF THIS AWC.
Sanctions Ordered: CensureMonetary/Fine $90,000.00Disgorgement/Restitution
Acceptance, Waiver & Consent(AWC)
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WITHOUT ADMITTING OR DENYING FINRA'S CLAIMS, THE FIRM SUBMITTEDAN AWC WHEREBY IT WAS CENSURED, FINED $90,000, ORDERED TO PAY$30,963.26, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS ANDREQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURESREGARDING FAIR PRICING REVIEWS OF FIXED INCOME TRANSACTIONSAND QUALIFYING SUPERVISORY PERSONNEL WITHIN 30 BUSINESS DAYSOF ACCEPTANCE OF THIS AWC BY THE NAC. A REGISTERED PRINCIPAL OFTHE FIRM SHALL SUBMIT SATISFACTORY PROOF OF PAYMENT OF THERESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTSUNDERTAKEN TO EFFECT RESTITUTION, TO FINRA NO LATER THAN 120DAYS AFTER ACCEPTANCE OF THIS AWC.
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