pruco securities, llc. · firm profile 2 - 9 page(s) firm operations 12 - 28 ... absher, michael...

BrokerCheck Report

PRUCO SECURITIES, LLC.

Section Title

Report Summary

Firm History

CRD# 5685

1

10

Firm Profile 2 - 9

Page(s)

Firm Operations 12 - 28

Disclosure Events 29

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CRD# 5685

SEC# 8-16402

Main Office Location

751 BROAD STREETNEWARK, NJ 07102-3777Regulated by FINRA Woodbridge Office

Mailing Address

751 BROAD STREETNEWARK, NJ 07102-3777

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

800-201-6690

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 28

Arbitration 12

Bond 2

Firm Profile

This firm is classified as a limited liability company.

This firm was formed in New Jersey on 09/22/2003.

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 10 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• 52 U.S. states and territories

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1©2020 FINRA. All rights reserved. Report about PRUCO SECURITIES, LLC.

https://adviserinfo.sec.gov/firm/summary/5685


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This firm is classified as a limited liability company.

This firm was formed in New Jersey on 09/22/2003.

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.


SEC#

5685

8-16402

Main Office Location

Mailing Address

Business Telephone Number

Doing business as PRUCO SECURITIES, LLC.

800-201-6690

Regulated by FINRA Woodbridge Office








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?

THE PRUDENTIAL INSURANCE COMPANY OF AMERICA

SOLE MEMBER

75% or more

No

Domestic Entity

12/2000

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


ABSHER, MICHAEL SCOTT

ELECTED MANAGER

Less than 5%

No

Individual

12/2018

Yes

2131443



Position


Position Start Date

BEGUN, ROBERT

PRINCIPAL OPERATIONS OFFICER, CHIEF SUPERVISORY OFFICER

Less than 5%

Individual

10/2019

4436053








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

No

Position



Position Start Date


FELICIANO, DEXTER MICHAEL

CHIEF OPERATING OFFICER, VICE PRESIDENT, ELECTED MANAGER

Less than 5%

No

Individual

10/2019

No

5483537



Position



Position Start Date


FONTANO, ANTHONY MICHAEL

ELECTED MANAGER

Less than 5%

No

Individual

07/2017

No

6852155



GAYLE, PETER CASEY

3095277








Firm Profile

Position



Position Start Date


ELECTED MANAGER

Less than 5%

No

Individual

07/2017

Yes

3095277


Position



Position Start Date


HEARN, BRADFORD ONEIL

CHAIRMAN, ELECTED MANAGER

Less than 5%

No

Individual

12/2018

Yes

2630134



Position


Position Start Date


HITCHCOCK, SALENE MARIE

ELECTED MANAGER

Less than 5%

Individual

06/2018

Yes

2590328









Firm Profile



No

Yes

Position



Position Start Date


HYNES, PATRICK LIAM

ELECTED MANAGER, PRESIDENT

Less than 5%

No

Individual

11/2018

Yes

2748918



Position



Position Start Date


IBRAHIM, HASAN

CHIEF LEGAL OFFICER, VICE PRESIDENT, & ASSISTANT SECRETARY

Less than 5%

No

Individual

07/2017

No

5008182



INGRAHAM, FRANK TODD

Individual

2918519









Firm Profile

Position



Position Start Date


CHIEF COMPLIANCE OFFICER, VICE PRESIDENT

Less than 5%

No

Individual

04/2020

No


Position



Position Start Date


SMIT, ROBERT PHILIP

CHIEF FINANCIAL OFFICER, PRINCIPAL FINANCIAL OFFICER,CONTROLLER

Less than 5%

No

Individual

02/2019

Yes

2332366



Position


Position Start Date


SMITH, CHARLES HERBERT

ANTI-MONEY LAUNDERING OFFICER

Less than 5%

Individual

10/2016

No

6720010









Firm Profile



No

No

Position



Position Start Date


WILCOX, WILLIAM DAVID

VICE PRESIDENT

Less than 5%

No

Individual

07/2018

No

2906726








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

Indirect Owners

Firm Profile

PRUDENTIAL FINANCIAL, INC.

SOLE MEMBER

THE PRUDENTIAL INSURANCE COMPANY OF AMERICA

75% or more

Yes

Domestic Entity

12/2001

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established









Firm History

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

01/01/2004Date of Succession:

This firm was previously:

Predecessor SEC#:

PRUCO SECURITIES CORPORATION

8-152208

5685Predecessor CRD#:

Description THE FIRM IS CONVERTING FROM A SUB-CHAPTER C CORPORATION TO ALIMITED LIABILITY COMPANY. THE LIMITED LIABILITY COMPANY ISASSUMING ALL OF THE RIGHTS, DUTIES, AND OBLIGATIONS OF THECORPORATION. THERE ARE NO ASSETS OR LIABILITIES NOT ASSUMED BYTHE SUCCESSOR. THERE IS NO SUBSTANTIAL CHANGE IN OWNERSHIPAND NO CHANGE IN CONTROL.



Predecessor SEC#:


8-16402


Description THE FIRM CONVERTED FROM A SUB-CHAPTER C CORPORATION TO ALIMITED LIABILITY COMPANY. THE LIMITED LIABILITY COMPANY ASSUMEDALL OF THE RIGHTS, DUTIES, AND OBLIGATIONS OF THE CORPORATION.THERE WERE NO ASSETS OR LIABILITIES NOT ASSUMED BY THESUCCESSOR. THERE WAS NO SUBSTANTIAL CHANGE IN OWNERSHIP ANDNO CHANGE IN CONTROL.



Predecessor SEC#:


8-16402





Predecessor SEC#:


8-152208







Predecessor SEC#: 8-152208

Description THE FIRM IS CONVERTING FROM A SUB-CHAPTER C CORPORATION TO ALIMITED LIABILITY COMPANY. THE LIMITED LIABILITY COMPANY ISASSUMING ALL OF THE RIGHTS, DUTIES, AND OBLIGATIONS OF THECORPORATION. THERE ARE NO ASSETS OR LIABILITIES NOT ASSUMED BYTHE SUCCESSOR.



Predecessor SEC#:


8-152208







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 52 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 04/09/1971

Self-Regulatory Organization Status Date Effective

FINRA Approved 04/16/1971






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 10/06/1982

Alaska Approved 09/24/1982

Arizona Approved 07/27/1982

Arkansas Approved 02/11/1993

California Approved 11/17/1981

Colorado Approved 02/01/1983

Connecticut Approved 07/26/1982

Delaware Approved 07/30/1982

District of Columbia Approved 11/25/1982

Florida Approved 04/27/1983

Georgia Approved 09/22/1981

Hawaii Approved 07/12/1982

Idaho Approved 03/03/1982

Illinois Approved 04/07/1982

Indiana Approved 04/23/1982

Iowa Approved 07/14/1983

Kansas Approved 05/15/1982

Kentucky Approved 07/16/1982

Louisiana Approved 04/20/1983

Maine Approved 02/14/1984

Maryland Approved 04/02/1982

Massachusetts Approved 01/07/1982

Michigan Approved 02/03/1983

Minnesota Approved 07/15/1982

Mississippi Approved 02/11/1982

Missouri Approved 07/18/1983

Montana Approved 04/20/1983

Nebraska Approved 11/13/1995

Nevada Approved 07/19/1983

New Hampshire Approved 05/04/1982

New Jersey Approved 07/14/1983

New Mexico Approved 05/06/1982

New York Approved 12/01/1981

U.S. States &Territories

Status Date Effective

North Carolina Approved 07/15/1982

North Dakota Approved 03/16/1982

Ohio Approved 07/16/1982

Oklahoma Approved 07/17/1982

Oregon Approved 03/16/1982

Pennsylvania Approved 12/04/1981

Puerto Rico Approved 02/26/2014

Rhode Island Approved 02/01/1983

South Carolina Approved 12/17/1981

South Dakota Approved 07/15/1982

Tennessee Approved 11/20/1981

Texas Approved 07/25/1983

Utah Approved 04/21/1983

Vermont Approved 02/13/1984

Virginia Approved 03/12/1982

Washington Approved 04/20/1983

West Virginia Approved 01/04/1982

Wisconsin Approved 04/27/1982

Wyoming Approved 02/12/1982






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.

This firm currently conducts 10 types of businesses.

Types of Business

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

Broker or dealer selling corporate debt securities

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

Mutual fund underwriter or sponsor

Mutual fund retailer

U S. government securities broker

Municipal securities broker

Broker or dealer selling variable life insurance or annuities

Investment advisory services

Non-exchange member arranging for transactions in listed securities by exchange member






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: CAMBRIDGE INVESTMENT RESEARCH, INC.

Business Address: 1776PLEASANT PLAIN ROADFAIRFIELD, IA 52556

CRD #: 39543

Effective Date: 01/08/2008

Description: CAMBRIDGE INVESTMENT RESEARCH, INC. ("CAMBRIDGE") AND THEREGISTRANT HAVE ENTERED INTO AN ARRANGEMENT WHEREBY THEREGISTRANT REFERS OR INTRODUCES CUSTOMERS TO CAMBRIDGE.PRUCO REGISTERED REPRESENTATIVES MAY RECEIVE A SHARE OFANY COMMISSIONS WHICH MAY RESULT FROM THE TRANSACTION OFSECURITIES BUSINESS BETWEEN CAMBRIDGE AND SUCHCUSTOMERS.

Name: THE LEADERS GROUP, INC.

Business Address: 26 W. DRY CREEK CIRCLESUITE 575LITTLETON, CO 80120

CRD #: 37157


Description: THE LEADERS GROUP, INC.("LEADERS GROUP")AND THE REGISTRANTHAVE ENTERED INTO AN ARRANGEMENT WHEREBY THE REGISTRANTREFERS OR INTRODUCES CUSTOMERS TO LEADERS GROUP. PRUCOREGISTERED REPRESENTATIVES MAY RECEIVE A SHARE OF ANYCOMMISSIONS WHICH MAY RESULT FROM THE TRANSACTION OFSECURITIES BUSINESS BETWEEN LEADERS GROUP AND SUCHCUSTOMERS.

Name: CENTAURUS FINANCIAL, INC.

Business Address: 333 CITY BLVD WESTSUITE #2010ORANGE, CA 92868

CRD #: 30833






Firm Operations

Introducing Arrangements

This firm does refer or introduce customers to other brokers and dealers.Business Address: 333 CITY BLVD WESTSUITE #2010ORANGE, CA 92868


Description: CENTAURUS FINANCIAL, INC. ("CENTAURUS") AND THE REGISTRANTHAVE ENTERED INTO AN ARRANGEMENT WHEREBY THE REGISTRANTREFERS OR INTRODUCES CUSTOMERS TO CENTAURUS. PRUCOREGISTERED REPRESENTATIVES MAY RECEIVE A SHARE OF ANYCOMMISSIONS WHICH MAY RESULT FROM THE TRANSACTION OFSECURITIES BUSINESS BETWEEN CENTAURUS AND SUCHCUSTOMERS.

Name: AXA ADVISORS, LLC

Business Address: 1290 AVENUE OF THE AMERICASNEW YORK, NY 10104

CRD #: 6627


Description: AXA ADVISORS, LLC AND THE REGISTRANT HAVE ENTERED INTO ANARRANGEMENT WHEREBY REGISTRANT REFERS OR INTRODUCESCUSTOMERS TO AXA ADVISORS, LLC. PRUCO REGISTEREDREPRESENTATIVES MAY RECEIVE A SHARE OF ANY COMMISSIONSWHICH MAY RESULT FROM THE TRANSACTION OF SECURITIESBUSINESS BETWEEN AXA ADVISORS, LLC AND SUCH CUSTOMERS.






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: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA

Business Address: 751 BROAD STREETNEWARK, NJ 07102-3777


Description: THE PRUDENTIAL INSURANCE COMPANY OF AMERICA PROVIDESREGISTRANT WITH ACCOUNTING AND RECORDKEEPING SERVICES ONA COST REIMBURSEMENT BASIS PURSUANT TO AN ADMINISTRATIVESERVICE AGREEMENT.

Name: NATIONAL FINANCIAL SERVICES LLC

Business Address: 200 SEAPORT BLVDMAIL ZONE Z1NBOSTON, MA 02210

CRD #: 13041


Description: THE REGISTRANT ENTERED INTO AN AGREEMENT WITH NATIONALFINANCIAL SERVICES, LLC. TO EXECUTE ORDERS AND CARRYACCOUNTS FOR ITS CUSTOMERS, AS WELL AS, PROPRIETARYACCOUNTS ON A FULLY DISCLOSED BASIS. THE REGISTRANT ACTS ASAN INTRODUCING BROKER. NATIONAL FINANCIAL SERVICES, LLC.ENGAGES IN ALL CASHIERING FUNCTIONS FOR INTRODUCEDACCOUNTS.

Name: NATIONAL FINANCIAL SERVICES LLC

Business Address: 200 SEAPORT BLVDMAIL ZONE Z1NBOSTON, MA 02210

CRD #: 13041


Description: THE REGISTRANT ENTERED INTO AN AGREEMENT WITH NATIONALFINANCIAL SERVICES, LLC., TO EXECUTE ORDERS AND CARRYACCOUNTS FOR ITS CUSTOMERS, AS WELL AS, PROPRIETARYACCOUNTS ON A FULLY DISCLOSED BASIS. THE REGISTRANT ACTS ASAN INTRODUCING BROKER. NATIONAL FINANCIAL SERVICES,LLC.ENGAGES IN ALL CASHIERING FUNCTIONS FOR INTRODUCEDACCOUNTS.






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

THE REGISTRANT ENTERED INTO AN AGREEMENT WITH NATIONALFINANCIAL SERVICES, LLC., TO EXECUTE ORDERS AND CARRYACCOUNTS FOR ITS CUSTOMERS, AS WELL AS, PROPRIETARYACCOUNTS ON A FULLY DISCLOSED BASIS. THE REGISTRANT ACTS ASAN INTRODUCING BROKER. NATIONAL FINANCIAL SERVICES,LLC.ENGAGES IN ALL CASHIERING FUNCTIONS FOR INTRODUCEDACCOUNTS.






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

10/14/2016

213 WASHINGTON ST.NEWARK, NJ 07102-2917

286153

PRUDENTIAL CUSTOMER SOLUTIONS LLC is under common control with the firm.

PRUDENTIAL CUSTOMER SOLUTIONS LLC AND PRUCO SECURITIES LLCARE SEC REGISTERED INVESTMENT ADVISERS UNDER COMMONCONTROL OF PRUDENTIAL INSURANCE COMPANY OF AMERICA (SEC FILENUMBER: 801-108896).

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

CAMYAN ISLANDS

Yes

07/01/2008

OGIER FIDUCIARY SERVICES (CAYMAN) LIMITED89 NEXUS WAYCAMANA BAY, CAYMAN ISLANDS KYI-9007

GAP ADVISORS (CAYMAN) LTD is under common control with the firm.

40% OWNED INDIRECT SUBSIDIARY OF PRUDENTIAL FINANCIAL, INC.,APPLICANT'S ULTIMATE PARENT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations

Organization Affiliates (continued)40% OWNED INDIRECT SUBSIDIARY OF PRUDENTIAL FINANCIAL, INC.,APPLICANT'S ULTIMATE PARENT.

Description:

Yes

No

INDIA

Yes

09/24/2008

NIRLON HOUSE, 2ND FLOORDR. ANNIE BESANT ROADWORLI, MUBAI, INDIA 400 030

PRAMERICA ASSET MANAGERS PRIVATE LIMITED is under common control with the firm.

INDIRECT SUBSIDIARY OF PRUDENTIAL FINANCIAL, INC., APPLICANT'SULTIMATE PARENT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

No

JAPAN

Yes

09/01/2006

THE PRUDENTIAL TOWER2-13-10NAGATACHO, CHIYODA-KU, JAPAN 100-0014

PRUDENTIAL INVESTMENT MANAGEMENT JAPAN CO., LTD. is under common control with the firm.

AN INDIRECT SUBSIDIARY OF PRUDENTIAL FINANCIAL, INC., APPLICANT'SULTIMATE PARENT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

08/16/2005

100 MULBERRY STREETGATEWAY CENTER TWO, 6TH FLOORNEWARK, NJ 07102

136274

PRUDENTIAL INTERNATIONAL INVESTMENTS ADVISERS is under common control with the firm.

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations

Organization Affiliates (continued)

Yes

No

No

SEC FILE # 801-64609INDIRECT SUBSIDIARY OF PRUDENTIAL FINANCIAL, INC., APPLICANT'SULTIMATE PARENT.

Description:



Country:

Foreign Entity:

Yes

Yes

HONG KONG

Yes

10/04/1988

UNITS 3001-3002 AND 3010, 30TH FLOOREDINBURGH TOWER, THE LANDMARK, 15 QUEEN'S RDCENTRAL HONG KONG, HONG KONG

PRAMERICA ASIA FUND MANAGEMENT LIMITED is under common control with the firm.

100% OWNED BY PRAMERICA FINANCIAL ASIA LIMITED, A SUBSIDIARY OFAPPLICANT'S ULTIMATE PARENT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

Yes

TAIWAN

Yes

11/06/1992

3F NO. 161,SECTION 5, NANJING EAST ROADTAIPEI, TAIWAN R.O.C. 10570

PRUDENTIAL FINANCIAL SECURITIES INVESTMENT TRUST ENTERPRISE is under common control with thefirm.

91% OWNED BY THE PRUDENTIAL INSURANCE COMPANY OF AMERICA, ASUBSIDIARY OF PRUDENTIAL FINANCIAL, INC., APPLICANT'S ULTIMATEPARENT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations

Organization Affiliates (continued)91% OWNED BY THE PRUDENTIAL INSURANCE COMPANY OF AMERICA, ASUBSIDIARY OF PRUDENTIAL FINANCIAL, INC., APPLICANT'S ULTIMATEPARENT.

Yes

Yes

GERMANY

Yes

01/01/2003

WITTELSBACHERPLATZ 1MUNCHEN, MU, GERMANY 80333

PRAMERICA REAL ESTATE INTERNATIONAL AG is under common control with the firm.


Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

No

ENGLAND, UK

Yes

05/30/1996

GRAND BUILDINGS, 1-3 STRANDTRAFALGER SQUARELONDON EN, ENGLAND, UK WC2N 5HR

PRAMERICA FUND MANAGEMENT LIMITED is under common control with the firm.


Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

ENGLAND, UK

Yes

07/01/1991


PRICOA CAPITAL GROUP LIMITED is under common control with the firm.


Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations


Yes

No


Description:



Yes

Yes

ENGLAND, UK

Yes

07/14/1999


PRAMERICA INVESTMENT MANAGEMENT LIMITED is under common control with the firm.


Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

No

SINGAPORE

Yes

06/11/1994

1 RAFFLES PLACE #26-61ONE RAFFLES PLACE, TOWER #2SINGAPORE, SINGAPORE 048616

PRAMERICA REAL ESTATE INVESTORS (ASIA) PTE. LTD. is under common control with the firm.


Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

50 RAFFLES PLACE#27-04 SINGAPORE LAND TOWERSINGAPORE, SINGAPORE 048623

PRAMERICA FIXED INCOME (ASIA) LIMITED is under common control with the firm.

Business Address:






Firm Operations


Yes

No

SINGAPORE

Yes

05/30/2008

50 RAFFLES PLACE#27-04 SINGAPORE LAND TOWERSINGAPORE, SINGAPORE 048623


Description:



Country:

Foreign Entity:

Effective Date:

Yes

No

No

01/23/2004

GATEWAY CENTER II, MCCARTER HWY & MARKET STREETNEWARK, NJ 07102

129752

QUANTITATIVE MANAGEMENT ASSOCIATES is under common control with the firm.

INDIRECT AFFILIATE OF APPLICANT; SEC FILE # 801-62692Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

No

04/01/2004

900 COTTAGE GROVE ROADBLOOMFIELD, CT 06002

105812

GLOBAL PORTFOLIO STRATEGIES, INC. is under common control with the firm.


Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations



Description:

No

Yes

No

05/01/2003

ONE CORPORATE DRIVESHELTON, CT 06484

21570

PRUDENTIAL ANNUITIES DISTRIBUTORS, INC is under common control with the firm.

