piper jaffray & co. - finra jaffray & co. crd# 665 sec# 8-15204 main office location 800 nicollet...

BrokerCheck Report

PIPER JAFFRAY & CO.

Section Title

Report Summary

Firm History

CRD# 665

1

9

Firm Profile 2 - 8

Page(s)

Firm Operations 10 - 20

Disclosure Events 21

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PIPER JAFFRAY & CO.

CRD# 665

SEC# 8-15204

Main Office Location

800 NICOLLET MALLMINNEAPOLIS, MN 55402-7020Regulated by FINRA Kansas City Office

Mailing Address

800 NICOLLET MALLSUITE 1000MINNEAPOLIS, MN 55402-7020

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

612-303-6000

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 134

Civil Event 1

Arbitration 55

Firm Profile

This firm is classified as a corporation.

This firm was formed in Delaware on 07/28/1969.

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 16 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 10 Self-Regulatory Organizations 53 U.S. states and territories

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12018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.

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This firm is classified as a corporation.

This firm was formed in Delaware on 07/28/1969.

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.

PIPER JAFFRAY & CO.

SEC#

665

8-15204

Main Office Location

Mailing Address

Business Telephone Number

Doing business as PIPER JAFFRAY & CO.

612-303-6000

Regulated by FINRA Kansas City Office

800 NICOLLET MALLMINNEAPOLIS, MN 55402-7020

800 NICOLLET MALLSUITE 1000MINNEAPOLIS, MN 55402-7020

Other Names of this Firm

Name Where is it used

HOPWOOD LANE, DIVISION OF PIPER JAFFRAY & CO. MN, NY, WA

SIMMONS & COMPANY INTERNATIONAL/ENERGY SPECIALISTS OFPIPER JAFF

AK, AL, AR, AZ, CA,CO, CT, DC, DE, FL,GA, HI, IA, ID, IL, IN,KS, KY, LA, MA, MD,ME, MI, MN, MO,MS, MT, NC, ND, NE,NH, NJ, NM, NV, NY,OH, OK, OR, PA, RI,SC, SD, TN, TX, UT,VA, VT, WA, WI, WV,WY


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AK, AL, AR, AZ, CA,CO, CT, DC, DE, FL,GA, HI, IA, ID, IL, IN,KS, KY, LA, MA, MD,ME, MI, MN, MO,MS, MT, NC, ND, NE,NH, NJ, NM, NV, NY,OH, OK, OR, PA, RI,SC, SD, TN, TX, UT,VA, VT, WA, WI, WV,WY


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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?

PIPER JAFFRAY COMPANIES

PARENT

75% or more

Yes

Domestic Entity

12/2003

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


ABRAHAM, CHAD RICHARD

CEO; BOARD MEMBER

Less than 5%

No

Individual

01/2018

Yes

2190836



Position


Position Start Date

CARTER, TIMOTHY LEE

CFO; BOARD MEMBER

Less than 5%

Individual

01/2018

2676342






Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


DUFF, ANDREW SCOTT

CHAIRMAN; BOARD MEMBER

Less than 5%

No

Individual

01/1996

Yes

719526



Position



Position Start Date


FAIRMAN, FRANCIS EVARTS IV

HEAD OF PUBLIC FINANCE SERVICES; BOARD MEMBER

Less than 5%

No

Individual

07/2005

Yes

1171131



GEELAN, JOHN WILLIAM JR.

4905460






Firm Profile

Position



Position Start Date


CHIEF LEGAL OFFICER

Less than 5%

No

Individual

01/2013

Yes

4905460


Position



Position Start Date


LARUE, ROBERT SCOTT

HEAD OF INVESTMENT BANKING; BOARD MEMBER

Less than 5%

No

Individual

01/2018

Yes

3185126



Position


Position Start Date


MCCAGUE, ANNCHARLOTTE

CHIEF COMPLIANCE OFFICER

Less than 5%

Individual

12/2005

Yes

1108448







Firm Profile



No

Yes

Position



Position Start Date


SCHONEMAN, DEBBRA LYNN

PRESIDENT; HEAD OF EQUITIES; BOARD MEMBER

Less than 5%

No

Individual

01/2018

Yes

1980635



Position



Position Start Date


WINGES, MARTIN BRADLEY

HEAD OF FIXED INCOME SERVICES; BOARD MEMBER

Less than 5%

No

Individual

01/2009

Yes

1929509






This section provides information relating to any indirect owners of the brokerage firm.

Indirect Owners

Firm Profile

No information reported.




Firm History

This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

No information reported.




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, 10 SROs 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 10/24/1969

