western international securities, inc. · western international securities, inc. crd# 39262 sec#...

BrokerCheck Report

WESTERN INTERNATIONAL SECURITIES, INC.

Section Title

Report Summary

Firm History

CRD# 39262

1

6

Firm Profile 2 - 5

Page(s)

Firm Operations 7 - 12

Disclosure Events 13

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WESTERN INTERNATIONALSECURITIES, INC.

CRD# 39262

SEC# 8-48572

Main Office Location

70 S. LAKE AVE.STE. 700PASADENA, CA 91101Regulated by FINRA Los Angeles Office

Mailing Address

70 S. LAKE AVE.STE. 700PASADENA, CA 91101

This firm is a brokerage firm and an investmentadviser firm. For more information aboutinvestment adviser firms, visit the SEC'sInvestment Adviser Public Disclosure website at:

Business Telephone Number

(888) 793-7717

https://www.adviserinfo.sec.gov

Report Summary for this Firm

This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.

Disclosure Events

Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.

Are there events disclosed about this firm? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 9

Arbitration 5

Firm Profile

This firm is classified as a corporation.

This firm was formed in Colorado on 04/14/1995.

Its fiscal year ends in December.

Firm History

Information relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.

Firm Operations

Is this brokerage firm currently suspended with anyregulator? No

This firm conducts 15 types of businesses.

This firm is affiliated with financial or investmentinstitutions.

This firm has referral or financial arrangements withother brokers or dealers.

This firm is registered with:

• the SEC• 1 Self-Regulatory Organization• 53 U.S. states and territories

www.finra.org/brokercheck User Guidance

1©2020 FINRA. All rights reserved. Report about WESTERN INTERNATIONAL SECURITIES, INC.

https://adviserinfo.sec.gov/firm/summary/39262


http://www.finra.org/brokercheck

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This firm is classified as a corporation.

This firm was formed in Colorado on 04/14/1995.

CRD#

This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.

Firm Profile

Firm Names and Locations

Its fiscal year ends in December.

WESTERN INTERNATIONAL SECURITIES, INC.

SEC#

39262

8-48572

Main Office Location

Mailing Address

Business Telephone Number

Doing business as WESTERN INTERNATIONAL SECURITIES, INC.

(888) 793-7717

Regulated by FINRA Los Angeles Office








This section provides information relating to all direct owners and executive officers of the brokerage firm.

Direct Owners and Executive Officers

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

CONCEPT BROKERAGE HOLDING CORP.

PARENT COMPANY

75% or more

No

Domestic Entity

04/1995

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


BIZUB, DONALD MICHAEL

CEO/MP/DIRECTOR

Less than 5%

No

Individual

12/1999

Yes

1600090



Position


Position Start Date

KAISER, BRADLEY CLIFFORD

CHIEF COMPLIANCE OFFICER

Less than 5%

Individual

02/2009

2523397








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

No

Position



Position Start Date


REA, WENDY AUSTIN

SR. MANAGING DIRECTOR

Less than 5%

No

Individual

02/2014

Yes

724857








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

Indirect Owners

Firm Profile

VADIM KEBETS

SHAREHOLDER

CONCEPT BROKERAGE HOLDING CORP

25% but less than 50%

No

Foreign Entity

06/2011

No



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established




XEEN, LLC

SHAREHOLDER

CONCERPT BROKERAGE HOLDING

25% but less than 50%

Domestic Entity

06/2011

No



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established









Firm History

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

No information reported.






Firm Operations

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

This firm is currently registered with the SEC, 1 SRO and 53 U.S. states and territories.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

This firm has ceased activity as a government securities broker or dealer:

Yes

Yes

No

No

Federal Regulator Status Date Effective

SEC Approved 11/29/1995

Self-Regulatory Organization Status Date Effective

FINRA Approved 11/29/1995






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 10/30/1996

Alaska Approved 07/31/1997

Arizona Approved 01/17/1997

Arkansas Approved 09/18/2001

California Approved 02/28/1996

Colorado Approved 11/30/1995

Connecticut Approved 09/23/1996

Delaware Approved 06/22/2000

District of Columbia Approved 07/26/2000

Florida Approved 09/18/1996

Georgia Approved 07/05/1996

Hawaii Approved 01/02/1997

Idaho Approved 10/07/1996

Illinois Approved 02/27/1996

Indiana Approved 02/21/1996

Iowa Approved 09/23/1996

Kansas Approved 04/11/1996

Kentucky Approved 08/14/1996

Louisiana Approved 07/10/2000

Maine Approved 01/28/2002

Maryland Approved 07/25/1996

Massachusetts Approved 09/04/1996

Michigan Approved 07/11/1996

Minnesota Approved 03/20/2001

Mississippi Approved 07/12/2000

Missouri Approved 08/21/2000

Montana Approved 08/21/2000

Nebraska Approved 10/11/1996

Nevada Approved 09/09/1996

New Hampshire Approved 07/06/2004

New Jersey Approved 09/19/1996

New Mexico Approved 09/25/1996

New York Approved 10/21/1996

U.S. States &Territories

Status Date Effective

North Carolina Approved 11/14/1996

North Dakota Approved 05/12/1997

Ohio Approved 07/16/1996

Oklahoma Approved 03/20/1996

Oregon Approved 10/11/1996

Pennsylvania Approved 09/25/1996

Puerto Rico Approved 12/10/2018

Rhode Island Approved 07/13/2001

South Carolina Approved 09/26/1996

South Dakota Approved 06/29/2001

Tennessee Approved 07/19/2000

Texas Approved 08/21/1996

Utah Approved 07/08/1996

Vermont Approved 11/18/1996

Virgin Islands Approved 10/21/2019

Virginia Approved 07/11/1996

Washington Approved 10/09/1996

West Virginia Approved 06/27/2001

Wisconsin Approved 08/11/1997

Wyoming Approved 02/20/1996






Firm Operations

Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.