PRUCO SECURITIES IS UNDER COMMON CONTROL WITH INDIRECTAFFILIATE OF APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

No

05/01/2003

ONE CORPORATE DRIVESHELTON, CT 06484

108897

AST INVESTMENT SERVICES, INC. is under common control with the firm.

PRUCO SECURITIES IS UNDER COMMON CONTROL WITH INDIRECTAFFILIATE OF APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

12/31/1987

751 BROAD STREETNEWARK, NJ 07102

105670

PRUDENTIAL INVESTMENTS LLC is under common control with the firm.

Effective Date:

Business Address:

CRD #:






Firm Operations


Yes

No

No

12/31/1987

INDIRECT AFFILIATE OF APPLICANT; SEC FILE NO. 801-31104Description:



Country:

Foreign Entity:

Effective Date:

Yes

No

No

03/09/1993

100 MULBERRY STREETGATEWAY CENTER 4NEWARK, NJ 07102

106442

PRUDENTIAL PRIVATE PLACEMENT INVESTORS, L.P. is under common control with the firm.




Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

No

04/16/1969

466 LEXINGTON AVENUENEW YORK, NY 10017

107959

JENNISON ASSOCIATES LLC is under common control with the firm.

JENNISON IS A WHOLLY-OWNED SUBSIDIARY OF PRUDENTIAL,APPLICANT'S ULTIMATE PARENT. (SEC FILE NO. 801-5608)

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations

Organization Affiliates (continued)JENNISON IS A WHOLLY-OWNED SUBSIDIARY OF PRUDENTIAL,APPLICANT'S ULTIMATE PARENT. (SEC FILE NO. 801-5608)

Description:

Yes

No

No

12/27/1976

PRUDENTIAL PLAZA751 BROAD STREETNEWARK, NJ 07102

THE PRUDENTIAL INSURANCE COMPANY OF AMERICA controls the firm.

PRUDENTIAL IS A REGISTERED INVESTMENT ADVISOR AND SOLE MEMBEROF APPLICANT. (SEC FILE NO. 801-12484)

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

No

No

06/06/1984

PRUDENTIAL PLAZA751 BROAD STREETNEWARK, NJ 07102

105676

PRUDENTIAL INVESTMENT MANAGEMENT, INC. is under common control with the firm.




Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

10/30/1986

100 MULBERRY STREETGATEWAY CENTER THREE, 14TH FLRNEWARK, NJ 07102-4777

18353

PRUDENTIAL INVESTMENT MANAGEMENT SERVICES LLC is under common control with the firm.

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations


No

Yes

No




Country:

Foreign Entity:

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 1 27 0

Arbitration N/A 12 N/A

Bond N/A 2 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 27

Reporting Source: Firm

Allegations: IN 2014, PICA DISCOVERED THAT IT HAD BILLED AND COLLECTED GROUPUNIVERSAL LIFE INSURANCE PREMIUM AT PREMIUM RATES THAT WEREMORE THAN THE MAXIMUM PREMIUM RATES SET FORTH IN CERTAINGROUP UNIVERSAL LIFE INSURANCE POLICIES. UPON DISCOVERY, PICASELF-REPORTED THIS MATTER TO ITS REGULATORS. THE INSURANCEDIVISION OF THE SOUTH DAKOTA DEPARTMENT OF LABOR ANDREGULATION ISSUED A CONSENT ORDER AND IMPOSED A MONETARYPENALTY. THE CONSENT ORDER WAS SIGNED AND RETURNED ALONGWITH A CHECK FOR $2,500 TO THE DIVISION ON SEPTEMBER 28, 2017.

Current Status: Final






Initiated By: INSURANCE DIVISION OF THE SOUTH DAKOTA DEPARTMENT OF LABORAND REGULATION

Principal Sanction(s)/ReliefSought:

Civil and Administrative Penalt(ies) /Fine(s)

Other Sanction(s)/ReliefSought:

Date Initiated: 09/11/2017

Docket/Case Number: 100621

Principal Product Type: Insurance

Other Product Type(s):

Allegations: IN 2014, PICA DISCOVERED THAT IT HAD BILLED AND COLLECTED GROUPUNIVERSAL LIFE INSURANCE PREMIUM AT PREMIUM RATES THAT WEREMORE THAN THE MAXIMUM PREMIUM RATES SET FORTH IN CERTAINGROUP UNIVERSAL LIFE INSURANCE POLICIES. UPON DISCOVERY, PICASELF-REPORTED THIS MATTER TO ITS REGULATORS. THE INSURANCEDIVISION OF THE SOUTH DAKOTA DEPARTMENT OF LABOR ANDREGULATION ISSUED A CONSENT ORDER AND IMPOSED A MONETARYPENALTY. THE CONSENT ORDER WAS SIGNED AND RETURNED ALONGWITH A CHECK FOR $2,500 TO THE DIVISION ON SEPTEMBER 28, 2017.

Resolution Date: 10/13/2017

Resolution:

Other Sanctions Ordered:

Sanction Details: UNDER A CONSENT ORDER, THE PRUDENTIAL INSURANCE COMPANY OFAMERICA ("PICA") WAS ORDERED TO PAY A $2,500 FINE FOR VIOLATINGSOUTH DAKOTA INSURANCE CODE §58-55-36 BY COLLECTING ASPREMIUMS OR CHARGES FOR INSURANCE ANY SUM IN EXCESS OF ORLESS THAN THE PREMIUMS OR CHARGES SPECIFIED IN THE POLICY INACCORDANCE WITH THE APPLICABLE CLASSIFICATIONS AND RATES ASFILED WITH AND APPROVED BY THE DIRECTOR OF THE INSURANCEDIVISION OF THE SOUTH DAKOTA DEPARTMENT OF LABOR ANDREGULATION.

Firm Statement IN 2014, PICA DISCOVERED THAT IT HAD BILLED AND COLLECTED GROUPUNIVERSAL LIFE INSURANCE PREMIUM AT PREMIUM RATES THAT WEREMORE THAN THE MAXIMUM PREMIUM RATES SET FORTH IN CERTAINGROUP UNIVERSAL LIFE INSURANCE POLICIES. UPON DISCOVERY, PICASELF-REPORTED THIS MATTER TO ITS REGULATORS. THE INSURANCEDIVISION OF THE SOUTH DAKOTA DEPARTMENT OF LABOR ANDREGULATION ISSUED A CONSENT ORDER AND IMPOSED A MONETARYPENALTY. THE CONSENT ORDER WAS SIGNED AND RETURNED ALONGWITH A CHECK FOR $2,500 TO THE DIVISION ON SEPTEMBER 28, 2017.

Sanctions Ordered: Monetary/Fine $2,500.00

Consent






IN 2014, PICA DISCOVERED THAT IT HAD BILLED AND COLLECTED GROUPUNIVERSAL LIFE INSURANCE PREMIUM AT PREMIUM RATES THAT WEREMORE THAN THE MAXIMUM PREMIUM RATES SET FORTH IN CERTAINGROUP UNIVERSAL LIFE INSURANCE POLICIES. UPON DISCOVERY, PICASELF-REPORTED THIS MATTER TO ITS REGULATORS. THE INSURANCEDIVISION OF THE SOUTH DAKOTA DEPARTMENT OF LABOR ANDREGULATION ISSUED A CONSENT ORDER AND IMPOSED A MONETARYPENALTY. THE CONSENT ORDER WAS SIGNED AND RETURNED ALONGWITH A CHECK FOR $2,500 TO THE DIVISION ON SEPTEMBER 28, 2017.

Disclosure 2 of 27

i

Reporting Source: Regulator

Initiated By: ILLINOIS


Other


SANCTION



URL for Regulatory Action:

Principal Product Type: Annuity(ies) - Variable


Allegations: PRUCO HAS FAILED TO REASONABLY SUPERVISE ITS REPRESENTATIVESAND REVIEWERS,AND ENFORCE ITS SUPERVISORY SYSTEMS ANDPROCEDURES DURING THE CTR REVIEW PROCESS FOR TRANSACTIONSWITH ILLINOIS CUSTOMERS. THESE FAILURES CAUSED THE APPROVAL OFCERTAIN VARIABLE ANNUITY APPLICATIONS WHICH SHOULD HAVEREQUIRED FURTHER SCRUTINY BY THE REVIEWER BEFORE APPROVAL.MOREOVER, PRUCO FAILED TO HAVE THE SUPERVISORY STRUCTURE INPLACE TO ADEQUATELY RESPOND TO THE DEPARTMENT'S REGULATORYREQUESTS REGARDING VARIABLE ANNUITY TRANSACTIONS WITHILLINOIS RESIDENTS.



Resolution:

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

No

Sanctions Ordered: CensureMonetary/Fine $750.00

Order






Other Sanctions Ordered: CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S)MONETARY PENALTY OTHER THAN FINESTOTAL AMOUNT: $750,000PORTION LEVIED AGAINST THE SUBJECT: $750,000DATE PAID BY THE SUBJECT:4/26/2017

Sanction Details: PORTION LEVIED AGAINST THE SUBJECT: $750,000DATE PAID BY THE SUBJECT:4/26/2017

Regulator Statement IF YOU HAVE ANY QUESTIONS PLEASE CONTACT ENFORCEMENTATTORNEY TOM SIANIS@(312) 793-3988

iReporting Source: Firm

Initiated By: STATE OF ILLINOISSECRETARY OF STATESECURITIES DEPARTMENT








Allegations: ON APRIL 20, 2017, PRUCO SECURITIES, LLC ENTERED INTO ASTIPULATION AND CONSENT ORDER WITH THE ILLINOIS SECURITIESDEPARTMENT. THE DEPARTMENT ALLEGED THAT PRUCO FAILED TOREASONABLY SUPERVISE AND ENFORCE ITS SUPERVISORY SYSTEMS INCONNECTION WITH CERTAIN SALES OF VARIABLE ANNUITIES IN ILLINOISFROM 2013-2016, AND FAILED TO SUPERVISE IN CONNECTION WITHRESPONDING TO THE DEPARTMENT'S REGULATORY REQUESTS. PRUCOHAS AGREED TO A FINE OF $750,000, PLUS COSTS AND RESTITUTION TOIMPACTED CUSTOMERS. PRUCO SECURITIES PAID THE FINE ON APRIL 26,2017.



Resolution:

Sanctions Ordered: CensureMonetary/Fine $750,000.00Disgorgement/Restitution

Consent






Other Sanctions Ordered: COSTS OF INVESTIGATION AND UNDERTAKINGS.

Sanction Details: PRUCO HAS AGREED TO A FINE OF $750,000, PLUS COSTS ANDRESTITUTION TO IMPACTED CUSTOMERS. PRUCO SECURITIES PAID THEFINE ON APRIL 26, 2017.


Disclosure 3 of 27

i


Initiated By: NEW JERSEY BUREAU OF SECURITIES




RESTITUTION


Docket/Case Number: 2012-019


Principal Product Type: Mutual Fund(s)


Allegations: FROM LATE 2003 THROUGH JUNE 2011 (THE "RELEVANT TIME PERIOD"),PRUCO'S COMMAND OPERATIONS STAFF, LOCATED IN WOODBRIDGE, NJSINCE 2004, UTILIZED A PROCESS FOR HANDLINGCERTAIN MUTUAL FUND ORDERS RECEIVED VIA FACSIMILE AND MAIL("PAPER ORDERS") THAT DID NOT COMPLY WITH INVESTMENT COMPANYACT ("ICA") RULE 22C-1. DURING THE RELEVANT TIME PERIOD, PRUCOFAILED TO HAVE AN ADEQUATE SUPERVISORY SYSTEM IN PLACE TOADDRESS THE PRICING OF PAPER ORDERS NECESSARY TO COMPLY WITHTHE PRICING REQUIREMENTS OF ICA RULE 22C-1. SPECIFICALLY,PRUCO'S SUPERVISORY SYSTEM IN PLACE WAS INADEQUATE TO ENSURETHAT CUSTOMERS SUBMITTING PAPER ORDERS FOR MUTUAL FUNDTRANSACTIONS RECEIVED THE CORRECT PRICE OR TO DETECT ANDPREVENT THE MISPRICING OF PAPER ORDERS FOR MUTUAL FUNDTRANSACTIONS. ADDITIONALLY, PRUCO FAILED DURING THE RELEVANTTIME PERIOD TO HAVE WRITTEN PROCEDURESFOR THE PRICING OF MUTUAL FUND ORDERS, PARTICULARLY ORDERSRECEIVED AND COMPLETE BEFORE 4 P.M. ON ANY PARTICULAR TRADINGDAY. PRUCO PROVIDED NO TRAINING OR TRAINING MATERIALS TO ITSCOMMAND OPERATIONS STAFF REGARDING THE PRICINGREQUIREMENTS OFICA RULE 22C-1 WITH RESPECT TO PAPER ORDERS.








RESTITUTION


Resolution:

Other Sanctions Ordered: THAT PRUCO IS ASSESSED AND SHALL PAY A CIVIL MONETARY PENALTY INTHE AMOUNT OF $40,000 AND COSTS IN THE AMOUNT OF $20,000.ADDITIONALLY, PRUCO SHALL PAY $40,000, WHICH SHALLBE PLACED IN A FUND TO BE USED FOR THE BUREAU'S INVESTOREDUCATION PROGRAM. PRUCO IS ORDERED TO PAY RESTITUTION IN THEAMOUNT OF UP TO $125,000 TO UP TO AN ADDITIONAL 253 NEW JERSEYACTIVE AND INACTIVE ACCOUNTS WHOSE ELIGIBILITY FOR OR AMOUNTOF RESTITUTION HAD NOT BEEN DETERMINED OR WHERE CERTAININFORMATION WAS NEEDED TO EFFECT RESTITUTION AS OF THE DATE OFTHIS CONSENT ORDER. PRUCO IS ORDERED TO IMPLEMENT ACORRECTIVE PLAN, DESIGNED TO STRENGTHEN THE INTERFACEBETWEEN THE PRUCO COMPLIANCE FUNCTION AND COMMANDOPERATIONS. A. PRUCO IS TO ENSURE THAT ITS RISK-BASEDMONITORING TOOLS FOR COMMAND FUNCTIONS USED BY COMPLIANCEOR OTHERWISE ARE REASONABLY SUFFICIENT TO PREVENT ARECURRENCE OF THE VIOLATIONS CITED HEREIN. B. PRUCO IS TOREASONABLY ENSURE ONGOING COMMUNICATION, UNDERSTANDING ANDEXECUTION OF COMMAND COMPLIANCE JOB RESPONSIBILITIES. C.PRUCO IS TO REASONABLY ENSURE ONGOING APPROPRIATE TRAININGFOR COMMAND COMPLIANCE STAFF. PRUCO IS TO COMPLETE ABUSINESS RULE AND PROCESS REVIEW TO IDENTIFY AND DOCUMENTCOMPLIANCE RULES, PROCEDURES AND IMPROVEMENT OPPORTUNITIESFOR COMMAND. UNLESS OTHERWISE AGREED TO BY THE BUREAU CHIEF,PRUCO HAS AN ONGOING OBLIGATION TO UPDATE THE BUREAU EVERYONE HUNDRED EIGHTY (180) DAYS FROM THE EFFECTIVE DATE OF THECONSENT ORDER AS TO THE STATUS OF PROVIDING RESTITUTION TOACTIVE AND INACTIVE ACCOUNTS PURSUANT TO PARAGRAPH 20 OF THISCONSENT ORDER.

Sanction Details: PRUCO FAILED TO PRICE PAPER ORDERS IN ACCORDANCE WITH THEREQUIREMENTS OF ICA RULE 22C-1, VIOLATING FINRA RULES 2010 ANDNASD RULE 2110, CONSTITUTING A VIOLATION OF N.J.S.A. 49:3-58(A)(L)(A)(2)(VII) AND N.J.A.C. 13:47A-6.3(A)(28). PRUCO'S CONDUCTCONSTITUTES A FAILURE TO REASONABLY SUPERVISE ITS AGENTS,PURSUANT TO N.J.S.A. 49:3-58(A)(L) AND N.J.S.A. 49:3-58(A)(2)(XI).


No

Sanctions Ordered: Monetary/Fine $40,000.00Disgorgement/Restitution

Consent






PRUCO FAILED TO PRICE PAPER ORDERS IN ACCORDANCE WITH THEREQUIREMENTS OF ICA RULE 22C-1, VIOLATING FINRA RULES 2010 ANDNASD RULE 2110, CONSTITUTING A VIOLATION OF N.J.S.A. 49:3-58(A)(L)(A)(2)(VII) AND N.J.A.C. 13:47A-6.3(A)(28). PRUCO'S CONDUCTCONSTITUTES A FAILURE TO REASONABLY SUPERVISE ITS AGENTS,PURSUANT TO N.J.S.A. 49:3-58(A)(L) AND N.J.S.A. 49:3-58(A)(2)(XI).

Regulator Statement THE BUREAU, IN ENTERING INTO THIS CONSENT ORDER AND ASSESSINGAPPROPRIATE SANCTIONS, HAS CONSIDERED THAT PRUCO SELF-REPORTED THE MUTUAL FUND PAPER ORDER ISSUE, UNDERTOOK ANINTERNAL REVIEW, IMPLEMENTED CHANGES TO ITS POLICIES ANDPROCEDURES, AND COMMENCED RESTITUTION TO AFFECTEDCUSTOMERS AS DESCRIBED BELOW. SINCE THIS OCCURRENCE, PRUCO,WITH THE ASSISTANCE OF A THIRD-PARTY, REVIEWED PAPER ORDERSFROM THE RELEVANT TIME PERIOD TO DETERMINE WHETHER THEYWERE ELIGIBLE FOR RESTITUTION. PRUCO INSTITUTED A RESTITUTIONMETHODOLOGY IN WHICH EACH ACTIVE AFFECTED CUSTOMER ACCOUNT,AND INACTIVE CUSTOMER ACCOUNTS ABOVE A DE MINIMIS THRESHOLD,HAVE RECEIVED OR WILL RECEIVE THE BEST PRICE FOR A SINGLE ORDEROR AGGREGATED ORDERS, AS APPLICABLE, BETWEENTHE ACTUAL TRADE DATE PRICE AND THE PRICE FOR THE TWO PRIORMARKET DAYS.


Initiated By: STATE OF NEW JERSEY BUREAU OF SECURITIES








Allegations: THE FIRM REPORTED TO THE NJ BUREAU OF SECURITIES ("BUREAU")ANOPERATIONAL ERROR RELATED TO ITS COMMAND BROKERAGE DESK'SDELAYED PROCESSING AND PRICING OF CERTAIN MUTUAL FUNDTRANSACTIONS RECEIVED VIA MAIL OR FACSIMILE ("PAPER TRADE")FROM LATE 2003 THROUGH JUNE 2011, DURING WHICH THE FIRM FAILEDTO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM FORTHE PRICING OF PAPER TRADES.


Resolution: Consent36©2020 FINRA. All rights reserved. Report about PRUCO SECURITIES, LLC.






Resolution:

Other Sanctions Ordered: THE BUREAU IMPOSED A $40,000 CIVIL PENALTY, $20,000 IN COSTS AND$40,000 PAYMENT TO THE BUREAU'S INVESTOR EDUCATION PROGRAM.THE FIRM MUST ALSO PAY RESTITUTION IN AN AMOUNT UP TO $125,000 TOIMPACTED NJ RESIDENTS AND IMPLEMENT A CORRECTIVE PLAN ANDPERFORM A BUSINESS RULE AND PROCESS REVIEW. UNLESS OTHERWISEAGREED TO BY THE BUREAU CHIEF, THE FIRM MUST UPDATE THE BUREAUEVERY 180 DAYS OF STATUS OF PROVIDING RESTITUTION TO ACTIVE ANDINACTIVE ACCOUNTS.

Sanction Details: ON 05/02/2013, THE FIRM AGREED TO A CONSENT ORDER, WITHOUTADMITTING OR DENYING THE FINDINGS, WHEREBY THE BUREAU IMPOSEDA $40,000 CIVIL PENALTY, $20,000 IN COSTS AND $40,000 PAYMENT TO THEBUREAU'S INVESTOR EDUCATION PROGRAM. THE FIRM MUST ALSO PAYRESTITUTION IN AN AMOUNT UP TO $125,000 TO IMPACTED NJ RESIDENTSAND IMPLEMENT A CORRECTIVE PLAN AND PERFORM A BUSINESS RULEAND PROCESS REVIEW. UNLESS OTHERWISE AGREED TO BY THE BUREAUCHIEF,THE FIRM MUST UPDATE THE BUREAU EVERY 180 DAYS ON STATUSOF PROVIDING RESTITUTION TO ACTIVE AND INACTIVE ACCOUNTS.