Self-Regulatory Organization Status Date Effective

FINRA Approved 10/16/1936

Cboe BYX Exchange, Inc. Approved 11/15/2012

Cboe BZX Exchange, Inc. Approved 10/15/2008

Cboe EDGA Exchange, Inc. Approved 05/14/2010

Cboe EDGX Exchange, Inc. Approved 05/14/2010

Investors' Exchange LLC Approved 08/10/2016

NYSE American LLC Approved 02/25/1988

NYSE Arca, Inc. Approved 04/09/2003

Nasdaq Stock Market Approved 07/12/2006

New York Stock Exchange Approved 11/17/1982




Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 10/24/1981

Alaska Approved 08/10/1972

Arizona Approved 03/10/1976

Arkansas Approved 05/24/1985

California Approved 01/02/1973

Colorado Approved 02/01/1983

Connecticut Approved 06/21/1976

Delaware Approved 10/06/1981

District of Columbia Approved 04/21/1983

Florida Approved 04/27/1983

Georgia Approved 09/22/1981

Hawaii Approved 12/08/1980

Idaho Approved 01/01/1971

Illinois Approved 06/29/1970

Indiana Approved 10/21/1981

Iowa Approved 07/14/1983

Kansas Approved 04/23/1975

Kentucky Approved 07/16/1982

Louisiana Approved 04/20/1983

Maine Approved 04/27/1984

Maryland Approved 10/03/1981

Massachusetts Approved 07/31/1981

Michigan Approved 02/03/1983

Minnesota Approved 07/15/1982

Mississippi Approved 04/20/1984

Missouri Approved 07/18/1983

Montana Approved 04/20/1983

Nebraska Approved 10/08/1981

Nevada Approved 07/18/1983

New Hampshire Approved 08/02/1983

New Jersey Approved 07/14/1983

New Mexico Approved 10/07/1981

New York Approved 01/02/1985

U.S. States &Territories

Status Date Effective

North Carolina Approved 07/15/1982

North Dakota Approved 10/21/1981

Ohio Approved 07/16/1982

Oklahoma Approved 07/17/1982

Oregon Approved 10/24/1981

Pennsylvania Approved 01/09/1980

Puerto Rico Approved 06/04/1998

Rhode Island Approved 05/07/1984

South Carolina Approved 04/28/1982

South Dakota Approved 07/15/1982

Tennessee Approved 08/17/1981

Texas Approved 07/25/1983

Utah Approved 04/21/1983

Vermont Approved 05/01/1984

Virgin Islands Approved 06/09/2005

Virginia Approved 09/22/1981

Washington Approved 04/20/1983

West Virginia Approved 11/07/1983

Wisconsin Approved 08/29/1969

Wyoming Approved 06/29/1965




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: APPLICANT ACTS AS A SWAP ADVISOR FOR THE PURPOSE OFENTERING INTO SWAP CONTRACTS ON A LIMITED BASIS.

This firm currently conducts 16 types of businesses.

Types of Business

Exchange member engaged in exchange commission business other than floor activities

Broker or dealer making inter-dealer markets in corporation securities over-the-counter

Broker or dealer retailing corporate equity securities over-the-counter

Broker or dealer selling corporate debt securities

Underwriter or selling group participant (corporate securities other than mutual funds)

Mutual fund retailer

U S. government securities dealer

U S. government securities broker

Municipal securities dealer

Municipal securities broker

Put and call broker or dealer or option writer

Broker or dealer selling securities of non-profit organizations (e.g., churches, hospitals)

Investment advisory services

Trading securities for own account

Private placements of securities

Broker or dealer selling interests in mortgages or other receivables




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: ONE PERSHING PLAZA10TH FLOORJERSEY CITY, NJ 07399

CRD #: 7560

Effective Date: 11/06/2015

Description: FULLY DISCLOSED CORRESPONDENT CLEARING RELATIONSHIP;




Firm Operations

Industry Arrangements

This firm does have books or records maintained by a third party.

This firm does have accounts, funds, or securities maintained by a third party.

This firm does have customer accounts, funds, or securities maintained by a third party.

Name: BROADRIDGE FINANCIAL SOLUTIONS, INC.

Business Address: 1981 MARCUS AVENUELAKE SUCCESS, NY 11042


Description: BOOKS AND RECORDS RETENTION

Name: OMGEO LLC

Business Address: 55 WATER STREETNEW YORK, NY 10041


Description: TO MAINTAIN AND PRESERVE CONFIRMATIONS FOR RECORDRETENTION

Name: BNP PARIBAS PRIME BROKERAGE, INC.

Business Address: 787 7TH AVENUENEW YORK, NY 100169

CRD #: 24962


Description: PROPRIETARY PRIME BROKER ACCOUNT OF PIPER JAFFRAY & CO.HELD UNDER A PAB AGREEMENT.

Name: PERSHING LLC


CRD #: 7560


Description: FULLY DISCLOSED CORRESPONDENT CLEARING ARRANGEMENT.

Name: PERSHING LLC

CRD #: 7560




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


CRD #: 7560


Description: FULLY DISCLOSED CORRESPONDENT CLEARING RELATIONSHIPS.




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

No

No

12/07/2017

800 NICOLLET MALLSUITE 1000MINNEAPOLIS, MN 55402

PIPER JAFFRAY FINANCE LLC is under common control with the firm.

UNDER COMMON CONTROL BY PARENT HOLDING COMPANY PIPERJAFFRAY COMPANIES

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

07/06/2017

800 NICOLLET MALLMINNEAPOLIS, MN 55402

PIPER JAFFRAY FINANCIAL LLC is under common control with the firm.


Description:



Country:

Foreign Entity:

Effective Date:

Business Address:


PIPER JAFFRAY FINANCIAL TRUST DEPOSITOR, LLC is under common control with the firm.

Business Address: 162018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.



Firm Operations

Organization Affiliates (continued)

No

Yes

No

07/06/2017



Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

No

GUERNSEY

Yes

02/29/2016

PO BOX 656,EAST WING, TRAFALGAR COURT, LES BANQUESST PETER PORT, GUERNSEY (UK) GY1 3PP

PARALLEL GENERAL PARTNER LIMITED is under common control with the firm.

UNDER COMMON CONTROL BY PARENT HOLDING COMPANY PIPERJAFFRAY COMPANIES. MERGED INTO PIPER JAFFRAY LTD AS OF MAY 1,2017

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

CHINA

Yes

10/10/2012

LEVEL 16, NEXXUS BUILDING41 CONNAUGHT RD., CENTRALHONG KONG, HONG KONG

PIPER JAFFRAY HONG KONG LIMITED is under common control with the firm.



Country:

Foreign Entity:

Effective Date:

Business Address:




Firm Operations


No

ENTITY IS OWNED BY PIPER JAFFRAY COMPANIES, THE HOLDINGCOMPANY AND UNDER COMMON CONTROL WITH PIPER JAFFRAY & CO.

