vfinance investments, inc · 2020. 6. 20. · vfinance investments, inc crd# 44962 sec# 8-50898...

BrokerCheck Report

VFINANCE INVESTMENTS, INC

Section Title

Report Summary

Registration and Withdrawal

Firm History

CRD# 44962

1

2

9

Firm Profile 3 - 8

Page(s)

Firm Operations 10 - 16

Disclosure Events 17

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CRD# 44962

SEC# 8-50898

Main Office Location

1200 N. FEDERAL HIGHWAYSUITE 400BOCA RATON, FL 33432

Mailing Address

ONE UNION SQUARE 600 UNIVERSITY STREETSUITE 2900SEATTLE, WA 98101

Business Telephone Number

561 981 1048

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 27

Arbitration 6

Firm Profile

This firm is classified as a corporation.

This firm was formed in Florida on 01/14/1998.

Its fiscal year ends in September.

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

This brokerage firm is no longer registered withFINRA or a national securities exchange.

www.finra.org/brokercheck User Guidance

1©2021 FINRA. All rights reserved. Report about VFINANCE INVESTMENTS, INC


http://www.finra.org/brokercheck

http://www.finra.org/brokercheck_reports


This section provides information relating to the date the brokerage firm ceased doing business and the firm's financialobligations to customers or other brokerage firms.

Registration Withdrawal Information

02/23/2018

No

This firm terminated orwithdrew registration on:

Does this brokerage firm oweany money or securities toany customer or brokeragefirm?






This firm is classified as a corporation.

This firm was formed in Florida on 01/14/1998.

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 September.


SEC#

44962

8-50898

Main Office Location

Mailing Address

Business Telephone Number

Doing business as VFINANCE INVESTMENTS, INC

561 981 1048

1200 N. FEDERAL HIGHWAYSUITE 400BOCA RATON, FL 33432

ONE UNION SQUARE 600 UNIVERSITY STREETSUITE 2900SEATTLE, WA 98101






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?

VFINANCE INVESTMENTS HOLDINGS

SHAREHOLDER

75% or more

No

Domestic Entity

01/2001

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


GROENEVELD, WILLIAM LAWRENCE

HEAD TRADER, PRESIDENT, CEO

Less than 5%

No

Individual

12/2003

Yes

2127534



Position


Position Start Date

GROENEVELD, WILLIAM LAWRENCE

DIRECTOR

Less than 5%

Individual

07/2016

2127534








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


JOHNSON, KAY ALISON

CCO

Less than 5%

No

Individual

01/2010

Yes

1583193



Position



Position Start Date


KNOPF, FRED N

GENERAL COUNSEL

Less than 5%

No

Individual

11/2017

Yes

6390806



MULLEN, MICHAEL ANTHONY

1428116







Direct Owners and Executive Officers (continued)

Firm Profile

Position



Position Start Date


DIRECTOR

Less than 5%

No

Individual

01/2017

Yes

1428116


Position



Position Start Date


WATSON, NATALIA TOVAR

FINOP/CFO

Less than 5%

No

Individual

10/2016

Yes

4782735








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

Indirect Owners

Firm Profile

NATIONAL HOLDINGS CORPORATION

SHAREHOLDER

VFINANCE INC.

75% or more

Yes

Domestic Entity

07/2008

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established




VFINANCE INC.

SHAREHOLDER

VFINANCE INVESTMENTS HOLDINGS

75% or more

Yes

Domestic Entity

01/2002

Yes









FBIO ACQUISITION INC.

NATIONAL HOLDINGS CORP.

Domestic Entity









Indirect Owners (continued)

Firm Profile

SHAREHOLDER (COMMON STOCK)


50% but less than 75%

No

09/2016

Yes







FORTRESS BIOTECH, INC.

SHAREHOLDER (COMMON STOCK)


50% but less than 75%

Yes

Domestic Entity

09/2016

Yes














Firm History

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

No information reported.






Firm Operations

RegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.

The firm's registration was from 09/09/1998 to 05/14/2018.

This firm is no longer registered.






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 13 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 retailer

U S. government securities dealer

U S. government securities broker

Municipal securities dealer

Municipal securities broker

Broker or dealer selling variable life insurance or annuities

Put and call broker or dealer or option writer

Trading securities for own account

Private placements of securities

Broker or dealer selling interests in mortgages or other receivables






Firm Operations

Clearing Arrangements

This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does refer or introduce customers to other brokers and dealers.

Name: INDUSTRIAL AND COMMERCIAL BANK OF CHINA FINANCIAL SERVICESLLC

Business Address: 1633 BROADWAYNEW YORK, NY 10019

CRD #: 131487

Effective Date: 11/01/2010

Description: A PORTION OF OUR CLEARING WILL BE DONE THROUGH INDUSTRIALAND COMMERCIAL BANK OF CHINA FINANCIAL SERVICES LLC.

Name: NATIONAL FINANCIAL SERVICES LLC

Business Address: 82 DEVONSHIRE STREETL7BBOSTON, MA 02109

CRD #: 13041


Description: A PORTION OF OUR CLEARING WILL BE DONE THROUGH NATINALFINANCIAL SERVICE






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.

Name: GOLD COAST STORAGE

Business Address: 1701-A NW 1ST AVENUEBOCA RATON, FL 33432


Description: GOLD COAST STORAGE PROVIDES OFF-SITE DOCUMENT STORAGEFOR VFINANCE.



CRD #: 131487





CRD #: 13041


Description: A PORTION OF OUR CLEARING WILL BE DONE THROUGH NATIONALFINANCIAL SERVICES



CRD #: 131487








Firm Operations

Industry Arrangements (continued)

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

This firm does not have individuals who control its management or policies through agreement.

This firm does not have individuals who wholly or partly finance the firm's business.

Control Persons/Financing




CRD #: 13041





CRD #: 131487





CRD #: 13041








Firm Operations

Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.

This firm is, directly or indirectly:

· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.

No

Yes

No

07/01/2008

1001 FOURTH AVENUE SUITE 3750SEATTLE, WA 98154

7569

NATIONAL SECURITIES CORPORATION is under common control with the firm.

NATIONAL SECURITIES CORPORATION, IS A SUBSIDIARY OF NATIONALHOLDINGS CORP. VFINANCE INVESTMENT HOLDINGS IS A WHOLLY OWNEDSUBSIDIARY OF NATIONAL HOLDINGS CORP.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

No

07/01/2008

1001 FOURTH AVENUE SUITE 3750SEATTLE, WA 98154

115927

NATIONAL ASSET MANAGEMENT, INC. is under common control with the firm.

NATIONAL ASSET MANAGEMENT,IS A SUBSIDIARY OF NATIONAL HOLDINGSCORP. VFINANCE INVESTMENT HOLDINGS IS A WHOLLY OWNEDSUBSIDIARY OF NATIONAL HOLDINGS CORP

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations

Organization Affiliates (continued)NATIONAL ASSET MANAGEMENT,IS A SUBSIDIARY OF NATIONAL HOLDINGSCORP. VFINANCE INVESTMENT HOLDINGS IS A WHOLLY OWNEDSUBSIDIARY OF NATIONAL HOLDINGS CORP

Description:

This firm is not directly or indirectly, controlled by the following:

· bank holding company· national bank· state member bank of the Federal Reserve System· state non-member bank· savings bank or association· credit union· or foreign bank






Disclosure Events

All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.

Final On AppealPending

Regulatory Event 0 27 0

Arbitration N/A 6 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: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOPUBLISH IMMEDIATELY A BID OR OFFER THAT REFLECTED THE PRICE ANDTHE FULL SIZE OF CUSTOMER LIMIT ORDERS FOR OVER-THE-COUNTER(OTC) EQUITY SECURITIES HELD BY THE FIRM THAT WERE AT A PRICETHAT WOULD HAVE IMPROVED THE BID OR OFFER OF THE FIRM IN SUCHSECURITIES.

Current Status: Final






Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 12/01/2016

Docket/Case Number: 2016048839601

Principal Product Type: Equity - OTC

Other Product Type(s):


Resolution Date: 12/01/2016

Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND FINED $25,000. TINES PAID IN FULL ONJANUARY 7, 2017.

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

No

Sanctions Ordered: CensureMonetary/Fine $25,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm







https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2016048839601


Initiated By: FINRA







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOPUBLISH IMMEDIATELY A BID OR OFFER THAT REFLECTED THE PRICE ANDTHE FULL SIZE OF CUSTOMER LIMIT ORDERS FOR OVER-THE-COUNTER(OTC) EQUITY SECURITIES HELD BY THE FIRM THAT WERE AT A PRICETHAT WOULD HAVE IMPROVED THE BID OR OFFER OF THE FIRM IN SUCHSECURITIES.


Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $25,000.



Disclosure 2 of 27

i


Initiated By: FINRA



Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOTRANSMIT 51,893 REPORTABLE ORDER EVENTS (ROES) TO THE ORDERAUDIT TRAIL SYSTEM (OATS). THE FINDINGS STATED THAT THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOTHE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND FINRARULES. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) FAILEDTO PROVIDE FOR ONE OR MORE OF THE MINIMUM REQUIREMENTS FORADEQUATE WSPS FOR OATS REPORTING.












Principal Product Type: No Product



Resolution:

Other Sanctions Ordered: UNDERTAKINGS: REVISE THE FIRM'S WSPS

Sanction Details: THE FIRM WAS CENSURED, FINED $17,500 AND REQUIRED TO REVISE THEFIRM'S WSPS. FINES PAID IN FULL ON NOVEMBER 18, 2016.


No




Initiated By: FINRA



Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOTRANSMIT 51,893 REPORTABLE ORDER EVENTS (ROES) TO THE ORDERAUDIT TRAIL SYSTEM (OATS). THE FINDINGS STATED THAT THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOTHE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND FINRARULES. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) FAILEDTO PROVIDE FOR ONE OR MORE OF THE MINIMUM REQUIREMENTS FORADEQUATE WSPS FOR OATS REPORTING.














Resolution:

Other Sanctions Ordered: UNDERTAKINGS: REVISE THE FIRM'S WSPS

Sanction Details: THE FIRM WAS CENSURED, FINED $17,500 AND REQUIRED TO REVISE THEFIRM'S WSPS.



Disclosure 3 of 27

i


Initiated By: FINRA






Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOPUBLISH IMMEDIATELY A BID OR OFFER THAT REFLECTED THE PRICE ANDTHE FULL SIZE OF CUSTOMER LIMIT ORDERS FOR OVER-THE-COUNTER(OTC) EQUITY SECURITIES HELD BY THE FIRM THAT WERE AT A PRICETHAT WOULD HAVE IMPROVED THE BID OR OFFER OF THE FIRM IN SUCHSECURITIES. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLESECURITIES LAWS AND REGULATIONS, AND THE RULES OF FINRA. THEFIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) FAILED TOPROVIDE FOR THE MINIMUM REQUIREMENTS FOR ADEQUATE WRITTENSUPERVISORY RELATING TO COMPLIANCE WITH FINRA RULE 6460.











Resolution:

Other Sanctions Ordered: UNDERTAKINGS

Sanction Details: THE FIRM WAS CENSURED, FINED $30,500, AND UNDERTAKES TO REVISEITS WSPS, WITH RESPECT TO THE AREA DESCRIBED IN THE AWC, ANDWITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC, A REGISTEREDPRINCIPAL OF THE FIRM SHALL SUBMIT TO FINRA A SIGNED, DATEDLETTER, OR AN E-MAIL PROVIDING THE FOLLOWING INFORMATION: AREFERENCE TO THIS MATTER; A REPRESENTATION THAT THE FIRM HASREVISED ITS WSPS, TO ADDRESS THE DEFICIENCIES DESCRIBED IN THEAWC; AND, THE DATE THE REVISED PROCEDURES WERE IMPLEMENTED.FINE PAID IN FULL ON SEPTEMBER 20, 2016.


No




Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOPUBLISH IMMEDIATELY A BID OR OFFER THAT REFLECTED THE PRICE ANDTHE FULL SIZE OF CUSTOMER LIMIT ORDERS FOR OVER-THE-COUNTER(OTC) EQUITY SECURITIES HELD BY THE FIRM THAT WERE AT A PRICETHAT WOULD HAVE IMPROVED THE BID OR OFFER OF THE FIRM IN SUCHSECURITIES. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLESECURITIES LAWS AND REGULATIONS, AND THE RULES OF FINRA. THEFIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) FAILED TOPROVIDE FOR THE MINIMUM REQUIREMENTS FOR ADEQUATE WRITTENSUPERVISORY RELATING TO COMPLIANCE WITH FINRA RULE 6460.







Initiated By: FINRA


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






WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOPUBLISH IMMEDIATELY A BID OR OFFER THAT REFLECTED THE PRICE ANDTHE FULL SIZE OF CUSTOMER LIMIT ORDERS FOR OVER-THE-COUNTER(OTC) EQUITY SECURITIES HELD BY THE FIRM THAT WERE AT A PRICETHAT WOULD HAVE IMPROVED THE BID OR OFFER OF THE FIRM IN SUCHSECURITIES. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLESECURITIES LAWS AND REGULATIONS, AND THE RULES OF FINRA. THEFIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) FAILED TOPROVIDE FOR THE MINIMUM REQUIREMENTS FOR ADEQUATE WRITTENSUPERVISORY RELATING TO COMPLIANCE WITH FINRA RULE 6460.


Resolution:


Sanction Details: THE FIRM WAS CENSURED, FINED $30,500, AND UNDERTAKES TO REVISEITS WSPS, WITH RESPECT TO THE AREA DESCRIBED IN THE AWC, ANDWITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC, A REGISTEREDPRINCIPAL OF THE FIRM SHALL SUBMIT TO FINRA A SIGNED, DATEDLETTER, OR AN E-MAIL PROVIDING THE FOLLOWING INFORMATION: AREFERENCE TO THIS MATTER; A REPRESENTATION THAT THE FIRM HASREVISED ITS WSPS, TO ADDRESS THE DEFICIENCIES DESCRIBED IN THEAWC; AND, THE DATE THE REVISED PROCEDURES WERE IMPLEMENTED.



Disclosure 4 of 27

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EXECUTEDSHORT SALE ORDERS AND FAILED TO PROPERLY MARK THE ORDERS ASSHORT. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEMDID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIESLAWS AND REGULATIONS, AND FINRA RULES. THE FIRM'S WRITTENSUPERVISORY PROCEDURES FAILED TO PROVIDE FOR ONE OF THE FOURMINIMUM REQUIREMENTS FOR ADEQUATE WRITTEN SUPERVISORYPROCEDURES FOR ORDER MARKING PURSUANT TO RULE 200(G) OFREGULATION SHO.