Firm Statement THE BUREAU MADE FINDINGS REGARDING (1)THE FIRM'S OPERATIONALERROR RELATED TO PAPER TRADES THAT VIOLATED INVESTMENTCOMPANY ACT RULE 22C-1 AND NEW JERSEY SECURITIES LAWS AND (2)ITS FAILURE TO REASONABLY SUPERVISE ITS AGENTS. WITHOUTADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THEDESCRIBED SANCTIONS AND TO ENTRY OF THE CONSENT ORDERRELATED TO THE MONETARY PENALTIES, RESTITUTION AND CORRECTIVEACTIONS.


Consent

Disclosure 4 of 27

i


Allegations: FINRA RULE 2010, NASD RULES 2110, 3010(A), 3010(B) - PRUCOSECURITIES, LLC IDENTIFIED AN ISSUE CONCERNING COMPLIANCE WITHINVESTMENT COMPANY ACT OF 1940 (ICA) RULE 22C-1 IN CONNECTIONWITH ITS PROCESSING AND PRICING OF CERTAIN PAPER ORDERS FORMUTUAL FUND TRADES BY ITS COMMAND BUSINESS UNIT WITHIN THEFIRM THAT PROVIDES RETAIL BROKERAGE BACK OFFICE SERVICES FORCERTAIN INVESTMENT PRODUCTS OFFERED THROUGH THE FIRM. THEFIRM DISCOVERED THAT FOR ALMOST EIGHT YEARS, THE BUSINESSUNIT'S PROCESS FOR HANDLING PAPER ORDERS DID NOT COMPLY WITHICA RULE 22C-1. THE BUSINESS UNIT WAS PRICING CERTAIN PAPERMUTUAL FUND ORDERS ON A DAY OTHER THAN THAT ON WHICHCOMPLETE ORDERS WERE RECEIVED AND COMPLETE PRIOR TO 4 P.M. ASA RESULT OF THIS PRACTICE, ON CERTAIN OCCASIONS, CUSTOMERSRECEIVED AN INFERIOR PRICE ON THEIR ORDERS. AS A RESULT, IT WASNECESSARY FOR THE FIRM, WITH THE ASSISTANCE OF A THIRD PARTYFIRM, TO REVIEW MORE THAN 1.8 MILLION PAPER ORDERS TODETERMINE WHETHER THEY WERE ELIGIBLE FOR RESTITUTION. IN ALL,RESTITUTION OF AT LEAST $10.7 MILLION PLUS INTEREST WILL BE PAID TOAPPROXIMATELY 37,000 ACCOUNTS REPRESENTING APPROXIMATELY34,000 CUSTOMERS FOR WHOM THE FIRM HAS ALREADY CALCULATEDTHE AMOUNT OF RESTITUTION. UP TO 3,240 ADDITIONAL CUSTOMERSWILL RECEIVE RESTITUTION UPON THE FIRM'S COMPLETION OF THERESTITUTION CALCULATIONS. THE FIRM FAILED TO HAVE AN ADEQUATESUPERVISORY SYSTEM TO ADDRESS THE PRICING OF PAPER MUTUALFUNDS NECESSARY TO COMPLY WITH THE PRICING REQUIREMENTS OFICA RULE 22C-1. ITS SUPERVISORY SYSTEM WAS INADEQUATE TOENSURE THAT CUSTOMERS SUBMITTING PAPER ORDERS FOR MUTUALFUND TRANSACTIONS RECEIVED THE CORRECT PRICE OR TO DETECTAND PREVENT THE MISPRICING OF PAPER ORDERS FOR MUTUAL FUNDTRANSACTIONS. THE FIRM FAILED TO HAVE WRITTEN PROCEDURES FORTHE PRICING OF MUTUAL FUND ORDERS, PARTICULARLY ORDERSRECEIVED AND COMPLETE BEFORE 4 P.M. ON ANY PARTICULAR TRADINGDAY. WHILE THE FIRM HAD NO WRITTEN PROCEDURES, ITS BUSINESSUNIT'S PAPER ORDER PRICING PRACTICE AND CODIFIED INTERNALGUIDELINES INCORRECTLY APPLIED A MUTUAL FUNDS PRICING PRACTICETHAT WAS INCONSISTENT WITH THE REQUIREMENTS OF ICA RULE 22C-1WHICH CONTINUED FOR AT LEAST EIGHT YEARS. DURING THIS TIMEPERIOD, THE FIRM DID NOT PROVIDE ITS EMPLOYEES WITH ANY TRAININGOR TRAINING MATERIAL REGARDING THE PRICING REQUIREMENTS OF ICARULE 22C-1 WITH RESPECT TO PAPER MUTUAL FUND ORDERS. INDETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDERED THATTHE FIRM SELF-REPORTED THE PAPER ORDER PRICING ISSUE,UNDERTOOK AN INTERNAL REVIEW OF THE ISSUES, IMPLEMENTEDCHANGES TO ITS POLICIES AND PROCEDURES AND COMMENCEDRESTITUTION TO THE AFFECTED CUSTOMERS.







Initiated By: FINRA





FINRA RULE 2010, NASD RULES 2110, 3010(A), 3010(B) - PRUCOSECURITIES, LLC IDENTIFIED AN ISSUE CONCERNING COMPLIANCE WITHINVESTMENT COMPANY ACT OF 1940 (ICA) RULE 22C-1 IN CONNECTIONWITH ITS PROCESSING AND PRICING OF CERTAIN PAPER ORDERS FORMUTUAL FUND TRADES BY ITS COMMAND BUSINESS UNIT WITHIN THEFIRM THAT PROVIDES RETAIL BROKERAGE BACK OFFICE SERVICES FORCERTAIN INVESTMENT PRODUCTS OFFERED THROUGH THE FIRM. THEFIRM DISCOVERED THAT FOR ALMOST EIGHT YEARS, THE BUSINESSUNIT'S PROCESS FOR HANDLING PAPER ORDERS DID NOT COMPLY WITHICA RULE 22C-1. THE BUSINESS UNIT WAS PRICING CERTAIN PAPERMUTUAL FUND ORDERS ON A DAY OTHER THAN THAT ON WHICHCOMPLETE ORDERS WERE RECEIVED AND COMPLETE PRIOR TO 4 P.M. ASA RESULT OF THIS PRACTICE, ON CERTAIN OCCASIONS, CUSTOMERSRECEIVED AN INFERIOR PRICE ON THEIR ORDERS. AS A RESULT, IT WASNECESSARY FOR THE FIRM, WITH THE ASSISTANCE OF A THIRD PARTYFIRM, TO REVIEW MORE THAN 1.8 MILLION PAPER ORDERS TODETERMINE WHETHER THEY WERE ELIGIBLE FOR RESTITUTION. IN ALL,RESTITUTION OF AT LEAST $10.7 MILLION PLUS INTEREST WILL BE PAID TOAPPROXIMATELY 37,000 ACCOUNTS REPRESENTING APPROXIMATELY34,000 CUSTOMERS FOR WHOM THE FIRM HAS ALREADY CALCULATEDTHE AMOUNT OF RESTITUTION. UP TO 3,240 ADDITIONAL CUSTOMERSWILL RECEIVE RESTITUTION UPON THE FIRM'S COMPLETION OF THERESTITUTION CALCULATIONS. THE FIRM FAILED TO HAVE AN ADEQUATESUPERVISORY SYSTEM TO ADDRESS THE PRICING OF PAPER MUTUALFUNDS NECESSARY TO COMPLY WITH THE PRICING REQUIREMENTS OFICA RULE 22C-1. ITS SUPERVISORY SYSTEM WAS INADEQUATE TOENSURE THAT CUSTOMERS SUBMITTING PAPER ORDERS FOR MUTUALFUND TRANSACTIONS RECEIVED THE CORRECT PRICE OR TO DETECTAND PREVENT THE MISPRICING OF PAPER ORDERS FOR MUTUAL FUNDTRANSACTIONS. THE FIRM FAILED TO HAVE WRITTEN PROCEDURES FORTHE PRICING OF MUTUAL FUND ORDERS, PARTICULARLY ORDERSRECEIVED AND COMPLETE BEFORE 4 P.M. ON ANY PARTICULAR TRADINGDAY. WHILE THE FIRM HAD NO WRITTEN PROCEDURES, ITS BUSINESSUNIT'S PAPER ORDER PRICING PRACTICE AND CODIFIED INTERNALGUIDELINES INCORRECTLY APPLIED A MUTUAL FUNDS PRICING PRACTICETHAT WAS INCONSISTENT WITH THE REQUIREMENTS OF ICA RULE 22C-1WHICH CONTINUED FOR AT LEAST EIGHT YEARS. DURING THIS TIMEPERIOD, THE FIRM DID NOT PROVIDE ITS EMPLOYEES WITH ANY TRAININGOR TRAINING MATERIAL REGARDING THE PRICING REQUIREMENTS OF ICARULE 22C-1 WITH RESPECT TO PAPER MUTUAL FUND ORDERS. INDETERMINING THE APPROPRIATE SANCTIONS, FINRA CONSIDERED THATTHE FIRM SELF-REPORTED THE PAPER ORDER PRICING ISSUE,UNDERTOOK AN INTERNAL REVIEW OF THE ISSUES, IMPLEMENTEDCHANGES TO ITS POLICIES AND PROCEDURES AND COMMENCEDRESTITUTION TO THE AFFECTED CUSTOMERS.





https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2011029046101






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 $550,000 AND ORDERED TOPAY AT LEAST $10.7 MILLION, PLUS INTEREST, IN RESTITUTION TOAPPROXIMATELY 34,000 CUSTOMERS FOR WHOM THE FIRM HAS ALREADYCALCULATED THE AMOUNT OF RESTITUTION. UP TO 3,240 ADDITIONALCUSTOMERS WILL RECEIVE RESTITUTION UPON THE FIRM'S COMPLETIONOF THE RESTITUTION CALCULATIONS. SUCH PAYMENTS COULD REACHOR EXCEED $2 MILLION. THE FIRM WILL ALSO UNDERTAKE TO PROVIDE ANUPDATED SCHEDULE TO FINRA OF CUSTOMERS TO BE PAID RESTITUTION.A REGISTERED FIRM PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OFPAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTEDEFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATERTHAN 120 DAYS AFTER THE DATE OF THE FINAL PAYMENTS TOCUSTOMERS THE FIRM HAS BEEN ABLE TO LOCATE. SUCH FINALPAYMENT SHALL OCCUR NO LATER THAN MARCH 31, 2013. IF THE FIRMCANNOT LOCATE ANY CUSTOMER IDENTIFIED IN THE SCHEDULE WITHIN120 DAYS, IT SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION ANDINTEREST TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY ORABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMERLAST RESIDED. THE FIRM SHALL PROVIDE SATISFACTORY PROOF OFSUCH ACTION TO FINRA WITHIN 45 DAYS OF FORWARDING THEUNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATESTATE AUTHORITY. WITHIN 90 DAYS OF THE ISSUANCE OF THIS AWC AREGISTERED FIRM PRINCIPAL SHALL SUBMIT TO FINRA THE TRANSACTIONAND PAYMENT INFORMATION REQUIRED RELATED TO THE 3,240CUSTOMER ACCOUNTS RESULTING IN ADDITIONAL RESTITUTIONPAYMENTS.


No


Acceptance, Waiver & Consent(AWC)






WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $550,000 AND ORDERED TOPAY AT LEAST $10.7 MILLION, PLUS INTEREST, IN RESTITUTION TOAPPROXIMATELY 34,000 CUSTOMERS FOR WHOM THE FIRM HAS ALREADYCALCULATED THE AMOUNT OF RESTITUTION. UP TO 3,240 ADDITIONALCUSTOMERS WILL RECEIVE RESTITUTION UPON THE FIRM'S COMPLETIONOF THE RESTITUTION CALCULATIONS. SUCH PAYMENTS COULD REACHOR EXCEED $2 MILLION. THE FIRM WILL ALSO UNDERTAKE TO PROVIDE ANUPDATED SCHEDULE TO FINRA OF CUSTOMERS TO BE PAID RESTITUTION.A REGISTERED FIRM PRINCIPAL SHALL SUBMIT SATISFACTORY PROOF OFPAYMENT OF RESTITUTION OR OF REASONABLE AND DOCUMENTEDEFFORTS UNDERTAKEN TO EFFECT RESTITUTION TO FINRA NO LATERTHAN 120 DAYS AFTER THE DATE OF THE FINAL PAYMENTS TOCUSTOMERS THE FIRM HAS BEEN ABLE TO LOCATE. SUCH FINALPAYMENT SHALL OCCUR NO LATER THAN MARCH 31, 2013. IF THE FIRMCANNOT LOCATE ANY CUSTOMER IDENTIFIED IN THE SCHEDULE WITHIN120 DAYS, IT SHALL FORWARD ANY UNDISTRIBUTED RESTITUTION ANDINTEREST TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY ORABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMERLAST RESIDED. THE FIRM SHALL PROVIDE SATISFACTORY PROOF OFSUCH ACTION TO FINRA WITHIN 45 DAYS OF FORWARDING THEUNDISTRIBUTED RESTITUTION AND INTEREST TO THE APPROPRIATESTATE AUTHORITY. WITHIN 90 DAYS OF THE ISSUANCE OF THIS AWC AREGISTERED FIRM PRINCIPAL SHALL SUBMIT TO FINRA THE TRANSACTIONAND PAYMENT INFORMATION REQUIRED RELATED TO THE 3,240CUSTOMER ACCOUNTS RESULTING IN ADDITIONAL RESTITUTIONPAYMENTS.


Initiated By: FINRA


Restitution



Docket/Case Number: AWC NO. 201102046101



Allegations: THE FIRM REPORTED TO FINRA AN OPERATIONAL ERROR RELATED TO ITSCOMMAND BROKERAGE DESK'S DELAYED PROCESSING AND PRICING OFCERTAIN MUTUAL FUND TRANSACTIONS RECEIVED VIA MAIL ORFACSIMILE ("PAPER TRADES") FROM LATE 2003 THROUGH JUNE 2011DURING WHICH THE FIRM FAILED TO ESTABLISH AND MAINTAIN ANADEQUATE SUPERVISORY SYSTEM FOR THE PRICING OF PAPER TRADES.



Resolution:


Sanction Details: ON 12/26/2012 THE FIRM AGREED TO AN AWC, WITHOUT ADMITTING ORDENYING THE FINDINGS, WHEREBY FINRA IMPOSED A CENSURE, A$550,000 FINE, A RESTITUTION IN AN AMOUNT OF AT LEAST $10.7 MILLION,PLUS INTEREST, AND UNDERTAKINGS RELATED TO THE RESTITUTION.

Firm Statement FINRA MADE FINDINGS REGARDING (1)THE FIRM'S OPERATIONAL ERRORRELATED TO PAPER TRADES THAT VIOLATED INVESTMENT COMPANY ACTRULE 22C-1 AND (2) ITS INADEQUATE SUPERVISORY SYSTEM TO ADDRESSTHE PRICING OF SUCH PAPER TRADES. WITHOUT ADMITTING ORDENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBEDSANCTIONS, TO THE ENTRY OF THE FINDINGS AND TO UNDERTAKINGSRELATED TO THE RESTITUTION, SUCH AS TO PROVIDE TO FINRA ANUPDATED SCHEDULE OF CUSTOMERS PAID RESTITUTION AS WELL ASSATISFACTORY PROOF OF PAYMENTS, EFFORTS TO EFFECTRESTITUTION, AND, AS APPLICABLE, ESCHEATMENT TO APPROPRIATESTATE AUTHORITIES.







www.finra.org/brokercheck User GuidanceFINRA MADE FINDINGS REGARDING (1)THE FIRM'S OPERATIONAL ERRORRELATED TO PAPER TRADES THAT VIOLATED INVESTMENT COMPANY ACTRULE 22C-1 AND (2) ITS INADEQUATE SUPERVISORY SYSTEM TO ADDRESSTHE PRICING OF SUCH PAPER TRADES. WITHOUT ADMITTING ORDENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBEDSANCTIONS, TO THE ENTRY OF THE FINDINGS AND TO UNDERTAKINGSRELATED TO THE RESTITUTION, SUCH AS TO PROVIDE TO FINRA ANUPDATED SCHEDULE OF CUSTOMERS PAID RESTITUTION AS WELL ASSATISFACTORY PROOF OF PAYMENTS, EFFORTS TO EFFECTRESTITUTION, AND, AS APPLICABLE, ESCHEATMENT TO APPROPRIATESTATE AUTHORITIES.

Disclosure 5 of 27

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Initiated By: KENTUCKY DEPARTMENT OF FINANCIAL INSTITUTIONS, DIVISION OFSECURITIES





Docket/Case Number: 2011-AH-0155


Principal Product Type: No Product


Allegations: FIRM FAILED TO REGISTER TWO AGENTS AS INVESTMENT ADVISERREPRESENTATIVES THAT ARE RECEIVING ADVSIORY COMPENSATION.



Resolution:


Sanction Details: FINE PAID ON 09/19/2011


No


Order







Initiated By: KENTUCKY DEPARTMENT OF FINANCIAL INSTITUTIONS





Docket/Case Number: 2011-AH-0155



Allegations: PRUCO SECURITIES DID NOT REGISTER TWO INDIVIDUALS ASINVESTMENT ADVISER REPRESENTATIVES WITH THE STATE.



Resolution:


Sanction Details: PRUCO SECURITIES PAID A $3,000 FINE.

Firm Statement THE KENTUCKY DEPARTMENT OF FINANCIAL INSTITUTIONS FOUND THATPRUCO SECURITIES HAD NOT REGISTERED TWO INDIVIDUALS ASINVESTMENT ADVISER REPRESENTATIVES WITH THE STATE. PRUCOSECURITIES CONSENTED TO THE DESCRIBED STATEMENT OF FACTS ANDPAID A $3,000 FINE.


Order

Disclosure 6 of 27

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Allegations: ON 3/30/2009, THE OFFICE EXECUTED A STIPULATION AND CONSENTAGREEMENT IN THE MATTER OF PRUCO WHO NEITHER ADMITTED NORDENIED THE FINDINGS BUT CONSENTED TO THE ENTRY OF THE OFFICE'SFINDINGS AS FOLLOWS: 1.) THAT PRUCO, BECAUSE OF THE ACTIONS OFONE OF ITS REGISTERED PRINCIPALS, FAILED TO PROPERLY SUPERVISEAN ASSOCIATED PERSON WHO SOLD AN UNREGISTERED SECURITY TO 7INVESTORS DURING YEARS 2002 AND 2003 IN THE FORM OF VIATICALSETTLEMENT CONTRACTS WHICH WERE NOT REGISTERED AS ASECURITY OR EXEMPT FROM REGISTRATION IN FLORIDA, 2.) THAT PRUCOHAD POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENTTHE SALE OF UNREGISTERED VIATICAL SETTLEMENT CONTRACTS ANDALSO TRAINED ITS REPRESENTATIVES, INCLUDING ITS REGISTEREDPRINCIPALS AND ASSOCIATED PERSONS, ON THESE POLICIES ANDPROCEDURES, AND; 3.) THAT THE ASSOCIATED PERSON HAD SUBMITTEDTO HIS REGISTERED PRINCIPAL THREE REQUEST FORMS TO APPROVEOUTSIDE BUSINESS ACTIVITIES AT OR ABOUT THE SAME TIME (TWOREQUESTS FOR AGENT APPOINTMENTS TO INSURANCE COMPANIES ANDA THIRD REQUEST FOR AN APPOINTMENT TO MUTUAL BENEFITSCORPORATION APPROVED UNDER THE BELIEF THAT IT WAS FOR ANAPPOINTMENT TO AN INSURANCE COMPANY SIMILAR TO THE OTHER TWOAPPOINTMENT REQUESTS).