Other Types of Business

This firm does effect transactions in commodities, commodity futures, or commodity options.This firm does not engage in other non-securities business.

Non-Securities Business Description:

This firm currently conducts 15 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 broker

Municipal securities broker

Broker or dealer selling variable life insurance or annuities

Solicitor of time deposits in a financial institution

Put and call broker or dealer or option writer

Investment advisory services

Broker or dealer selling tax shelters or limited partnerships in primary distributions

Broker or dealer selling tax shelters or limited partnerships in the secondary market

Private placements of securities

Broker or dealer selling interests in mortgages or other receivables

Broker or dealer involved in a networking, kiosk or similar arrangment with a: bank, savings bank or association, orcredit union






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: NATIONAL FINANCIAL SERVICES LLC

Business Address: 200 SEAPORT BLVDBOSTON, MA 02210

CRD #: 13041

Effective Date: 12/02/2015

Description: NATIONAL FINANCIAL SERVICES IS A CLEARING AGENT FOR WESTERNINTERNATIONAL SECURITIES, INC. ON A FULLY-DISCLOSED BASIS.

Name: WEDBUSH SECURITIES INC.

Business Address: 1000 WILSHIRE BLVD., SUITE 900LOS ANGELES, CA 90017

CRD #: 877


Description: WESTERN ENTERED INTO CLEARING ARRANGEMENT WITH WEDBUSHSECURITIES.

Name: PERSHING LLC

Business Address: ONE PERSHING PLAZAJERSEY CITY, NJ 07399

CRD #: 7560


Description: PERSHING LLC WILL CLEAR SECURITIES TRANSACTIONS AND HOLDFUNDS AND SECURITIES FOR THE WESTERN INTERNATIONALSECURITIES,INC. WESTERN OPERATES ON FULLY DISCLOSED BASIS






Firm Operations

Industry Arrangements

This firm does not have books or records maintained by a third party.

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

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

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

Name: NATIONAL FINANCIAL SERVICES LLC

Business Address: 200 SEAPORT BLVDBOSTON, MA 02210

CRD #: 13041


Description: NATIONAL FINANCIAL SERVICES IS THE CLEARING AGENT ON A FULLY-DISCLOSED BASIS FOR WESTERN INTERNATIONAL SECURITIES.

Name: PERSHING LLC

Business Address: ONE PERSHING PLAZAJERSEY CITY, NJ 07399

CRD #: 7560


Description: WESTERN OPERATES ON FULLY DISCLOSED BASIS THROUGHPERSHING






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

01/17/2014

70 SOUTH LAKE AVENUEPASADENA, CA 91101-4709

166180

HAMILTON GRANT LLC is under common control with the firm.

DONALD MICHAEL BIZUB (CRD # 1600090) IS CEO OF BOTH ENTITIESDescription:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

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

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






Disclosure Events

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

Final On AppealPending

Regulatory Event 1 8 0

Arbitration N/A 5 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.

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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.

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or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.

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§ 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 8

Reporting Source: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITDISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLEORGANIZATION CUSTOMERS WHO WERE ELIGIBLE TO PURCHASE CLASSA SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALESCHARGE. THE FINDINGS STATED THAT THESE ELIGIBLE CUSTOMERSWERE INSTEAD SOLD CLASS A SHARES WITH A FRONT-END SALESCHARGE OR CLASS B OR C SHARES WITH BACK-END SALES CHARGESAND HIGHER ONGOING FEES AND EXPENSES. THESE SALESDISADVANTAGED ELIGIBLE CUSTOMERS BY CAUSING SUCH CUSTOMERSTO PAY HIGHER FEES THAN THEY WERE ACTUALLY REQUIRED TO PAY.THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLYSUPERVISE THE APPLICATION OF SALES-CHARGE WAIVERS TO ELIGIBLEMUTUAL FUND SALES. THE FIRM RELIED ON ITS FINANCIAL ADVISORS TODETERMINE THE APPLICABILITY OF SALES-CHARGE WAIVERS, BUT FAILEDTO MAINTAIN REASONABLE WRITTEN POLICIES OR PROCEDURES TOASSIST FINANCIAL ADVISORS IN MAKING THIS DETERMINATION. INADDITION, THE FIRM FAILED TO ADEQUATELY NOTIFY AND TRAIN ITSFINANCIAL ADVISORS REGARDING THE AVAILABILITY OF MUTUAL FUNDSALES-CHARGE WAIVERS FOR ELIGIBLE CUSTOMERS. THE FIRM FAILEDTO ADOPT REASONABLE CONTROLS TO DETECT INSTANCES IN WHICHTHEY DID NOT PROVIDE SALES-CHARGE WAIVERS TO ELIGIBLECUSTOMERS IN CONNECTION WITH THEIR MUTUAL FUND PURCHASES. ASA RESULT, THE FIRM ESTIMATES THAT ELIGIBLE CUSTOMERS WEREOVERCHARGED BY APPROXIMATELY $305,000 FOR MUTUAL FUNDPURCHASES MADE SINCE JANUARY 1, 2011.