Description:


Yes

No

No

11/30/2012


165620

PJC CAPITAL PARTNERS LLC is under common control with the firm.


Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

No

03/01/2010

180 N. STETSON AVECHICAGO, IL 60601

108254

ADVISORY RESEARCH INC is under common control with the firm.

ADVISORY RESEARCH INC IS A FEDERALLY REGISTERED INVESTMENTADVISER WHICH IS UNDER COMMON CONTROL BY PARENT HOLDINGCOMPANY PIPER JAFFRAY COMPANIES

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

145876

PIPER JAFFRAY INVESTMENT MANAGEMENT, LLC is under common control with the firm.

CRD #:




Firm Operations


Yes

No

No

05/12/2008



Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

Yes

UNITED KINGDOM

Yes

10/06/2001

13TH FLOOR88 WOOD ST.LONDON EC2V 7RS, ENGLAND

163758

PIPER JAFFRAY LTD is under common control with the firm.

BROKER-DEALER REGISTERED THROUGH THE FINANCIAL CONDUCTAUTHORITY WHICH IS UNDER COMMON CONTROL BY PARENT HOLDINGCOMPANY PIPER JAFFRAY COMPANIES.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

DELAWARE

No

03/14/1983


PIPER JAFFRAY VENTURES INC. is under common control with the firm.



Country:

Foreign Entity:

Effective Date:

Business Address:




Firm Operations


No

ORGANIZES AND MANAGES FUNDS FOR INVESTING IN PRIVATELY HELDCOMPANIES. PIPER JAFFRAY VENTURES, INC IS UNDER COMMONCONTROL BY PARENT HOLDING COMPANY PIPER JAFFRAY COMPANIES

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




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 0 134 0

Civil Event 0 1 0

Arbitration N/A 55 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 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 134

Reporting Source: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT UNTIMELYSUBMITTED DOCUMENTS RELATING TO PRIMARY OFFERINGS OFMUNICIPAL SECURITIES TO THE ELECTRONIC MUNICIPAL MARKET ACCESSDATABASE (EMMA). THE FINDINGS STATED THAT THE UNTIMELYSUBMISSIONS RESULTED FROM TURNOVER IN THE FIRM'S DEPARTMENTTHAT HANDLED THE DOCUMENTS, A SITUATION THAT THE FIRM'S WSPSDID NOT ADEQUATELY ADDRESS.

Current Status: Final




Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 07/07/2016

Docket/Case Number: 2015043589201

Principal Product Type: Other

Other Product Type(s): PRIMARY OFFERINGS OF MUNICIPAL SECURITIES


Resolution Date: 07/07/2016

Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND FINED $12,500. FINE PAID IN FULL ONAUGUST 8, 2016.

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Sanctions Ordered: CensureMonetary/Fine $12,500.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm




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Initiated By: FINRA


Other


N/A




Other Product Type(s): PRIMARY OFFERINGS OF MUNICIPAL SECURITIES

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT UNTIMELYSUBMITTED DOCUMENTS RELATING TO PRIMARY OFFERINGS OFMUNICIPAL SECURITIES TO THE ELECTRONIC MUNICIPAL MARKET ACCESSDATABASE (EMMA). THE FINDINGS STATED THAT THE UNTIMELYSUBMISSIONS RESULTED FROM TURNOVER IN THE FIRM'S DEPARTMENTTHAT HANDLED THE DOCUMENTS, A SITUATION THAT THE FIRM'S WSPSDID NOT ADEQUATELY ADDRESS.


Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $12,500



Disclosure 2 of 134

i


Allegations: SEC ADMIN RELEASES 33-9837; 34-75231, JUNE 18, 2015: THE SECURITIESAND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESISTPROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST PIPERJAFFRAY & CO. ("RESPONDENT"). RESPONDENT WILLFULLY VIOLATEDSECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVESVIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERAL SECURITIESLAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITING OF CERTAINMUNICIPAL SECURITIES OFFERINGS. RESPONDENT, A REGISTEREDBROKER-DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAINOFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASISFOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIALREPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTIONWITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENT OFFERINGAND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLYMISLEADING DISCLOSURE DOCUMENTS.THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THECOMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION(MCDC) INITIATIVE.





Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION


Cease and Desist



Docket/Case Number: 3-16630

Principal Product Type: Debt - Municipal

Other Product Type(s):

SEC ADMIN RELEASES 33-9837; 34-75231, JUNE 18, 2015: THE SECURITIESAND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESISTPROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST PIPERJAFFRAY & CO. ("RESPONDENT"). RESPONDENT WILLFULLY VIOLATEDSECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVESVIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERAL SECURITIESLAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITING OF CERTAINMUNICIPAL SECURITIES OFFERINGS. RESPONDENT, A REGISTEREDBROKER-DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAINOFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASISFOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIALREPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTIONWITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENT OFFERINGAND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLYMISLEADING DISCLOSURE DOCUMENTS.THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THECOMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION(MCDC) INITIATIVE.


Resolution:

Other Sanctions Ordered: UNDERTAKINGS

Sanction Details: THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION17(A)(2)OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THEAMOUNT OF $500,000 AND COMPLY WITH THE UNDERTAKINGSENUMERATED IN THE OFFER OF SETTLEMENT.

Regulator Statement IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER")WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THEFOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INRESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THATRESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OFTHE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THISORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THESECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENTCONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES ANDPROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIESUNDERWRITING DUE DILIGENCE.