Initiated By: FLORIDA OFFICE OF FINANCIAL REGULATION ("OFFICE")


Other


ON 3/30/2009, THE OFFICE EXECUTED A STIPULATION & CONSENTAGREEMENT WHEREBY PRUCO AGREED TO, WITHIN 90 DAYS AFTERENTRY OF THE FINAL ORDER, MAKE RESCISSION OFFERS TO 4INVESTORS, MINUS APPLICABLE CREDITS, PLUS UNREIMBURSEDPREMIUMS PAID RELATING TO VIATICAL SETTLEMENT CONTRACTS SOLDBY AN ASSOCIATED PERSON FOR THE PERIOD FROM MAY 5, 2004THROUGH OCTOBER 30, 2008.


Docket/Case Number: 0300-S-10/06


Principal Product Type: Other

Other Product Type(s): VIATICAL SETTLEMENT CONTRACTS

ON 3/30/2009, THE OFFICE EXECUTED A STIPULATION AND CONSENTAGREEMENT IN THE MATTER OF PRUCO WHO NEITHER ADMITTED NORDENIED THE FINDINGS BUT CONSENTED TO THE ENTRY OF THE OFFICE'SFINDINGS AS FOLLOWS: 1.) THAT PRUCO, BECAUSE OF THE ACTIONS OFONE OF ITS REGISTERED PRINCIPALS, FAILED TO PROPERLY SUPERVISEAN ASSOCIATED PERSON WHO SOLD AN UNREGISTERED SECURITY TO 7INVESTORS DURING YEARS 2002 AND 2003 IN THE FORM OF VIATICALSETTLEMENT CONTRACTS WHICH WERE NOT REGISTERED AS ASECURITY OR EXEMPT FROM REGISTRATION IN FLORIDA, 2.) THAT PRUCOHAD POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENTTHE SALE OF UNREGISTERED VIATICAL SETTLEMENT CONTRACTS ANDALSO TRAINED ITS REPRESENTATIVES, INCLUDING ITS REGISTEREDPRINCIPALS AND ASSOCIATED PERSONS, ON THESE POLICIES ANDPROCEDURES, AND; 3.) THAT THE ASSOCIATED PERSON HAD SUBMITTEDTO HIS REGISTERED PRINCIPAL THREE REQUEST FORMS TO APPROVEOUTSIDE BUSINESS ACTIVITIES AT OR ABOUT THE SAME TIME (TWOREQUESTS FOR AGENT APPOINTMENTS TO INSURANCE COMPANIES ANDA THIRD REQUEST FOR AN APPOINTMENT TO MUTUAL BENEFITSCORPORATION APPROVED UNDER THE BELIEF THAT IT WAS FOR ANAPPOINTMENT TO AN INSURANCE COMPANY SIMILAR TO THE OTHER TWOAPPOINTMENT REQUESTS).


Resolution:


No


Order







Sanction Details: ON 4/1/2009, THE OFFICE ENTERED A FINAL ORDER ADOPTING THESTIPULATION AND CONSENT AGREEMENT WHEREBY PRUCO NEITHERADMITTED NOR DENIED THE OFFICE'S FINDINGS BUT AGREED, IN LIEU OFAN ADMINISTRATIVE FINE, PAID COSTS AND EXPENSES OF THEEXAMINATION AND RESOLUTION OF THE MATTER IN THE AMOUNT OFFIFTEEN THOUSAND DOLLARS ($15,000.00).



Initiated By: STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION.


Restitution


PRUCO AGREED TO FULLY COMPLY WITH ALL PROVISIONS OF CHAPTER517, FLORIDA STATUTES AND RULE CHAPTER 69W, FLORIDA ADMIN. CODE;TO MAKE SETTLEMENT OFFERS TO FOUR INVESTORS WITHIN 90 DAYS OFTHE ORDER RELATED TO THEIR INVESTMENT IN CERTAIN VIATICALSETTLEMENT CONTRACTS; AND TO PAY THE COSTS AND EXPENSES OFTHE EXAMINATION TO THE DEPT.


Docket/Case Number: 0300-S-10/06

Principal Product Type: Investment Contract(s)

Other Product Type(s): VIATICAL SETTLEMENT CONTRACTS

Allegations: ALLEGATIONS RELATE TO A PRUCO SECURITIES REGISTERED PRINCIPALWHO HAD MISTAKENLY APPROVED A REGISTERED REPRESENTATIVE'SAPPOINTMENT TO A VIATICAL COMPANY CONTRARY TO COMPANY POLICYAND ALLEGEDLY FAILED TO PROPERLY SUPERVISE A REGISTEREDREPRESENTATIVE. THE REPRESENTATIVE SUBSEQUENTLY SOLD ANUNREGISTERED SECURITY TO CERTAIN INVESTORS IN THE FORM OFVIATICAL SETTLEMENT CONTRACTS WHICH WERE NOT REGISTERED AS ASECURITY NOR AN EXEMPT SECURITY UNDER FLORIDA LAW.



Resolution:


Order






Other Sanctions Ordered: WITHIN 90 DAYS OF THE FINAL ORDER PRUCO WILL MAKE SETTLEMENTOFFERS TO A TOTAL OF FOUR INVESTORS IN A TOTAL AMOUNT NOT LESSTHAN $128,000.00. PRUCO WILL ALSO PROVIDE THE STATE WITH COPIESOF THE OFFERS AND ACCEPTANCES/REJECTIONS, AND, IN LIEU OF ANADMINISTRATIVE FINE, PRUCO SHALL PAY $15,000 TO THE DEPT. FOR ITSEXAMINATION COSTS AND EXPENSES.

Sanction Details: PRUCO HAS 90 DAYS AFTER ENTRY OF THE FINAL ORDER (90 DAYS FROMAPRIL 1, 2009) TO MAKE SETTLEMENT OFFERS TO THE FOUR IDENTIFIEDINVESTORS. IN ADDITION, PRUCO PAID $15,000 TO THE DEPT. FOR ITSEXAMINATION COSTS AND EXPENSES.

Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS OF THE STATE'SEXAMINATION, PRUCO CONSENTED WITH THE DESCRIBED SANCTIONSAND TO THE ENTIRETY OF THE FINDINGS; THEREFORE PRUCO WASREQUIRED TO MAKE SETTLEMENT OFFERS TO THE FOUR IDENTIFIEDINVESTORS AND TO PAY $15,000TO THE DEPT. FOR ITS EXAMINATIONCOSTS AND EXPENSES.

Disclosure 7 of 27

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Initiated By: VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES &HEALTHCARE ADMINISTRATION



ADMINISTRATIVE SANCTIONS


Docket/Case Number: 07-031-S



Other Product Type(s): REGISTRATION VIOLATIONS

Allegations: UNREGISTERED SALES REP ACTIVITY



Resolution:

Other Sanctions Ordered: PRUCO WAS ORDERED TO PAY 22,500 IN BACK REGISTRATION FEESALONG WITH 5,000 FOR PAYMENT OF INVESTIGATIONS EXPENSES INADDITION TO THE MONETARY FINE STATED ABOVE.


Order






Other Sanctions Ordered: PRUCO WAS ORDERED TO PAY 22,500 IN BACK REGISTRATION FEESALONG WITH 5,000 FOR PAYMENT OF INVESTIGATIONS EXPENSES INADDITION TO THE MONETARY FINE STATED ABOVE.

Sanction Details: BETWEEN JAN. 1, 2005 AND SEPT. 15, 2006, APPROXIMATELY 90PRUDENTIAL INSURANCE COMPANY OF AMERICA (PICA)EMPLOYEESWERE REGISTERED WITH FINRA AND WORKED IN PRUCO'S CUSTOMERVALUE CENTER (CVC). DURING THAT PERIOD CVC AGENTS HANDLEDVARIABLE PRODUCTS WITH AS MANY AS 120 VERMONT RESIDENTS.NONE OF THE CVC AGENTS WERE REGISTERED AS AGENTS WITH THEDIVISION DURING THIS PERIOD.


Initiated By: VERMONT DEPARTMENT OF BANKING, INSURANCE, SECURITIES ANDHEALTH CARE ADMINISTRATION, SECURITIES DIVISION




UNDERTAKINGS: PRUCO MUST PROVIDE EVIDENCE THAT CERTAININDIVIDUALS REGISTERED IN VERMONT WHO ACT AS AGENTS WEREREGISTERED WITH THE DEPARTMENT WITHIN 30 DAYS OF THE ORDER;PRUCO MUST PROVIDE EVIDENCE TO VERMONT THAT IT HAS I) UPDATEDITS COMPLIANCE MANUALS;II)SYSTEMS/PROCEDURES IN PLACE TOPREVENT CONSUMMATION OF A SECURITIES TRANSACTION BY AGENTWHO IS NOT REGISTERED;III) TAKEN STEPS TO FULFILL ITS SUPERVISORYRESPONSIBILITIES.





Allegations: BETWEEN 1/1/2001 AND 2/20/2007 PRUCO DID NOT REGISTER CERTAINAGENTS WITH VERMONT FOR VARYING PERIODS OF TIME. FINALLY,PRUCO FAILED TO ADHERE TO ITS OWN INTERNAL WRITTEN POLICIESWITH RESPECT TO REGISTRATION OF CERTAIN AGENTS WITH VERMONT.



Resolution:



Stipulation and Consent







Sanction Details: PRUCO PAID A TOTAL $57,500.00 TO VERMONT CONSISTING OF ANADMINISTRATIVE PENALTY, BACK REGISTRATION FEES ANDINVESTIGATION EXPENSES.

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATION, PRUCO CONSENTEDTO THE DESCRIBED UNDERTAKINGS ON ON JULY 23, 2008. PRUCO MUSTPROVIDE EVIDENCE THAT CERTAIN INDIVIDUALS REGISTERED INVERMONT WHO ACT AS AGENTS WERE REGISTERED WITH THEDEPARTMENT WITHIN 30 DAYS OF THE ORDER; PRUCO MUST PROVIDEEVIDENCE TO VERMONT THAT IT HAS I) UPDATED ITS COMPLIANCEMANUALS;II)SYSTEMS/PROCEDURES IN PLACE TO PREVENTCONSUMMATION OF A SECURITIES TRANSACTION BY AGENT WHO IS NOTREGISTERED;III) TAKEN STEPS TO FULFILL ITS SUPERVISORYRESPONSIBILITIES.

Disclosure 8 of 27

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Allegations: NASD RULES 2110, 2310 AND 3010: THE FIRM MADE UNSUITABLERECOMMENDATIONS OF CLASS B SHARES MUTUAL FUNDS. THE FIRM DIDNOT CONSISTENTLY CONSIDER THAT LARGE INVESTMENTS IN CLASS ASHARES OF MUTUAL FUNDS ENTITLE CUSTOMERS TO BREAKPOINTDISCOUNTS ON SALES CHARGES, USUALLY BEGINNING AT THE $50,000INVESTMENT LEVEL, WHICH ARE GENERALLY NOT AVAILABLE FORINVESTMENTS IN CLASS B AND CLASS C SHARES. IN FACT, CUSTOMERSMAY BE ENTITLED TO BREAKPOINTS BASED UPON A SINGLE MUTUALFUND PURCHASE, MULTIPLE PURCHASES IN THE SAME "FAMILY OFFUNDS," AND/OR MUTUAL FUND INVESTMENTS HELD, AT THE TIME OF THENEW PURCHASE, BY MEMBERS OF THE CUSTOMER'S "HOUSEHOLD," ASTHAT TERM IS DEFINED IN THE PROSPECTUS OF THE FUND IN WHICH THESHARES ARE BEING PURCHASED. UNLIKE CLASS A SHARES, CLASS BSHARES ARE SUBJECT TO CONTINGENT DEFERRED SALES CHARGES("CDSCS") FOR A PERIOD OF TIME, GENERALLY SIX YEARS, AS WELL ASHIGHER ONGOING DISTRIBUTION AND SERVICE FEES ("RULE 12B-1 FEES")FOR AS LONG AS THE CLASS B SHARES ARE HELD. THE CDSCS AND THEHIGHER ONGOING RULE 12B1 FEES AFFECT THE RETURN ONCUSTOMERS' MUTUAL FIND INVESTMENTS. IN ADDITION THE FIRMSUPERVISORY AND COMPLIANCE POLICIES AND PROCEDURES DURINGTHE REVIEW PERIOD WERE NOT REASONABLY ESTABLISHED, MAINTAINEDAND/OR ENFORCED SO THAT THE FIRM, AT THE TIME OF EACH SALE,PROVIDED CONSIDERATION TO, ON A CONSISTENT BASIS, THE BENEFITSOF THE VARIOUS MUTUAL FUND SHARE CLASSES AS THEY APPLIED TOINDIVIDUAL CUSTOMERS.







Initiated By: FINRA




Docket/Case Number: E052003045301



NASD RULES 2110, 2310 AND 3010: THE FIRM MADE UNSUITABLERECOMMENDATIONS OF CLASS B SHARES MUTUAL FUNDS. THE FIRM DIDNOT CONSISTENTLY CONSIDER THAT LARGE INVESTMENTS IN CLASS ASHARES OF MUTUAL FUNDS ENTITLE CUSTOMERS TO BREAKPOINTDISCOUNTS ON SALES CHARGES, USUALLY BEGINNING AT THE $50,000INVESTMENT LEVEL, WHICH ARE GENERALLY NOT AVAILABLE FORINVESTMENTS IN CLASS B AND CLASS C SHARES. IN FACT, CUSTOMERSMAY BE ENTITLED TO BREAKPOINTS BASED UPON A SINGLE MUTUALFUND PURCHASE, MULTIPLE PURCHASES IN THE SAME "FAMILY OFFUNDS," AND/OR MUTUAL FUND INVESTMENTS HELD, AT THE TIME OF THENEW PURCHASE, BY MEMBERS OF THE CUSTOMER'S "HOUSEHOLD," ASTHAT TERM IS DEFINED IN THE PROSPECTUS OF THE FUND IN WHICH THESHARES ARE BEING PURCHASED. UNLIKE CLASS A SHARES, CLASS BSHARES ARE SUBJECT TO CONTINGENT DEFERRED SALES CHARGES("CDSCS") FOR A PERIOD OF TIME, GENERALLY SIX YEARS, AS WELL ASHIGHER ONGOING DISTRIBUTION AND SERVICE FEES ("RULE 12B-1 FEES")FOR AS LONG AS THE CLASS B SHARES ARE HELD. THE CDSCS AND THEHIGHER ONGOING RULE 12B1 FEES AFFECT THE RETURN ONCUSTOMERS' MUTUAL FIND INVESTMENTS. IN ADDITION THE FIRMSUPERVISORY AND COMPLIANCE POLICIES AND PROCEDURES DURINGTHE REVIEW PERIOD WERE NOT REASONABLY ESTABLISHED, MAINTAINEDAND/OR ENFORCED SO THAT THE FIRM, AT THE TIME OF EACH SALE,PROVIDED CONSIDERATION TO, ON A CONSISTENT BASIS, THE BENEFITSOF THE VARIOUS MUTUAL FUND SHARE CLASSES AS THEY APPLIED TOINDIVIDUAL CUSTOMERS.


Resolution:

Other Sanctions Ordered: UNDERTAKINGS

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 $100,000.00 AND MUSTCOMPLY WITH THE FOLLOWING UNDERTAKINGS: THE FIRM WILL PROVIDEREMEDIATION IN ACCORDANCE WITH A METHODOLOGY NOTUNACCEPTABLE TO FINRA STAFF (THE "REMEDIATION METHODOLOGY").THE REMEDIATION METHODOLOGY WILL BE PROVIDED IN WRITING TOFINRA STAFF PRIOR TO RETAINING THE THIRD PARTY EXAMINER. WITHIN90 DAYS FROM THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRMSHALL SUBMIT TO FINRA FOR REVIEW A SAMPLE LETTER NOTIFYINGCLIENTS OF REMEDIATION PAYMENTS. THE LETTER SHALL NOT BEUNACCEPTABLE TO FINRA. THE FIRM WILL PROVIDE REMEDIATION TOCERTAIN CUSTOMERS WHO, DURING THE PERIOD JANUARY 1, 2002THROUGH THE EFFECTIVE DATE OF THIS AWC, PURCHASED CLASS BSHARES OF MUTUAL FUNDS. WITHIN 60 DAYS FROM THE DATE OF THENOTICE OF ACCEPTANCE OF THIS AWC, RETAIN A THIRD PARTY EXAMINERTO ASSESS THE FIRM'S REMEDIATION AND PROVIDE A REPORT TO FINRASTAFF. WITHIN 270 DAYS FROM THE NOTICE OF ACCEPTANCE OF THISAWC, THE FIRM SHALL COMPLETE THE REMEDIATION PROCESS. WITHIN60 DAYS FROM THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRMSHALL DESIGNATE AND TRAIN STAFF (THE "RESPONSE TEAM") TO FIELDAND RESPOND TO CLIENT INQUIRIES IN CONNECTION WITH THIS AWC ANDTHE REMEDIATION PROCESSES PURSUANT TO THIS AWC. WITHIN 330DAYS FROM THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALLFILE AN INITIAL REPORT WITH FINRA, AND SIMULTANEOUSLY WITH THETHIRD PARTY EXAMINER. WITHIN 420 DAYS AFTER THE DATE OF NOTICEOF ACCEPTANCE OF THIS AWC, THE FIRM SHALL REQUIRE ITS THIRDPARTY EXAMINER TO SUBMIT A WRITTEN FINAL REPORT TO THE FIRM,AND TO FINRA.


No

Sanctions Ordered: CensureMonetary/Fine $100,000.00






https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=E052003045301


WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE THE FIRM IS CENSURED, FINED $100,000.00 AND MUSTCOMPLY WITH THE FOLLOWING UNDERTAKINGS: THE FIRM WILL PROVIDEREMEDIATION IN ACCORDANCE WITH A METHODOLOGY NOTUNACCEPTABLE TO FINRA STAFF (THE "REMEDIATION METHODOLOGY").THE REMEDIATION METHODOLOGY WILL BE PROVIDED IN WRITING TOFINRA STAFF PRIOR TO RETAINING THE THIRD PARTY EXAMINER. WITHIN90 DAYS FROM THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRMSHALL SUBMIT TO FINRA FOR REVIEW A SAMPLE LETTER NOTIFYINGCLIENTS OF REMEDIATION PAYMENTS. THE LETTER SHALL NOT BEUNACCEPTABLE TO FINRA. THE FIRM WILL PROVIDE REMEDIATION TOCERTAIN CUSTOMERS WHO, DURING THE PERIOD JANUARY 1, 2002THROUGH THE EFFECTIVE DATE OF THIS AWC, PURCHASED CLASS BSHARES OF MUTUAL FUNDS. WITHIN 60 DAYS FROM THE DATE OF THENOTICE OF ACCEPTANCE OF THIS AWC, RETAIN A THIRD PARTY EXAMINERTO ASSESS THE FIRM'S REMEDIATION AND PROVIDE A REPORT TO FINRASTAFF. WITHIN 270 DAYS FROM THE NOTICE OF ACCEPTANCE OF THISAWC, THE FIRM SHALL COMPLETE THE REMEDIATION PROCESS. WITHIN60 DAYS FROM THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRMSHALL DESIGNATE AND TRAIN STAFF (THE "RESPONSE TEAM") TO FIELDAND RESPOND TO CLIENT INQUIRIES IN CONNECTION WITH THIS AWC ANDTHE REMEDIATION PROCESSES PURSUANT TO THIS AWC. WITHIN 330DAYS FROM THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM SHALLFILE AN INITIAL REPORT WITH FINRA, AND SIMULTANEOUSLY WITH THETHIRD PARTY EXAMINER. WITHIN 420 DAYS AFTER THE DATE OF NOTICEOF ACCEPTANCE OF THIS AWC, THE FIRM SHALL REQUIRE ITS THIRDPARTY EXAMINER TO SUBMIT A WRITTEN FINAL REPORT TO THE FIRM,AND TO FINRA.


Initiated By: FINRA


Censure


MONETARY FINE, UNDERTAKING.