Current Status: Final






Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 07/16/2019

Docket/Case Number: 2017056440501

Principal Product Type: Mutual Fund(s)

Other Product Type(s):


Resolution Date: 07/16/2019

Resolution:

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

No

Acceptance, Waiver & Consent(AWC)





https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2017056440501


Other Sanctions Ordered: UNDERTAKING - PROVIDE FINRA A PLAN TO OFFER REMEDIATION TOELIGIBLE CUSTOMERS

Sanction Details: THE FIRM WAS CENSURED, FINED $75,000 AND REQUIRED TO PROVIDEFINRA WITH A PLAN TO REMEDIATE ELIGIBLE CUSTOMERS WHOQUALIFIED FOR, BUT DID NOT RECEIVE, THE APPLICABLE MUTUAL FUNDSALES-CHARGE WAIVER. AS PART OF THIS SETTLEMENT, THE FIRMAGREES TO PAY RESTITUTION TO ELIGIBLE CUSTOMERS, WHICH ISESTIMATED TO TOTAL $375,000 (I.E., THE AMOUNT ELIGIBLE CUSTOMERSWERE OVERCHARGED, INCLUSIVE OF INTEREST). FINES PAID IN FULL ONJULY 26, 2019.


No

Sanctions Ordered: CensureMonetary/Fine $75,000.00

iReporting Source: Firm








Initiated By: FINRA





Principal Product Type: Mutual Fund(s)


WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITDISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLEORGANIZATION CUSTOMERS WHO WERE ELIGIBLE TO PURCHASE CLASSA SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALESCHARGE. THE FINDINGS STATED THAT THESE ELIGIBLE CUSTOMERSWERE INSTEAD SOLD CLASS A SHARES WITH A FRONT-END SALESCHARGE OR CLASS B OR C SHARES WITH BACK-END SALES CHARGESAND HIGHER ONGOING FEES AND EXPENSES. THESE SALESDISADVANTAGED ELIGIBLE CUSTOMERS BY CAUSING SUCH CUSTOMERSTO PAY HIGHER FEES THAN THEY WERE ACTUALLY REQUIRED TO PAY.THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLYSUPERVISE THE APPLICATION OF SALES-CHARGE WAIVERS TO ELIGIBLEMUTUAL FUND SALES. THE FIRM RELIED ON ITS FINANCIAL ADVISORS TODETERMINE THE APPLICABILITY OF SALES-CHARGE WAIVERS, BUT FAILEDTO MAINTAIN REASONABLE WRITTEN POLICIES OR PROCEDURES TOASSIST FINANCIAL ADVISORS IN MAKING THIS DETERMINATION. INADDITION, THE FIRM FAILED TO ADEQUATELY NOTIFY AND TRAIN ITSFINANCIAL ADVISORS REGARDING THE AVAILABILITY OF MUTUAL FUNDSALES-CHARGE WAIVERS FOR ELIGIBLE CUSTOMERS. THE FIRM FAILEDTO ADOPT REASONABLE CONTROLS TO DETECT INSTANCES IN WHICHTHEY DID NOT PROVIDE SALES-CHARGE WAIVERS TO ELIGIBLECUSTOMERS IN CONNECTION WITH THEIR MUTUAL FUND PURCHASES. ASA RESULT, THE FIRM ESTIMATES THAT ELIGIBLE CUSTOMERS WEREOVERCHARGED BY APPROXIMATELY $305,000 FOR MUTUAL FUNDPURCHASES MADE SINCE JANUARY 1, 2011.


Resolution:

Other Sanctions Ordered: UNDERTAKING - PROVIDE FINRA A PLAN TO OFFER REMEDIATION TOELIGIBLE CUSTOMERS

Sanction Details: THE FIRM WAS CENSURED, FINED $75,000 AND REQUIRED TO PROVIDEFINRA WITH A PLAN TO REMEDIATE ELIGIBLE CUSTOMERS WHOQUALIFIED FOR, BUT DID NOT RECEIVE, THE APPLICABLE MUTUAL FUNDSALES-CHARGE WAIVER. AS PART OF THIS SETTLEMENT, THE FIRMAGREES TO PAY RESTITUTION TO ELIGIBLE CUSTOMERS, WHICH ISESTIMATED TO TOTAL $375,000 (I.E., THE AMOUNT ELIGIBLE CUSTOMERSWERE OVERCHARGED, INCLUSIVE OF INTEREST).