Initiated By: FINRA





Principal Product Type: Other

Other Product Type(s): UNSPECIFIED SECURITIES

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EXECUTEDSHORT SALE ORDERS AND FAILED TO PROPERLY MARK THE ORDERS ASSHORT. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEMDID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIESLAWS AND REGULATIONS, AND FINRA RULES. THE FIRM'S WRITTENSUPERVISORY PROCEDURES FAILED TO PROVIDE FOR ONE OF THE FOURMINIMUM REQUIREMENTS FOR ADEQUATE WRITTEN SUPERVISORYPROCEDURES FOR ORDER MARKING PURSUANT TO RULE 200(G) OFREGULATION SHO.


Resolution:

Other Sanctions Ordered: UNDERTAKING: REVISE THE FIRM'S WRITTEN SUPERVISORYPROCEDURES

Sanction Details: THE FIRM WAS CENSURED, FINED $17,500 AND UNDERTAKES TO REVISEITS WRITTEN SUPERVISORY PROCEDURES.FINE PAID IN FULL ON APRIL 7, 2016.


No




Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EXECUTEDSHORT SALE ORDERS AND FAILED TO PROPERLY MARK THE ORDERS ASSHORT. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEMDID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIESLAWS AND REGULATIONS, AND FINRA RULES. THE FIRM'S WRITTENSUPERVISORY PROCEDURES FAILED TO PROVIDE FOR ONE OF THE FOURMINIMUM REQUIREMENTS FOR ADEQUATE WRITTEN SUPERVISORYPROCEDURES FOR ORDER MARKING PURSUANT TO RULE 200(G) OFREGULATION SHO.








Initiated By: FINRA







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EXECUTEDSHORT SALE ORDERS AND FAILED TO PROPERLY MARK THE ORDERS ASSHORT. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEMDID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIESLAWS AND REGULATIONS, AND FINRA RULES. THE FIRM'S WRITTENSUPERVISORY PROCEDURES FAILED TO PROVIDE FOR ONE OF THE FOURMINIMUM REQUIREMENTS FOR ADEQUATE WRITTEN SUPERVISORYPROCEDURES FOR ORDER MARKING PURSUANT TO RULE 200(G) OFREGULATION SHO.


Resolution:

Other Sanctions Ordered: UNDERTAKING: REVISE THE FIRM'S WRITTEN SUPERVISORYPROCEDURES

Sanction Details: THE FIRM WAS CENSURED, FINED $17,500 AND UNDERTAKES TO REVISEITS WRITTEN SUPERVISORY PROCEDURES.



Disclosure 5 of 27

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITCONDITIONED SETTLEMENT OF A DISPUTE WITH A CUSTOMER ON THECUSTOMER'S AGREEMENT TO CONSENT TO, OR NOT TO OPPOSE, AREQUEST FOR EXPUNGEMENT OF ALL REFERENCE TO THE CUSTOMERDISPUTE INFORMATION FROM AN INDIVIDUAL RESPONDENT'S CRDRECORD, WHEN FINRA RULE 2081 PROHIBITS CONDITIONINGSETTLEMENT ON A CUSTOMER'S AGREEMENT NOT TO OBJECT TO, OROPPOSE ANY EFFORTS TO SEEK, EXPUNGEMENT. THE FINDINGS STATEDTHAT SPECIFICALLY, THE FIRM'S CUSTOMER FILED ARBITRATION WITHFINRA DISPUTE RESOLUTION AGAINST THE FIRM AND ONE OF ITSFORMER REGISTERED REPRESENTATIVES, THEREAFTER, THE FIRM ANDTHE REPRESENTATIVE ENTERED INTO A SIGNED SETTLEMENTAGREEMENT WITH THE CUSTOMER. HOWEVER, THE ARBITRATION PANELDENIED THE REPRESENTATIVE'S REQUEST FOR EXPUNGEMENT ANDREFERRED THIS MATTER TO FINRA'S DEPARTMENT OF ENFORCEMENTFOR INVESTIGATION. THE FINDINGS ALSO STATED THAT THE FIRMBECAME AWARE THAT THE SECURITIES AND EXCHANGE COMMISSIONHAD APPROVED FINRA RULE 2081 AND DESPITE THE EFFECTIVE DATE OFRULE 2081, THE FIRM FAILED TO ESTABLISH ANY SYSTEMS ORPROCEDURES TO COMPLY WITH THE RULE UNTIL TEN MONTHS AFTERTHE RULE'S EFFECTIVE DATE. THE FIRM FINALLY IMPLEMENTED SYSTEMSAND PROCEDURES TO ADDRESS RULE 2081'S PROHIBITION.








Initiated By: FINRA







WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITCONDITIONED SETTLEMENT OF A DISPUTE WITH A CUSTOMER ON THECUSTOMER'S AGREEMENT TO CONSENT TO, OR NOT TO OPPOSE, AREQUEST FOR EXPUNGEMENT OF ALL REFERENCE TO THE CUSTOMERDISPUTE INFORMATION FROM AN INDIVIDUAL RESPONDENT'S CRDRECORD, WHEN FINRA RULE 2081 PROHIBITS CONDITIONINGSETTLEMENT ON A CUSTOMER'S AGREEMENT NOT TO OBJECT TO, OROPPOSE ANY EFFORTS TO SEEK, EXPUNGEMENT. THE FINDINGS STATEDTHAT SPECIFICALLY, THE FIRM'S CUSTOMER FILED ARBITRATION WITHFINRA DISPUTE RESOLUTION AGAINST THE FIRM AND ONE OF ITSFORMER REGISTERED REPRESENTATIVES, THEREAFTER, THE FIRM ANDTHE REPRESENTATIVE ENTERED INTO A SIGNED SETTLEMENTAGREEMENT WITH THE CUSTOMER. HOWEVER, THE ARBITRATION PANELDENIED THE REPRESENTATIVE'S REQUEST FOR EXPUNGEMENT ANDREFERRED THIS MATTER TO FINRA'S DEPARTMENT OF ENFORCEMENTFOR INVESTIGATION. THE FINDINGS ALSO STATED THAT THE FIRMBECAME AWARE THAT THE SECURITIES AND EXCHANGE COMMISSIONHAD APPROVED FINRA RULE 2081 AND DESPITE THE EFFECTIVE DATE OFRULE 2081, THE FIRM FAILED TO ESTABLISH ANY SYSTEMS ORPROCEDURES TO COMPLY WITH THE RULE UNTIL TEN MONTHS AFTERTHE RULE'S EFFECTIVE DATE. THE FIRM FINALLY IMPLEMENTED SYSTEMSAND PROCEDURES TO ADDRESS RULE 2081'S PROHIBITION.


Resolution:



FINE PAID IN FULL ON FEBRUARY 9, 2016.


No










Initiated By: FINRA







Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITCONDITIONED SETTLEMENT OF A DISPUTE WITH A CUSTOMER ON THECUSTOMER'S AGREEMENT TO CONSENT TO, OR NOT TO OPPOSE, AREQUEST FOR EXPUNGEMENT OF ALL REFERENCE TO THE CUSTOMERDISPUTE INFORMATION FROM AN INDIVIDUAL RESPONDENT'S CRDRECORD, WHEN FINRA RULE 2081 PROHIBITS CONDITIONINGSETTLEMENT ON A CUSTOMER'S AGREEMENT NOT TO OBJECT TO, OROPPOSE ANY EFFORTS TO SEEK, EXPUNGEMENT. THE FINDINGS STATEDTHAT SPECIFICALLY, THE FIRM'S CUSTOMER FILED ARBITRATION WITHFINRA DISPUTE RESOLUTION AGAINST THE FIRM AND ONE OF ITSFORMER REGISTERED REPRESENTATIVES, THEREAFTER, THE FIRM ANDTHE REPRESENTATIVE ENTERED INTO A SIGNED SETTLEMENTAGREEMENT WITH THE CUSTOMER. HOWEVER, THE ARBITRATION PANELDENIED THE REPRESENTATIVE'S REQUEST FOR EXPUNGEMENT ANDREFERRED THIS MATTER TO FINRA'S DEPARTMENT OF ENFORCEMENTFOR INVESTIGATION. THE FINDINGS ALSO STATED THAT THE FIRMBECAME AWARE THAT THE SECURITIES AND EXCHANGE COMMISSIONHAD APPROVED FINRA RULE 2081 AND DESPITE THE EFFECTIVE DATE OFRULE 2081, THE FIRM FAILED TO ESTABLISH ANY SYSTEMS ORPROCEDURES TO COMPLY WITH THE RULE UNTIL TEN MONTHS AFTERTHE RULE'S EFFECTIVE DATE. THE FIRM FINALLY IMPLEMENTED SYSTEMSAND PROCEDURES TO ADDRESS RULE 2081'S PROHIBITION.



Resolution:












Disclosure 6 of 27

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Initiated By: FINRA


Other


N/A




Other Product Type(s): OVER-THE-COUNTER SECURITIES

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT ACCEPTEDAND HELD CUSTOMER ORDERS IN OVER-THE-COUNTER (OTC)SECURITIES, TRADED FOR ITS OWN ACCOUNT AT PRICES THAT WOULDHAVE SATISFIED THE CUSTOMER ORDERS, AND FAILED TO EXECUTE ORIMMEDIATELY EXECUTE THE CUSTOMER ORDERS UP TO THE SIZE AND ATTHE SAME PRICE AT WHICH IT TRADED FOR ITS OWN ACCOUNT OR AT ABETTER PRICE.



Resolution:


Sanction Details: THE FIRM WAS CENSURED, FINED $7,500, AND HAS ALREADYVOLUNTARILY MADE RESTITUTION TO AFFECTED CUSTOMERS.FINE PAID IN FULL ON DECEMBER 17, 2015.


No

Sanctions Ordered: CensureMonetary/Fine $7,500.00Disgorgement/Restitution








THE FIRM WAS CENSURED, FINED $7,500, AND HAS ALREADYVOLUNTARILY MADE RESTITUTION TO AFFECTED CUSTOMERS.FINE PAID IN FULL ON DECEMBER 17, 2015.


Initiated By: FINRA


Other


N/A




Other Product Type(s): OVER-THE-COUNTER SECURITIES

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT ACCEPTEDAND HELD CUSTOMER ORDERS IN OVER-THE-COUNTER (OTC)SECURITIES, TRADED FOR ITS OWN ACCOUNT AT PRICES THAT WOULDHAVE SATISFIED THE CUSTOMER ORDERS, AND FAILED TO EXECUTE ORIMMEDIATELY EXECUTE THE CUSTOMER ORDERS UP TO THE SIZE AND ATTHE SAME PRICE AT WHICH IT TRADED FOR ITS OWN ACCOUNT OR AT ABETTER PRICE.



Resolution:


Sanction Details: THE FIRM WAS CENSURED, FINED $7,500, AND HAS ALREADYVOLUNTARILY MADE RESTITUTION TO AFFECTED CUSTOMERS.



Disclosure 7 of 27

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TODISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN REGULATION NMSSECURITIES (INCLUDING THE ORDERS' FULL SIZE AND PRICE) IN ITSPUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THATWOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCHSECURITY; OR WHEN THE ORDER WAS, PRICED EQUAL TO THE FIRM'S BIDOR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCHSECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DEMINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'SBID OR OFFER IN EACH SUCH SECURITY. THE FINDINGS STATED THAT THEFIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOTHE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULESOF FINRA. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS)FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS FOR ADEQUATEWSPS CONCERNING LIMIT ORDER DISPLAY.








Initiated By: NASDAQ STOCK MARKET






Other Product Type(s): REGULATION NMS SECURITIES



Resolution:

Other Sanctions Ordered: UNDERTAKING: REVISE THE FIRM'S WSPS.

Sanction Details: THE FIRM WAS CENSURED, FINED $36,000 AND UNDERTAKES TO REVISEITS WSPS.


No









Initiated By: NASDAQ STOCK MARKET






Other Product Type(s): REGULATION NMS SECURITIES




Resolution:

Other Sanctions Ordered: UNDERTAKING: REVISE THE FIRM'S WSPS.

Sanction Details: THE FIRM WAS CENSURED, FINED $36,000 AND UNDERTAKES TO REVISEITS WSPS.








Disclosure 8 of 27

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Initiated By: FINRA


Other


N/A





Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOPUBLISH IMMEDIATELY A BID OR OFFER THAT REFLECTED THE PRICE ANDTHE FULL SIZE OF CUSTOMER LIMIT ORDERS FOR OTC EQUITYSECURITIES HELD BY THE FIRM THAT WERE AT A PRICE THAT WOULDHAVE IMPROVED THE BID OR OFFER OF THE FIRM IN SUCH SECURITIES.THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO FINRA RULE 6460.



Resolution:

Other Sanctions Ordered: UNDERTAKING: THE FIRM IS REQUIRED TO REVISE IT'S WSPS.

Sanction Details: SEE ABOVE

Regulator Statement FINE PAID IN FULL ON JULY 1, 2014.


No










Initiated By: FINRA


Other






Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOPUBLISH IMMEDIATELY A BID OR OFFER THAT REFLECTED THE PRICE ANDTHE FULL SIZE OF CUSTOMER LIMIT ORDERS FOR OTC EQUITYSECURITIES HELD BY THE FIRM THAT WERE AT A PRICE THAT WOULDHAVE IMPROVED THE BID OR OFFER OF THE FIRM IN SUCH SECURITIES.THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO FINRA RULE 6460.



Resolution:

Other Sanctions Ordered: UNDERTAKING: THE FIRM IS REQUIRED TO REVISE IT'S WSPS.




Disclosure 9 of 27

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN CERTAININSTANCES, IT FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY. THEFINDINGS STATED THAT IN SOME TRANSACTIONS FOR OR WITH ACUSTOMER, THE FIRM FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY ORSELL IN SUCH A MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS.








Initiated By: FINRA


Other


N/A





WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN CERTAININSTANCES, IT FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY. THEFINDINGS STATED THAT IN SOME TRANSACTIONS FOR OR WITH ACUSTOMER, THE FIRM FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY ORSELL IN SUCH A MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS.


Resolution:

Other Sanctions Ordered: THE FIRM IS ORDERED TO PAY $2,617.11, PLUS INTEREST, IN RESTITUTIONTO CUSTOMERS.


Regulator Statement FINE PAID IN FULL ON JULY 1, 2014.


No




Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN CERTAININSTANCES, IT FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY. THEFINDINGS STATED THAT IN SOME TRANSACTIONS FOR OR WITH ACUSTOMER, THE FIRM FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY ORSELL IN SUCH A MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS.