Docket/Case Number: E05200304530



Allegations: THAT PRUCO VIOLATED NASD RULES 2110, 2310 AND 3010. ON CERTAINOCCASIONS, PRUCO MADE UNSUITABLE RECOMMENDATIONS OF CLASS BSHARE MUTUAL FUNDS. PRUCO DID NOT ADEQUATELY CONSIDER ON ACONSISTENT BASIS THAT LARGE INVESTMENTS IN CLASS A SHARES OFMUTUAL FUNDS ENTITLE CUSTOMERS TO BREAKPOINT DISCOUNTS ONSALES CHARGES. IN ADDITION, PRUCO'S SUPERVISORY AND COMPLIANCEPOLICIES AND PROCEDURES DURING THE REVIEW PERIOD WERE NOTREASONABLY ESTABLISHED, MAINTAINED AND/OR ENFORCED TO ACHIEVECOMPLIANCE WITH THE NASD RULES REFERENCED ABOVE.



Resolution:










Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, PRUCO CONSENTED TOTHE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE PRUCO WAS CENSURED, FINED $100,000.00 AND MUSTCOMPLY WITH THE FOLLOWING UNDERTAKINGS: PRUCO WILL PROVIDEREMEDIATION TO CERTAIN CUSTOMERS WHO, DURING THE PERIODJANUARY 1, 2002 THROUGH THE EFFECTIVE DATE OF THIS AWC,PURCHASED CLASS B AND/OR CLASS C SHARES OF MUTUAL FUNDS.WITHIN 60 DAYS FROM THE DATE OF THIS NOTICE OF ACCEPTANCE OFTHIS AWC, RETAIN A THIRD PARTY EXAMINER TO ASSESS PRUCO'SREMEDIATION AND PROVIDE A REPORT TO FINRA STAFF. WITHIN 270 DAYSFROM THE NOTICE OF ACCEPTANCE OF THIS AWC, PRUCO SHALLCOMPLETE THE REMEDIATION PROCESS. WITHIN 60 DAYS FROM THENOTICE OF ACCEPTANCE OF THIS AWC, PRUCO SHALL DESIGNATE ANDTRAIN STAFF (THE "RESPONSE TEAM") TO FIELD AND RESPOND TO CLIENTINQUIRIES IN CONNECTION WITH THIS AWC. WITHIN 330 DAYS FROM THENOTICE OF ACCEPTANCE OF THIS AWC, PRUCO SHALL FILE AN INITIALREPORT WITH FINRA, AND SIMULTANEOUSLY WITH THE THIRD PARTYEXAMINER. WITHIN 420 DAYS AFTER THE DATE OF NOTICE OFACCEPTANCE OF THIS AWC, PRUCO SHALL REQUIRE ITS THIRD PARTYEXAMINER TO SUBMIT A WRITTEN FINAL REPORT TO THE FIRM, AND TOFINRA.

Disclosure 9 of 27

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Initiated By: STATE OF MAINE, OFFICE OF SECURITIES


Restitution



Docket/Case Number: 05-059-CAG



Allegations: THE STATE OF MAINE, OFFICE OF SECURITIES ("OFFICE") ALLEGED THATPRUCO FAILED TO REASONABLY SUPERVISE THE ACTIVITIES OF AREGISTERED REPRESENTATIVE, WHO ALLEGEDLY ENGAGED INUNETHICAL CONDUCT OF RECOMMENDING UNSUITABLE TRANSACTIONSAND MUTUAL FUND SWITCHING WITHOUT SUFFICIENT REGARD FOR HISCLIENTS' BEST INTERESTS.









Resolution:


Sanction Details: ON JULY 5, 2007, PRUCO PAID $36,528.97 TO THE OFFICE FORDISTRIBUTION TO SEVEN CLIENTS.

Firm Statement PRUCO AND THE OFFICE ENTERED INTO A CONSENT AGREEMENT ONJUNE 21, 2007. THE OFFICE ALLEGED THAT PRUCO FAILED TOREASONABLY SUPERVISE THE ACTIVITIES OF A FORMER REGISTEREDREPRESENTATIVE WHO WAS ALLEGED TO HAVE ENGAGED IN UNETHICALCONDUCT OF RECOMMENDING UNSUITABLE TRANSACTIONS AND MUTUALFUND SWITCHING WITHOUT SUFFICIENT REGARD FOR HIS CLIENTS' BESTINTERESTS. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS,PRUCOAGREED TO PAY THE SUM OF $36,528.97 IN RESTITUTION TO SEVEN MAINECLIENTS, WHICH PRUCO PAID 0N JULY 5, 2007.

Sanctions Ordered: Disgorgement/Restitution

Consent

Disclosure 10 of 27

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Allegations: SEC RULE 17A-4, NASD RULES 2110, 2210, 3010 AND 3110: BETWEENJANUARY 1, 2001 AND SEPTEMBER 30, 2005, PRUCO SECURITIES, LLC ANDAN AFFILIATED FIRM COLLECTIVELY ("RESPONDENTS") COMMITTEDNUMEROUS SEPARATE VIOLATIONS OF NASD RULES, INCLUDING FAILURETO FILE ADVERTISEMENTS AND SALES LITERATURE IN A TIMELY MANNERWITH NASD, FAILURE TO HAVE A REGISTERED PRINCIPAL APPROVEADVERTISEMENTS AND SALES LITERATURE PRIOR TO USE WITH THEPUBLIC, AND FAILURE TO COMPLY WITH RESPONDENTS' RECORDKEEPINGOBLIGATIONS FOR COMMUNICATIONS WITH THE PUBLIC. THESE FAILURESINVOLVED WIDELY DISTRIBUTED ADVERTISEMENTS AND SALESLITERATURE FOR A BROAD RANGE OF PRODUCTS, INCLUDING MUTUALFUNDS, 529 COLLEGE SAVINGS PLANS, QUALIFIED RETIREMENT PLANS,AND VARIABLE ANNUITY AND VARIABLE LIFE INSURANCE PRODUCTS.THESE VIOLATIONS RESULTED FROM A SYSTEMIC FAILURE BYRESPONDENTS TO ADEQUATELY SUPERVISE THEIR INTERNAL MARKETINGREVIEW PROCESS. RESPONDENTS FAILED TO ESTABLISH, MAINTAIN ANDENFORCE SUPERVISORY SYSTEMS AND PROCEDURES REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH CERTAIN NASD RULESGOVERNING FILING, APPROVAL AND RECORDKEEPING WITH RESPECT TOADVERTISING AND SALES LITERATURE. IN SEVERAL INSTANCES,RESPONDENTS FAILED TO FILE PIECES IN A TIMELY MANNER WITH NASDAND LACKED ADEQUATE SYSTEMS AND PROCEDURES TO MONITOR THETIMELINESS OF NASD FILINGS. RESPONDENTS FAILED TO TAKESUFFICIENT REMEDIAL ACTIONS IN RESPONSE TO WRITTEN WARNINGSFROM NASD THAT ITS FILINGS WERE NOT TIMELY. IN MANY INSTANCES,RESPONDENTS USED ADVERTISEMENTS WITH THE INVESTING PUBLICBEFORE A REGISTERED PRINCIPAL APPROVED THE PIECES FOR USE, ASREQUIRED BY NASD RULES. THIS ACTIVITY WENT LARGELY UNDETECTEDBY RESPONDENTS, AS THEY HAD NO SYSTEMS OR PROCEDURES TORECORD WHEN ADVERTISEMENTS WERE FIRST USED WITH THE PUBLIC,AND THEIR SYSTEMS AND PROCEDURES TO DETECT WHENADVERTISEMENTS WERE USED PRIOR TO THE REQUISITE INTERNALAPPROVAL WERE NOT ADEQUATE.







Initiated By: NASD




Docket/Case Number: EAF0401420002


Other Product Type(s): 529 COLLEGE SAVINGS PLANS, QUALIFIED RETIREMENT PLANS, ANDVARIABLE ANNUITY AND VARIABLE LIFE INSURANCE PRODUCTS

SEC RULE 17A-4, NASD RULES 2110, 2210, 3010 AND 3110: BETWEENJANUARY 1, 2001 AND SEPTEMBER 30, 2005, PRUCO SECURITIES, LLC ANDAN AFFILIATED FIRM COLLECTIVELY ("RESPONDENTS") COMMITTEDNUMEROUS SEPARATE VIOLATIONS OF NASD RULES, INCLUDING FAILURETO FILE ADVERTISEMENTS AND SALES LITERATURE IN A TIMELY MANNERWITH NASD, FAILURE TO HAVE A REGISTERED PRINCIPAL APPROVEADVERTISEMENTS AND SALES LITERATURE PRIOR TO USE WITH THEPUBLIC, AND FAILURE TO COMPLY WITH RESPONDENTS' RECORDKEEPINGOBLIGATIONS FOR COMMUNICATIONS WITH THE PUBLIC. THESE FAILURESINVOLVED WIDELY DISTRIBUTED ADVERTISEMENTS AND SALESLITERATURE FOR A BROAD RANGE OF PRODUCTS, INCLUDING MUTUALFUNDS, 529 COLLEGE SAVINGS PLANS, QUALIFIED RETIREMENT PLANS,AND VARIABLE ANNUITY AND VARIABLE LIFE INSURANCE PRODUCTS.THESE VIOLATIONS RESULTED FROM A SYSTEMIC FAILURE BYRESPONDENTS TO ADEQUATELY SUPERVISE THEIR INTERNAL MARKETINGREVIEW PROCESS. RESPONDENTS FAILED TO ESTABLISH, MAINTAIN ANDENFORCE SUPERVISORY SYSTEMS AND PROCEDURES REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH CERTAIN NASD RULESGOVERNING FILING, APPROVAL AND RECORDKEEPING WITH RESPECT TOADVERTISING AND SALES LITERATURE. IN SEVERAL INSTANCES,RESPONDENTS FAILED TO FILE PIECES IN A TIMELY MANNER WITH NASDAND LACKED ADEQUATE SYSTEMS AND PROCEDURES TO MONITOR THETIMELINESS OF NASD FILINGS. RESPONDENTS FAILED TO TAKESUFFICIENT REMEDIAL ACTIONS IN RESPONSE TO WRITTEN WARNINGSFROM NASD THAT ITS FILINGS WERE NOT TIMELY. IN MANY INSTANCES,RESPONDENTS USED ADVERTISEMENTS WITH THE INVESTING PUBLICBEFORE A REGISTERED PRINCIPAL APPROVED THE PIECES FOR USE, ASREQUIRED BY NASD RULES. THIS ACTIVITY WENT LARGELY UNDETECTEDBY RESPONDENTS, AS THEY HAD NO SYSTEMS OR PROCEDURES TORECORD WHEN ADVERTISEMENTS WERE FIRST USED WITH THE PUBLIC,AND THEIR SYSTEMS AND PROCEDURES TO DETECT WHENADVERTISEMENTS WERE USED PRIOR TO THE REQUISITE INTERNALAPPROVAL WERE NOT ADEQUATE.


Resolution:

Other Sanctions Ordered: UNDERTAKINGS

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 $525,000, JOINTLY ANDSEVERALLY, AND REQUIRED TO COMPLY WITH THE FOLLOWINGUNDERTAKINGS: THE FIRM'S INTERNAL AUDIT DEPARTMENT MUSTCONDUCT AN AUDIT AND PREPARE WRITTEN FINDINGS REGARDINGRESPONDENT'S COMPLIANCE WITH NASD RULES RELATING TO THEFILING, APPROVAL AND RECORDKEEPING REQUIREMENTS FORADVERTISEMENTS AND SALES LITERATURE, WHICH ARE THE SUBJECT OFTHIS AWC, APPLYING REASONABLE AUDITING STANDARDS, WHICH SHALLINCLUDE AUDIT SAMPLING, FOR THE 90-DAY PERIOD FOLLOWING THEFIRST DAY OF THE MONTH AFTER THE NOTICE OF ACCEPTANCE OF THISAWC. NO LATER THAN 180 DAYS FOLLOWING THE NOTICE OFACCEPTANCE OF THIS AWC, THE FIRM SHALL REVIEW THE WRITTENFINDINGS AND SUBMIT A REPORT TO NASD. NO LATER THAT 180 DAYSFOLLOWING THE NOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICER OFTHE FIRM, WHO IS REGISTERED WITH NASD, MUST CERTIFY IN WRITINGTO NASD THAT (I) THE FIRM'S INTERNAL AUDIT DEPARTMENT CONDUCTEDTHE AUDIT REQUIRED AND PREPARED WRITTEN FINDINGS AND (II) SUCHOFFICER HAS REVIEWED THE WRITTEN FINDINGS AND REPORT. A THIRDPARTY CONSULTANT MUST BE RETAINED TO PERFORM A REVIEW OF THEFIRM'S SYSTEMS AND PROCEDURES RELATING TO THE MARKETING ANDADVERTISING REVIEW PROCESS AND TO MAKE RECOMMENDATIONS FORIMPROVEMENTS. NO LATER THAT 300 DAYS FOLLOWING THE NOTICE OFACCEPTANCE OF THIS AWC, AN OFFICER OF THE FIRM MUST CERTIFY INWRITING TO NASD THAT THE FIRM HAS REVIEWED THEIR SYSTEMS ANDPROCEDURES FOR COMPLYING WITH THEIR ADVERTISING FILING,APPROVAL AND RECORDKEEPING OBLIGATIONS UNDER NASD RULES2210, 3110 AND SEC RULE 17A-4 AND HAVE ESTABLISHED SYSTEMS ANDPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHSUCH REQUIREMENTS.


No







https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=EAF0401420002


WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE THE FIRM IS CENSURED, FINED $525,000, JOINTLY ANDSEVERALLY, AND REQUIRED TO COMPLY WITH THE FOLLOWINGUNDERTAKINGS: THE FIRM'S INTERNAL AUDIT DEPARTMENT MUSTCONDUCT AN AUDIT AND PREPARE WRITTEN FINDINGS REGARDINGRESPONDENT'S COMPLIANCE WITH NASD RULES RELATING TO THEFILING, APPROVAL AND RECORDKEEPING REQUIREMENTS FORADVERTISEMENTS AND SALES LITERATURE, WHICH ARE THE SUBJECT OFTHIS AWC, APPLYING REASONABLE AUDITING STANDARDS, WHICH SHALLINCLUDE AUDIT SAMPLING, FOR THE 90-DAY PERIOD FOLLOWING THEFIRST DAY OF THE MONTH AFTER THE NOTICE OF ACCEPTANCE OF THISAWC. NO LATER THAN 180 DAYS FOLLOWING THE NOTICE OFACCEPTANCE OF THIS AWC, THE FIRM SHALL REVIEW THE WRITTENFINDINGS AND SUBMIT A REPORT TO NASD. NO LATER THAT 180 DAYSFOLLOWING THE NOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICER OFTHE FIRM, WHO IS REGISTERED WITH NASD, MUST CERTIFY IN WRITINGTO NASD THAT (I) THE FIRM'S INTERNAL AUDIT DEPARTMENT CONDUCTEDTHE AUDIT REQUIRED AND PREPARED WRITTEN FINDINGS AND (II) SUCHOFFICER HAS REVIEWED THE WRITTEN FINDINGS AND REPORT. A THIRDPARTY CONSULTANT MUST BE RETAINED TO PERFORM A REVIEW OF THEFIRM'S SYSTEMS AND PROCEDURES RELATING TO THE MARKETING ANDADVERTISING REVIEW PROCESS AND TO MAKE RECOMMENDATIONS FORIMPROVEMENTS. NO LATER THAT 300 DAYS FOLLOWING THE NOTICE OFACCEPTANCE OF THIS AWC, AN OFFICER OF THE FIRM MUST CERTIFY INWRITING TO NASD THAT THE FIRM HAS REVIEWED THEIR SYSTEMS ANDPROCEDURES FOR COMPLYING WITH THEIR ADVERTISING FILING,APPROVAL AND RECORDKEEPING OBLIGATIONS UNDER NASD RULES2210, 3110 AND SEC RULE 17A-4 AND HAVE ESTABLISHED SYSTEMS ANDPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHSUCH REQUIREMENTS.


Initiated By: NASD


Docket/Case Number: EAF0401420002

Allegations: THAT THE BROKER-DEALER VIOLATED NASD RULES REGARDINGPRINCIPAL APPROVAL, NASD FILING AND RECORDKEEPING WITHRESPECT TO CERTAIN ADVERTISING AND SALES LITERATURE AND THATTHE BROKER-DEALER FAILED TO ESTABLISH, MAINTIAN AND ENFORCESUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH THESE NASD RULES.






https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=EAF0401420002



Censure





Resolution:

Other Sanctions Ordered: UNDERTAKINGS: INTERNAL AUDIT AND OFFICER CERTIFICATIONSRELATED TO INTERNAL AUDIT AND COMPLIANCE WITH NASD ADVERTISINGRULES WITH RESPECT TO REGISTERED PRINCIPAL APPROVAL, FILING ANDRECORDKEEPING OF ADVERTISING AND A REPORT OF STATUS OFIMPLEMENTATION OF CONSULTANT RECOMMENDATIONS.

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, PRUCO AND ANAFFILIATED BROKER-DEALER CONSENTED TO THE DESCRIBEDSANCTIONS AND TO THE ENTRY OF THE FINDINGS. THE FINE OF $525,000WAS PAID BY PRUCO AND THE AFFILIATED BROKER-DEALER ON MAY 10,2007. PRUCO AND AN AFFILIATED BROKER-DEALER WERE ALSOCENSURED.

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, PRUCO AND ANAFFILIATED BROKER-DEALER CONSENTED TO THE DESCRIBEDSANCTIONS AND TO THE ENTRY OF THE FINDINGS. THE FINE OF $525,000WAS PAID BY PRUCO AND THE AFFILIATED BROKER-DEALER ON MAY 10,2007.



Disclosure 11 of 27

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Initiated By: STATE OF NEBRASKA, DEPARTMENT OF BANKING AND FINANCE


Docket/Case Number: NONE

Allegations: THE ORDER ALLEGES PRUCO SECURITIES, LLC (PRUCO) VIOLATED NASDCONDUCT RULE 2820(D) AND 48NAC12.003.06 BY DISREGARDING, AND NOTTAKING ACTION TO CORRECT, THE REPEATED UNTIMELY TRANSMISSIONOF PAYMENTS RECEIVED BY A REGISTERED REPRESENTATIVE FROM ACUSTOMER FOR THE CUSTOMER'S ACCOUNT.










Docket/Case Number: NONE




Resolution:


Sanction Details: PRUCO PAID A FINE OF $7,500 AND PAID THE COST OF THE INVESTIGATIONIN THE AMOUNT OF $5,000.

Firm Statement PRUCO AND THE DEPARTMENT ENTERED A CONSENT ORDER ON APRIL 4,2006. THE DEPARTMENT FOUND THAT PRUCO VIOLATED NASD CONDUCTRULE 2820(D) AND 48NAC12.003.06 BY DISREGARDING, AND NOT TAKINGACTION, TO CORRECT THE REPEATED UNTIMELY TRANSMISSION OFPAYMENTS RECEIVED BY A REGISTERED REPRESENTATIVE FROM ACUSTOMER FOR THE CUSTOMER'S ACCOUNT. PRUCO AGREED TO ANORDER TO PAY $7,500 AND INVESTIGATIVE COSTS OF $5,000.


Order

Disclosure 12 of 27

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Initiated By: NASD


Docket/Case Number: E9B2003004301


Allegations: ACTED IN CONTRAVENTION OF ARTICLE V, SECTIONS 2(C), 3(A) AND 3(B)OF NASD'S BY-LAWS, VIOLATED NASD CONDUCT RUES 2110 AND 3010;RESPONDENT FAILED TO FILE IN A TIMELY MANNER CERTAINAMENDMENTS TO FORM U4 AND FORM U5 AND FILED LATE FORMS U5 FORTERMINATED REGISTERED REPRESENTATIVES. IT'S SUPERVISORYSYSTEM AND PROCEDURES WERE NOT REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH ITS ARTICLE V REPORTING OBLIGATIONS.






https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=E9B2003004301







Resolution:

Other Sanctions Ordered: UNDERTAKINGS: REQUIRED AUDITS AND OFFICER CERTIFICATIONSRELATING TO ARTICLE V REPORTING OBLIGATIONS.

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENTMEMBER CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS; THEREFORE, FIRM IS CENSURED AND FINED$550,000.