Yes

Sanctions Ordered: Monetary/Fine $500,000.00Cease and Desist/Injunction

Order



www.finra.org/brokercheck User GuidanceIN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER")WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THEFOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INRESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THATRESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OFTHE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THISORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THESECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENTCONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES ANDPROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIESUNDERWRITING DUE DILIGENCE.




Allegations: SEC ADMIN RELEASES 33-9837; 34-75231, JUNE 18, 2015: THE SECURITIESAND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESISTPROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST PIPERJAFFRAY & CO. ("RESPONDENT"). RESPONDENT WILLFULLY VIOLATEDSECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVESVIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERAL SECURITIESLAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITING OF CERTAINMUNICIPAL SECURITIES OFFERINGS. RESPONDENT, A REGISTEREDBROKER-DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAINOFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASISFOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIALREPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTIONWITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENT OFFERINGAND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLYMISLEADING DISCLOSURE DOCUMENTS. THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THE COMMISSION PURSUANT TO THEDIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIESCONTINUING DISCLOSURE COOPERATION (MCDC) INITIATIVE.






Cease and Desist







Resolution:


Sanction Details: THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION17(A)(2)OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THEAMOUNT OF $500,000 AND COMPLY WITH THE UNDERTAKINGSENUMERATED IN THE OFFER OF SETTLEMENT.

Firm Statement IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER")WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THEFOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INRESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THATRESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OFTHE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THISORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THESECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENTCONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES ANDPROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIESUNDERWRITING DUE DILIGENCE.

Sanctions Ordered: Monetary/Fine $500,000.00Cease and Desist/Injunction

Order




IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER")WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THEFOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INRESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THATRESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OFTHE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THISORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THESECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENTCONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES ANDPROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIESUNDERWRITING DUE DILIGENCE.

Disclosure 3 of 134

i


Initiated By: FINRA







Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITINACCURATELY REPORTED THE M020 SPECIAL CONDITION INDICATOR TOTHE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN REPORTSOF TRANSACTIONS IN MUNICIPAL SECURITIES. THE FINDINGS STATEDTHAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHRESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS ANDTHE RULES OF THE MUNICIPAL SECURITIES RULEMAKING BOARD (MSRB)CONCERNING THE ACCURATE REPORTING OF SPECIAL CONDITIONINDICATOR CODES.



Resolution:


No







Sanction Details: THE FIRM WAS CENSURED AND FINED $15,000.

FINE PAID IN FULL ON FEBRUARY 25, 2015.


Initiated By: FINRA


Other


MONETARY FINE





Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITINACCURATELY REPORTED THE M020 SPECIAL CONDITION INDICATOR TOTHE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN REPORTSOF TRANSACTIONS IN MUNICIPAL SECURITIES. THE FINDINGS STATEDTHAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHRESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS ANDTHE RULES OF THE MUNICIPAL SECURITIES RULEMAKING BOARD (MSRB)CONCERNING THE ACCURATE REPORTING OF SPECIAL CONDITIONINDICATOR CODES.



Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $15,000.



Disclosure 4 of 134

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Disclosure 4 of 134


Initiated By: FINRA






Other Product Type(s): SECURITIZED PRODUCTS

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS WITHIN THETIME REQUIRED BY FINRA RULE 6730(A).



Resolution:


Sanction Details: SEE ABOVE

Regulator Statement FINE PAID IN FULL MAY 16, 2014.


No

Sanctions Ordered: Monetary/Fine $5,000.00



Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS WITHIN THETIME REQUIRED BY FINRA RULE 6730(A).





Initiated By: FINRA


Other


MONETARY FINE




Other Product Type(s): SECURITIZED PRODUCTS

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS WITHIN THETIME REQUIRED BY FINRA RULE 6730(A).


Resolution:


Sanction Details: TOTAL AMOUNT: $5,000.00; 100% LEVIED AGAINST THE APPLICANT.

Sanctions Ordered: Monetary/Fine $5,000.00


Disclosure 5 of 134

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Initiated By: FINRA



Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)THE CORRECT TIME OF TRADE EXECUTION FOR S1 TRANSACTIONS INTRACE-ELIGIBLE AGENCY DEBT SECURITIES; FAILED TO REPORT TOTRACE S1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15MINUTES OF THE TIME OF EXECUTION; FAILED TO SHOW THE CORRECTTIME OF EXECUTION ON THE MEMORANDUM OF BROKERAGE ORDERS;AND FAILED TO REPORT TO TRACE THE CORRECT TIME OF TRADEEXECUTION FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZEDPRODUCTS.



http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2013038861401https://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2013037791201






Other Product Type(s): AGENCY DEBT SECURITIES


Resolution:


Sanction Details: SEE ABOVE


No




Initiated By: FINRA



Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)THE CORRECT TIME OF TRADE EXECUTION FOR S1 TRANSACTIONS INTRACE-ELIGIBLE AGENCY DEBT SECURITIES; FAILED TO REPORT TOTRACE S1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15MINUTES OF THE TIME OF EXECUTION; FAILED TO SHOW THE CORRECTTIME OF EXECUTION ON THE MEMORANDUM OF BROKERAGE ORDERS;AND FAILED TO REPORT TO TRACE THE CORRECT TIME OF TRADEEXECUTION FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZEDPRODUCTS.



http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2013037791201https://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2013037791201



Censure


FINE



Other Product Type(s): AGENCY DEBT SECURITIES


Resolution:


Sanction Details: FINE $17,500.00



Disclosure 6 of 134

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Allegations: SEC ADMIN RELEASES 33-9472, 34-70804, NOVEMBER 5, 2013: THESECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT") AND SECTIONS 15(B) AND 15(B)(C)(2) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST PIPERJAFFRAY & CO. ("PIPER").