Initiated By: FINRA


Other






WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN CERTAININSTANCES, IT FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY. THEFINDINGS STATED THAT IN SOME TRANSACTIONS FOR OR WITH ACUSTOMER, THE FIRM FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY ORSELL IN SUCH A MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS.


Resolution:

Other Sanctions Ordered: THE FIRM IS ORDERED TO PAY $2617.11, PLUS INTEREST, IN RESTITUTIONTO CUSTOMERS.




Disclosure 10 of 27

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Initiated By: FINRA

Allegations: FINRA RULE 2010, NASD RULES 2111(A), 2320 - VFINANCE INVESTMENTS,INC. FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY. INTRANSACTIONS FOR OR WITH A CUSTOMER, THE FIRM FAILED TO USEREASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALERMARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THERESULTANT PRICE TO ITS CUSTOMERS WAS AS FAVORABLE AS POSSIBLEUNDER PREVAILING MARKET CONDITIONS.








Initiated By: FINRA








Resolution:


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 $12,500 AND ORDERED TOPAY $467.71, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. AREGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORYPROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE ANDDOCUMENTED EFFORTS UNDERTAKEN TOEFFECT RESTITUTION, TO FINRA NO LATER THAN 120 DAYS AFTERACCEPTANCE OF THIS AWC. ANY UNDISTRIBUTED RESTITUTION ANDINTEREST SHALL BE FORWARDED TO THE APPROPRIATE ESCHEAT,UNCLAIMED PROPERTY OR ABANDONED-PROPERTY FUND FOR THESTATE IN WHICH THE CUSTOMER IS KNOWN TO HAVE LAST RESIDED.FINE PAID IN FULL ON NOVEMBER 12, 2013.


No












Initiated By: FINRA









Resolution:


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 $12,500 AND ORDERED TOPAY $467.71, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. AREGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORYPROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE ANDDOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION, TOFINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. ANYUNDISTRIBUTED RESTITUTION AND INTEREST SHALL BE FORWARDED TOTHE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONED-PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS KNOWN TOHAVE LAST RESIDED.



Disclosure 11 of 27

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Allegations: RULE 101 OF SECURITIES EXCHANGE ACT REGULATION M, SECTION 17(A)OF THE SECURITIES EXCHANGE ACT, RULE 17A-4 THEREUNDER, NASDRULES 2110, 3010(A), 3010(D), 3010(D)(2), 3070(A), 3110 - VFINANCEINVESTMENTS, INC. ACTED AS THE PRIVATE PLACEMENT AGENT FOR APLACEMENT OF UP TO $5 MILLION IN CONVERTIBLE NOTES ISSUED BY ACOMPANY. INVESTORS, SOME OF WHOM WERE FIRM CUSTOMERS,INVESTED A TOTAL OF $5,950,000 IN THE PRIVATE PLACEMENT WHILE THEISSUER WAS ON THE FIRM'S RESTRICTED LIST FOR THE DURATION OF ITSPARTICIPATION IN THE OFFERING. A NUMBER OF CUSTOMERS WERESOLICITED TO BUY THE ISSUER'S STOCK WHILE THE FIRM WASCONDUCTING THE PRIVATE PLACEMENT. THE FIRM DID NOT ADEQUATELYSUPERVISE THE PURCHASES OF STOCKS ON THE RESTRICTED LISTALTHOUGH THE FIRM'S PROCEDURES REQUIRED IT TO MONITORPURCHASES OF SECURITIES OF ISSUERS ON ITS RESTRICTED LIST,INCLUDING THOSE FOR WHICH IT WAS CONDUCTING OFFERINGS. THEFIRM FAILED TO ENFORCE THOSE PROCEDURES ADEQUATELY ANDINSTEAD AUTHORIZED PURCHASES OF THE ISSUER BY CUSTOMERSWITHOUT CONDUCTING AN ADEQUATE INQUIRY INTO THE FACTS ANDCIRCUMSTANCES SURROUNDING THOSE PURCHASES; THEREBY FAILINGTO REASONABLY SUPERVISE ACTIVITY IN THE ISSUER'S STOCK IN AMANNER REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHREGULATION M. THE FIRM FAILED TO DISCLOSE INVOLVEMENT OF ASTATUTORILY DISQUALIFIED PERSON WHO WORKED CLOSELY WITH FIRMEMPLOYEES IN CONNECTION WITH THE PRIVATE PLACEMENT,COMMUNICATING DIRECTLY WITH THE FIRM'S INVESTMENT BANKINGDEPARTMENT AND OTHERS. A REGISTERED REPRESENTATIVE INVOLVEDIN THE SOLICITATION OF PURCHASES OF THE STOCK USED HISPERSONAL EMAIL ACCOUNT TO SOLICIT PURCHASES OF STOCK AND FOROTHER BUSINESS PURPOSES AND FORWARDED AND ADDRESSED SOMEOF THE EMAILS TO FIRM EMAIL ADDRESSES OF OTHER FIRM EMPLOYEES,INCLUDING MANAGERIAL-LEVEL EMPLOYEES. OTHER THAN EMAILS SENTTO OR FROM OTHER FIRM EMPLOYEES, THE REPRESENTATIVE'S EMAILSWERE NOT CAPTURED BY THE FIRM'S EMAIL SYSTEM FOR RETENTIONAND REVIEW ALTHOUGH THE SEC HAD PREVIOUSLY BROUGHT CHARGESAGAINST THE FIRM AND ITS PRESIDENT FOR FAILING TO CAPTURE,RETAIN AND PRODUCE EMAILS SENT TO AND FROM ANOTHER FIRMEMPLOYEE WHO USED AN OUTSIDE EMAIL ACCOUNT AND INSTANTMESSAGING. THE FIRM SHOULD HAVE BEEN ON HEIGHTENEDAWARENESS OF ITS OBLIGATIONS TO SUPERVISE THE USE OF EXTERNALEMAIL ACCOUNTS. THE FIRM DID NOT CREATE AND IMPLEMENTPROCEDURES REASONABLY DESIGNED TO REVIEW INCOMING ANDOUTGOING SECURITIES-RELATED AND INVESTMENT BANKING-RELATEDCORRESPONDENCE, INCLUDING ELECTRONIC CORRESPONDENCE SOTHAT THE FIRM DID NOT ADEQUATELY SUPERVISE EMPLOYEES' OUTSIDEEMAIL ACCOUNTS.







Initiated By: FINRA





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

Other Product Type(s): CONVERTIBLE NOTES

RULE 101 OF SECURITIES EXCHANGE ACT REGULATION M, SECTION 17(A)OF THE SECURITIES EXCHANGE ACT, RULE 17A-4 THEREUNDER, NASDRULES 2110, 3010(A), 3010(D), 3010(D)(2), 3070(A), 3110 - VFINANCEINVESTMENTS, INC. ACTED AS THE PRIVATE PLACEMENT AGENT FOR APLACEMENT OF UP TO $5 MILLION IN CONVERTIBLE NOTES ISSUED BY ACOMPANY. INVESTORS, SOME OF WHOM WERE FIRM CUSTOMERS,INVESTED A TOTAL OF $5,950,000 IN THE PRIVATE PLACEMENT WHILE THEISSUER WAS ON THE FIRM'S RESTRICTED LIST FOR THE DURATION OF ITSPARTICIPATION IN THE OFFERING. A NUMBER OF CUSTOMERS WERESOLICITED TO BUY THE ISSUER'S STOCK WHILE THE FIRM WASCONDUCTING THE PRIVATE PLACEMENT. THE FIRM DID NOT ADEQUATELYSUPERVISE THE PURCHASES OF STOCKS ON THE RESTRICTED LISTALTHOUGH THE FIRM'S PROCEDURES REQUIRED IT TO MONITORPURCHASES OF SECURITIES OF ISSUERS ON ITS RESTRICTED LIST,INCLUDING THOSE FOR WHICH IT WAS CONDUCTING OFFERINGS. THEFIRM FAILED TO ENFORCE THOSE PROCEDURES ADEQUATELY ANDINSTEAD AUTHORIZED PURCHASES OF THE ISSUER BY CUSTOMERSWITHOUT CONDUCTING AN ADEQUATE INQUIRY INTO THE FACTS ANDCIRCUMSTANCES SURROUNDING THOSE PURCHASES; THEREBY FAILINGTO REASONABLY SUPERVISE ACTIVITY IN THE ISSUER'S STOCK IN AMANNER REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHREGULATION M. THE FIRM FAILED TO DISCLOSE INVOLVEMENT OF ASTATUTORILY DISQUALIFIED PERSON WHO WORKED CLOSELY WITH FIRMEMPLOYEES IN CONNECTION WITH THE PRIVATE PLACEMENT,COMMUNICATING DIRECTLY WITH THE FIRM'S INVESTMENT BANKINGDEPARTMENT AND OTHERS. A REGISTERED REPRESENTATIVE INVOLVEDIN THE SOLICITATION OF PURCHASES OF THE STOCK USED HISPERSONAL EMAIL ACCOUNT TO SOLICIT PURCHASES OF STOCK AND FOROTHER BUSINESS PURPOSES AND FORWARDED AND ADDRESSED SOMEOF THE EMAILS TO FIRM EMAIL ADDRESSES OF OTHER FIRM EMPLOYEES,INCLUDING MANAGERIAL-LEVEL EMPLOYEES. OTHER THAN EMAILS SENTTO OR FROM OTHER FIRM EMPLOYEES, THE REPRESENTATIVE'S EMAILSWERE NOT CAPTURED BY THE FIRM'S EMAIL SYSTEM FOR RETENTIONAND REVIEW ALTHOUGH THE SEC HAD PREVIOUSLY BROUGHT CHARGESAGAINST THE FIRM AND ITS PRESIDENT FOR FAILING TO CAPTURE,RETAIN AND PRODUCE EMAILS SENT TO AND FROM ANOTHER FIRMEMPLOYEE WHO USED AN OUTSIDE EMAIL ACCOUNT AND INSTANTMESSAGING. THE FIRM SHOULD HAVE BEEN ON HEIGHTENEDAWARENESS OF ITS OBLIGATIONS TO SUPERVISE THE USE OF EXTERNALEMAIL ACCOUNTS. THE FIRM DID NOT CREATE AND IMPLEMENTPROCEDURES REASONABLY DESIGNED TO REVIEW INCOMING ANDOUTGOING SECURITIES-RELATED AND INVESTMENT BANKING-RELATEDCORRESPONDENCE, INCLUDING ELECTRONIC CORRESPONDENCE SOTHAT THE FIRM DID NOT ADEQUATELY SUPERVISE EMPLOYEES' OUTSIDEEMAIL ACCOUNTS.


Resolution:


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 AND FINED $65,000.FINE PAID IN FULL ON MARCH 7, 2016.


No




Allegations: RULE 101 OF SECURITIES EXCHANGE ACT REGULATION M, SECTION 17(A)OF THE SECURITIES EXCHANGE ACT, RULE 17A-4 THEREUNDER, NASDRULES 2110,3010(A), 3010(D), 3010(D)(2), 3070(A), 3110 - VFINANCEINVESTMENTS, INC. ACTED AS THE PRIVATE PLACEMENT AGENT FOR ANISSUER. A NUMBER OF CUSTOMERS WERE SOLICITED TO BUY THEISSUER'S STOCK WHILE THE FIRM WAS CONDUCTING THE PRIVATEPLACEMENT. THE FIRM DID NOT ADEQUATELY SUPERVISE THEPURCHASES OF STOCKS ON THE RESTRICTED LIST. THEREBY FAILING TOREASONABLY SUPERVISE ACTIVITY IN THE ISSUER'S STOCK IN A MANNERREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REGULATION M.THE FIRM FAILED TO DISCLOSE INVOLVEMENT OF A STATUTORILYDISQUALIFIED PERSON WHO WORKED CLOSELY WITH FIRM EMPLOYEESIN CONNECTION WITH THE PRIVATE PLACEMENT. THE FIRM DID NOTCREATE AND IMPLEMENT PROCEDURES REASONABLY DESIGNED TOREVIEW INCOMING AND OUTGOING SECURITIES-RELATED ANDINVESTMENT BANKING-RELATED CORRESPONDENCE, INCLUDINGELECTRONIC CORRESPONDENCE SO THAT THE FIRM DID NOTADEQUATELY SUPERVISE EMPLOYEES' OUTSIDE EMAIL ACCOUNTS.








Initiated By: FINRA






Other Product Type(s): CONVERTIBLE NOTES

RULE 101 OF SECURITIES EXCHANGE ACT REGULATION M, SECTION 17(A)OF THE SECURITIES EXCHANGE ACT, RULE 17A-4 THEREUNDER, NASDRULES 2110,3010(A), 3010(D), 3010(D)(2), 3070(A), 3110 - VFINANCEINVESTMENTS, INC. ACTED AS THE PRIVATE PLACEMENT AGENT FOR ANISSUER. A NUMBER OF CUSTOMERS WERE SOLICITED TO BUY THEISSUER'S STOCK WHILE THE FIRM WAS CONDUCTING THE PRIVATEPLACEMENT. THE FIRM DID NOT ADEQUATELY SUPERVISE THEPURCHASES OF STOCKS ON THE RESTRICTED LIST. THEREBY FAILING TOREASONABLY SUPERVISE ACTIVITY IN THE ISSUER'S STOCK IN A MANNERREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REGULATION M.THE FIRM FAILED TO DISCLOSE INVOLVEMENT OF A STATUTORILYDISQUALIFIED PERSON WHO WORKED CLOSELY WITH FIRM EMPLOYEESIN CONNECTION WITH THE PRIVATE PLACEMENT. THE FIRM DID NOTCREATE AND IMPLEMENT PROCEDURES REASONABLY DESIGNED TOREVIEW INCOMING AND OUTGOING SECURITIES-RELATED ANDINVESTMENT BANKING-RELATED CORRESPONDENCE, INCLUDINGELECTRONIC CORRESPONDENCE SO THAT THE FIRM DID NOTADEQUATELY SUPERVISE EMPLOYEES' OUTSIDE EMAIL ACCOUNTS.


Resolution:


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 AND FINED $65,000.