Disclosure 2 of 8

i


Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WSPSREASONABLY DESIGNED TO ENSURE THAT REGISTEREDREPRESENTATIVES' RECOMMENDATIONS REGARDING LEVERAGED,INVERSE, AND INVERSE-LEVERAGED EXCHANGE-TRADED FUNDS (NON-TRADITIONAL ETFS) COMPLIED WITH APPLICABLE SECURITIES LAW ANDREGULATIONS, AND FINRA RULES. THE FINDINGS STATED THAT THE FIRMFAILED TO REASONABLY SUPERVISE ITS SOLICITATION OF NON-TRADITIONAL ETF TRANSACTIONS IN RETAIL ACCOUNTS. THE FIRM DIDNOT HAVE WRITTEN POLICIES OR PROCEDURES THAT ADDRESSED THEUNIQUE FEATURES AND RISKS ASSOCIATED WITH NON-TRADITIONALETFS, ALTHOUGH IT PROVIDED EDUCATION REGARDING THESEPRODUCTS DURING ANNUAL COMPLIANCE MEETINGS. IN ADDITION, THEFIRM LACKED ANY SYSTEM THAT ENABLED SUPERVISORY PERSONNEL TOADEQUATELY MONITOR THE RISKS PECULIAR TO NON-TRADITIONAL ETFS,MOST PARTICULARLY THE RISK POSED BY LONG-TERM HOLDING OF APRODUCT THAT RESETS DAILY. THE FIRM HAD NO EXCEPTION REPORTSOR ALERTS SPECIFIC TO NON-TRADITIONAL ETFS, LET ALONE ANYSUPERVISORY TOOL THAT COULD DETECT THE DIVERGENCE OF A NON-TRADITIONAL ETF FROM ITS LINKED INDEX, AND IT HAD NO AUTOMATEDMETHOD OF CALCULATING AND MONITORING HOLDING PERIODS. THEFINDINGS ALSO STATED THAT THE FIRM, THROUGH ITSREPRESENTATIVES, FAILED TO PERFORM AN ADEQUATE REASONABLEBASIS SUITABILITY ANALYSIS OF NON-TRADITIONAL ETFS TOUNDERSTAND THE RISKS AND FEATURES ASSOCIATED WITH THESEPRODUCTS BEFORE OFFERING THEM FOR SALE TO RETAIL CUSTOMERS(OR, PARTICULARLY, RECOMMENDING THESE PRODUCTS AS LONG-TERMINVESTMENTS TO RETAIL CUSTOMERS). IN ADDITION, THE FIRM'SREPRESENTATIVES SOLICITED AND EFFECTED NON-TRADITIONAL ETFPURCHASES THAT WERE UNSUITABLE FOR SPECIFIC CUSTOMERS. FIRMREPRESENTATIVES RECOMMENDED THESE PRODUCTS (AND THE LONG-TERM HOLDING OF THESE PRODUCTS) TO CONSERVATIVE CUSTOMERSWITH MODEST FINANCIAL SITUATIONS, SOME OF WHOM WERE ELDERLY.MOREOVER, SOME OF THESE CUSTOMERS HELD NON-TRADITIONAL ETFPOSITIONS FOR EXTENDED PERIODS.








Initiated By: FINRA


Other


N/A



Principal Product Type: Other

Other Product Type(s): INVERSE-LEVERAGED EXCHANGE-TRADED FUNDS (NON-TRADITIONALETFS)

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WSPSREASONABLY DESIGNED TO ENSURE THAT REGISTEREDREPRESENTATIVES' RECOMMENDATIONS REGARDING LEVERAGED,INVERSE, AND INVERSE-LEVERAGED EXCHANGE-TRADED FUNDS (NON-TRADITIONAL ETFS) COMPLIED WITH APPLICABLE SECURITIES LAW ANDREGULATIONS, AND FINRA RULES. THE FINDINGS STATED THAT THE FIRMFAILED TO REASONABLY SUPERVISE ITS SOLICITATION OF NON-TRADITIONAL ETF TRANSACTIONS IN RETAIL ACCOUNTS. THE FIRM DIDNOT HAVE WRITTEN POLICIES OR PROCEDURES THAT ADDRESSED THEUNIQUE FEATURES AND RISKS ASSOCIATED WITH NON-TRADITIONALETFS, ALTHOUGH IT PROVIDED EDUCATION REGARDING THESEPRODUCTS DURING ANNUAL COMPLIANCE MEETINGS. IN ADDITION, THEFIRM LACKED ANY SYSTEM THAT ENABLED SUPERVISORY PERSONNEL TOADEQUATELY MONITOR THE RISKS PECULIAR TO NON-TRADITIONAL ETFS,MOST PARTICULARLY THE RISK POSED BY LONG-TERM HOLDING OF APRODUCT THAT RESETS DAILY. THE FIRM HAD NO EXCEPTION REPORTSOR ALERTS SPECIFIC TO NON-TRADITIONAL ETFS, LET ALONE ANYSUPERVISORY TOOL THAT COULD DETECT THE DIVERGENCE OF A NON-TRADITIONAL ETF FROM ITS LINKED INDEX, AND IT HAD NO AUTOMATEDMETHOD OF CALCULATING AND MONITORING HOLDING PERIODS. THEFINDINGS ALSO STATED THAT THE FIRM, THROUGH ITSREPRESENTATIVES, FAILED TO PERFORM AN ADEQUATE REASONABLEBASIS SUITABILITY ANALYSIS OF NON-TRADITIONAL ETFS TOUNDERSTAND THE RISKS AND FEATURES ASSOCIATED WITH THESEPRODUCTS BEFORE OFFERING THEM FOR SALE TO RETAIL CUSTOMERS(OR, PARTICULARLY, RECOMMENDING THESE PRODUCTS AS LONG-TERMINVESTMENTS TO RETAIL CUSTOMERS). IN ADDITION, THE FIRM'SREPRESENTATIVES SOLICITED AND EFFECTED NON-TRADITIONAL ETFPURCHASES THAT WERE UNSUITABLE FOR SPECIFIC CUSTOMERS. FIRMREPRESENTATIVES RECOMMENDED THESE PRODUCTS (AND THE LONG-TERM HOLDING OF THESE PRODUCTS) TO CONSERVATIVE CUSTOMERSWITH MODEST FINANCIAL SITUATIONS, SOME OF WHOM WERE ELDERLY.MOREOVER, SOME OF THESE CUSTOMERS HELD NON-TRADITIONAL ETFPOSITIONS FOR EXTENDED PERIODS.

Resolution: Acceptance, Waiver & Consent(AWC) 18©2020 FINRA. All rights reserved. Report about WESTERN INTERNATIONAL SECURITIES, INC.







Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED, FINED $125,000, AND ORDERED TO PAY$521,098.10, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS. FINES PAIDIN FULL ON MARCH 20, 2018.