No




Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS


Censure


Docket/Case Number: E9B2003004301



Allegations: FROM JANUARY 2002 THROUGH SEPTEMBER 2004, PRUCO FAILED TO FILEIN A TIMELY MANNER CERTAIN AMENDMENTS TO FORM U4 AND FORM U5.AND FROM JULY 2001 THROUGH SEPTEMBER 2004, RESPONDENT FAILEDTO FILE IN A TIMELY MANNER CERTAIN FORM U5 FOR TERMINATEDREGISTERED REPRESENTATIVES.








Censure



Resolution:

Other Sanctions Ordered: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, PRUCOCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; PRUCO WAS CENSURED AND FINED $550,000.00

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, PRUCOCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; PRUCO WAS CENSURED AND FINED $550,000.00

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS OF NASDARTICLE V REPORTING OBLIGATIONS, PRUCO SECURITIES, LLC ENTEREDINTO AN ACCEPTANCE, WAIVER, AND CONSENT ("AWC")WITH THE NASD.PRUCO SECURITIES, LLC PAID A $550,000.00 FINE.



Disclosure 13 of 27

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Initiated By: NORTH DAKOTA




Docket/Case Number:




Allegations: AGENT DALE F. ROEHRICH, THROUGH THE FIRM, ENGAGED IN ANUNSUITABLE SWITCH OF A LIFE INSURANCE PRODUCT INTO A VARIABLELIFE INSURANCE PRODUCT. THE ALLOCATION OF THE INVESTMENTSWITHIN THAT POLICY WERE ALSO UNSUITABLE. THE RESPONDENT FAILEDTO ADEQUATELY SUPERVISE THE AGENT WITH RESPECT TO THISTRANSACTION.











Resolution:


Sanction Details: CIVIL PENALTY BASED ON THE FIRM'S FAILURE TO SUPERVISE MR.ROEHRICH.

Regulator Statement THE AGENT, DALE F. ROEHRICH, IS NOT A PARTY TO THIS SETTLEMENT,AND IS THE SUBJECT OF A RELATED ENFORCEMENT ACTION.


No


Consent


Initiated By: NORTH DAKOTA SECURITIES DEPARTMENT





Docket/Case Number: NDSD #04-310



Allegations: THE ORDER ALLEGES PRUCO SECURITIES, LLC FAILED TO REASONABLYSUPERVISE A REPRESENTATIVE WITH RESPECT TO A LIFE INSURANCETRANSACTION.


Resolution: Consent








Sanction Details: PRUCO AGREED TO PAY AN ADMINISTRATIVE PENALTY OF $2,000.


Disclosure 14 of 27

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Initiated By: TEXAS


Reprimand


ADMINISTRATIVE FINE


Docket/Case Number: IC04-CAF-12



Other Product Type(s): SECURITIES

Allegations: PRUCO SECURITIES, LLC CONDUCTED SECURITIES-RELATED ACTIVITY ATLOCATIONS NOT REGISTERED AS BRANCH OFFICES WITH THESECURITIES COMMISSIONER. PRUCO SECURITIES, LLC MAINTAINEDRECORDS RELATED TO PRUCO SECURITIES, LLC SECURITIES ACTIVITY ATTHE UNREGISTERED OFFICES. EACH LOCATION IN TEXAS WHERE PRUCOSECURITIES,LLC SECURITIES-RELATED ACTIVITY RECORDS WEREMAINTAINED CONSTITUTES A "BRANCH OFFICE" AS THAT TERM ISDEFINED BY SECTION 115.1(B)(1) OF THE BOARD RULES. PRUCOSECURITIES, LLC FAILURE TO REGISTER EACH BRANCH OFFICECONSTITUTES A VIOLATION OF SECTION 115.1(B)(1) OF THE BOARDRULES. PRUCO SECURITIES, LLC SECURITIES-RELATED ACTIVITY ATUNREGISTERED BRANCH OFFICES CONSTITUTES A VIOLATION OFSECTION 115.2(C) OF THE BOARD RULES.



Resolution:


No

Order






Other Sanctions Ordered: REPRIMAND

Sanction Details: PRUCO SECURITIES, LLC PAID $10,000 AS AN ADMINISTRATIVE FINEPURSUANT TO SECTION 23-1 OF THE TEXAS SECURITIES ACT.

Regulator Statement PRUCO SECURITIES, LLC IS ALSO HEREBY REPRIMANDED.


No



Initiated By: TEXAS STATE SECURITIES BOARD


Reprimand


ADMINISTRATIVE FINE


Docket/Case Number: IC04-CAF-12


Other Product Type(s): SECURITIES

Allegations: PRUCO SECURITIES, LLC CONDUCTED SECURITIES SALES-RELATEDACTIVITY AT LOCATIONS NOT REGISTERED AS BRANCH OFFICES WITHTHE SECURITIES COMMISIONER. PRUCO SECURITIES, LLC MAINTAINEDRECORDS RELATED TO PRUCO SECURITIES, LLC SECURITIES ACTIVITY ATTHE UNREGISTERED OFFICES. EACH LOCATION IN TEXAS WHERE PRUCOSECURITIES, LLC SECURITIES SALES RELATED ACTIVITY RECORDS WEREMAINTAINED CONSTITUTES A "BRANCH OFFICE",AS THAT TERM ISDEFINED BY SECTION 115.1 (B)(1) OF THE BOARD RULES. PRUCOSECURITIES, LLC FAILURE TO REGISTER EACH BRANCH OFFICECONSTITUTES A VIOLATION OF SECTION 115.1(B)(1) OF THE BOARDRULES. PRUCO SECURITIES, LLC SECURITIES RELATED ACTIVITY ATUNREGISTERED BRANCH OFFICES CONSTITUES A VIOLATION OF SECTION115.2(C) OF THE BOARD RULES.


Resolution: Order60©2020 FINRA. All rights reserved. Report about PRUCO SECURITIES, LLC.






Resolution:

Other Sanctions Ordered: REPRIMAND

Sanction Details: PRUCO SECURITIES, LLC PAID $10,000.00 AS AN ADMINISTRATIVE FINEPURSUANT TO SECTION 23-1 OF THE TEXAS SECURITIES ACT.PRUCO SECURITIES, LLC WAS ALSO REPRIMANDED.


Order

Disclosure 15 of 27

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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.




Docket/Case Number: C9B030004



Allegations: NASD CONDUCT RULES 2110, 3070 - RESPONDENT MEMBER PRUCOSECURITIES DURING 2001, FAILED TO FILE WITH NASD IN A TIMELYMANNGER 166 OF 398 RULE 3070 REPORTS. THE RULE ENUMERATES TEN(10) TYPES OF OCCURRENCES THAT TRIGGER THIS REPORTINGOBLIGATION. SUCH EVENTS INCLUDE, BUT ARE NOT LIMITED TO,SITUATIONS WHERE A MEMBER, OR A PERSON ASSOCIATED WITH THEMEMBER: HAS BEEN CHARGED OR PLEADED GUILTY TO A FELONYCHARGE; IS THE SUBJECT OF A WRITTEN CUSTOMER COMPLAINTINVOLVING ALLEGATIONS OF THEFT OR FORGERY; OR HAS BEEN THESUBJECT OF ANY CLAIM FOR DAMAGES BY A CUSTOMER, BROKER, ORDEALER THAT IS SETTLED FOR AN AMOUNT EXCEEDING $15,000.



Resolution:








Other Sanctions Ordered: PRUCO SECURITIES ALSO AGREES TO THE FOLLOWING UNDERTAKINGS:FOR A PERIOD OF FIVE YEARS, PRUCO SECURITIES SHALL PROVIDE SEMI-ANNUAL TRAINING ON RULE 3070 AND THE FIRM'S INTERNALPROCEDURES FOR RULE 3070 REPORTING TO ITS BROKER DEALER UNIT,POLICYHOLDERS RELATIONS DEPARTMENT AND CUSTOMER SERVICEORGANIZATION. DISIGNATE IN WRITING THE NAME AND TITLE OF THEREGISTERED SECURITIES PRINCIPAL WITH PRIMARY RESPONSIBILITYFOR RULE 3070. DESIGNATE IN WRITING THE NAME AND TITLE OF THEREGISTERED PRINCIPAL WITH PRIMARY RESPONSIBILITY FOR THE FIRM'SCOMPLIANCE WITH RULE 3070 REPORTING. SUBMIT TO THE NASD STAFF AREPORT DETAILING ANY 3070 FILINGS THAT WERE NOT MADE TIMELYDURING THE QUARTER.

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENTMEMBER CONSENTED TO THE FINDING OF THE ALLEGATIONS AND TO THEFOLLOWING SANCTIONS: A CENSURE AND A FINE OF $100,000.00




Censure






Allegations: DURING 2001, PRUCO SECURITIES FAILED TO FILE WITH THE NASD IN ATIMELY MANNER 166 OF 398 RULE 3070 REPORTS.



Resolution:


Sanction Details: PRUCO SECURITIES (PRUCO)PAID A FINE OF $100,000.00

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS OF NASDCONDUCT RULES 3070 & 2110, PRUCO ENTERD INTO A LETTER OFACCEPTANCE, WAIVER, AND CONSENT WITH THE NASD AND PAID A FINEOF $100,000.00. THE MATTER INVOLVED CERTAIN ITEMS THAT WERE FILEDIN AN UNTIMELY MANNER PURSUANT TO RULE 3070.








Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS OF NASDCONDUCT RULES 3070 & 2110, PRUCO ENTERD INTO A LETTER OFACCEPTANCE, WAIVER, AND CONSENT WITH THE NASD AND PAID A FINEOF $100,000.00. THE MATTER INVOLVED CERTAIN ITEMS THAT WERE FILEDIN AN UNTIMELY MANNER PURSUANT TO RULE 3070.

Disclosure 16 of 27

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Initiated By: MAINE OFFICE OF SECURITIES


Censure



Docket/Case Number: 00-027 & 00-044


Principal Product Type: Investment Contract(s)


Allegations: FAILURE TO SUPERVISE SALES REPRESENTATIVE WHO SOLDUNREGISTERED SECURITIES TO PRUCO CLIENTS.



Resolution:


Sanction Details: PRUCO WAS CENSURED FOR FAILING TO REASONABLY SUPERVISE ONEOF ITS SALES REPRESENTATIVES.

Regulator Statement IN NOVEMBER 2002, THE SECURITIES ADMINISTRATOR ISSUED TONOTICES OF INTENT TO ISSUE A CEASE AND DESIST ORDER AGAINSTSEVERAL RESPONDENTS WHO SOLD UNREGISTERED SECURITIES TOMAINE RESIDENTS. TIMOTHY E. GRANT, A FORMER SALESREPRESENTATIVE OF PRUCO, WAS NAMED AS A RESPONDENT IN BOTH OFTHE NOVEMBER NOTICES. THE CURRENT NOTICE OF INTENT TOCENSURE BROKER-DEALER ALLEGES THAT PRUCO FAILED TOREASONABLY SUPERVISE GRANT.


No

Sanctions Ordered: Censure

Order






IN NOVEMBER 2002, THE SECURITIES ADMINISTRATOR ISSUED TONOTICES OF INTENT TO ISSUE A CEASE AND DESIST ORDER AGAINSTSEVERAL RESPONDENTS WHO SOLD UNREGISTERED SECURITIES TOMAINE RESIDENTS. TIMOTHY E. GRANT, A FORMER SALESREPRESENTATIVE OF PRUCO, WAS NAMED AS A RESPONDENT IN BOTH OFTHE NOVEMBER NOTICES. THE CURRENT NOTICE OF INTENT TOCENSURE BROKER-DEALER ALLEGES THAT PRUCO FAILED TOREASONABLY SUPERVISE GRANT.


Initiated By: STATE OF MAINE, DEPARTMENT OF PROFESSIONAL AND FINANCIALREGULATION, OFFICE OF SECURITIES


Other



Docket/Case Number: NOS: 00-027 & 00-044


Other Product Type(s): UNREGISTERED SECURITIES

Allegations: ORDER ALLEGES THAT PRUCO SECURITIES ("PRUCO") FAILED TOREASONABLY SUPERVISE ONE OF ITS SALES REPRESENTATIVES.



Resolution:


Sanction Details: PRUCO SECURITIES WAS ISSUED AN ORDER OF CENSURE ON 2/19/03.

Firm Statement THE MAINE SECURITIES DEPARTMENT CENSURED PRUCO FOR FAILURETO REASONABLY SUPERVISE ONE OF ITS SALES REPRESENTATIVES.

Sanctions Ordered: Censure

Order

Disclosure 17 of 27

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Allegations: NASD RULES 2110, 3010 AND 3070 - RESPONDENT MEMBER FAILED TO FILEWITH THE NASD IN A TIMELY MANNER CUSTOMER COMPLAINTS THATWERE REQUIRED TO BE REPORTED. APPROXIMATELY 25 OF THESECUSTOMER COMPLAINTS INCORRECTLY IDENTIFIED THE DATES ONWHICH THE FIRM INITIALLY BECAME AWARE OF THE SUBJECTCOMPLAINTS; AND, FAILED TO ESTABLISH, MAINTAIN, AND ENFORCEPROCEDURES (INCLUDING WRITTEN SUPERVISORY PROCEDURES)REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH NASD CONDUCTRULE 3070.







Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS







Allegations: NASD RULES 2110, 3010 AND 3070 - RESPONDENT MEMBER FAILED TO FILEWITH THE NASD IN A TIMELY MANNER CUSTOMER COMPLAINTS THATWERE REQUIRED TO BE REPORTED. APPROXIMATELY 25 OF THESECUSTOMER COMPLAINTS INCORRECTLY IDENTIFIED THE DATES ONWHICH THE FIRM INITIALLY BECAME AWARE OF THE SUBJECTCOMPLAINTS; AND, FAILED TO ESTABLISH, MAINTAIN, AND ENFORCEPROCEDURES (INCLUDING WRITTEN SUPERVISORY PROCEDURES)REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH NASD CONDUCTRULE 3070.


Resolution:


Sanction Details: CENSURED AND FINED $50,000.00.




Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS REGULATION, INC.



Allegations: FROM 1996-2000, PRUCO SECURITIES ("PRUSEC") FAILED TO FILE WITHNASDR APPROX 245 CUSTOMER COMPLAINTS IN A TIMELY MANNER.APPRX 25 OF THESE COMPLAINTS INCORRECTLY IDENTIFIED THE DATESON WHICH PRUSEC BECAME AWARE OF THE COMPLAINTS. FROM 1996-1999, PRUSEC FAILED TO ESTABLISH, MAINTAIN, ENFORCE PROCEDURESDESIGNED TO ENSURE COMPLIANCE WITH NASD RULE 3070.








Censure






Resolution:


Sanction Details: PRUCO SECURITIES PAID A $50,000 FINE.

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS OF NASDCONDUCT RULES 2110, 3010, & 3070, PRUCO SECURITIES ENTERED INTOAN ACCEPTANCE, WAIVER, AND CONSENT ("AWC") WITH THE NASDR.PRUCO SECURITIES ALSO PAID A $50,000 FINE.



Disclosure 18 of 27

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Initiated By: ILLINOIS SECURITIES DEPARTMENT


Revocation






Allegations: THE RESPONDENT FAILED TO SUPERVISE, ITS SALESPERSON'SWITHDRAWAL IN ILLINOIS, THE SALESPERSON DID OFFERED, PURCHASEAND SOLD SECURITIES ON BEHALF OF CLIENTS AS A SALESPERSONEMPLOYED BY THE RESPONDENT, AFTER HE WAS OFFICIALLYWITHDRAWN IN ILLINOIS. RESPONDENT FAILED TO FILE A REQUIREDDOCUMENT BY NOT FILING AN APPLICATION FOR REGISTRATION PRIORTO EMPLOYING THE REGISTERED REPRESENTATIVE AS A SALESPERSONIN ILLINOIS.

Current Status: Pending







Revocation


Regulator Statement A NOTICE OF HEARING, ISSUED SEPTEMBER 8, 2000. THE HEARING WILLBE HELD NOVEMBER 15, 2000. CONTACT: (217) 785-4948


Initiated By: ILLINIOIS SECURITIES DEPARTMENT


Other


REIMBURSEMENT OF INVESTIGATION COSTS AND PAYMENT TO THEDEPARTMENT REPRESENTATING COMMISSIONS PAID TO THEREPRESENTATIVE WHILE THE REPRESENTATIVE WAS INADVERTENTLYUNREGISTERED.





Allegations: PRIOR TO THE ISSUE OF THE NOTICE OF HEARING, PRUCO SECURITIESWAS IN DISCUSSIONS WITH THE ILLINOIS SECURITIES DEPARTMENT TORESOLVE A CLERICAL ERROR OF THE FIRM. PRUCO SECURITIESINADVERTENTLY FILED A FULL U5 FOR A REGISTERED REPRESENTATIVEWHILE REPRESENTATIVE WAS STILL ACTIVE. THE REPRESENTATIVECONTINUED TO SELL, SERVICE, AND RECEIVE COMMISSIONS WHILEBEING UNREGISTERED UNAWARE OF THE ERROR.



Resolution:

Firm Statement FIRM ENTERED INTO A SETTLEMENT AGREEMENT WITH THE SECURITIESDEPARMTENT ON 11/27/00. PRUCO SECURITIES HAS AGREED TO PAY $500FOR REIMBURSEMENT OF INVESTIGATIVE COSTS. IN ADDITION, THE FIRMAGREED TO PAY THE SECURITIES DEPARTMENT $7,635.42 WHICHREPRESENTS THE COMMISSIONS EARNED BY THE REPRESENTATIVEWHILE UNREGISTERED.

Settled






Disclosure 19 of 27

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Initiated By: NEVADA SECURITIES DIVISION


Other


OTHER - CONSENT AGREEMENT AND REIMBURSEMENT OFINVESTIGATING COSTS.


Docket/Case Number: FILE NO. 199-004 JN/SE



Allegations: PURSUANT TO AN INVESTIGATION, THE NEVEDA SECURITIES DIVISIONFOUND THAT PRUCO SECURITIES ("PRUSEC"), CONDUCTED BUSINESS ATUNLICENSED BRANCH OFFICES THROUGHOUT NEVADA, WHICH DID NOTQUALIFY FOR THE EXCEPTION PREVIOUSLY GRANTED PURSUANT TO ANO-ACTION LETTER.



Resolution:

Firm Statement PRUSEC VOLUNTARILY ENTERED INTO A CONSENT AGREEMENT. PRUSECAGREED TO REGISTER ALL OFFICES AS BRANCHES WITH DIVISION ANDAGREES TO COMPLY WITH ALL PROVISIONS OF THE NV SECURITIES ACT,NRS 90.211 ET. SEQ. AND THE RULES PROMULGATED THERETO IN THEFUTURE. PRUSEC AGREED TO PAY $10,000 AS REIMBURSEMENT FOR THEDIVISION'S COSTS OF INVESTIGATION.