THE COMMISSION FOUND THAT IN 2011, A MUNICIPAL CORPORATION("DISTRICT") DEFAULTED ON $41.77 MILLION IN BOND ANTICIPATIONNOTES ("BANS") IT HAD ISSUED IN NOVEMBER 2008 TO FINANCE A MULTI-USE ARENA AND ICE HOCKEY RINK (THE "REGIONAL CENTER") LOCATEDIN THE CITY OF WENATCHEE, WASHINGTON (THE "CITY"). PIPER SERVEDAS SOLE UNDERWRITER FOR THE BANS. THE OFFICIAL STATEMENT FORTHE BANS WAS MATERIALLY FALSE AND MISLEADING.

PIPER WAS HIRED BY THE DISTRICT AS UNDERWRITER AS A LAST MINUTEREPLACEMENT FOR A PREDECESSOR UNDERWRITING FIRM("PREDECESSOR"). THE PREDECESSOR HAD BEEN WORKING WITH THEDISTRICT FOR OVER A YEAR AND HAD COMPLETED A PRELIMINARYOFFICIAL STATEMENT FOR LONG-TERM BONDS WHICH HAD RECEIVED ANINVESTMENT GRADE RATING. THAT PREDECESSOR WITHDREW INSEPTEMBER 2008 AFTER THE GLOBAL FINANCIAL CRISIS PREVENTEDACCESS TO THE BOND MARKET AND THE FIRM WAS UNABLE TOCOMPLETE THE FINANCING. PIPER'S ENGAGEMENT WITH THE DISTRICTSTARTED ON OCTOBER 27, 2008. BY THE TIME PIPER BECAME THEUNDERWRITER ON THE DEAL, THE CITY AND THE DISTRICT WEREDESPERATE TO FIND FINANCING FOR THE REGIONAL CENTER WITHIN AMONTH BECAUSE OF ONEROUS LEASE PAYMENTS BEING DEMANDED BYTHE CONSTRUCTION LENDER. PIPER SUGGESTED SEVERAL FINANCINGOPTIONS, ALTHOUGH ONLY ONE, SHORT-TERM BANS, WAS CONSIDEREDVIABLE. THE DISTRICT DETERMINED TO ISSUE THREE YEAR BANS THATWOULD MATURE IN 2011, WITH THE PRINCIPAL OF THE BANS TO BEREPAID SOLELY THROUGH THE ISSUANCE OF LONG-TERM BONDS.

PIPER CONDUCTED INADEQUATE DUE DILIGENCE AND, AS A RESULT,FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THETRUTHFULNESS AND COMPLETENESS OF MATERIAL STATEMENTS IN THEOFFICIAL STATEMENT. THE OFFICIAL STATEMENT FOR THE BANS WAS ALIGHTLY REVISED VERSION OF THE PRELIMINARY OFFICIAL STATEMENTPREPARED BY THE PREDECESSOR AND THE DISTRICT'S BOND COUNSELTHAT INCLUDED SIMILAR DISCLOSURES AND RELIED ON THE SAMEPROJECTIONS FOR THE REGIONAL CENTER PROVIDED BY THE COMPANY("COMPANY") HIRED TO DEVELOP AND MANAGE THE REGIONAL CENTER.PIPER CONDUCTED A CURSORY INQUIRY INTO THE PROJECTIONSPROVIDED BY THE COMPANY, DID NOT INQUIRE ABOUT PRIORPROJECTIONS OR REVISIONS, AND DID NOT ASK TO SEE ANINDEPENDENT CONSULTANT'S REVIEW OF THE PROJECTIONS DESPITEBEING MADE AWARE OF ITS EXISTENCE, DEPRIVING BAN PURCHASERSOF MATERIAL INFORMATION RELATING TO THE REVENUE PROJECTIONS,THE FIRST SOURCE OF PAYMENT FOR THE MAJORITY OF THE BANS.

AN INDEPENDENT CONSULTANT HAD BEEN ASKED TO REVIEW THECOMPANY'S EARLIER PROJECTIONS AND HAD RAISED QUESTIONS ABOUTTHE REGIONAL CENTER'S ECONOMIC VIABILITY. DESPITE TWO SEPARATEREVIEWS OF PRIOR COMPANY PROJECTIONS BY THE INDEPENDENTCONSULTANT, THE OFFICIAL STATEMENT PRESENTED THE MOST RECENTVERSION OF THE COMPANY'S PROJECTIONS ALONG WITH A FALSE ANDMISLEADING STATEMENT TO THE EFFECT THAT NO FINANCIAL ADVISOR,ACCOUNTING OR OTHER FIRM HAD EXAMINED THOSE PROJECTIONS TOVERIFY THE REASONABLENESS OF THE COMPANY'S ASSUMPTIONS ORITS CONCLUSIONS.

PIPER WAS UNAWARE THAT THE PROJECTIONS IN THE OFFICIALSTATEMENT HAD BEEN REVISED UPWARD FROM PROJECTIONSGENERATED A FEW MONTHS EARLIER AFTER A CLAIM BY THE CITY'SFORMER MAYOR AND THE DISTRICT'S CONTRACT MANAGER THAT THECOMPANY'S PROJECTIONS WERE INCONSISTENT WITH ITS PRIORPROJECTIONS AND NOT SUFFICIENTLY OPTIMISTIC. DURING ACONFERENCE CALL WITH THE COMPANY'S PRESIDENT AND THECOMPANY'S FINANCIAL CONSULTANT, THE CITY'S FORMER MAYOR MADEAN IMPASSIONED ARGUMENT THAT THEY KNEW THE LOCAL CITIZENSBETTER THAN THE COMPANY, (CONTINUED IN COMMENT)





SEC ADMIN RELEASES 33-9472, 34-70804, NOVEMBER 5, 2013: THESECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT") AND SECTIONS 15(B) AND 15(B)(C)(2) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST PIPERJAFFRAY & CO. ("PIPER").