No

Sanctions Ordered: CensureMonetary/Fine $125,000.00Disgorgement/Restitution



Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WSPSREASONABLY DESIGNED TO ENSURE THAT REGISTEREDREPRESENTATIVES' RECOMMENDATIONS REGARDING LEVERAGED,INVERSE, AND INVERSE-LEVERAGED EXCHANGE-TRADED FUNDS (NON-TRADITIONAL ETFS) COMPLIED WITH APPLICABLE SECURITIES LAW ANDREGULATIONS, AND FINRA RULES. THE FINDINGS STATED THAT THE FIRMFAILED TO REASONABLY SUPERVISE ITS SOLICITATION OF NON-TRADITIONAL ETF TRANSACTIONS IN RETAIL ACCOUNTS. THE FIRM DIDNOT HAVE WRITTEN POLICIES OR PROCEDURES THAT ADDRESSED THEUNIQUE FEATURES AND RISKS ASSOCIATED WITH NON-TRADITIONALETFS, ALTHOUGH IT PROVIDED EDUCATION REGARDING THESEPRODUCTS DURING ANNUAL COMPLIANCE MEETINGS. IN ADDITION, THEFIRM LACKED ANY SYSTEM THAT ENABLED SUPERVISORY PERSONNEL TOADEQUATELY MONITOR THE RISKS PECULIAR TO NON-TRADITIONAL ETFS,MOST PARTICULARLY THE RISK POSED BY LONG-TERM HOLDING OF APRODUCT THAT RESETS DAILY. THE FIRM HAD NO EXCEPTION REPORTSOR ALERTS SPECIFIC TO NON-TRADITIONAL ETFS, LET ALONE ANYSUPERVISORY TOOL THAT COULD DETECT THE DIVERGENCE OF A NON-TRADITIONAL ETF FROM ITS LINKED INDEX, AND IT HAD NO AUTOMATEDMETHOD OF CALCULATING AND MONITORING HOLDING PERIODS. THEFINDINGS ALSO STATED THAT THE FIRM, THROUGH ITSREPRESENTATIVES, FAILED TO PERFORM AN ADEQUATE REASONABLEBASIS SUITABILITY ANALYSIS OF NON-TRADITIONAL ETFS TOUNDERSTAND THE RISKS AND FEATURES ASSOCIATED WITH THESEPRODUCTS BEFORE OFFERING THEM FOR SALE TO RETAIL CUSTOMERS(OR, PARTICULARLY, RECOMMENDING THESE PRODUCTS AS LONG-TERMINVESTMENTS TO RETAIL CUSTOMERS). IN ADDITION, THE FIRM'SREPRESENTATIVES SOLICITED AND EFFECTED NON-TRADITIONAL ETFPURCHASES THAT WERE UNSUITABLE FOR SPECIFIC CUSTOMERS. FIRMREPRESENTATIVES RECOMMENDED THESE PRODUCTS (AND THE LONG-TERM HOLDING OF THESE PRODUCTS) TO CONSERVATIVE CUSTOMERSWITH MODEST FINANCIAL SITUATIONS, SOME OF WHOM WERE ELDERLY.MOREOVER, SOME OF THESE CUSTOMERS HELD NON-TRADITIONAL ETFPOSITIONS FOR EXTENDED PERIODS.







Initiated By: FINRA


Censure





Other Product Type(s): EXCHANGE TRADE FUNDS

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WSPSREASONABLY DESIGNED TO ENSURE THAT REGISTEREDREPRESENTATIVES' RECOMMENDATIONS REGARDING LEVERAGED,INVERSE, AND INVERSE-LEVERAGED EXCHANGE-TRADED FUNDS (NON-TRADITIONAL ETFS) COMPLIED WITH APPLICABLE SECURITIES LAW ANDREGULATIONS, AND FINRA RULES. THE FINDINGS STATED THAT THE FIRMFAILED TO REASONABLY SUPERVISE ITS SOLICITATION OF NON-TRADITIONAL ETF TRANSACTIONS IN RETAIL ACCOUNTS. THE FIRM DIDNOT HAVE WRITTEN POLICIES OR PROCEDURES THAT ADDRESSED THEUNIQUE FEATURES AND RISKS ASSOCIATED WITH NON-TRADITIONALETFS, ALTHOUGH IT PROVIDED EDUCATION REGARDING THESEPRODUCTS DURING ANNUAL COMPLIANCE MEETINGS. IN ADDITION, THEFIRM LACKED ANY SYSTEM THAT ENABLED SUPERVISORY PERSONNEL TOADEQUATELY MONITOR THE RISKS PECULIAR TO NON-TRADITIONAL ETFS,MOST PARTICULARLY THE RISK POSED BY LONG-TERM HOLDING OF APRODUCT THAT RESETS DAILY. THE FIRM HAD NO EXCEPTION REPORTSOR ALERTS SPECIFIC TO NON-TRADITIONAL ETFS, LET ALONE ANYSUPERVISORY TOOL THAT COULD DETECT THE DIVERGENCE OF A NON-TRADITIONAL ETF FROM ITS LINKED INDEX, AND IT HAD NO AUTOMATEDMETHOD OF CALCULATING AND MONITORING HOLDING PERIODS. THEFINDINGS ALSO STATED THAT THE FIRM, THROUGH ITSREPRESENTATIVES, FAILED TO PERFORM AN ADEQUATE REASONABLEBASIS SUITABILITY ANALYSIS OF NON-TRADITIONAL ETFS TOUNDERSTAND THE RISKS AND FEATURES ASSOCIATED WITH THESEPRODUCTS BEFORE OFFERING THEM FOR SALE TO RETAIL CUSTOMERS(OR, PARTICULARLY, RECOMMENDING THESE PRODUCTS AS LONG-TERMINVESTMENTS TO RETAIL CUSTOMERS). IN ADDITION, THE FIRM'SREPRESENTATIVES SOLICITED AND EFFECTED NON-TRADITIONAL ETFPURCHASES THAT WERE UNSUITABLE FOR SPECIFIC CUSTOMERS. FIRMREPRESENTATIVES RECOMMENDED THESE PRODUCTS (AND THE LONG-TERM HOLDING OF THESE PRODUCTS) TO CONSERVATIVE CUSTOMERSWITH MODEST FINANCIAL SITUATIONS, SOME OF WHOM WERE ELDERLY.MOREOVER, SOME OF THESE CUSTOMERS HELD NON-TRADITIONAL ETFPOSITIONS FOR EXTENDED PERIODS.