Consent

Disclosure 20 of 27

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Allegations: NASD RULES 1021, 1031, 1032, 1140, 2110, 2210, IM-1000-3, IM-2210-2, 2310,AND 3010, AND 17(A) OF THE SECURITIES ACT OF 1933 - RESPONDENTMEMBER, THROUGH ITS REGISTERED REPRESENTATIVES ORASSOCIATED PERSONS, INDUCEDCUSTOMERS WHO ALREADY OWNED PRUDENTIAL LIFE INSURANCE TOPURCHASE NEW POLICIES BY MISREPRESENTING THAT THE POLICIESCOULD BE ACQUIRED USING CASH VALUES AND FUTURE DIVIDENDSFROM THEIR EXISTING POLICIES FOR LITTLE OR NO ADDITIONAL CASHPAYMENT, WHEN IN FACT, THOSE CASH VALUES AND DIVIDENDS OFTENWERE INSUFFICIENT TO PAY THE PREMIUMS FOR NEW POLICIES, ANDBOTH THE NEW AND EXISTING POLICIES FREQUENTLY LAPSED WHENCASH VALUES AND DIVIDENDS WERE USED TO ACQUIRE NEW POLICIESIN THIS FASHION; MISREPRESENTED, THROUGH MISLEADING SALESPRESENTATIONS, THAT PREMIUM PAYMENTS WOULD END, OR "VANISH,"AFTER A CERTAIN NUMBER OF YEARS, MISREPRESENTED THAT VARIABLELIFE WAS NOT INSURANCE BUT, INSTEAD, WAS AN INVESTMENT, SAVINGSOR RETIREMENT PLAN, AND MADE SALES TO CUSTOMERS FOR WHOMSUCHSALES WERE UNSUITABLE, INCLUDING PERSONS WHO DID NOT KNOWTHEY WERE PURCHASING INSURANCE OR DID NOT WANT TO PURCHASEINSURANCE; USED MISLEADING SALES LITERATURE; FAILED TOESTABLISH, MAINTAIN, AND ENFORCE REASONABLE SUPERVISORYPROCEDURES IN THAT PRUCO'S SUPERVISORY SYSTEMS AND CONTROLSWERE INEFFECTIVE AND DID NOT DIFFERENTIATE ADEQUATELY BETWEENSECURITIES AND NON-SECURITIES PRODUCTS, AND DID NOTADEQUATELY RESPOND TO PROBLEMS IT IDENTIFIED; FAILED TOREGISTER ASSOCIATED PERSONS WHO WERE ENGAGED IN THE FIRM'SSECURITIES BUSINESS, ENABLING THESE PERSONS TO SELLREGISTERED PRODUCTS PRIOR TO BECOMING REGISTERED AND TOEARN COMMISSIONS ON THOSE SALES, AND FAILED TO REGISTER ASPRINCIPALS ASSOCIATED PERSONS WHO WERE ACTIVELY ENGAGED INTHE MANAGEMENT OF PRUDENTIAL'S SECURITIES BUSINESS; AND,FAILED TO FILE OR FILED INACCURATE FORMS U-4 AND U-5). THESEMISREPRESENTATIONS AND VIOLATIONS OCCURRED NATIONWIDE ANDAFFECTED MORE THAN 200,000 SALES OFINSURANCE.











Docket/Case Number: CAF990010



NASD RULES 1021, 1031, 1032, 1140, 2110, 2210, IM-1000-3, IM-2210-2, 2310,AND 3010, AND 17(A) OF THE SECURITIES ACT OF 1933 - RESPONDENTMEMBER, THROUGH ITS REGISTERED REPRESENTATIVES ORASSOCIATED PERSONS, INDUCEDCUSTOMERS WHO ALREADY OWNED PRUDENTIAL LIFE INSURANCE TOPURCHASE NEW POLICIES BY MISREPRESENTING THAT THE POLICIESCOULD BE ACQUIRED USING CASH VALUES AND FUTURE DIVIDENDSFROM THEIR EXISTING POLICIES FOR LITTLE OR NO ADDITIONAL CASHPAYMENT, WHEN IN FACT, THOSE CASH VALUES AND DIVIDENDS OFTENWERE INSUFFICIENT TO PAY THE PREMIUMS FOR NEW POLICIES, ANDBOTH THE NEW AND EXISTING POLICIES FREQUENTLY LAPSED WHENCASH VALUES AND DIVIDENDS WERE USED TO ACQUIRE NEW POLICIESIN THIS FASHION; MISREPRESENTED, THROUGH MISLEADING SALESPRESENTATIONS, THAT PREMIUM PAYMENTS WOULD END, OR "VANISH,"AFTER A CERTAIN NUMBER OF YEARS, MISREPRESENTED THAT VARIABLELIFE WAS NOT INSURANCE BUT, INSTEAD, WAS AN INVESTMENT, SAVINGSOR RETIREMENT PLAN, AND MADE SALES TO CUSTOMERS FOR WHOMSUCHSALES WERE UNSUITABLE, INCLUDING PERSONS WHO DID NOT KNOWTHEY WERE PURCHASING INSURANCE OR DID NOT WANT TO PURCHASEINSURANCE; USED MISLEADING SALES LITERATURE; FAILED TOESTABLISH, MAINTAIN, AND ENFORCE REASONABLE SUPERVISORYPROCEDURES IN THAT PRUCO'S SUPERVISORY SYSTEMS AND CONTROLSWERE INEFFECTIVE AND DID NOT DIFFERENTIATE ADEQUATELY BETWEENSECURITIES AND NON-SECURITIES PRODUCTS, AND DID NOTADEQUATELY RESPOND TO PROBLEMS IT IDENTIFIED; FAILED TOREGISTER ASSOCIATED PERSONS WHO WERE ENGAGED IN THE FIRM'SSECURITIES BUSINESS, ENABLING THESE PERSONS TO SELLREGISTERED PRODUCTS PRIOR TO BECOMING REGISTERED AND TOEARN COMMISSIONS ON THOSE SALES, AND FAILED TO REGISTER ASPRINCIPALS ASSOCIATED PERSONS WHO WERE ACTIVELY ENGAGED INTHE MANAGEMENT OF PRUDENTIAL'S SECURITIES BUSINESS; AND,FAILED TO FILE OR FILED INACCURATE FORMS U-4 AND U-5). THESEMISREPRESENTATIONS AND VIOLATIONS OCCURRED NATIONWIDE ANDAFFECTED MORE THAN 200,000 SALES OFINSURANCE.

Resolution: Acceptance, Waiver & Consent(AWC)







Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, PRUCOSECURITIES CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED$20 MILLION. IN ADDITION, THE FIRM AGREES TO RETAIN AN OUTSIDECONSULTANT TO REVIEW AND MAKE RECOMMENDATIONS CONCERNINGTHE ADEQUACY OF PRUCO'S CURRENT POLICIES AND PROCEDURES ASTHEY RELATE TO THE MATTER DESCRIBED IN THIS AWC INCLUDING: (A)REPRESENTATIONS, PRESENTATIONS AND OTHER COMMUNICATIONSWITH CUSTOMERS OR PROSPECTIVE CUSTOMERS REGARDING THEOFFER, SALE OR PURCHASE OF VARIABLE LIFE PRODUCTS; (B)SUITABILITY DETERMINATIONS WITH RESPECT TO VARIABLE LIFEPRODUCTS; (C) THE FILING, REVIEW AND APPROVAL OFADVERTISEMENTS AND SALES LITERATURE WITH RESPECT TO VARIABLELIFE PRODUCTS; (D) THE REGISTRATION OF PRINCIPALS, REGISTEREDREPRESENTATIVES, AND ASSOCIATED PERSONS: (E) THE FILING OFFORMS U-4 AND U-5; AND (F) SUPERVISORY PROCEDURES WITH RESPECTTO VARIABLE LIFE PRODUCTS. THE CONSULTANT WILL PROVIDE ANINITIAL REPORT TO PRUCO AND TO THE NASD SIX MONTHS AFTERACCEPTANCE OF THE AWC CONTAINING RECOMMENDATIONS, IFAPPROPRIATE, FOR THE ADOPTION OF POLICIES AND PROCEDURES BYPRUCO WITH RESPECT TO MATTERSDESCRIBED IN THIS AWC, AND PRUCO SHALL EITHER ADOPT ALLRECOMMENDATIONS OR PROPOSE AN ALTERNATIVE PROCEDUREDESIGNED TO ACHIEVE THE SAME OBJECTIVE WITHIN SIX MONTHS AFTERTHE REPORT IS DELIVERED.

Sanctions Ordered: CensureMonetary/Fine $20,000,000.00



Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS REGULATION, INC.


Allegations: THE NASD ALLEGED THAT PRUCO SECURITIES COMMITED CERTAINVIOLATIONS WITH RESPECT TO MISREPRESENTATIONS MADE INCONNECTION WITH SOME VARIABLE LIFE INSURANCE SALES DURING1983-1995. THE NASD ALSO ALLEGED THE FAILURE TO REGISTERNUMEROUS EMPLOYEES; PROPERLY FILE ON FORMS U4 ADN U5'S; ANDESTABLISH REASONABLE SUPERVISORY PROCEDURES.








Censure


Docket/Case Number: CAF990010




Resolution:


Sanction Details: PRUSEC WAS CENSURED AND FINED $20 MILLION WHICH WAS PAID INCONJUNCTION WITH THE RESOLUTION DATE OF 7/7/99.

Firm Statement IN CONNECTION WITH ITS SETTLEMENT WITH THE NASD, PRUCOSECURITIES AGREED TO A CENSURE, TO PAY A FINE OF $20 MILLION, ANDTO RETAIN AN OUTSIDE CONSULTANT. THE AWC ACKNOWLEDGED THESTEPS TAKEN BY PRUDENTIAL AND PRUCO SECURITIES TO ENHANCE ANDSTRENGHTHEN ITS POLICIES AND PROCEDURES, SOME OF WHICH AREDETAILED IN THE AWC.

Sanctions Ordered: CensureMonetary/Fine $20,000,000.00


Disclosure 21 of 27

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Initiated By: CONNECTICUT DEPT. OF BANKING


Docket/Case Number: ST-98-5164-S


Principal Product Type:


Allegations: FROM APPROXIMATELY MAY 1993 TO MAY 1998, THEFIRM ALLEGEDLY TRANSACTED BUSINESS FROM 4 CONNECTICUTLOCATIONSWITHOUT REGISTERING THOSE SITES AS BRANCH OFFICES UNDER THECONNECTICUT UNIFORM SECURITIES ACT.











Resolution:


Sanction Details: STIPULATION AND AGREEMENT EXECUTED AUGUST 19,1998 PURSUANT TO WHICH THE FIRM AGREED TO 1) COMPLETE ANINTERNAL REVIEW OF ITS SUPERVISORY AND COMPLIANCE PROCEDURESWITHIN 120 DAYS AND FILE A SUMMARIZING REPORT WITH THE DEPT.;2) PROVIDE QUARTERLY REPORTS TO THE DEPT. FOR 1 YEARDESCRIBINGANY COMPLAINTS, ACTIONS OR PROCEEDINGS INVOLVING CONNECTICUTRESIDENTS; AND 3) PAY A $6,000 FINE TO THE AGENCY.

Regulator Statement CONTACT: C. ANTANAITIS, 860-240-8233.


Stipulation and Consent


Initiated By: CONNECTICUT DEPARTMENT OF BANKING





Docket/Case Number: ST-98-1564-S



Allegations: FROM APPROXIMATELY APRIL 1993 TO MAY 1998, PRUCO SECURITIES("PRUSEC") ALLEGEDLY TRANSACTED BUSINESS FROM AS MANY AS FOURPLACES OF BUSINESS IN CONNECTICUT WITHOUT REGISTERING EACHLOCATION AS A BRANCH OFFICE IN ALLEGED CONTRAVENTION OFSECTION 36B-6(D) OF THE ACT.









Resolution:


Sanction Details: PRUSEC WAS FINED $6,000 WHICH WAS PAID IN CONJUNCTION WITH THERESOLUTION DATE OF 8/9/98.

Firm Statement PRUSEC AGREED TO SUBMIT WITHIN 120 DAYS OF EXECUTION OF THESTIPULATION A REPORT SUMMARIZING THE RESULTS OF AN INTERNALREVIEW OF ITS PRESENT SUPERVISORY AND COMPLIANCEPROCEDURES; SUBMIT TO THE DIVISION DIRECTOR FOR A PERIOD OF 1YEAR ENDING ON 9/30/99 A WRITTEN REPORT EACH CALENDAR QUARTERDESCRIBING ANY SECURITIES-RELATED COMPLAINTS, ACTIONS ORPROCEEDINGS (INCLUDING ARBITRATION) INITIATED BY CT RESIDENTSAGAINST THE FIRM OR ANY OF THE FIRM'S AGENTS, OFFICERS.DIRECTORS, EMPLOYEES OR REPRESENTATIVES; AND PAY A $6,000 FINETO THE DEPARTMENT.


Other

Disclosure 22 of 27

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Initiated By: CONNECTICUT DEPT. OF BANKING


Docket/Case Number: 95-2853-CO



Allegations: THE FIRM ALLEGEDLY FAILED TO SUPERVISE THEACTIVITIES OF ONE [D[D[D[D[D[D[D MICHAEL JOHN SULLO (CRDNUMBER 2037711), A FORMER PRUC AGENT WHO ALLEGEDLY SOLDAPPROXIMATELY $175,000 OF GUARANTEED UNREGISTEREDPROMISSORYNOTES TO THE PUBLIC WHILE EMPLOYED BY PRUCO, AND USED THESALESPROCEEDS FOR HIS PERSONAL BENEFIT. SULLO WAS SUBSEQUENTLYCONVICTED OF 20 COUNTS OF SECURITIES FRAUD AND 16 COUNTS OFFIRST DEGREE LARCENY IN 4/95, AND IS PRESENTLY SERVING A 20YEAR SENTENCE.












Resolution:


Sanction Details: PER CONSENT ORDER DATED 11/28/95, THE FIRMUNDERTOOK TO OFFER RESCISSION TO AFFECTED INVESTORS IN THEAMOUNT OF APPROXIMATELY $175,000. THE FIRM WAS ALSO FINED$25,000 AND ORDERED TO PAY THE AGENCY $5,000 FOR ITSINVESTIGATIVE COSTS. IN ADDITION, THE CONSENT ORDER REQUIREDTHE FIRM TO CONDUCT PERIODIC AUDITS OF ITS CONNECTICUT OFFICESAND TO FILE QUARTERLY REPORTS REGARDING SECURITIESCOMPLAINTSRECEIVED FROM CONNECTICUT RESIDENTS.

Regulator Statement CONTACT: JEFF HALPERIN, 860-240-8148


Consent


Initiated By: CONNECTICUT DEPARTMENT OF BANKING




Docket/Case Number: 95-2853-CO



Allegations: IT WAS ALLEGED THAT PRUCO SECURITIES ("PRUSEC") FAILED TOSUPERVISE A FORMER REGISTERED REPRESENTATIVE AND FAILED TOESTABLISH ADEQUATE INTERNAL CONTROL AND THEREBY VIOLATED THECONNECTICUT UNIFORM SECURITIES ACT.









Resolution:



Firm Statement PRUSEC, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THECOMPLAINT, CONSENTED TO THE ENTRY OF A FINAL CONSENT ORDERAND ENTERED INTO AN AGREEMENT WITH THE DEPARTMENT OF BANKING(THE "DEPARTMENT"). PRUSEC CONSENTED TO THE FOLLOWING: TOCONDUCT AN INTERNAL REVIEW OF ITS PRESENT SUPERVISORY ANDCOMPLIANCE PROCEDURES; TO CONDUCT A COMPREHENSIVE AUDIT OFITS NEW HAVEN, CT BRANCH OFFICE, TO CONDUCT AUDITS OF ITS CTBRANCH OFFICES IN 1996 AND 1997; TO PAY THE SUM OF $30,000 AND TOFILE A REPORT WITH THE DEPARTMENT OF BANKING WHICH REFLECTSTHE SECURITIES-RELATED COMPLAINTS, ACTIONS, OR PROCEEDINGSFILED AGAINT PRUSEC RECEIVED OR INITIATED BY CT RESIDENTS.


Consent

Disclosure 23 of 27

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Docket/Case Number: C3A950043



Allegations:



Resolution: Acceptance, Waiver & Consent(AWC)








Sanction Details:

Regulator Statement ON NOVEMBER 3, 1995, DISTRICT NO. 3 NOTIFIED RESPONDENT PRUCOSECURITIES CORPORATION THAT THE LETTER OF ACCEPTANCE, WAIVERAND CONSENT NO. C3A950043 WAS ACCEPTED; THEREFORE, THE FIRM ISCENSURED AND FINED $15,000 - (ARTICLE III, SECTION 1 OF THERULES OF FAIR PRACTICE - CERTAIN ASSOCIATED PERSONS OFRESPONDENT MEMBER SOLICITED RETAIL CUSTOMERS TO PURCHASE AVARIABLE LIFE INSURANCE PRODUCT. UPON OBTAINING CUSTOMERINSTRUCTIONS TO PURCHASE THE VARIABLE PRODUCT, AN ORDER WASENTERED TO PURCHASE A FIXED LIFE INSURANCE PRODUCT.SUBSEQUENTLY, WHEN THESE AGENTS WERE REGISTERED WITH THENASD,THE PRODUCT WAS EXCHANGE FOR A VARIABLE PRODUCT).

**$15,000.00 PAID ON 02/21/96, INVOICE # 95-3A-799**



Initiated By: NAT'L ASSOC OF SECURITIES DEALERS, INC. DBBC FOR DISTRICT #3





Docket/Case Number: C3A950043



Allegations: THE NASD ALLEGED THAT PRUCO SECURITIES ("PRUSEC") HAD CERTAINASSOCIATE PERSONS ALSO AFFILIATED WITH THE PRUDENTIALINSURANCE COMPANY OF AMERICA, ENGAGED IN CERTAIN CONDUCTTHAT CONSTITUTED VIOLATIONS OF ARTICLE III, SECTION 1 OF THE RULESOF FAIR PRACTICE.


Resolution: Consent76©2020 FINRA. All rights reserved. Report about PRUCO SECURITIES, LLC.






Resolution:


Sanction Details: PRUSEC WAS CENSURED AND FINED $15,000 WHICH WAS PAID INCONJUCTION WITH THE RESOLUTION DATE OF 11/3/95.

Firm Statement PRUSEC, WITHOUT ADMITTING OR DENYING THE NASD'S ALLEGATIONS,CONSENTED TO THE ENTRY OF A FINAL CONSENT ORDER, AND ENTEREDINTO AN AGREEMENT WITH THE NASD. PRUSEC CONSENTED TO ACENSURE AND FINE OF $15,000. SPECIFICALLY, DURING THE PERIODFROM APPROXIMATELY 1/1/85 THROUGH APPROXIMATELY 3/31/88,CERTAIN AGENTS SOLICITED RETAIL CUSTOMERS TO PURCHASEVARIABLE LIFE INSURANCE PRODUCTS. UPON OBTAINING CUSTOMERINSTRUCTIONS TO PURCHASE THE VARIABLE PRODUCT, AN ORDER WASENTERED TO PURCHASE A FIXED LIFE INSURANCE PRODUCT.SUBSEQUENTLY, WHEN THESE AGENTS WERE REGISTERED WITH THENASD, THE PRODUCT WAS EXCHANGED FOR A VARIABLE PRODUCT.


Consent

Disclosure 24 of 27

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Initiated By: OKLAHOMA DEPARTMENT OF SECURITIES




Allegations: THE OKLAHOMA DEPARTMENT OF SECURITIES(DEPARTMENT) CONDUCTED AN EXAMINATION OF PRUCO SECURITIESCORPORATION (PRUCO) OF SOUTH PLAINSFIELD, NEW JERSEY. IN ORDERTO RESOLVE THE ISSUED RAISED DURING THE EXAMINATION, PURCO ANDTHE DEPARTMENT ENTERED INTO AN AGREEMENT ON DECEMBER 21,1995,WHEREIN PRUCO AGREED TO COMPLY WITH ALL PROVISIONS OF THEOKLAHOAM SECURITIES ACT AND THE RULES OF THE OKLAHOMASECURITIES COMMISSION AND THE ADMINISTRATOR OF THEDEPARTMENTOF SECURITIES. PRUCO FURTHER AGREED TO SUBMIT TO THEDEPARTMENTA CHECK IN THE AMOUNT OF $2,500.00 AS A CIVIL PENALTY.













Resolution:


Sanction Details: Not Provided

Regulator Statement CONTACT: REBECCA A. CRYER, (405) 235-0230

Sanctions Ordered:

Consent


Initiated By: STATE OF OKLAHOMA, DEPARTMENT OF SECURITIES





Docket/Case Number: ODS 95-145



Allegations: IT WAS ALLEGED THAT PRUCO SECURITIES CORPORATION ("PRUSEC")FAILED TO DESIGNATE CERTAIN BRANCH AND NON-BRANCH SALESOFFICES AS REQUIRED BY THE OKLAHOMA SECURITIES ACT ("THE ACT").ALSO, THAT PRUSEC, THROUGH IT'S LAWTON, OK BRANCH OFFICE,ALLOWED THOMAS JULIAN TO UNDERTAKE THE ACTIVITIES OF AN AGENTWITHOUT THE BENEFIT OF BEING REGISTERED AS AN AGENT IN THESTATE OF OKLAHOMA AS REQUIRED BY THE ACT.