Other Product Type(s): BOND ANTICIPATION NOTES

SEC ADMIN RELEASES 33-9472, 34-70804, NOVEMBER 5, 2013: THESECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT") AND SECTIONS 15(B) AND 15(B)(C)(2) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST PIPERJAFFRAY & CO. ("PIPER").







Resolution:

Other Sanctions Ordered: UNDERTAKINGS

Sanction Details: THE COMMISSION DEEMED IT APPROPRIATE, IN THE PUBLIC INTEREST,AND FOR THE PROTECTION OF INVESTORS TO IMPOSE THE SANCTIONSAGREED TO IN PIPER'S OFFER. ACCORDINGLY, PURSUANT SECTION 8A OFTHE SECURITIES ACT AND SECTIONS 15(B) AND 15(B)(C) OF THEEXCHANGE ACT, IT IS HEREBY ORDERED THAT PIPER SHALL CEASE ANDDESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANYFUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND (3) OF THE SECURITIESACT. PIPER IS CENSURED. PIPER SHALL PAY A CIVIL MONEY PENALTY INTHE AMOUNT OF $300,000. PIPER SHALL COMPLY WITH THEUNDERTAKINGS ENUMERATED IN THE ORDER.

Regulator Statement (CONTINUED FROM #7) AND THOSE CITIZENS WOULD ULTIMATELYSUPPORT THE REGIONAL CENTER EVEN THOUGH THE COMPANY WASEXPERIENCING WEAK TICKET SALES AND OTHER TROUBLING INDICATORSREGARDING ANTICIPATED REVENUE. THE COMPANY REVISED ITSPROJECTIONS UPWARD AND THE MORE OPTIMISTIC REVISEDPROJECTIONS WERE INCLUDED IN THE OFFICIAL STATEMENT, WITHOUTDISCLOSING THAT THE CITY'S FORMER MAYOR OR THE DISTRICT'SCONTRACT MANAGER HAD QUESTIONED THE ASSUMPTIONS UNDERLYINGTHE PRIOR SET OF PROJECTIONS, OR THAT THE COMPANY HAD RELIEDON THE FORMER MAYOR'S VERBAL ASSERTIONS OF FUTURE COMMUNITYSUPPORT.

PIPER STATED THAT THEY FOCUSED THEIR DUE DILIGENCE EFFORTS ONA CONTINGENT LOAN AGREEMENT ENTERED INTO BY THE CITY THATOPERATED AS A BACKSTOP FOR THE PAYMENT OF THE INTEREST (BUTNOT THE PRINCIPAL) ON THE BANS, AND THE CITY'S ABILITY TO MAKEPAYMENTS IF NECESSARY. UNDER THAT CONTINGENT LOAN AGREEMENT,THE CITY WAS OBLIGATED TO LOAN TO THE DISTRICT FUNDS TO PAYINTEREST ON THE BANS IN THE EVENT THE DISTRICT'S REVENUES WEREINSUFFICIENT. NONETHELESS, A PARAGRAPH IN THE BODY OF THEPREDECESSOR'S PRELIMINARY OFFICIAL STATEMENT THAT HIGHLIGHTEDHOW THE CITY'S LOW REMAINING DEBT CAPACITY CONSTRAINED ITSOBLIGATIONS UNDER THAT CONTINGENT LOAN AGREEMENT WASDELETED FROM THE BODY OF THE OFFICIAL STATEMENT FOR THE BANS,THEREBY MISLEADING BAN PURCHASERS CONCERNING THE LIKELIHOODOF PERMANENT FINANCING.

THE REGIONAL CENTER'S FINANCIAL RESULTS FOR 2008 THROUGH 2011WERE WORSE THAN THE COMPANY'S MOST PESSIMISTIC PROJECTIONS,WITH THE REGIONAL CENTER OPERATING AT A SIGNIFICANT NETOPERATING LOSS. MOREOVER, AFTER THE CITY FILED A VALIDATIONPROCEEDING, THE CHELAN COUNTY, WASHINGTON, SUPERIOR COURTRULED IN 2011 THAT OBLIGATIONS UNDER A CONTINGENT LOANAGREEMENT CONSTITUTED "INDEBTEDNESS" WITHIN THE MEANING OFTHE STATE CONSTITUTION AND THEREFORE WOULD BE LIMITED TO THECITY'S REMAINING DEBT CAPACITY OF $19.3 MILLION, AS THE DELETEDDISCLOSURE LANGUAGE HAD WARNED. CONSEQUENTLY, THE DISTRICTWAS UNABLE TO ISSUE LONG-TERM BONDS, AND THE DISTRICTDEFAULTED ON THE PAYMENT OF PRINCIPAL ON THE BANS IN DECEMBER2011.

THE WASHINGTON STATE LEGISLATURE SUBSEQUENTLY PASSEDLEGISLATION TO HELP THE DISTRICT CURE ITS DEFAULT BY ALLOWINGTHE CITY TO IMPOSE AN ADDITIONAL SALES TAX WITHOUT VOTERAPPROVAL AND FURTHER ALLOWING THE DISTRICT TO SUBMIT TOVOTERS A PROPOSITION TO IMPOSE AN ADDITIONAL SALES TAX. THEVOTERS OF THE DISTRICT LATER APPROVED AN ADDITIONAL SALES TAX.ON SEPTEMBER 28, 2012, THE DISTRICT SOLD LONG-TERM BONDSSECURED SOLELY BY SALES TAX REVENUES TO REFINANCE THE BANS.