Resolution:


Sanction Details: THE FIRM WAS CENSURED, FINED $125,000, AND ORDERED TO PAY$521,098.10, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS.



Disclosure 3 of 8

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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 TOENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH LAWS, RULES ANDREGULATIONS APPLICABLE TO SUPERVISE A REGISTEREDREPRESENTATIVE'S PRIVATE SECURITIES TRANSACTIONS INVOLVING AFOREIGN CURRENCY TRADING PROGRAM CONDUCTED THROUGH THEREPRESENTATIVE'S INVESTMENT ADVISER. THE FINDINGS STATED THATTHE FIRM FURTHER FAILED TO ENFORCE WSPS REASONABLY DESIGNEDTO DETECT AND PREVENT THE REPRESENTATIVE'S MISCONDUCTTHROUGH HIS INVESTMENT ADVISER RELATED TO FOREX TRADINGACTIVITIES. THE FINDINGS ALSO STATED THAT THE FIRM'S WSPSMANDATED THAT THE FIRM PRESERVE EMPLOYEE SECURITIES ANDBUSINESS-RELATED EMAIL AND TO REVIEW, ON A DAILY BASIS, INCOMINGAND OUTGOING EMAILS FOR REGISTERED REPRESENTATIVES THAT AREIDENTIFIED THROUGH SAMPLING OR FILTERING TECHNIQUES UTILIZED BYTHE FIRM. THE REPRESENTATIVE UTILIZED AN EMAIL ADDRESS OF HISINVESTMENT ADVISER AND HIS EMAILS WERE CAPTURED BY A THIRDPARTY VENDOR THAT HOSTED THE INVESTMENT ADVISER'S SERVER. THEFIRM'S PROCEDURES ALLOWED THE REPRESENTATIVE TO UTILIZE ANOUTSIDE EMAIL VENDOR WITH THE CONDITION THAT HIS SECURITIES ANDBUSINESS-RELATED EMAILS WOULD BE FORWARDED TO AN EMAILADDRESS HOSTED ON THE FIRM'S INTERNAL MAIL SERVER, WHERE THEEMAILS WOULD BE CAPTURED AND RETAINED. ON SEVERAL OCCASIONS,THE FIRM'S ELECTRONIC STORAGE MEDIA VENDOR NOTIFIED THE FIRMTHAT IT WAS NOT CAPTURING THE REPRESENTATIVE'S EMAILCOMMUNICATIONS. DESPITE THESE RED FLAGS, THE FIRM FAILED TOTAKE ADEQUATE STEPS TO ENSURE THAT THE REPRESENTATIVE'SEMAILS WERE CAPTURED AND PRESERVED BY THE FIRM. THE FIRMFAILED TO RETAIN THOUSANDS OF THE REPRESENTATIVE'S EMAILS OVERA MORE THAN A YEAR PERIOD. HAD THE FIRM CAPTURED ALL OF THEREPRESENTATIVE'S SECURITIES AND BUSINESS RELATED EMAILS ANDCONDUCTED A REVIEW OF THESE EMAILS, IT MAY HAVE ALERTED THEFIRM THAT THE REPRESENTATIVE WAS INVOLVED IN MISCONDUCT INCONNECTION WITH HIS RETAIL FOREX ACTIVITIES. THE FINDINGS ALSOINCLUDED THAT THE FIRM FAILED TO IMPLEMENT ADEQUATE WRITTENPROCEDURES TO EVALUATE ANOTHER REGISTERED REPRESENTATIVE'SPROPOSED INVESTMENT ADVISER ACTIVITIES TO DETERMINE WHETHERTHE ACTIVITY SHOULD HAVE BEEN TREATED AS AN OUTSIDE SECURITIESACTIVITY. THE FIRM FURTHER FAILED TO DETECT AND PREVENT THEREPRESENTATIVE FROM ENGAGING IN PRIVATE SECURITIESTRANSACTIONS RELATED TO HIS INVESTMENT ADVISER THAT HAD NOTBEEN PREVIOUSLY APPROVED BY THE FIRM. THE REPRESENTATIVEDIRECTED CERTAIN SECURITIES TRANSACTIONS FOR AN OPEN-ENDMUTUAL FUND, THROUGH THE FIRM'S CLEARING FIRM, AND OTHERSECURITIES TRANSACTIONS AWAY FROM THE FIRM. THE FIRM FAILED TORECORD CERTAIN SECURITIES TRANSACTIONS DIRECTED AWAY FROMTHE FIRM ON ITS BOOKS AND RECORDS AS PRESCRIBED IN THE FIRM'SWSPS. THE FIRM DID NOT BECOME AWARE OF THE REPRESENTATIVE'SPRIVATE SECURITIES TRANSACTIONS RELATED TO THE MUTUAL FUNDUNTIL FINRA BROUGHT THE ACTIVITY TO THE FIRM'S ATTENTION DURINGTHE FIRM'S ROUTINE EXAMINATION.








Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH LAWS, RULES ANDREGULATIONS APPLICABLE TO SUPERVISE A REGISTEREDREPRESENTATIVE'S PRIVATE SECURITIES TRANSACTIONS INVOLVING AFOREIGN CURRENCY TRADING PROGRAM CONDUCTED THROUGH THEREPRESENTATIVE'S INVESTMENT ADVISER. THE FINDINGS STATED THATTHE FIRM FURTHER FAILED TO ENFORCE WSPS REASONABLY DESIGNEDTO DETECT AND PREVENT THE REPRESENTATIVE'S MISCONDUCTTHROUGH HIS INVESTMENT ADVISER RELATED TO FOREX TRADINGACTIVITIES. THE FINDINGS ALSO STATED THAT THE FIRM'S WSPSMANDATED THAT THE FIRM PRESERVE EMPLOYEE SECURITIES ANDBUSINESS-RELATED EMAIL AND TO REVIEW, ON A DAILY BASIS, INCOMINGAND OUTGOING EMAILS FOR REGISTERED REPRESENTATIVES THAT AREIDENTIFIED THROUGH SAMPLING OR FILTERING TECHNIQUES UTILIZED BYTHE FIRM. THE REPRESENTATIVE UTILIZED AN EMAIL ADDRESS OF HISINVESTMENT ADVISER AND HIS EMAILS WERE CAPTURED BY A THIRDPARTY VENDOR THAT HOSTED THE INVESTMENT ADVISER'S SERVER. THEFIRM'S PROCEDURES ALLOWED THE REPRESENTATIVE TO UTILIZE ANOUTSIDE EMAIL VENDOR WITH THE CONDITION THAT HIS SECURITIES ANDBUSINESS-RELATED EMAILS WOULD BE FORWARDED TO AN EMAILADDRESS HOSTED ON THE FIRM'S INTERNAL MAIL SERVER, WHERE THEEMAILS WOULD BE CAPTURED AND RETAINED. ON SEVERAL OCCASIONS,THE FIRM'S ELECTRONIC STORAGE MEDIA VENDOR NOTIFIED THE FIRMTHAT IT WAS NOT CAPTURING THE REPRESENTATIVE'S EMAILCOMMUNICATIONS. DESPITE THESE RED FLAGS, THE FIRM FAILED TOTAKE ADEQUATE STEPS TO ENSURE THAT THE REPRESENTATIVE'SEMAILS WERE CAPTURED AND PRESERVED BY THE FIRM. THE FIRMFAILED TO RETAIN THOUSANDS OF THE REPRESENTATIVE'S EMAILS OVERA MORE THAN A YEAR PERIOD. HAD THE FIRM CAPTURED ALL OF THEREPRESENTATIVE'S SECURITIES AND BUSINESS RELATED EMAILS ANDCONDUCTED A REVIEW OF THESE EMAILS, IT MAY HAVE ALERTED THEFIRM THAT THE REPRESENTATIVE WAS INVOLVED IN MISCONDUCT INCONNECTION WITH HIS RETAIL FOREX ACTIVITIES. THE FINDINGS ALSOINCLUDED THAT THE FIRM FAILED TO IMPLEMENT ADEQUATE WRITTENPROCEDURES TO EVALUATE ANOTHER REGISTERED REPRESENTATIVE'SPROPOSED INVESTMENT ADVISER ACTIVITIES TO DETERMINE WHETHERTHE ACTIVITY SHOULD HAVE BEEN TREATED AS AN OUTSIDE SECURITIESACTIVITY. THE FIRM FURTHER FAILED TO DETECT AND PREVENT THEREPRESENTATIVE FROM ENGAGING IN PRIVATE SECURITIESTRANSACTIONS RELATED TO HIS INVESTMENT ADVISER THAT HAD NOTBEEN PREVIOUSLY APPROVED BY THE FIRM. THE REPRESENTATIVEDIRECTED CERTAIN SECURITIES TRANSACTIONS FOR AN OPEN-ENDMUTUAL FUND, THROUGH THE FIRM'S CLEARING FIRM, AND OTHERSECURITIES TRANSACTIONS AWAY FROM THE FIRM. THE FIRM FAILED TORECORD CERTAIN SECURITIES TRANSACTIONS DIRECTED AWAY FROMTHE FIRM ON ITS BOOKS AND RECORDS AS PRESCRIBED IN THE FIRM'SWSPS. THE FIRM DID NOT BECOME AWARE OF THE REPRESENTATIVE'SPRIVATE SECURITIES TRANSACTIONS RELATED TO THE MUTUAL FUNDUNTIL FINRA BROUGHT THE ACTIVITY TO THE FIRM'S ATTENTION DURINGTHE FIRM'S ROUTINE EXAMINATION.