Resolution: Consent







Resolution:



Firm Statement PRUSEC ENTERED INTO AN AGREEMENT WITH THE DEPARMENT OFSECURITIES. PRUSEC CONSENTED TO THE FOLLOWING: TO COMPLYWITH ALL PROVISIONS OF THE ACT AND THE RULES, INSOFAR AS SUCHPROVISIONS APPLY TO THE ACTIVITIES OF PRUSEC; TO PROMPTLY FILE ACORRECTING AMENDMENT WHEN A MATERIAL CHANGE OCCURS IN THEDESIGNATION OF A BRANCH OR NON-BRANCH OFFICE; TO CAUSE ANYAND ALL PERSON ACTING AS AN AGENT FOR PRUSEC IN THE STATE OFOKLAHOMA TO BE REGISTERED UNDER THE ACT AS AN AGENT PRIOR TOALLOWING SUCH PERSON TO RENDER SERVICES IN THE STATE OFOKLAHOMA; AND TO PAY THE SUM OF $2,500 AS A CIVIL PENALTY.


Consent

Disclosure 25 of 27

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Initiated By: VERMONT SECURITIES DIVISION








Allegations: FAILURE TO REGISTER BRANCH OFFICES



Resolution:



Consent







Sanction Details: RESPONDENT ENTERED INTO A CONSENT ORDER WHEREINIT NEITHER ADMITTED NOR DENIED THE DIVISION'S ALLEGATIONS.RESPONDENT AGREED TO PAY A $1,000 ADMINISTRATIVE PENALTY AND$250 IN COSTS.

Regulator Statement RESPONDENT FAILED TO REGISTER CERTAIN BRANCHOFFICES IN 1993. THE DIVISION DID NOT BRING AN ENFORCEMENTACTION PURUSANT TO RESPONDENT'S ASSURANCES THAT ITIMPLEMENTEDPROCEDURES TO ENSURE ITS BRANCH OFFICES WERE REGISTERED. IN1994, RESPONDENT FAILED AGAIN TO REGISTER CERTAIN BRANCHOFFICES.


Initiated By: STATE OF VERMONT DEPARTMENT OF BANKING, INSURANCE ANDSECURITIES








Allegations: IT WAS ALLEGED THAT PRUCO SECURITIES DID NOT REGISTER TWOBRANCH OFFICES PRIOR TO THEIR TRANSACTION OF BUSINESS.



Resolution:


Sanction Details: PRUSEC WASD FINED $1,000 AND PAY $250 FOR ADMINISTRATIVE COSTWHICH WAS PAID IN CONJUNCTION WITH THE RESOLUTION DATE 2/14/95.

Firm Statement PRUCO SECURITIES, WITHOUT ADMITTING OR DENYING THEALLEGATIONS OF THE COMPLAINT, CONSENTED TO THE ENTRY OFCONSENT ORDER AND ENTERED INTO AN AGREEMENT WITH THEDEPARTMENT OF BANKING, INSURANCE AND SECURITIES TO REASONBLYSUPERVISE ITS AGENTS, OFFICES AND EMPLOYEES WITH A VIEW TOPREVENTING VIOLATION OF SAME, TO PAY AN ADMINISTRATIVE PENALTYOF $1,000 AND TO PAY $250 FOR ADMINISTRATIVE COSTS INCURRED INCONNECTION WITH THE INVESTIGATION.


Consent






Firm Statement PRUCO SECURITIES, WITHOUT ADMITTING OR DENYING THEALLEGATIONS OF THE COMPLAINT, CONSENTED TO THE ENTRY OFCONSENT ORDER AND ENTERED INTO AN AGREEMENT WITH THEDEPARTMENT OF BANKING, INSURANCE AND SECURITIES TO REASONBLYSUPERVISE ITS AGENTS, OFFICES AND EMPLOYEES WITH A VIEW TOPREVENTING VIOLATION OF SAME, TO PAY AN ADMINISTRATIVE PENALTYOF $1,000 AND TO PAY $250 FOR ADMINISTRATIVE COSTS INCURRED INCONNECTION WITH THE INVESTIGATION.

Disclosure 26 of 27

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Initiated By: NEW MEXICO SECURITIES DIVISION








Allegations: (NO CHANGE)



Resolution:


Sanction Details: 2/06/95 CDO #95-93-084-038CD IS WITHDRAWN AS ITPERTAINS TO PRUCO SECURITIES CORP. AND FINAL ORDER ISSUEDPURSUANT TO CONSENT AGREEMENT WHEREIN PRUCO NEITHER ADMITSNORDENIES ALLEGATIONS IT FAILED TO ADEQUATELY SUPERVISE ITS AGENTSJACK COLE AND CLOVIS MARTIN. PRUCO CENSURED AND FINED $20,000.TO BE REDUCED BY AMOUNT PAID TO CLIENT, UP TO $16,000.00,PURSUANT TO CONSENT AGREEMENT.

Regulator Statement CONTACT: BILL DAVIS (505) 827-7140.


Consent






Regulator Statement CONTACT: BILL DAVIS (505) 827-7140.


Initiated By: STATE OF NEW MEXICO SECURITIES DIVISION





Docket/Case Number: ORDER #: 96-93-084 CA



Allegations: IT WAS ALLEGED THAT PRUCO SECURITIES FAILED TO SUPERVISECERTAIN ASSOCIATED PERSON ALSO AFFILIATED WITH THE PRUDENTIALINSURANCE COMPANY OF AMERICA.



Resolution:


Sanction Details: PRUSEC WAS CENSURED AND FINED $20,000 WHICH WAS PAID INCONJUCTION WITH THE RESOLUTION DATE OF 5/30/96. THE FINE WASREDUCED BY A CLIENT REIMBURSEMENT OF UP TO $16,000. PRUSECALSO PAID $2,152 IN INVESTIGATION COSTS.

Firm Statement PRUCO SECURITIES, WITHOUT ADMITTING OR ACKNOWLEDGING THEALLEGATIONS, AGREED TO THE ENTRY OF THE CONSENT ORDER ANDAGREEMENT WITH THE NEW MEXICO SECURITIES DIVISION TO BECENSURED FOR INADEQUATE SUPERVISION OF TWO OF ITS AGENTS, PAYA CIVIL PENALTY OF $20,000 (TO BE REDUCED BY A CLIENTREIMBURSEMENT OF UP TO $16,000), TO REIMBURSE THE STATE FOR THECOSTS OF INVESTIGATION THE AMOUNT OF $2,152, TO NOTIFY THE STATEOF BRANCH OFFICES WITHIN THE STATE, AND TO SUBMIT A COPY OF ITSSUPERVISORY AND COMPLIANCE PROCEDURES AS WELL ASPROCEDURES AIMED AT PREVENTING AND DETECTING POSSIBLE FUTURESTATE VIOLATIONS.


Consent






PRUCO SECURITIES, WITHOUT ADMITTING OR ACKNOWLEDGING THEALLEGATIONS, AGREED TO THE ENTRY OF THE CONSENT ORDER ANDAGREEMENT WITH THE NEW MEXICO SECURITIES DIVISION TO BECENSURED FOR INADEQUATE SUPERVISION OF TWO OF ITS AGENTS, PAYA CIVIL PENALTY OF $20,000 (TO BE REDUCED BY A CLIENTREIMBURSEMENT OF UP TO $16,000), TO REIMBURSE THE STATE FOR THECOSTS OF INVESTIGATION THE AMOUNT OF $2,152, TO NOTIFY THE STATEOF BRANCH OFFICES WITHIN THE STATE, AND TO SUBMIT A COPY OF ITSSUPERVISORY AND COMPLIANCE PROCEDURES AS WELL ASPROCEDURES AIMED AT PREVENTING AND DETECTING POSSIBLE FUTURESTATE VIOLATIONS.

Disclosure 27 of 27

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Docket/Case Number: C05910073



Allegations:



Resolution:


Sanction Details:

Regulator Statement ON JANUARY 6, 1992, THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT C05910073 (DISTRICT NO. 5) SUBMITTED BY RESPONDENTPRUCO SECURITIES CORPORATION WAS ACCEPTED; THEREFORE,RESPONDENT MEMBER IS CENSURED AND FINED $7,500. IN ADDITION,THE FIRM AGREES TO FULLY COMPLY WITH THE FINGERPRINTREQUIREMENTS OF SEC RULE 17F-2 COMMENCING 30 DAYS FROM THEACCEPTANCE OF THIS AWC. (ARTICLE III, SECTIONS 1 AND 27 OF THERULES OF FAIR PRACTICE - RESPONDENT MEMBER FAILED TOADEQUATELYINVESTIGATE THE CHARACTER OF AN EMPLOYEE WHO HAD TWO FELONYCONVICTIONS, AND WHILE EMPLOYED AT RESPONDENT MEMBER,COMMITTEDAN ADDITIONAL FELONY OF EMBEZZLEMENT; AND, FAILED TO COMPLYWITH ITS WRITTEN INTERNAL PROCEDURES REGARDING THE HIRING OFNEW EMPLOYEES). **$7,500.00 PAID ON 1/28/92 INVOICE #92-05-53**








ON JANUARY 6, 1992, THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT C05910073 (DISTRICT NO. 5) SUBMITTED BY RESPONDENTPRUCO SECURITIES CORPORATION WAS ACCEPTED; THEREFORE,RESPONDENT MEMBER IS CENSURED AND FINED $7,500. IN ADDITION,THE FIRM AGREES TO FULLY COMPLY WITH THE FINGERPRINTREQUIREMENTS OF SEC RULE 17F-2 COMMENCING 30 DAYS FROM THEACCEPTANCE OF THIS AWC. (ARTICLE III, SECTIONS 1 AND 27 OF THERULES OF FAIR PRACTICE - RESPONDENT MEMBER FAILED TOADEQUATELYINVESTIGATE THE CHARACTER OF AN EMPLOYEE WHO HAD TWO FELONYCONVICTIONS, AND WHILE EMPLOYED AT RESPONDENT MEMBER,COMMITTEDAN ADDITIONAL FELONY OF EMBEZZLEMENT; AND, FAILED TO COMPLYWITH ITS WRITTEN INTERNAL PROCEDURES REGARDING THE HIRING OFNEW EMPLOYEES). **$7,500.00 PAID ON 1/28/92 INVOICE #92-05-53**




Censure



Docket/Case Number: C05910073



Allegations: IT WAS ALLEGED THAT PRUSEC FAILED TO COMPLY WITH WRITTENINTERNAL PROCEDURES REGARDING HIRING OF NEW EMPLOYEES.



Resolution:


Sanction Details: PRUSEC WAS CENSURED AND FINED $7,500 WHICH WAS PAID ON 1/28/92.

Firm Statement PRUSEC NEITHER ADMITTED NOR DENIED THE EXISTENCE OF ANYVIOLATIVE ACTIVITY, THE NASD FOUND THAT PRUSEX HAD VIOLATEDARTICLE III, SECTION 1 ADN 27 OF THE ASSOCIATION'S RULES OF FAIRPRACTICE IN FAILING TO ADEQUATELY INVESTIGATE THE BACKGROUNDOF AN APPLICANT FOR EMPLOYMENT. PRUSEC FURTHER AGREES TOCOMPLY WITH THE FINGERPRINT REQUIREMENT IN THE FUTURE.








Regulatory - Pending

This type of disclosure event may include a pending formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulatory agency such as the Securities and ExchangeCommission, foreign financial regulatory body) for alleged violations of investment-related rules or regulations.

Disclosure 1 of 1


Initiated By: ALABAMA SECURITIES COMMISSION


Other


SHOW CAUSE ORDER


Docket/Case Number:



Other Product Type(s): VARIABLE LIFE INSURANCE & HEDGE FUND INVESTMENT

Allegations: DURING THE COURSE OF THE INVESTIGATION REGARDING AN ALABAMAREGISTERED REPRESENTATIVE, INFORMATION WAS OBTAINED THAT ANUMBER OF ALABAMA RESIDENTS HAD PURCHASED VARIABLE LIFEINSURANCE POLICIES THROUGH METLIFE. LATER THIS SAMEREPRESENTATIVE, WHILE EMPLOYED WITH PRUCO, HAD THESE ALABAMAINVESTORS TRANSFER THE SAME PRODUCT TO A PRUCO ACCOUNT.LATER, THE REPRESENTATIVE HAD THESE SAME INVESTORS DUMP THEIRPRUCO PRODUCT AND INVEST IN HIS "HEDGE FUND." A CRD DATABASEREVIEW SHOWED 12 COMPLAINTS THROUGH BOTH METLIFE AND PRUCO.IN 2012, BAGWELL, WHILE ACTING AS THE REPRESENTATIVE'SSUPERVISOR, INVESTED IN THE REPRESENTATIVE'S "HEDGE FUND" WITHNOTIFYING PRUCO OF THE OUTSIDE BUSINESS ACTIVITY. A NOTICE OFTHE RIGHT TO A HEARING WAS ATTACHED AS PART OF THE ORDER FORTHE RESPONDENTS TO RESPOND TO THE COMMISSION WITHIN 28 DAYSOF RECEIVING THE ORDER.


Regulator Statement CONTACT SA RANDY JONES AT 334-242-2984 FOR FURTHER INFORMATION.


Allegations: RESPONDENT PRUCO SECURITIES, LLC AND FORMER REGISTEREDPRINCIPAL TERRY JOE BAGWELL FAILED TO EXERCISE DILIGENTSUPERVISION OVER THE SECURITIES ACTIVITIES OF AN ASSOCIATEDPERSON, ALLOWING UNSUITABLE TRANSACTIONS AND UNAPPROVEDOUTSIDE BUSINESS ACTIVITIES THAT INVOLVED CLIENTS' INVESTMENTSIN A "HEDGE FUND," WHICH OFFERED AND SOLD UNREGISTEREDSECURITIES AND OPERATED AS A PONZI SCHEME. RESPONDENTS AREORDERED TO SHOW CAUSE TO THE COMMISSION WHY THEY SHOULDNOT BE SUSPENDED, REVOKED, CENSORED OR BARRED FROM THESECURITIES INDUSTRY IN THE STATE OF ALABAMA.







Initiated By: ALABAMA SECURITIES COMMISSION


Other


SHOW CAUSE ORDER


Docket/Case Number:


Other Product Type(s): VARIABLE LIFE INSURANCE & HEDGE FUND INVESTMENT

Allegations: RESPONDENT PRUCO SECURITIES, LLC AND FORMER REGISTEREDPRINCIPAL TERRY JOE BAGWELL FAILED TO EXERCISE DILIGENTSUPERVISION OVER THE SECURITIES ACTIVITIES OF AN ASSOCIATEDPERSON, ALLOWING UNSUITABLE TRANSACTIONS AND UNAPPROVEDOUTSIDE BUSINESS ACTIVITIES THAT INVOLVED CLIENTS' INVESTMENTSIN A "HEDGE FUND," WHICH OFFERED AND SOLD UNREGISTEREDSECURITIES AND OPERATED AS A PONZI SCHEME. RESPONDENTS AREORDERED TO SHOW CAUSE TO THE COMMISSION WHY THEY SHOULDNOT BE SUSPENDED, REVOKED, CENSORED OR BARRED FROM THESECURITIES INDUSTRY IN THE STATE OF ALABAMA.






Arbitration Award - Award / Judgment

Brokerage firms are not required to report arbitration claims filed against them by customers; however, BrokerCheckprovides summary information regarding FINRA arbitration awards involving securities and commodities disputesbetween public customers and registered securities firms in this section of the report. The full text of arbitration awards issued by FINRA is available at www.finra.org/awardsonline.

Disclosure 1 of 12


Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

09/09/2002

02-05190

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS

$3,779.31

AWARD AGAINST PARTY

02/14/2003

$275.00

There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.

Disclosure 2 of 12

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

01/25/2004

04-00326

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES





www.finra.org/awardsonline

https://www.finra.org/arbitration-mediation/arbitration-awards-online?search=02-05190





Disposition:

Disposition Date:



$65,775.40

AWARD AGAINST PARTY

05/10/2007

$140,000.00


Disclosure 3 of 12

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

05/21/2004

04-03617

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACT


$311,097.22

AWARD AGAINST PARTY

07/22/2005

$20,000.00


Disclosure 4 of 12

i



Arbitration Forum:

Case Initiated:

Allegations:

NASD

12/07/2005

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-FAILURE TO SUPERVISE







Case Initiated:

Case Number:



Disposition:

Disposition Date:


12/07/2005

05-06147

ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$118,789.00

AWARD AGAINST PARTY

10/26/2006

$60,000.00


Disclosure 5 of 12

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

12/12/2008

08-04669

ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES

$1,000,000.00

AWARD AGAINST PARTY

12/11/2009

$43,356.60


Disclosure 6 of 12

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Allegations: ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-NEGLIGENCE; ACCOUNTRELATED-TRANSFER








Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


FINRA

01/10/2012

12-00042

VARIABLE ANNUITIES

$7,722.92

AWARD AGAINST PARTY

07/06/2012

$4,575.00


Disclosure 7 of 12

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

11/27/2013

13-03439

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE

VARIABLE ANNUITIES

$13,170.75

AWARD AGAINST PARTY

06/02/2014

$17,941.75


Disclosure 8 of 12

i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

88-02056

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHERCONTROVERSY INVOLVED


$53,948.56

AWARD AGAINST PARTY

01/02/1990

$11,680.75


Disclosure 9 of 12

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

12/05/1990

90-02764

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-NEGLIGENCE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUTUAL FUNDS

$35,799.50

AWARD AGAINST PARTY

09/19/1991

$7,000.00

There may be a non-monetary award associated with this arbitration.








Please select the Case Number above to view more detailed information.

Disclosure 10 of 12

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

10/24/1994

94-03686

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVED


$10,000.00

AWARD AGAINST PARTY

06/19/1995

$4,643.71


Disclosure 11 of 12

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:

NASD

12/02/1994

94-03880

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES

$200,000.00

AWARD AGAINST PARTY

01/22/1997








Sum of All Relief Awarded: $45,000.00


Disclosure 12 of 12

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

07/26/1995

95-03370

ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOTUSE-NO OTHER CONTROVERSY INVOLVED

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$9,317.35

AWARD AGAINST PARTY

03/26/1996

$1,472.47








Civil Bond

This type of disclosure event involves a civil bond for the brokerage firm that has been denied, paid, or revoked by abonding company.

Disclosure 1 of 2


Policy Holder: PRUCO SECURITIES, LLC

Bonding Company Name: U.S. SPECIALTY INSURANCE COMPANY

Disposition: Payout

Disposition Date: 02/03/2011

Payout Details: A DISPOSITION REACHED WITH THE BOND COMPANY ON 02/03/2011RESULTED IN A $1,400,000 PAYOUT TO THE FIRM, WITH $610,000 PAID ON12/30/2010 AND $790,000 PAID ON 2/14/2011.

Firm Statement IN 2010 THE FIRM SUBMITTED A CLAIM UNDER ITS FIDELITY BONDSEEKING PAYMENT FOR LOSS INCURRED DUE TO MISAPPROPRIATION BYA FORMER REGISTERED REPRESENTATIVE OF THE FIRM. THE FORMERREPRESENTATIVE WAS DISCHARGED BY THE FIRM AND FORM U5DISCLOSURE WAS FILED WITH FINRA.

Disclosure 2 of 2

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Policy Holder: PRUCO SECURITIES CORPORATION

Bonding Company Name: AETNA CASUALTY AND SURETY COMPANY

Disposition: Payout

Disposition Date: 04/25/1985

Payout Details: $99,380 PAID OUT ON APRIL 25, 1985

Firm Statement DURING 1984 REGISTRANT FILED CLAIMS TOTALING $99,380 UNDER ITSSTOCKBROKERS' BLANKET BOND STANDARD FORM 14, NO. 001F20845BCA, ISSUED BY AETNA CASUALTY AND SURETY COMPANY. THE CLAIM,WHICH WAS PAID ON APRIL 25, 1985, WAS IN CONNECTION WITH A "DISHONEST ACT" BY A FORMER REGISTERED REPRESENTATIVE OFREGISTRANT. A FORM U-5 WAS FILED WITH THE NATIONAL ASSOCIATIONOF SECURITIES DEALERS CONCERNING SUCH FORMER EMPLOYEE






End of Report

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