Disclosure 12 of 27

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Allegations: SECTIONS 15(C) AND 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934,SEC RULES 15C3-1, 17A-3, 17A-5, AND 17A-11, FINRA RULE 2010, NASDRULE 3110(A): THE FIRM CONDUCTED A SECURITIES BUSINESS WHILE ITFAILED TO MAINTAIN ITS REQUIRED MINIMUM NET CAPITAL. IN SUM, THEFIRM BOOKED TRANSACTIONS FOR WHICH THERE WAS NO ECONOMICSUBSTANCE OR SUPPORT; DOUBLE-COUNTED CERTAIN COMMISSIONSAND PROFITS AND LOSSES IN PROPRIETARY TRADING ACCOUNTS,RESULTING IN OVERSTATEMENTS OF ITS INCOME AND NET CAPITALPOSITIONS; IMPROPERLY TREATED CERTAIN CONTRIBUTIONS FROM ARELATED COMPANY AS CAPITAL CONTRIBUTIONS. IN CONNECTION WITHTHE MISCLASSIFICATIONS AND DOUBLE-COUNTING ERRORS, THE FIRMFAILED TO FILE THE REQUISITE NOTIFICATIONS OF ITS NET CAPITALDEFICIENCIES, FAILED TO FILE EARLY WARNING NOTIFICATIONS, FILEDINACCURATE MONTHLY FOCUS REPORTS AND AN INACCURATE ANNUALAUDIT, AND MAINTAINED INACCURATE BOOKS AND RECORDS.








Initiated By: FINRA


Other


N/A





SECTIONS 15(C) AND 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934,SEC RULES 15C3-1, 17A-3, 17A-5, AND 17A-11, FINRA RULE 2010, NASDRULE 3110(A): THE FIRM CONDUCTED A SECURITIES BUSINESS WHILE ITFAILED TO MAINTAIN ITS REQUIRED MINIMUM NET CAPITAL. IN SUM, THEFIRM BOOKED TRANSACTIONS FOR WHICH THERE WAS NO ECONOMICSUBSTANCE OR SUPPORT; DOUBLE-COUNTED CERTAIN COMMISSIONSAND PROFITS AND LOSSES IN PROPRIETARY TRADING ACCOUNTS,RESULTING IN OVERSTATEMENTS OF ITS INCOME AND NET CAPITALPOSITIONS; IMPROPERLY TREATED CERTAIN CONTRIBUTIONS FROM ARELATED COMPANY AS CAPITAL CONTRIBUTIONS. IN CONNECTION WITHTHE MISCLASSIFICATIONS AND DOUBLE-COUNTING ERRORS, THE FIRMFAILED TO FILE THE REQUISITE NOTIFICATIONS OF ITS NET CAPITALDEFICIENCIES, FAILED TO FILE EARLY WARNING NOTIFICATIONS, FILEDINACCURATE MONTHLY FOCUS REPORTS AND AN INACCURATE ANNUALAUDIT, AND MAINTAINED INACCURATE BOOKS AND RECORDS.


Resolution:


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 AND FINED $25,000. FINE PAID INFULL ON SEPTEMBER 8, 2014.


No










Initiated By: FINRA








Allegations: SECTIONS 15(C) AND 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934,SEC RULES 15C3-1, 17A-3, 17A-5, AND 17A-11, FINRA RULE 2010, NASDRULE 3110(A): THE FIRM CONDUCTED A SECURITIES BUSINESS WHILE ITFAILED TO MAINTAIN ITS REQUIRED MINIMUM NET CAPITAL. IN SUM, THEFIRM BOOKED TRANSACTIONS FOR WHICH THERE WAS NO ECONOMICSUBSTANCE OR SUPPORT; DOUBLE-COUNTED CERTAIN COMMISSIONSAND PROFITS AND LOSSES IN PROPRIETARY TRADING ACCOUNTS,RESULTING IN OVERSTATEMENTS OF ITS INCOME AND NET CAPITALPOSITIONS; IMPROPERLY TREATED CERTAIN CONTRIBUTIONS FROM ARELATED COMPANY AS CAPITAL CONTRIBUTIONS. IN CONNECTION WITHTHE MISCLASSIFICATIONS AND DOUBLE-COUNTING ERRORS, THE FIRMFAILED TO FILE THE REQUISITE NOTIFICATIONS OF ITS NET CAPITALDEFICIENCIES, FAILED TO FILE EARLY WARNING NOTIFICATIONS, FILEDINACCURATE MONTHLY FOCUS REPORTS AND AN INACCURATE ANNUALAUDIT, AND MAINTAINED INACCURATE BOOKS AND RECORDS.



Resolution:


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 AND FINED $25,000.



Disclosure 13 of 27

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Initiated By: FINRA


Other


N/A



Principal Product Type: Debt - Corporate


Allegations: NASD RULES 2110, 2440, INTERPRETATIVE MATERIAL-2440-1, ANDINTERPRETATIVE MATERIAL-2440-2: DURING THE REVIEW PERIOD, IN 13TRANSACTIONS, THE FIRM SOLD CORPORATE BONDS TO CUSTOMERSAND FAILED TO SELL SUCH BONDS AT A PRICE THAT WAS FAIR, TAKINGINTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDINGMARKET CONDITIONS WITH RESPECT TO EACH BOND AT THE TIME OF THETRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WASENTITLED TO A PROFIT.



Resolution:


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 $22,500 AND REQUIRED TOPAY $7,738.92, PLUS INTEREST IN RESTITUTION TO CUSTOMERS. AREGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORYPROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE ANDDOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION TOFINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. IFFOR ANY REASON, RESPONDENT CANNOT LOCATE ANY CUSTOMERAFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN SUCH PERIOD,OR SUCH ADDITIONAL PERIOD AGREED TO BY THE STAFF, RESPONDENTSHALL FORWARD ANY UNDISTRIBUTED RESTITUTION AND INTEREST TOTHE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONED-PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS KNOWN TOHAVE LAST RESIDED.


No









WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED, FINED $22,500 AND REQUIRED TOPAY $7,738.92, PLUS INTEREST IN RESTITUTION TO CUSTOMERS. AREGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT SATISFACTORYPROOF OF PAYMENT OF THE RESTITUTION, OR OF REASONABLE ANDDOCUMENTED EFFORTS UNDERTAKEN TO EFFECT RESTITUTION TOFINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THIS AWC. IFFOR ANY REASON, RESPONDENT CANNOT LOCATE ANY CUSTOMERAFTER REASONABLE AND DOCUMENTED EFFORTS WITHIN SUCH PERIOD,OR SUCH ADDITIONAL PERIOD AGREED TO BY THE STAFF, RESPONDENTSHALL FORWARD ANY UNDISTRIBUTED RESTITUTION AND INTEREST TOTHE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONED-PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER IS KNOWN TOHAVE LAST RESIDED.


Initiated By: FINRA






Principal Product Type: Debt - Corporate


Allegations: NASD RULES 2110, 2440, INTERPRETATIVE MATERIAL-2440-1, ANDINTERPRETATIVE MATERIAL-2440-2: DURING THE REVIEW PERIOD, IN 13TRANSACTIONS, THE FIRM SOLD CORPORATE BONDS TO CUSTOMERSAND FAILED TO SELL SUCH BONDS AT A PRICE THAT WAS FAIR, TAKINGINTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDINGMARKET CONDITIONS WITH RESPECT TO EACH BOND AT THE TIME OF THETRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WASENTITLED TO A PROFIT.



Resolution:


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 $22,500 AND REQUIRED TOPAY $7,738.92, PLUS INTEREST IN RESTITUTION TO CUSTOMERS









WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED, FINED $22,500 AND REQUIRED TOPAY $7,738.92, PLUS INTEREST IN RESTITUTION TO CUSTOMERS

Disclosure 14 of 27

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Reporting Source: Firm

Initiated By: STATE OF FLORIDA DEPARTMENT OF FINANCIALSERVICES





Docket/Case Number: 122032-11-AG



Allegations: THE STATE OF FLORIDA DENIED VFINANCE'S APPLICATION FORINSURANCE BASED ON A FINDING THAT A QUESTION ON THEAPPLICATION, ASKING WHETHER THE FIRM/AGENCY, MAJORITY OWNERS,PARTNERS, OFFICERS OR DIRECTORS EVER HAD ANY PROFESSIONALLICENSE SUBJECT TO AN ADMINISTRATIVE FINE OR PENALTY, WASINCORRECTLY ANSWERED "NO" WHEN IT SHOULD HAVE BEEN ANSWERED "YES", RESULTING IN ALLEGED VIOLATIONS OF SECTIONS 626.6115 AND626.6215, FLORIDA STATUTES.



Resolution:


Sanction Details: FIRM CHARGED ADMINISTRATIVE PENALTY OF $5000 IN ORDER FORFIRM'S LICENSE TO BE REINSTATED.

Firm Statement FIRM'S INCORRECT RESPONSE WAS AN INADVERTENT ERROR BASED ONADVICE OF OUTSIDE COUNSEL AND WAS NOT INTENDED TO MISLEAD ORMISREPRESENT ITS ADMINISTRATIVE HISTORY.

Sanctions Ordered: Monetary/Fine $5,000.00

Order

Disclosure 15 of 27

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Initiated By: INSURANCE COMMISSIONER OF STATE OF OKLAHOMA





Docket/Case Number: 10-0643-DIS



Allegations: FIRM VIOLATED 36 O.S. § 1435.13(A)(1); PROVIDING INCORRECT,MISLEADING, INCOMPLETE OR MATERRIALLY UNTRUE INFORMATION INTHE LICENSE APPLICATION.



Resolution:


Sanction Details: FINE OF $1000 ASSESSED IN ORDER FOR FIRM'S LICENSE TO BEREINSTATED. FINE PAID ON 06/16/2010.

Firm Statement FINE PAID ON 06/16/2010


Order

Disclosure 16 of 27

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Allegations: FINRA RULE 7450 - VFINANCE INVESTMENTS, INC. TRANSMITTED TO THEORDER AUDIT TRAIL SYSTEM (OATS) REPORTS THAT CONTAINEDINACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA; THEREPORTS WERE MARKED WITH A LIMIT ORDER DISPLAY INDICATOR OF "Y", INDICATING THAT THE FIRM RECEIVED INSTRUCTIONS FROM THECUSTOMER THAT A BLOCK SIZE LIMIT ORDER SHOULD BE DISPLAYED,WHEN IN FACT NO SUCH INSTRUCTION WAS RECEIVED. THE FIRMTRANSMITTED TO OATS REPORTS THAT CONTAINED INACCURATE,INCOMPLETE OR IMPROPERLY FORMATTED DATA; REPORTS OMITTEDDESK (DS)INFORMATION ON NEW ORDER (NW) REPORTS; REPORTSOMITTED DESK (DS)INFORMATION ON NEW ORDER (NW) REPORTS ANDTHE FIRM SUBMITTED ERRONEOUS ROUTE (RT) REPORTS; AND IN ONEINSTANCE, REPORTS CONTAINED INACCURATE ACCOUNT TYPE CODES.







Initiated By: FINRA







FINRA RULE 7450 - VFINANCE INVESTMENTS, INC. TRANSMITTED TO THEORDER AUDIT TRAIL SYSTEM (OATS) REPORTS THAT CONTAINEDINACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA; THEREPORTS WERE MARKED WITH A LIMIT ORDER DISPLAY INDICATOR OF "Y", INDICATING THAT THE FIRM RECEIVED INSTRUCTIONS FROM THECUSTOMER THAT A BLOCK SIZE LIMIT ORDER SHOULD BE DISPLAYED,WHEN IN FACT NO SUCH INSTRUCTION WAS RECEIVED. THE FIRMTRANSMITTED TO OATS REPORTS THAT CONTAINED INACCURATE,INCOMPLETE OR IMPROPERLY FORMATTED DATA; REPORTS OMITTEDDESK (DS)INFORMATION ON NEW ORDER (NW) REPORTS; REPORTSOMITTED DESK (DS)INFORMATION ON NEW ORDER (NW) REPORTS ANDTHE FIRM SUBMITTED ERRONEOUS ROUTE (RT) REPORTS; AND IN ONEINSTANCE, REPORTS CONTAINED INACCURATE ACCOUNT TYPE CODES.


Resolution:


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 AND FINED $12,500. FINE PAID INFULL DECEMBER 7, 2011.


No




Allegations: FINRA RULE 7450 - VFINANCE INVESTMENTS, INC. TRANSMITTED TO THEORDER AUDIT TRAILSYSTEM (OATS) REPORTS THAT CONTAINED INACCURATE, INCOMPLETEOR IMPROPERLYFORMATTED DATA; THE REPORTS WERE MARKED WITH A LIMIT ORDERDISPLAY INDICATOROF "Y", INDICATING THAT THE FIRM RECEIVED INSTRUCTIONS FROM THECUSTOMER THAT ABLOCK SIZE LIMIT ORDER SHOULD BE DISPLAYED, WHEN IN FACT NOSUCH INSTRUCTIONWAS RECEIVED. THE FIRM TRANSMITTED TO OATS REPORTS THATCONTAINED INACCURATE,INCOMPLETE OR IMPROPERLY FORMATTED DATA; REPORTS OMITTEDDESK(DS)INFORMATION ON NEW ORDER (NW) REPORTS; REPORTS OMITTEDDESK(DS)INFORMATION ON NEW ORDER (NW) REPORTS AND THE FIRMSUBMITTED ERRONEOUSROUTE (RT) REPORTS; AND IN ONE INSTANCE, REPORTS CONTAINEDINACCURATE ACCOUNTTYPE CODES.








Initiated By: FINRA







FINRA RULE 7450 - VFINANCE INVESTMENTS, INC. TRANSMITTED TO THEORDER AUDIT TRAILSYSTEM (OATS) REPORTS THAT CONTAINED INACCURATE, INCOMPLETEOR IMPROPERLYFORMATTED DATA; THE REPORTS WERE MARKED WITH A LIMIT ORDERDISPLAY INDICATOROF "Y", INDICATING THAT THE FIRM RECEIVED INSTRUCTIONS FROM THECUSTOMER THAT ABLOCK SIZE LIMIT ORDER SHOULD BE DISPLAYED, WHEN IN FACT NOSUCH INSTRUCTIONWAS RECEIVED. THE FIRM TRANSMITTED TO OATS REPORTS THATCONTAINED INACCURATE,INCOMPLETE OR IMPROPERLY FORMATTED DATA; REPORTS OMITTEDDESK(DS)INFORMATION ON NEW ORDER (NW) REPORTS; REPORTS OMITTEDDESK(DS)INFORMATION ON NEW ORDER (NW) REPORTS AND THE FIRMSUBMITTED ERRONEOUSROUTE (RT) REPORTS; AND IN ONE INSTANCE, REPORTS CONTAINEDINACCURATE ACCOUNTTYPE CODES.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THEDESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE,THE FIRM ISCENSURED AND FINED $12,500.