AS A RESULT OF THE NEGLIGENT CONDUCT, PIPER WILLFULLY VIOLATEDSECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT.

IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS, PIPERSUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THECOMMISSION DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED,PIPER CONSENTED TO THE ENTRY OF THE ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTIONS 15(B) AND15(B)(C) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS,AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER("ORDER").


No

Sanctions Ordered: CensureMonetary/Fine $300,000.00Cease and Desist/Injunction

Order




Regulator Statement (CONTINUED FROM #7) AND THOSE CITIZENS WOULD ULTIMATELYSUPPORT THE REGIONAL CENTER EVEN THOUGH THE COMPANY WASEXPERIENCING WEAK TICKET SALES AND OTHER TROUBLING INDICATORSREGARDING ANTICIPATED REVENUE. THE COMPANY REVISED ITSPROJECTIONS UPWARD AND THE MORE OPTIMISTIC REVISEDPROJECTIONS WERE INCLUDED IN THE OFFICIAL STATEMENT, WITHOUTDISCLOSING THAT THE CITY'S FORMER MAYOR OR THE DISTRICT'SCONTRACT MANAGER HAD QUESTIONED THE ASSUMPTIONS UNDERLYINGTHE PRIOR SET OF PROJECTIONS, OR THAT THE COMPANY HAD RELIEDON THE FORMER MAYOR'S VERBAL ASSERTIONS OF FUTURE COMMUNITYSUPPORT.









(CONTINUED FROM #7) AND THOSE CITIZENS WOULD ULTIMATELYSUPPORT THE REGIONAL CENTER EVEN THOUGH THE COMPANY WASEXPERIENCING WEAK TICKET SALES AND OTHER TROUBLING INDICATORSREGARDING ANTICIPATED REVENUE. THE COMPANY REVISED ITSPROJECTIONS UPWARD AND THE MORE OPTIMISTIC REVISEDPROJECTIONS WERE INCLUDED IN THE OFFICIAL STATEMENT, WITHOUTDISCLOSING THAT THE CITY'S FORMER MAYOR OR THE DISTRICT'SCONTRACT MANAGER HAD QUESTIONED THE ASSUMPTIONS UNDERLYINGTHE PRIOR SET OF PROJECTIONS, OR THAT THE COMPANY HAD RELIEDON THE FORMER MAYOR'S VERBAL ASSERTIONS OF FUTURE COMMUNITYSUPPORT.







Allegations: SEC ADMIN RELEASES 33-9472, 34-70804, NOVEMBER 5, 2013: THESECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT") AND SECTIONS 15(B) AND 15(B)(C)(2) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST PIPERJAFFRAY & CO. ("PIPER"). THE COMMISSION FOUND THAT IN 2011, AMUNICIPAL CORPORATION ("DISTRICT") DEFAULTED ON $41.77 MILLION INBOND ANTICIPATION NOTES ("BANS") IT HAD ISSUED IN NOVEMBER 2008TO FINANCE A MULTI-USE ARENA AND ICE HOCKEY RINK (THE "REGIONALCENTER") LOCATED IN THE CITY OF WENATCHEE, WASHINGTON (THE "CITY"). PIPER SERVED AS SOLE UNDERWRITER FOR THE BANS. THEOFFICIAL STATEMENT FOR THE BANS WAS MATERIALLY FALSE ANDMISLEADING. PIPER WAS HIRED BY THE DISTRICT AS UNDERWRITER AS ALAST MINUTE REPLACEMENT FOR A PREDECESSOR UNDERWRITING FIRM("PREDECESSOR"). THE PREDECESSOR HAD BEEN WORKING WITH THEDISTRICT FOR OVER A YEAR AND HAD COMPLETED A PRELIMINARYOFFICIAL STATEMENT FOR LONG-TERM BONDS WHICH HAD RECEIVED ANINVESTMENT GRADE RATING. THAT PREDECESSOR WITHDREW INSEPTEMBER 2008 AFTER THE GLOBAL FINANCIAL CRISIS PREVENTEDACCESS TO THE BOND MARKET AND THE FIRM WAS UNABLE TOCOMPLETE THE FINANCING. PIPER'S ENGAGEMENT WITH THE DISTRICTSTARTED ON OCTOBER 27, 2008. BY THE TIME PIPER BECAME THEUNDERWRITER ON THE DEAL, THE CITY AND THE DISTRICT WEREDESPERATE TO FIND FINANCING FOR THE REGIONAL CENTER WITHIN AMONTH BECAUSE OF ONEROUS LEASE PAYMENTS BEING DEMANDED BYTHE CONSTRUCTION LENDER. PIPER SUGGESTED SEVERAL FINANCINGOPTIONS, ALTHOUGH ONLY ONE, SHORT-TERM BANS, WAS CONSIDEREDVIABLE. THE DISTRICT DETERMINED TO ISSUE THREE YEAR BANS THATWOULD MATURE IN 2011, WITH THE PRINCIPAL OF THE BANS TO BEREPAID SOLELY THROUGH THE ISSUANCE OF LONG-TERM BONDS. PIPERCONDUCTED INADEQUATE DUE DILIGENCE AND, AS A RESULT, FAILED TOFORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS ANDCOMPLETENESS OF MATERIAL STATEMENTS IN THE OFFICIAL STATEMENT.THE OFFICIAL STATEMENT FOR THE BANS WAS A LIGHTLY REVISEDVERSION OF THE PRELIMINARY OFFICIAL STATEMENT PREPARED BY THEPREDECESSOR AND THE DISTRICT'S BOND COUNSEL THAT INCLUDEDSIMILAR DISCLOSURES AND RELIED ON THE SAME PROJECTIONS FORTHE REGIONAL CENTER PROVIDED BY THE COMPANY ("COMPANY") HIREDTO DEVELOP AND MANAGE THE REGIONAL CENTER. PIPER CONDUCTED ACURSORY INQUIRY INTO THE PROJECTIONS PROVIDED BY THE COMPANY,DID NOT INQUIRE ABOUT PRIOR PROJECTIONS OR REVISIONS, AND DIDNOT ASK TO SEE AN INDEPENDENT CONSULTANT'S REVIEW OF THEPROJECTIONS DESPITE BEING MADE AWARE OF ITS EXISTENCE,DEPRIVING BAN PURCHASERS OF MATERIAL INFORMATION RELATING TOTHE REVENUE PROJECTIONS, THE FIRST SOURCE OF PAYMENT FOR THEMAJORITY OF THE BANS. AN INDEPENDENT CONSULTANT HAD BEENASKED TO REVIEW THE COMPANY'S EARLIER PROJECTIONS AND HADRAISED QUESTIONS ABOUT THE REGIONAL CENTER'S ECONOMICVIABILITY. DESPITE TWO SEPARATE REVIEWS OF PRIOR COMPANYPROJECTIONS BY THE INDEPENDENT CONSULTANT, THE OFFICIALSTATEMENT PRESENTED THE MOST RECENT VERSION OF THECOMPANY'S PROJECTIONS ALONG WITH A FALSE AND MISLEADINGSTATEMENT TO THE EFFECT THAT NO FINANCIAL ADVISOR, ACCOUNTINGOR OTHER FIRM HAD EXAMINED THOSE PROJECTIONS TO VERIFY THEREASONABLENESS OF THE COMPANY'S ASSUMPTIONS OR ITSCONCLUSIONS. PIPER WAS UNAWARE THAT THE PROJECTIONS IN THEOFFICIAL STATEMENT HAD BEEN REVISED UPWARD FROM PROJECTIONSGENERATED A FEW MONTHS EARLIER AFTER A CLAIM BY THE CITY'SFORMER MAYOR AND THE DISTRICT'S CONTRACT MANAGER THAT THECOMPANY'S PROJECTIONS WERE INCONSISTENT WITH ITS PRIORPROJECTIONS AND NOT SUFFICIENTLY OPTIMISTIC. DURING ACONFERENCE CALL WITH THE COMPANY'S PRESIDENT AND THECOMPANY'S FINANCIAL CONSULTANT, THE CITY'S FORMER MAYOR MADEAN IMPASSIONED ARGUMENT THAT THEY KNEW THE LOCAL CITIZENSBETTER THAN THE COMPANY, (CONTINUED IN COMMENT)