Disclosure 17 of 27

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Initiated By: FINRA





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


Allegations: SEC RULES 200(G) AND 203(B)(3) OF REGULATION SHO - VFINANCEINVESTMENTS, INC. FAILED TO PROPERLY MARK SELL ORDERS AS SHORT.THE FIRM ACCEPTED SHORT SALE ORDERS IN AN EQUITY SECURITYFROM ANOTHER PERSON, OR EFFECTED SHORT SALES IN AN EQUITYSECURITY FOR ITS OWN ACCOUNT WITHOUT BORROWING THE SECURITY,OR ENTERING INTO A BONA FIDE ARRANGEMENT TO BORROW THESECURITY; OR REASONABLE GROUNDS TO BELIEVE THAT THE SECURITYCOULD BE BORROWED SO THAT IT COULD BE DELIVERED ON THE DATEDELIVERY IS DUE; AND DOCUMENTING COMPLIANCE WITH SEC RULE203(B)(1) OF REGULATION SHO.



Resolution:




No



iReporting Source: 50©2021 FINRA. All rights reserved. Report about VFINANCE INVESTMENTS, INC







Initiated By: FINRA


Censure


FINE





Allegations: SEC RULES 200(G) AND 203(B)(3) OF REGULATION SHO - VFINANCEINVESTMENTS, INC. FAILED TO PROPERLY MARK SELL ORDERS AS SHORT.THE FIRM ACCEPTED SHORT SALE ORDERS IN AN EQUITY SECURITYFROM ANOTHER PERSON, OR EFFECTED SHORT SALES IN AN EQUITYSECURITY FOR ITS OWN ACCOUNT WITHOUT BORROWING THE SECURITY,OR ENTERING INTO A BONA FIDE ARRANGEMENT TO BORROW THESECURITY; OR REASONABLE GROUNDS TO BELIEVE THAT THE SECURITYCOULD BE BORROWED SO THAT IT COULD BE DELIVERED ON THE DATEDELIVERY IS DUE; AND DOCUMENTING COMPLIANCE WITH SEC RULE203(B)(1) OF REGULATION SHO.



Resolution:





Disclosure 18 of 27

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Allegations: NASD RULE 2110 - THE BREAKPOINT SELF-ASSESSMENT FOLLOW-UPREVIEW CONDUCTED FOR VFINANCE INVESTMENTS, INC. FOUND THATTHE FIRM FAILED TO ACCURATELY COMPLETE THE SELF-ASSESSMENT OFBREAKPOINT COMPLIANCE REQUIRED BY FINRA OF CERTAIN MEMBERFIRMS THAT SOLD FRONT-END LOAD MUTUAL FUNDS. FINRA FOUND THATTHE FIRM'S SELF-ASSESSMENT UNDERREPORTED THE NUMBER OFTRANSACTIONS WITH MISSED BREAKPOINTS. HAD THE FIRM ACCURATELYCOMPLETED ITS SELF-ASSESSMENT, FINRA WOULD HAVE DIRECTED THEFIRM TO UNDERTAKE ADDITIONAL REMEDIAL STEPS.








Initiated By: FINRA





Principal Product Type: Mutual Fund(s)


NASD RULE 2110 - THE BREAKPOINT SELF-ASSESSMENT FOLLOW-UPREVIEW CONDUCTED FOR VFINANCE INVESTMENTS, INC. FOUND THATTHE FIRM FAILED TO ACCURATELY COMPLETE THE SELF-ASSESSMENT OFBREAKPOINT COMPLIANCE REQUIRED BY FINRA OF CERTAIN MEMBERFIRMS THAT SOLD FRONT-END LOAD MUTUAL FUNDS. FINRA FOUND THATTHE FIRM'S SELF-ASSESSMENT UNDERREPORTED THE NUMBER OFTRANSACTIONS WITH MISSED BREAKPOINTS. HAD THE FIRM ACCURATELYCOMPLETED ITS SELF-ASSESSMENT, FINRA WOULD HAVE DIRECTED THEFIRM TO UNDERTAKE ADDITIONAL REMEDIAL STEPS.


Resolution:




No




Allegations: ON MARCH 23, 2009, FINRA ANNOUNCED ITS ACCEPTANCE OF AN AWCSIGNED BY VFINANCE WITH RESPECT TO PARTICIPATION IN FINRA'SREQUIRED SELF-ASSESSMENT. IN ITS FOLLOW-UP REVIEW OF THEBREAKPOINT SELF-ASSESSMENT, FINRA ALLEGED THAT VFINANCE FAILEDTO ACCURATELY COMPLETE THE SELF-ASSESSMENT. WITHOUTADMITTING OR DENYING THE FINDINGS, VFINANCE HAS AGREED TO ACENSURE AND FINE OF $27,500.








Initiated By: FINRA


Censure


FINE



Principal Product Type: Mutual Fund(s)


ON MARCH 23, 2009, FINRA ANNOUNCED ITS ACCEPTANCE OF AN AWCSIGNED BY VFINANCE WITH RESPECT TO PARTICIPATION IN FINRA'SREQUIRED SELF-ASSESSMENT. IN ITS FOLLOW-UP REVIEW OF THEBREAKPOINT SELF-ASSESSMENT, FINRA ALLEGED THAT VFINANCE FAILEDTO ACCURATELY COMPLETE THE SELF-ASSESSMENT. WITHOUTADMITTING OR DENYING THE FINDINGS, VFINANCE HAS AGREED TO ACENSURE AND FINE OF $27,500.


Resolution:


Sanction Details: CENSURE AND FINED $27,500

Firm Statement VFINANCE UNINTENTIONALLY MISCALCULATED THE NUMBER OFTRANSACTIONS DURING ITS MUTUAL FUND BREAKPOINT SELF-ASSESSMENT.



Disclosure 19 of 27

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Allegations: SEC RULE 10B-10, NASD RULES 2110, 2320, 6955(A) - VFINANCEINVESTMENTS, INC., IN TRANSACTIONS FOR OR WITH A CUSTOMER,FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THATTHE RESULTANT PRICE TO ITS CUSTOMERS WAS AS FAVORABLE ASPOSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM FAILED TOPROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THECORRECT COMMISSION AND/OR THE REPORTED PRICE OF THETRANSACTIONS. THE FIRM TRANSMITTED TO THE ORDER AUDIT TRAILSYSTEM (OATS) REPORTS THAT CONTAINED INACCURATE, INCOMPLETEOR IMPROPERLY FORMATTED DATA; SPECIFICALLY, THE FIRM SUBMITTEDTHE INCORRECT TYPE OF REPORT.








Initiated By: FINRA






Other Product Type(s): UNKNOWN TYPE OF SECURITIES

SEC RULE 10B-10, NASD RULES 2110, 2320, 6955(A) - VFINANCEINVESTMENTS, INC., IN TRANSACTIONS FOR OR WITH A CUSTOMER,FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THATTHE RESULTANT PRICE TO ITS CUSTOMERS WAS AS FAVORABLE ASPOSSIBLE UNDER PREVAILING MARKET CONDITIONS. THE FIRM FAILED TOPROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THECORRECT COMMISSION AND/OR THE REPORTED PRICE OF THETRANSACTIONS. THE FIRM TRANSMITTED TO THE ORDER AUDIT TRAILSYSTEM (OATS) REPORTS THAT CONTAINED INACCURATE, INCOMPLETEOR IMPROPERLY FORMATTED DATA; SPECIFICALLY, THE FIRM SUBMITTEDTHE INCORRECT TYPE OF REPORT.


Resolution:


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 $22,000, AND ORDERED TOPAY $1,814.68, PLUS INTEREST, IN RESTITUTION TO INVESTORS.SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OFREASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECTRESTITUTION, SHALL BE FORWARDED TO FINRA NO LATER THAN 120 DAYSAFTER ACCEPTANCE OF THIS AWC BY THE NAC. ANY UNDISTRIBUTEDRESTITUTION AND INTEREST SHALL BE FORWARDED TO THEAPPROPRIATE ESCHEAT, UNCLAIMED PROPERTY OR ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED.


No










Initiated By: FINRA


Censure


FINE AND RESTITUTION


Docket/Case Number: 20060045472-01



Allegations: ALLEGEDLY FAILED TO USE REASONABLE DUE DILIGENCE TO FIND THEBEST INTER-DEALER MARKET IN 37 CUSTOMER TRANSACTIONS, 20INSTANCES OF INCORRECT DISCLOSURE OF COMMISSIONS ORREPORTED PRICES, AND SUBMITTED 18 INACCURATE OATS REPORTSBETWEEN OCT-DEC 2005 AND MARCH 2006.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS OF CENSURE AND FINE OF $22,000 ANDORDERED TO PAY $1814.68 PLUS INTEREST IN RESTITUTION TOINVESTORS.

Firm Statement SOME POTENTIAL VIOLATIONS OCCURRED AS TRADERS SOUGHT OUTTHE BEST PRICES AVAILABLE FOR CUSTOMERS BUT TOOK LONGER THANTHE "30 SECONDS" USED AS A RULE OF THUMB BY FINRA FOR EXECUTIONSPEEDS REGARDLESS OF LIQUIDITY OR ADVERSE MARKET IMPACT.OTHER POTENTIAL VIOLATIONS WERE DUE TO VENDOR ROUNDINGERRORS OF DECIMALIZATION OUT TO 1/100TH OF A PENNY.



Disclosure 20 of 27

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Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE 34-57727, APRIL 28, 2008:THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") FILEDADMINISTRATIVE PROCEEDING PURSUANT TOSECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGEACT") AGAINST VFINANCE INVESTMENTS, INC. ("VFINANCE" OR "RESPONDENT"). IT ALLEGED THAT VFINANCE FAILED REASONABLY TOSUPERVISE ITS BROKERS WITH A VIEW TO PREVENTING AND DETECTINGTHE REGISTERED REPRESENTATIVE'S VIOLATIONS OF SECTION 5 OF THESECURITIES ACT. FROM SEPTEMBER 2002 THROUGH JUNE 2003, AREGISTERED REPRESENTATIVE THEN ASSOCIATED WITH VFINANCEVIOLATED SECTION 5 OF THE SECURITIES ACT OF 1933 ("SECURITIESACT") WHEN HE ENGAGED IN THE ILLEGAL DISTRIBUTION OF THESECURITIES BY OFFERING AND SELLING RESTRICTED SHARES OF THETWO ISSUERS THROUGH THE OVER-THE-COUNTER BULLETIN BOARD("OTCBB"). NO REGISTRATION STATEMENT WAS IN EFFECT AS TO THOSEOFFERS AND SALES, AND NO VALID EXEMPTIONS FROM REGISTRATIONWERE APPLICABLE TO THEM. PRIOR TO OFFERING AND SELLING SECURITIES, THE REGISTEREDREPRESENTATIVE FAILED TO CONDUCT A REASONABLE INQUIRYREGARDING THESE SECURITIES TO DETERMINE WHETHER VFINANCE'SCUSTOMER WAS AN UNDERWRITER OR WAS OTHERWISE ENGAGED IN ANILLEGAL DISTRIBUTION OF SECURITIES. VFINANCE FAILED REASONABLYTO SUPERVISE ITS REGISTERED REPRESENTATIVE'S CONDUCT WITH AVIEW TO PREVENTING AND DETECTING HIS SECTION 5 VIOLATIONS.VFINANCE HAD INADEQUATE PROCEDURES IN PLACE DURING THERELEVANT PERIOD TO REQUIRE THAT ITS REGISTERED REPRESENTATIVECONDUCT THE APPROPRIATE DUE DILIGENCE CONCERNING THE ORIGINAND OWNERSHIP OF THINLY-TRADED SECURITIES THAT VFINANCEOFFERED AND SOLD ON BEHALF OF ITS CUSTOMERS. VFINANCE ALSODID NOT ESTABLISH REASONABLE PROCEDURES OR SYSTEMS FORTRAINING ITS REGISTERED REPRESENTATIVE WITH REGARD TOCOMPLIANCE WITH THE REGISTRATION PROVISIONS OF THE SECURITIESACT.







Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION






Other Product Type(s): STOCK

Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE 34-57727, APRIL 28, 2008:THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") FILEDADMINISTRATIVE PROCEEDING PURSUANT TOSECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGEACT") AGAINST VFINANCE INVESTMENTS, INC. ("VFINANCE" OR "RESPONDENT"). IT ALLEGED THAT VFINANCE FAILED REASONABLY TOSUPERVISE ITS BROKERS WITH A VIEW TO PREVENTING AND DETECTINGTHE REGISTERED REPRESENTATIVE'S VIOLATIONS OF SECTION 5 OF THESECURITIES ACT. FROM SEPTEMBER 2002 THROUGH JUNE 2003, AREGISTERED REPRESENTATIVE THEN ASSOCIATED WITH VFINANCEVIOLATED SECTION 5 OF THE SECURITIES ACT OF 1933 ("SECURITIESACT") WHEN HE ENGAGED IN THE ILLEGAL DISTRIBUTION OF THESECURITIES BY OFFERING AND SELLING RESTRICTED SHARES OF THETWO ISSUERS THROUGH THE OVER-THE-COUNTER BULLETIN BOARD("OTCBB"). NO REGISTRATION STATEMENT WAS IN EFFECT AS TO THOSEOFFERS AND SALES, AND NO VALID EXEMPTIONS FROM REGISTRATIONWERE APPLICABLE TO THEM. PRIOR TO OFFERING AND SELLING SECURITIES, THE REGISTEREDREPRESENTATIVE FAILED TO CONDUCT A REASONABLE INQUIRYREGARDING THESE SECURITIES TO DETERMINE WHETHER VFINANCE'SCUSTOMER WAS AN UNDERWRITER OR WAS OTHERWISE ENGAGED IN ANILLEGAL DISTRIBUTION OF SECURITIES. VFINANCE FAILED REASONABLYTO SUPERVISE ITS REGISTERED REPRESENTATIVE'S CONDUCT WITH AVIEW TO PREVENTING AND DETECTING HIS SECTION 5 VIOLATIONS.VFINANCE HAD INADEQUATE PROCEDURES IN PLACE DURING THERELEVANT PERIOD TO REQUIRE THAT ITS REGISTERED REPRESENTATIVECONDUCT THE APPROPRIATE DUE DILIGENCE CONCERNING THE ORIGINAND OWNERSHIP OF THINLY-TRADED SECURITIES THAT VFINANCEOFFERED AND SOLD ON BEHALF OF ITS CUSTOMERS. VFINANCE ALSODID NOT ESTABLISH REASONABLE PROCEDURES OR SYSTEMS FORTRAINING ITS REGISTERED REPRESENTATIVE WITH REGARD TOCOMPLIANCE WITH THE REGISTRATION PROVISIONS OF THE SECURITIESACT.








Resolution:

Other Sanctions Ordered: UNDERTAKINGSRESPONDENT HAS UNDERTAKEN TO:RETAIN, WITHIN FORTY-FIVE (45) DAYS OF THE DATE OF THIS ORDER, ATVFINANCE'SEXPENSE, AN INDEPENDENT CONSULTANT, NOT UNACCEPTABLE TO THECOMMISSION'S STAFF, TO CONDUCT A REVIEW OF VFINANCE'S EXISTINGPROCEDURES REGARDING ITS COMPLIANCE WITH SECTION 5 OF THESECURITIES ACT. THE INDEPENDENT CONSULTANT WILL SUBMIT, WITHIN120 DAYS OF THE DATE OF THIS ORDER, TO VFINANCE AND THECOMMISSION'S STAFF, A WRITTEN REPORT (THE "INITIAL REPORT")DESCRIBING THE REVIEW PERFORMED, HIS OR HER FINDINGS, AND ANYRECOMMENDATIONS; ADOPT AND IMPLEMENT, WITHIN 150 DAYS OF THEDATE OF THIS ORDER, AT VFINANCE'S EXPENSE, SUCH PROCEDURESRECOMMENDED BY THE INDEPENDENT CONSULTANT IN THE INITIALREPORT.

Sanction Details: WITHOUT ADMITTING OR DENYING THEFINDINGS RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER;ACCORDINGLY, PURSUANT TO SECTION 15(B) OF THE EXCHANGE ACT, ITIS ORDERED THAT:RESPONDENT VFINANCE IS CENSURED PURSUANT TO SECTION 15(B)(4)OF THE EXCHANGE ACT; RESPONDENT SHALL, WITHIN TEN (10) DAYS OFTHE ENTRY OF THIS ORDER, PAY DISGORGEMENT IN THE AMOUNT OF$19,787 AND PREJUDGMENT INTEREST OF $6,772 TO THE SECURITIES ANDEXCHANGE COMMISSION.


No

Sanctions Ordered: CensureDisgorgement/Restitution

Order


Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE 34-57727, APRIL 28, 2008:THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") FILEDADMINISTRATIVE PROCEEDING PURSUANT TO SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINSTVFINANCE INVESTMENTS, INC. ("VFINANCE" OR "RESPONDENT"). ITALLEGED THAT VFINANCE FAILED REASONABLY TO SUPERVISE ITSBROKERS WITH A VIEW TO PREVENTING AND DETECTING THEREGISTERED REPRESENTATIVE'S VIOLATIONS OF SECTION 5 OF THESECURITIES ACT. FROM SEPTEMBER 2002 THROUGH JUNE 2003, AREGISTERED REPRESENTATIVE THEN ASSOCIATED WITH VFINANCEALLEGEDLY VIOLATED SECTION 5 OF THE SECURITIES ACT OF 1933("SECURITIES ACT") WHEN HE ENGAGED IN THE ILLEGAL DISTRIBUTIONOF THE SECURITIES BY OFFERING AND SELLING RESTRICTED SHARES OFTHE TWO ISSUERS THROUGH THE OVER-THE-COUNTER BULLETIN BOARD("OTCBB"). NO REGISTRATION STATEMENT WAS IN EFFECT AS TO THOSEOFFERS AND SALES, AND NO VALID EXEMPTIONS FROM REGISTRATIONWERE APPLICABLE TO THEM. PRIOR TO OFFERING AND SELLINGSECURITIES, THE REGISTERED REPRESENTATIVE ALLEGEDLY FAILED TOCONDUCT A REASONABLE INQUIRY REGARDING THESE SECURITIES TODETERMINE WHETHER VFINANCE'S CUSTOMER WAS AN UNDERWRITEROR WAS OTHERWISE ENGAGED IN AN ILLEGAL DISTRIBUTION OFSECURITIES. VFINANCE ALLEGEDLY FAILED REASONABLY TO SUPERVISEITS REGISTERED REPRESENTATIVE'S CONDUCT WITH A VIEW TOPREVENTING AND DETECTING HIS SECTION 5 VIOLATIONS. VFINANCEALLEGEDLY HAD INADEQUATE PROCEDURES IN PLACE DURING THERELEVANT PERIOD TO REQUIRE THAT ITS REGISTERED REPRESENTATIVECONDUCT THE APPROPRIATE DUE DILIGENCE CONCERNING THE ORIGINAND OWNERSHIP OF THINLY-TRADED SECURITIES THAT VFINANCEOFFERED AND SOLD ON BEHALF OF ITS CUSTOMERS. VFINANCE ALSOALLEGEDLY DID NOT ESTABLISH REASONABLE PROCEDURES ORSYSTEMS FOR TRAINING ITS REGISTERED REPRESENTATIVE WITHREGARD TO COMPLIANCE WITH THE REGISTRATION PROVISIONS OF THESECURITIES ACT.









Censure


DISGORGEMENT AND PREJUDGMENT INTEREST TO BE PAID TO SEC





Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE 34-57727, APRIL 28, 2008:THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") FILEDADMINISTRATIVE PROCEEDING PURSUANT TO SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINSTVFINANCE INVESTMENTS, INC. ("VFINANCE" OR "RESPONDENT"). ITALLEGED THAT VFINANCE FAILED REASONABLY TO SUPERVISE ITSBROKERS WITH A VIEW TO PREVENTING AND DETECTING THEREGISTERED REPRESENTATIVE'S VIOLATIONS OF SECTION 5 OF THESECURITIES ACT. FROM SEPTEMBER 2002 THROUGH JUNE 2003, AREGISTERED REPRESENTATIVE THEN ASSOCIATED WITH VFINANCEALLEGEDLY VIOLATED SECTION 5 OF THE SECURITIES ACT OF 1933("SECURITIES ACT") WHEN HE ENGAGED IN THE ILLEGAL DISTRIBUTIONOF THE SECURITIES BY OFFERING AND SELLING RESTRICTED SHARES OFTHE TWO ISSUERS THROUGH THE OVER-THE-COUNTER BULLETIN BOARD("OTCBB"). NO REGISTRATION STATEMENT WAS IN EFFECT AS TO THOSEOFFERS AND SALES, AND NO VALID EXEMPTIONS FROM REGISTRATIONWERE APPLICABLE TO THEM. PRIOR TO OFFERING AND SELLINGSECURITIES, THE REGISTERED REPRESENTATIVE ALLEGEDLY FAILED TOCONDUCT A REASONABLE INQUIRY REGARDING THESE SECURITIES TODETERMINE WHETHER VFINANCE'S CUSTOMER WAS AN UNDERWRITEROR WAS OTHERWISE ENGAGED IN AN ILLEGAL DISTRIBUTION OFSECURITIES. VFINANCE ALLEGEDLY FAILED REASONABLY TO SUPERVISEITS REGISTERED REPRESENTATIVE'S CONDUCT WITH A VIEW TOPREVENTING AND DETECTING HIS SECTION 5 VIOLATIONS. VFINANCEALLEGEDLY HAD INADEQUATE PROCEDURES IN PLACE DURING THERELEVANT PERIOD TO REQUIRE THAT ITS REGISTERED REPRESENTATIVECONDUCT THE APPROPRIATE DUE DILIGENCE CONCERNING THE ORIGINAND OWNERSHIP OF THINLY-TRADED SECURITIES THAT VFINANCEOFFERED AND SOLD ON BEHALF OF ITS CUSTOMERS. VFINANCE ALSOALLEGEDLY DID NOT ESTABLISH REASONABLE PROCEDURES ORSYSTEMS FOR TRAINING ITS REGISTERED REPRESENTATIVE WITHREGARD TO COMPLIANCE WITH THE REGISTRATION PROVISIONS OF THESECURITIES ACT.

Resolution: Order 58©2021 FINRA. All rights reserved. Report about VFINANCE INVESTMENTS, INC






Resolution:

Other Sanctions Ordered: UNDERTAKINGS RESPONDENT HAS UNDERTAKEN TO: RETAIN, WITHINFORTY-FIVE (45) DAYS OF THE DATE OF THIS ORDER, AT VFINANCE'SEXPENSE, AN INDEPENDENT CONSULTANT, NOT UNACCEPTABLE TO THECOMMISSION'S STAFF, TO CONDUCT A REVIEW OF VFINANCE'S EXISTINGPROCEDURES REGARDING ITS COMPLIANCE WITH SECTION 5 OF THESECURITIES ACT. THE INDEPENDENT CONSULTANT WILL SUBMIT, WITHIN120 DAYS OF THE DATE OF THIS ORDER, TO VFINANCE AND THECOMMISSION'S STAFF, A WRITTEN REPORT (THE "INITIAL REPORT")DESCRIBING THE REVIEW PERFORMED, HIS OR HER FINDINGS, AND ANYRECOMMENDATIONS; ADOPT AND IMPLEMENT, WITHIN 150 DAYS OF THEDATE OF THIS ORDER, AT VFINANCE'S EXPENSE, SUCH PROCEDURESRECOMMENDED BY THE INDEPENDENT CONSULTANT IN THE INITIALREPORT.

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS RESPONDENTCONSENTS TO THE ENTRY OF THIS ORDER; ACCORDINGLY, PURSUANT TOSECTION 15(B) OF THE EXCHANGE ACT, IT IS ORDERED THAT:RESPONDENT VFINANCE IS CENSURED PURSUANT TO SECTION 15(B)(4)OF THE EXCHANGE ACT; RESPONDENT SHALL, WITHIN TEN (10) DAYS OFTHE ENTRY OF THIS ORDER, PAY DISGORGEMENT IN THE AMOUNT OF$19,787 AND PREJUDGMENT INTEREST OF $6,772 TO THE SECURITIES ANDEXCHANGE COMMISSION.

Sanctions Ordered: CensureDisgorgement/Restitution

Order

Disclosure 21 of 27

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Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE 34-57088, JANUARY 3, 2008:THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION(COMMISSION) ISSUED AN ORDER INSTITUTING ADMINISTRATIVE ANDCEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTIONS 15(B) AND21C OF THE SECURITIES EXCHANGE ACT OF 1934 (ORDER) AGAINSTVFINANCE INVESTMENTS, INC., AND OTHERS. THE DIVISION OFENFORCEMENT ALLEGES IN THE ORDER THAT RESPONDENTS, FAILED TORETAIN RECORDS AND PRODUCE THEM TO THE COMMISSION STAFF. THEDIVISION OF ENFORCEMENT ALLEGES THAT THROUGH ITS CONDUCT,VFINANCE WILLFULLY VIOLATED THE DOCUMENT RETENTION ANDPRODUCTION REQUIREMENTS OF SECTION 17(A) OF THE SECURITIESEXCHANGE ACT OF 1934 AND RULES 17A-4(B)(4) AND 17A-4(J)THEREUNDER.









Cease and Desist





Other Product Type(s): BOOKS AND RECORDS

SEC ADMINISTRATIVE PROCEEDING RELEASE 34-57088, JANUARY 3, 2008:THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION(COMMISSION) ISSUED AN ORDER INSTITUTING ADMINISTRATIVE ANDCEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTIONS 15(B) AND21C OF THE SECURITIES EXCHANGE ACT OF 1934 (ORDER) AGAINSTVFINANCE INVESTMENTS, INC., AND OTHERS. THE DIVISION OFENFORCEMENT ALLEGES IN THE ORDER THAT RESPONDENTS, FAILED TORETAIN RECORDS AND PRODUCE THEM TO THE COMMISSION STAFF. THEDIVISION OF ENFORCEMENT ALLEGES THAT THROUGH ITS CONDUCT,VFINANCE WILLFULLY VIOLATED THE DOCUMENT RETENTION ANDPRODUCTION REQUIREMENTS OF SECTION 17(A) OF THE SECURITIESEXCHANGE ACT OF 1934 AND RULES 17A-4(B)(4) AND 17A-4(J)THEREUNDER.


Resolution:


Sanction Details: SEC ADMIN PROCEEDINGS 34-62448, JULY 2, 2010: THE SEC FOUND THATVFINANCE WILLFULLY VIOLATED SECURITIES EXCHANGE ACT SECTIONS17(A) AND SEC RULES 17A-4(B)(4),17A-4(J). ON THE BASIS OF THECOMMISSION'S OPINION ISSUED JULY 2, 2010: IT ISORDERED THAT VFINANCE INVESTMENTS, INC. BE, AND IT HEREBY IS,CENSURED; AND IT IS FURTHER ORDERED THAT VFINANCE INVESTMENTS,INC. CEASE AND DESIST FROM COMMITTING OR BEING A CAUSE OF ANYVIOLATIONS OR FUTURE VIOLATIONS OF SECTION 17(A) OF THESECURITIES EXCHANGE ACT OF 1934 AND RULES 17A-4(B)(4) AND 17A-4(J)BY FAILING TO PRESERVE OR PRODUCE REQUIRED RECORDS; AND IT ISFURTHER ORDERED THAT VFINANCE INVESTMENTS, INC. PAY A CIVILMONEY PENALTY IN THE AMOUNT OF $100,000.

Regulator Statement SEC INITIAL DECISION RELEASE 360 ADMINISTRATIVE PROCEEDING,NOVEMBER 7, 2008: THE ALJ FOUND THAT VFINANCE WILLFULLY VIOLATEDSECTION 17(A) OF THE EXCHANGE ACT AND RULES 17A-4(B)(4) AND 17A-4(J) THEREUNDER. IT IS ORDERED THAT, PURSUANT TO SECTION 21C OFTHE SECURITIES EXCHANGE ACT OF 1934, VFINANCE INVESTMENTS, INC.,SHALL CEASE-AND-DESIST FROM COMMITTING OR CAUSING ANYVIOLATIONS OR FUTURE VIOLATIONS OF SECTION 17(A) OF THESECURITIES EXCHANGE ACT OF 1934, AND RULES 17A-4(B)(4) AND 17A-4(J)THEREUNDER; ACT AND RULES 17A-4(B)(4) AND 17A-4(J) THEREUNDER. ITIS FURTHER ORDERED THAT, PURSUANT TO SECTION 21B OF THESECURITIES EXCHANGE ACT OF 1934, VFINANCE INVESTMENTS, INC.,SHALL PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF ONEHUNDRED THOUSAND DOLLARS ($100,000). PAYMENT OF THE MONEYPENALTY AND DISGORGEMENT SHALL BE MADE ON THE FIRST BUSINESSDAY FOLLOWING THE DAY THIS ORDER BECOMES EFFECTIVE. APPEALEDTO THE COMMISSION ON JANUARY 2, 2009.