SEC ADMIN RELEASES 33-9472, 34-70804, NOVEMBER 5, 2013: THESECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT") AND SECTIONS 15(B) AND 15(B)(C)(2) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST PIPERJAFFRAY & CO. ("PIPER"). THE COMMISSION FOUND THAT IN 2011, AMUNICIPAL CORPORATION ("DISTRICT") DEFAULTED ON $41.77 MILLION INBOND ANTICIPATION NOTES ("BANS") IT HAD ISSUED IN NOVEMBER 2008TO FINANCE A MULTI-USE ARENA AND ICE HOCKEY RINK (THE "REGIONALCENTER") LOCATED IN THE CITY OF WENATCHEE, WASHINGTON (THE "CITY"). PIPER SERVED AS SOLE UNDERWRITER FOR THE BANS. THEOFFICIAL STATEMENT FOR THE BANS WAS MATERIALLY FALSE ANDMISLEADING. PIPER WAS HIRED BY THE DISTRICT AS UNDERWRITER AS ALAST MINUTE REPLACEMENT FOR A PREDECESSOR UNDERWRITING FIRM("PREDECESSOR"). THE PREDECESSOR HAD BEEN WORKING WITH THEDISTRICT FOR OVER A YEAR AND HAD COMPLETED A PRELIMINARYOFFICIAL STATEMENT FOR LONG-TERM BONDS WHICH HAD RECEIVED ANINVESTMENT GRADE RATING. THAT PREDECESSOR WITHDREW INSEPTEMBER 2008 AFTER THE GLOBAL FINANCIAL CRISIS PREVENTEDACCESS TO THE BOND MARKET AND THE FIRM WAS UNABLE TOCOMPLETE THE FINANCING. PIPER'S ENGAGEMENT WITH THE DISTRICTSTARTED ON OCTOBER 27, 2008. BY THE TIME PIPER BECAME THEUNDERWRITER ON THE DEAL, THE CITY AND THE DISTRICT WEREDESPERATE TO FIND FINANCING FOR THE REGIONAL CENTER WITHIN AMONTH BECAUSE OF ONEROUS LEASE PAYMENTS BEING DEMANDED BYTHE CONSTRUCTION LENDER. PIPER SUGGESTED SEVERAL FINANCINGOPTIONS, ALTHOUGH ONLY ONE, SHORT-TERM BANS, WAS CONSIDEREDVIABLE. THE DISTRICT DETERMINED TO ISSUE THREE YEAR BANS THATWOULD MATURE IN 2011, WITH THE PRINCIPAL OF THE BANS TO BEREPAID SOLELY THROUGH THE ISSUANCE OF LONG-TERM BONDS. PIPERCONDUCTED INADEQUATE DUE DILIGENCE AND, AS A RESULT, FAILED TOFORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS ANDCOMPLETENESS OF MATERIAL STATEMENTS IN THE OFFICIAL STATEMENT.THE OFFICIAL STATEMENT FOR THE BANS WAS A LIGHTLY REVISEDVERSION OF THE PRELIMINARY OFFICIAL STATEMENT PREPAR

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