No

Sanctions Ordered: CensureMonetary/Fine $100,000.00Cease and Desist/Injunction

Order





www.finra.org/brokercheck User GuidanceSEC INITIAL DECISION RELEASE 360 ADMINISTRATIVE PROCEEDING,NOVEMBER 7, 2008: THE ALJ FOUND THAT VFINANCE WILLFULLY VIOLATEDSECTION 17(A) OF THE EXCHANGE ACT AND RULES 17A-4(B)(4) AND 17A-4(J) THEREUNDER. IT IS ORDERED THAT, PURSUANT TO SECTION 21C OFTHE SECURITIES EXCHANGE ACT OF 1934, VFINANCE INVESTMENTS, INC.,SHALL CEASE-AND-DESIST FROM COMMITTING OR CAUSING ANYVIOLATIONS OR FUTURE VIOLATIONS OF SECTION 17(A) OF THESECURITIES EXCHANGE ACT OF 1934, AND RULES 17A-4(B)(4) AND 17A-4(J)THEREUNDER; ACT AND RULES 17A-4(B)(4) AND 17A-4(J) THEREUNDER. ITIS FURTHER ORDERED THAT, PURSUANT TO SECTION 21B OF THESECURITIES EXCHANGE ACT OF 1934, VFINANCE INVESTMENTS, INC.,SHALL PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF ONEHUNDRED THOUSAND DOLLARS ($100,000). PAYMENT OF THE MONEYPENALTY AND DISGORGEMENT SHALL BE MADE ON THE FIRST BUSINESSDAY FOLLOWING THE DAY THIS ORDER BECOMES EFFECTIVE. APPEALEDTO THE COMMISSION ON JANUARY 2, 2009.




Cease and Desist




Other Product Type(s): BOOKS AND RECORDS

Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE 34-57088, JANUARY 3, 2008:THE UNITED STATESSECURITIES AND EXCHANGE COMMISSION (COMMISSION) ISSUED ANORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTIONS 15(B) AND21C OF THE SECURITIES EXCHANGE ACT OF 1934 (ORDER) AGAINSTVFINANCE INVESTMENTS,INC., AND OTHERS. THE DIVISION OF ENFORCEMENT ALLEGES IN THEORDER THATRESPONDENTS, FAILED TO RETAIN RECORDS AND PRODUCE THEM TOTHE COMMISSIONSTAFF. THE DIVISION OF ENFORCEMENT ALLEGES THAT THROUGH ITSCONDUCT, VFINANCEWILLFULLY VIOLATED THE DOCUMENT RETENTION AND PRODUCTIONREQUIREMENTS OFSECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULES17A-4(B)(4) AND 17A-4(J) THEREUNDER.








Cease and Desist



Resolution:


Sanction Details: SEC ADMIN PROCEEDINGS 34-62448, JULY 2, 2010: THE SEC FOUND THATVFINANCEWILLFULLY VIOLATED SECURITIES EXCHANGE ACT SECTIONS 17(A) ANDSEC RULES 17A-4(B)(4),17A-4(J). ON THE BASIS OF THE COMMISSION'S OPINION ISSUEDJULY 2, 2010: IT ISORDERED THAT VFINANCE INVESTMENTS, INC. BE, AND IT HEREBY IS,CENSURED; AND ITIS FURTHER ORDERED THAT VFINANCE INVESTMENTS, INC. CEASE ANDDESIST FROMCOMMITTING OR BEING A CAUSE OF ANY VIOLATIONS OR FUTUREVIOLATIONS OFSECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULES17A-4(B)(4) AND17A-4(J) BY FAILING TO PRESERVE OR PRODUCE REQUIRED RECORDS;AND IT IS FURTHERORDERED THAT VFINANCE INVESTMENTS, INC. PAY A CIVIL MONEYPENALTY IN THEAMOUNT OF $100,000.

Firm Statement SEC INITIAL DECISION RELEASE 360 ADMINISTRATIVE PROCEEDING,NOVEMBER 7, 2008: THEALJ FOUND THAT VFINANCE WILLFULLY VIOLATED SECTION 17(A) OF THEEXCHANGE ACTAND RULES 17A-4(B)(4) AND 17A-4(J) THEREUNDER. IT IS ORDERED THAT,PURSUANT TOSECTION 21C OF THE SECURITIES EXCHANGE ACT OF 1934, VFINANCEINVESTMENTS, INC.,SHALL CEASE-AND-DESIST FROM COMMITTING OR CAUSING ANYVIOLATIONS OR FUTUREVIOLATIONS OF SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF1934, AND RULES 17A-4(B)(4) AND 17A-4(J) THEREUNDER; ACT AND RULES 17A-4(B)(4) AND 17A-4(J) THEREUNDER. ITIS FURTHER ORDERED THAT, PURSUANT TO SECTION 21B OF THESECURITIES EXCHANGEACT OF 1934, VFINANCE INVESTMENTS, INC., SHALL PAY A CIVILMONETARY PENALTY IN THEAMOUNT OF ONE HUNDRED THOUSAND DOLLARS ($100,000). PAYMENT OFTHE MONEYPENALTY AND DISGORGEMENT SHALL BE MADE ON THE FIRST BUSINESSDAY FOLLOWINGTHE DAY THIS ORDER BECOMES EFFECTIVE. APPEALED TO THECOMMISSION ON JANUARY 2,2009.

Sanctions Ordered: CensureMonetary/Fine $100,000.00Cease and Desist/Injunction

Order






SEC INITIAL DECISION RELEASE 360 ADMINISTRATIVE PROCEEDING,NOVEMBER 7, 2008: THEALJ FOUND THAT VFINANCE WILLFULLY VIOLATED SECTION 17(A) OF THEEXCHANGE ACTAND RULES 17A-4(B)(4) AND 17A-4(J) THEREUNDER. IT IS ORDERED THAT,PURSUANT TOSECTION 21C OF THE SECURITIES EXCHANGE ACT OF 1934, VFINANCEINVESTMENTS, INC.,SHALL CEASE-AND-DESIST FROM COMMITTING OR CAUSING ANYVIOLATIONS OR FUTUREVIOLATIONS OF SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF1934, AND RULES 17A-4(B)(4) AND 17A-4(J) THEREUNDER; ACT AND RULES 17A-4(B)(4) AND 17A-4(J) THEREUNDER. ITIS FURTHER ORDERED THAT, PURSUANT TO SECTION 21B OF THESECURITIES EXCHANGEACT OF 1934, VFINANCE INVESTMENTS, INC., SHALL PAY A CIVILMONETARY PENALTY IN THEAMOUNT OF ONE HUNDRED THOUSAND DOLLARS ($100,000). PAYMENT OFTHE MONEYPENALTY AND DISGORGEMENT SHALL BE MADE ON THE FIRST BUSINESSDAY FOLLOWINGTHE DAY THIS ORDER BECOMES EFFECTIVE. APPEALED TO THECOMMISSION ON JANUARY 2,2009.

Disclosure 22 of 27

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Initiated By: NASD







Allegations: SEC RULE 11AC1-5 N/K/A REG NMS 605, NASD RULES 3010) - VFINANCEINVESTMENTS, INC.'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULESCONCERNING SUPERVISORY SYSTEM, PROCEDURES ANDQUALIFICATION, SEC RULE 11AC1-5, SEC RULE 11AC1-6, REGULAR ANDRIGOROUS REVIEWS, RISKLESS PRINCIPAL TRADE REPORTING, BESTEXECUTION, TRADING RULES REGARDING ACTIVITY DURING TRADINGHALTS AND OATS; FAILED TO ENFORCE ITS WRITTEN SUPERVISORYPROCEDURES IN EFFECT WITH RESPECT TO CUSTOMER SHORT SALEREPORTING AND OATS; MADE AVAILABLE REPORTS ON THE COVEREDORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT IT RECEIVEDFOR EXECUTION FROM ANY PERSON THAT INCLUDED MATERIAL,INACCURATE ORDER EXECUTION STATISTICS.









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 $40,000 AND REQUIRED TOREVISE THE FIRM'S SUPERVISORY PROCEDURES REGARDINGSUPERVISORY SYSTEM, PROCEDURES AND QUALIFICATION, SEC RULE11AC1-5, SEC RULE 11AC1-6, REGULAR AND RIGOROUS REVIEWS,RISKLESS PRINCIPAL TRADE REPORTING, BEST EXECUTION, TRADINGRULES REGARDING ACTIVITY DURING TRADING HALTS AND OATS WITHIN30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC.


No




Initiated By: NASD


Allegations: BASED ON EXAMINATIONS CONDUCTED DURING 2004 AND 2005, NASDNOTED APPARENT VIOLATIONS OF SEC RULE 11AC1-5 N/K/A REG NMS 605,NASD RULES 3010) - VFINANCE INVESTMENTS, INC.'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS AND NASD RULES CONCERNING SUPERVISORY SYSTEM,PROCEDURES AND QUALIFICATION, SEC RULE 11AC1-5, SEC RULE 11AC1-6, REGULAR AND RIGOROUS REVIEWS, RISKLESS PRINCIPAL TRADEREPORTING, BEST EXECUTION, TRADING RULES REGARDING ACTIVITYDURING TRADING HALTS AND OATS; FAILED TO ENFORCE ITS WRITTENSUPERVISORY PROCEDURES IN EFFECT WITH RESPECT TO CUSTOMERSHORT SALE REPORTING AND OATS; MADE AVAILABLE REPORTS ON THECOVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIES THAT ITRECEIVED FOR EXECUTION FROM ANY PERSON THAT INCLUDEDMATERIAL, INACCURATE ORDER EXECUTION STATISTICS.








Censure


FINED 40000.00






Resolution:


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 $40,000 AND REQUIRED TOREVISE THE FIRM'S SUPERVISORY PROCEDURES REGARDINGSUPERVISORY SYSTEM, PROCEDURES AND QUALIFICATION, SEC RULE11AC1-5, SEC RULE 11AC1-6, REGULAR AND RIGOROUS REVIEWS,RISKLESS PRINCIPAL TRADE REPORTING, BEST EXECUTION, TRADINGRULES REGARDING ACTIVITY DURING TRADING HALTS AND OATS WITHIN30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC.

Firm Statement AWC WAS ENTERED INTO IN JANUARY 2007, BUT RELATED TO ACTIVITYFROM 2004 AND 2005 EXAMINATIONS.



Disclosure 23 of 27

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Allegations: SEC RULE 11AC1-4, NASD RULES 2110, 3010, 6955(A) - VFINANCEINVESTMENTS, INC. FAILED TO DISPLAY IMMEDIATELY CUSTOMER LIMITORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION WHEN EACHSUCH ORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'SBID OR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCHSECURITY AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DEMINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'SBID OR OFFER IN EACH SECURITY; THE FIRM'S SUPERVISORY SYSTEMFAILED TO PROVIDE FOR SUPERVISION REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS, AND NASD RULES CONCERNING SEC RULE 11AC1-4;TRANSMITTED TO OATS REPORTS THAT CONTAINED INACCURATE,INCOMPLETE, OR IMPROPERLY FORMATTED DATA, SPECIFICALLY,INACCURATE TIMESTAMPS; AND FAILED TO REPORT TO OATS ROUTEREPORTS FOR REPORTABLE ORDER EVENTS (ROES).







Initiated By: NASD






Other Product Type(s): NASDAQ SECURITIES

SEC RULE 11AC1-4, NASD RULES 2110, 3010, 6955(A) - VFINANCEINVESTMENTS, INC. FAILED TO DISPLAY IMMEDIATELY CUSTOMER LIMITORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION WHEN EACHSUCH ORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'SBID OR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCHSECURITY AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DEMINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'SBID OR OFFER IN EACH SECURITY; THE FIRM'S SUPERVISORY SYSTEMFAILED TO PROVIDE FOR SUPERVISION REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS, AND NASD RULES CONCERNING SEC RULE 11AC1-4;TRANSMITTED TO OATS REPORTS THAT CONTAINED INACCURATE,INCOMPLETE, OR IMPROPERLY FORMATTED DATA, SPECIFICALLY,INACCURATE TIMESTAMPS; AND FAILED TO REPORT TO OATS ROUTEREPORTS FOR REPORTABLE ORDER EVENTS (ROES).


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, VFINANCECONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, THE FIRM IS CNESURED, FINED $17,500, ANDREQUIRED TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURESWITH RESPECT TO SEC RULE 11AC1-4 COMPLIANCE WITHIN 30 BUSINESSDAYS. WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THENAC, A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT A SIGNEDLETTER TO NASD REFERENCING THIS MATTER; A REPRESENTATION THATTHE FIRM HAS REVISED ITS WRITTEN SUPERVISORY PROCEDURES TOADDRESS THE DEFICIENCIES; AND THE DATE THE REVISED PROCEDURESWERE IMPLEMENTED.

Regulator Statement .


No










Initiated By: NASD


Censure



Docket/Case Number: 20042000061-01 AWC


Other Product Type(s): OTC ORDER AND SEC 11AC1-4

Allegations: ON 61 OCCASIONS DURING THE REVIEW PERIOD THE FIRM FAILED TODISPLAY IMMEDIATELY 61 CUSTOMER LIMIT ORDERS IN NASDAQ AND THEFIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIVEVE COMPLAINCE WITH RESPECT TOTHE APPLICABLE SECURITIES LAWS AND REGULATIONS CONCERING SECRULE 11AC1-4



Resolution:


Sanction Details: A CENSURE, A $17,500 FINE (A $7,500 FINE FOR THE LIMIT ORDER DISPLYVIOLATIONS, A $5,000 FINE FOR THE SUPERVISION VIOLATION, AND A$5,000 FINE FOR THE OATS VIOLATIONS); AND AN UNDERTAKING TOREVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES.

Firm Statement VFINANCE HEREBY ACCEPTS AND CONSENTS, WITHOUT ADMITTING ORDENYING THE ALLEGATIONS OR FINDINGS, AND SOLELY FOR THEPURPOSES OF THIS PROCEEDING AND ANY OTHER PROCEEDINGBROUGHT BY OR ON BEHALF OF NASD, OR TO WHICH NASD IS A PARTY,PRIOR TO A HEARING AND WITHOUT AN ADJUDICATION OF ANY ISSUE OFLAW OR FACT, TO THE ENTRY OF THE FOLLOWING FINDINGS BY THENASD.



Disclosure 24 of 27

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Disclosure 24 of 27




Censure


UNDERTAKINGS, CIVIL PENALTY





Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE NO. 51530 DATED APRIL 12,2005; THE COMMISSION'S COMPLAINT ALLEGED VIOLATIONS OF SECTION10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER ANDSECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER,WITHIN THE MEANINGOF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT. DURING NOVEMBER ANDDECEMBER 2001, A TRADER THEN ASSOCIATED WITH VFINANCEASSISTED A STOCK PROMOTER IN MANIPULATING THE MARKET FOR " ACOMPANY" STOCK, WITHOUT THE KNOWLEDGE OF VFINANCE. DURINGTHE RELEVANT PERIOD, THE COMPANYWAS A SHELL COMPANY WITH NO REPORTED SIGNIFICANT OPERATIONS,ASSETS, OR REVENUES. THE COMPANY'S STOCK WAS QUOTED ON THEOTC BULLETIN BOARD. BETWEEN NOVEMBER 8, 2001 AND DECEMBER 6,2001, THE CLOSING PRICE OF THE COMPANYSTOCK INCREASED FROM $.19 TO $4.55 PER SHARE. THE PRICEINCREASE WAS NOT DUE TO CORPORATEDEVELOPMENTS, SINCE THERE WAS ONLY ONE PRESS RELEASE DURINGTHIS PERIOD, WHICH WAS ISSUED ONNOVEMBER 11. ON DECEMBER 7, THE CLOSING PRICE OF THE STOCKDROPPED TO $.95, DUE IN PART TO AFORWARD STOCK SPLIT.DURING THE RELEVANT PERIOD, THE TRADERMADE A MARKET IN THE COMPANY STOCK ON BEHALFOF VFINANCE. DURING THAT TIME, THE PROMOTER REPEATEDLYCONTACTED THE TRADER AT VFINANCE'SOFFICES. THE TRADER ADMITTED THAT, IN RESPONSE TO INSTRUCTIONSRECEIVED FROM THE PROMOTER, HEREPEATEDLY RAISED VFINANCE'S QUOTED INSIDE BID PRICE FOR THECOMPANY'S STOCK TO AS HIGH AS $3.65 BYDECEMBER 6, 2001.










Resolution:


Sanction Details: PURSUANT TO SECTION 15(B)(4) OF THE EXCHANGE ACT, THATRESPONDENT VFINANCE BE, ANDHEREBY IS, CENSURED;THAT RESPONDENT VFINANCE SHALL, WITHIN 30DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVILMONEY PENALTY IN THE AMOUNT OF $50,000 TO THE UNITED STATESTREASURY.


No


Order


Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE NO. 51530 DATED APRIL 12,2005; THE COMMISSION'S COMPLAINT ALLEGED VIOLATIONS OF SECTION10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER ANDSECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER,WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT.DURING NOVEMBER AND DECEMBER 2001, A TRADER THEN ASSOCIATEDWITH VFINANCE ASSISTED A STOCK PROMOTER IN MANIPULATING THEMARKET FOR " A COMPANY" STOCK, WITHOUT THE KNOWLEDGE OFVFINANCE. DURING THE RELEVANT PERIOD, THE COMPANY WAS A SHELLCOMPANY WITH NO REPORTED SIGNIFICANT OPERATIONS, ASSETS, ORREVENUES. THE COMPANY'S STOCK WAS QUOTED ON THE OTC BULLETINBOARD. BETWEEN NOVEMBER 8, 2001 AND DECEMBER 6, 2001, THECLOSING PRICE OF THE COMPANY STOCK INCREASED FROM $.19 TO $4.55PER SHARE. THE PRICE INCREASE WAS NOT DUE TO CORPORATEDEVELOPMENTS, SINCE THERE WAS ONLY ONE PRESS RELEASE DURINGTHIS PERIOD, WHICH WAS ISSUED ON NOVEMBER 11. ON DECEMBER 7,THE CLOSING PRICE OF THE STOCK DROPPED TO $.95, DUE IN PART TO AFORWARD STOCK SPLIT.DURING THE RELEVANT PERIOD, THE TRADERMADE A MARKET IN THE COMPANY STOCK ON BEHALF OF VFINANCE.DURING THAT TIME, THE PROMOTER REPEATEDLY CONTACTED THETRADER AT VFINANCE'S OFFICES. THE TRADER ADMITTED THAT, INRESPONSE TO INSTRUCTIONS RECEIVED FROM THE PROMOTER, HEREPEATEDLY RAISED VFINANCE'S QUOTED INSIDE BID PRICE FOR THECOMPANY'S STOCK TO AS HIGH AS $3.65 BY DECEMBER 6, 2001.









Censure







SEC ADMINISTRATIVE PROCEEDING RELEASE NO. 51530 DATED APRIL 12,2005; THE COMMISSION'S COMPLAINT ALLEGED VIOLATIONS OF SECTION10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER ANDSECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER,WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT.DURING NOVEMBER AND DECEMBER 2001, A TRADER THEN ASSOCIATEDWITH VFINANCE ASSISTED A STOCK PROMOTER IN MANIPULATING THEMARKET FOR " A COMPANY" STOCK, WITHOUT THE KNOWLEDGE OFVFINANCE. DURING THE RELEVANT PERIOD, THE COMPANY WAS A SHELLCOMPANY WITH NO REPORTED SIGNIFICANT OPERATIONS, ASSETS, ORREVENUES. THE COMPANY'S STOCK WAS QUOTED ON THE OTC BULLETINBOARD. BETWEEN NOVEMBER 8, 2001 AND DECEMBER 6, 2001, THECLOSING PRICE OF THE COMPANY STOCK INCREASED FROM $.19 TO $4.55PER SHARE. THE PRICE INCREASE WAS NOT DUE TO CORPORATEDEVELOPMENTS, SINCE THERE WAS ONLY ONE PRESS RELEASE DURINGTHIS PERIOD, WHICH WAS ISSUED ON NOVEMBER 11. ON DECEMBER 7,THE CLOSING PRICE OF THE STOCK DROPPED TO $.95, DUE IN PART TO AFORWARD STOCK SPLIT.DURING THE RELEVANT PERIOD, THE TRADERMADE A MARKET IN THE COMPANY STOCK ON BEHALF OF VFINANCE.DURING THAT TIME, THE PROMOTER REPEATEDLY CONTACTED THETRADER AT VFINANCE'S OFFICES. THE TRADER ADMITTED THAT, INRESPONSE TO INSTRUCTIONS RECEIVED FROM THE PROMOTER, HEREPEATEDLY RAISED VFINANCE'S QUOTED INSIDE BID PRICE FOR THECOMPANY'S STOCK TO AS HIGH AS $3.65 BY DECEMBER 6, 2001.


Resolution:


Sanction Details: PURSUANT TO SECTION 15(B)(4) OF THE EXCHANGE ACT, THATRESPONDENT VFINANCE BE, AND HEREBY IS, CENSURED;THATRESPONDENT VFINANCE SHALL, WITHIN 30 DAYS OF THE ENTRY OF THISORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $50,000 TO THEUNITED STATES TREASURY.

Firm Statement WITHOUT THE KNOWLEDGE OF VFINANCE DURING NOVEMBER ANDDECEMBER 2001, A TRADER ASSISTED A STOCK PROMOTER INMANIPULATING THE MARKET FOR GATEWAY INTERNATIONAL HOLDINGS,INC.("GATEWAY") STOCK. SINCE VFINANCE WAS UNAWARE OF THETRADERS ACTIONS THE NASD AND THE COMMISSION HAVE SANCTIONEDTHE FIRM FOR FAILING TO MAINTAIN ADEQUATE SUPERVISORY POLICIESAND PROCEDURES.


Order

Disclosure 25 of 27

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Allegations: NASD RULES 2110, 3010 - RESPONDENT MEMBER FAILED TO PROVIDE ASUPERVISORY SYSTEM REASONABLE DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS CONCERNING THE ACTIVITIES OF FIRM'S EMPLOYEES.







Initiated By: NASD




Docket/Case Number: CMS040186



Allegations: NASD RULES 2110, 3010 - RESPONDENT MEMBER FAILED TO PROVIDE ASUPERVISORY SYSTEM REASONABLE DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS CONCERNING THE ACTIVITIES OF FIRM'S EMPLOYEES.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, VFINANCEINVESTMENTS, INC., CONSENTED TO THE DESCRIBED SANCTIONS AND TOTHE ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED ANDFINED $7,500.


No




Initiated By: NASD


Allegations: THE FIRM FAILED TO REASONABLY SUPERVISE THE ACTIVITIES OF A REGREP WITH COMPLIANCE WITH NASD RULE 3050.








Censure



Docket/Case Number: CMS040186 AWC




Resolution:


Sanction Details: VFINANCE WAS CENSURED AND ON 12/6/2004 VFINANCE PAID A FINE OF$7500



Disclosure 26 of 27

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Initiated By: NASD






Other Product Type(s): UNSPECIFIED TYPE OF FINANCIAL PRODUCT.

Allegations: SEC RULE 11AC1-1, NASD CONDUCT RULE 3320 AND NASD MARKETPLACERULE 4613(B) - RESPONDENT MEMBER FAILED TO EXECUTE 16 ORDERSUPON PRESENTMENT AND THEREBY FAILED TO HONOR ITS PUBLISHEDQUOTATION.



Resolution: Acceptance, Waiver & Consent(AWC)








Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENTMEMBER CONSENTED TO THE FINDING OF THE ALLEGATIONS AND TO THEFOLLOWING SANCTIONS: FINED $5,000.00.


No



Initiated By: NASD








Allegations: NASD RULE VIOLATIONS:MARKET RULE 4613(B)AN ORDER WAS PRESENTED TO VFIN AT VFIN'S PUBLISHED QUOTATIONSIZE. VFIN FAILED TO EXECUTE ANY OF THE 16 ORDERS.

CONDUCT RULE 3320



Resolution:


Sanction Details: FINE WAS $5,000.00.








Sanction Details: FINE WAS $5,000.00.

Firm Statement AN ORDER WAS PRESENTED TO VFIN AT VFIN'S PUBLISHED QUOTATIONSIZE. VFIN FAILED TO EXECUTE ANY OF THE 16 ORDERS.

Disclosure 27 of 27

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Initiated By: NASD







Allegations: NASD CONDUCT RULES 2110, 3010, 3350 AND 3370, NASD MARKETPLACERULE 6130 - RESPONDENT MEMBER ("FIRM") EXECUTED SHORT SALETRANSACTIONS IN A NASDAQ NATIONAL MARKET ("NNM") SECURITY ANDFAILED TO REPORT EACH OF THESE TRANSACTIONS TO AUTOMATEDCONFIRMATION TRANSACTION SERVICE ("ACT") WITH A SHORT SALEMODIFIER. THE FIRM ALSO EXECUTED SHORT SALE ORDERS IN NNMSECURITY AND FAILED TO MAKE AN AFFIRMATIVE DETERMINATION PRIORTO EXECUTING SUCH TRANSACTIONS. IN ADDITION, THE FIRM EXECUTEDSHORT SALE TRANSACTIONS IN NNM SECURITY, AT OR BELOW THECURRENT INSIDE BID WHEN THE CURRENT INSIDE BID WAS BELOW THEPRECEDING INSIDE BID IN THE SECURITY. THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLESECURITIES LAWS AND REGULATIONS CONCERNING SHORT SALES.SPECIFICALLY, THE MEMBER'S SUPERVISORY SYSTEM DID NOT INCLUDEWRITTEN SUPERVISORY PROCEDURES PROVIDING FOR: (1) THEIDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISIONWITH RESPECT TO THE APPLICABLE RULES; (2) A STATEMENT OF THESUPERVISORY STEP(S) TO BE TAKE BY THE IDENTIFIED PERSON(S); (3) ASTATEMENT AS TO HOW OFTEN SUCH PERSON(S) SHOULD TAKE SUCHSTEP(S); AND (4) A STATEMENT AS TO HOW THE COMPLETION OF THESTEP(S) INCLUDE IN THE WRITTEN SUPERVISORY PROCEDURES SHOULDBE DOCUMENTED.









Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENTMEMBER CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED$17,500.




Initiated By: NASD








Allegations: NASD RULE VIOLATIONS:MARKEPLACE RULE 6130CONDUCT RULE 3370CONDUCT RULE 3350CONDUCT RULE 2110 AND 3010



Resolution:


Sanction Details: CENSURED AND FINE WAS 17,500. NASD AGREED TO INSTALLMENTPAYMENTS








Sanction Details: CENSURED AND FINE WAS 17,500. NASD AGREED TO INSTALLMENTPAYMENTS

Firm Statement THE FIRM EXECUTED 29 SHORT SALES WITHOUT THE PROPER SHORTSALE MODIFIER






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 6


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

11/06/2002

02-06461

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NOOTHER CONTROVERSY INVOLVED

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

$1,710,000.00

AWARD AGAINST PARTY

01/27/2004

$15,500.01

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 6

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

12/06/2004

04-08231

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

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;OPTIONS 77©2021 FINRA. All rights reserved. Report about VFINANCE INVESTMENTS, INC




www.finra.org/awardsonline

https://www.finra.org/arbitration-mediation/arbitration-awards-online?search=02-06461





Disposition:

Disposition Date:


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

$149,287.41

AWARD AGAINST PARTY

03/01/2006

$1,750.00


Disclosure 3 of 6

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

12/09/2004

04-08292

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-NEGLIGENCE; DO NOTUSE-NO OTHER CONTROVERSY INVOLVED

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$20,262.81

AWARD AGAINST PARTY

12/08/2005

$18,600.00


Disclosure 4 of 6

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Arbitration Forum:

Case Initiated:

Allegations:

FINRA

02/28/2008

DO NOT USE-NO OTHER CONTROVERSY INVOLVED; UNKNOWN TYPE OFCONTROVERSIES







Case Initiated:

Case Number:



Disposition:

Disposition Date:


02/28/2008

08-00472

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

$260,000.00

AWARD AGAINST PARTY

08/06/2009

$759,802.66


Disclosure 5 of 6

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

06/24/2009

09-03716

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT

COMMON STOCK

$15,147.01

AWARD AGAINST PARTY

11/12/2009

$8,005.00


Disclosure 6 of 6

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Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-FRAUD;ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY;ACCOUNT ACTIVITY-VIOLATE OF BLUE SKY LWS; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER








Arbitration Forum:

Case Initiated:

Case Number:



Disposition:

Disposition Date:


FINRA

06/29/2015

15-01516

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-FRAUD;ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNT ACTIVITY-SUITABILITY;ACCOUNT ACTIVITY-VIOLATE OF BLUE SKY LWS; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER

OTHER TYPES OF SECURITIES

$970,500.00

AWARD AGAINST PARTY

05/12/2017

$600,000.01








End of Report

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