Initiated By: FINRA





Principal Product Type: No Product


WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH LAWS, RULES ANDREGULATIONS APPLICABLE TO SUPERVISE A REGISTEREDREPRESENTATIVE'S PRIVATE SECURITIES TRANSACTIONS INVOLVING AFOREIGN CURRENCY TRADING PROGRAM CONDUCTED THROUGH THEREPRESENTATIVE'S INVESTMENT ADVISER. THE FINDINGS STATED THATTHE FIRM FURTHER FAILED TO ENFORCE WSPS REASONABLY DESIGNEDTO DETECT AND PREVENT THE REPRESENTATIVE'S MISCONDUCTTHROUGH HIS INVESTMENT ADVISER RELATED TO FOREX TRADINGACTIVITIES. THE FINDINGS ALSO STATED THAT THE FIRM'S WSPSMANDATED THAT THE FIRM PRESERVE EMPLOYEE SECURITIES ANDBUSINESS-RELATED EMAIL AND TO REVIEW, ON A DAILY BASIS, INCOMINGAND OUTGOING EMAILS FOR REGISTERED REPRESENTATIVES THAT AREIDENTIFIED THROUGH SAMPLING OR FILTERING TECHNIQUES UTILIZED BYTHE FIRM. THE REPRESENTATIVE UTILIZED AN EMAIL ADDRESS OF HISINVESTMENT ADVISER AND HIS EMAILS WERE CAPTURED BY A THIRDPARTY VENDOR THAT HOSTED THE INVESTMENT ADVISER'S SERVER. THEFIRM'S PROCEDURES ALLOWED THE REPRESENTATIVE TO UTILIZE ANOUTSIDE EMAIL VENDOR WITH THE CONDITION THAT HIS SECURITIES ANDBUSINESS-RELATED EMAILS WOULD BE FORWARDED TO AN EMAILADDRESS HOSTED ON THE FIRM'S INTERNAL MAIL SERVER, WHERE THEEMAILS WOULD BE CAPTURED AND RETAINED. ON SEVERAL OCCASIONS,THE FIRM'S ELECTRONIC STORAGE MEDIA VENDOR NOTIFIED THE FIRMTHAT IT WAS NOT CAPTURING THE REPRESENTATIVE'S EMAILCOMMUNICATIONS. DESPITE THESE RED FLAGS, THE FIRM FAILED TOTAKE ADEQUATE STEPS TO ENSURE THAT THE REPRESENTATIVE'SEMAILS WERE CAPTURED AND PRESERVED BY THE FIRM. THE FIRMFAILED TO RETAIN THOUSANDS OF THE REPRESENTATIVE'S EMAILS OVERA MORE THAN A YEAR PERIOD. HAD THE FIRM CAPTURED ALL OF THEREPRESENTATIVE'S SECURITIES AND BUSINESS RELATED EMAILS ANDCONDUCTED A REVIEW OF THESE EMAILS, IT MAY HAVE ALERTED THEFIRM THAT THE REPRESENTATIVE WAS INVOLVED IN MISCONDUCT INCONNECTION WITH HIS RETAIL FOREX ACTIVITIES. THE FINDINGS ALSOINCLUDED THAT THE FIRM FAILED TO IMPLEMENT ADEQUATE WRITTENPROCEDURES TO EVALUATE ANOTHER REGISTERED REPRESENTATIVE'SPROPOSED INVESTMENT ADVISER ACTIVITIES TO DETERMINE WHETHERTHE ACTIVITY SHOULD HAVE BEEN TREATED AS AN OUTSIDE SECURITIESACTIVITY. THE FIRM FURTHER FAILED TO DETECT AND PREVENT THEREPRESENTATIVE FROM ENGAGING IN PRIVATE SECURITIESTRANSACTIONS RELATED TO HIS INVESTMENT ADVISER THAT HAD NOTBEEN PREVIOUSLY APPROVED BY THE FIRM. THE REPRESENTATIVEDIRECTED CERTAIN SECURITIES TRANSACTIONS FOR AN OPEN-ENDMUTUAL FUND, THROUGH THE FIRM'S CLEARING FIRM, AND OTHERSECURITIES TRANSACTIONS AWAY FROM THE FIRM. THE FIRM FAILED TORECORD CERTAIN SECURITIES TRANSACTIONS DIRECTED AWAY FROMTHE FIRM ON ITS BOOKS AND RECORDS AS PRESCRIBED IN THE FIRM'SWSPS. THE FIRM DID NOT BECOME AWARE OF THE REPRESENTATIVE'SPRIVATE SECURITIES TRANSACTIONS RELATED TO THE MUTUAL FUNDUNTIL FINRA BROUGHT THE ACTIVITY TO THE FIRM'S ATTENTION DURINGTHE FIRM'S ROUTINE EXAMINATION.


Resolution:


Sanction Details: SEE ABOVE

Regulator Statement FINE PAID IN FULL ON SEPTEMBER 19, 2014.


No




Allegations: THE ALLEGATIONS WERE THAT THE FIRM FAILED TO MAINTAIN ANDPRESERVE CERTAIN ELECTRONIC COMMUNICATIONS FOR BUSINESSPURPOSES AND FAILED TO ENFORCE ITS WSPS REQUIRING THE REVIEWOF INCOMING AND OUTGOING SECURITIES AND BUSINESS RELATEDELECTRONIC COMMUNICATIONS BEFORE AND AFTER DECEMBER 2008.THE FIRM FAILED TO: IMPLEMENT ADEQUATE WRITTEN PROCEDURES TOEVALUATE INVESTMENT ADVISER ACTIVITIES TO DETERMINE IF THEACTIVITY WAS AN OUTSIDE SECURITIES ACTIVITY; AND, DETECT ANDPREVENT AN INVESTMENT ADVISOR FROM ENGAGING IN PRIVATESECURITIES TRANSACTION IN A REGISTERED MUTUAL FUND AND RECORDCERTAIN TRANSACTIONS ON ITS BOOKS AND RECORDS.








Initiated By: FINRA


Censure


FINE





THE ALLEGATIONS WERE THAT THE FIRM FAILED TO MAINTAIN ANDPRESERVE CERTAIN ELECTRONIC COMMUNICATIONS FOR BUSINESSPURPOSES AND FAILED TO ENFORCE ITS WSPS REQUIRING THE REVIEWOF INCOMING AND OUTGOING SECURITIES AND BUSINESS RELATEDELECTRONIC COMMUNICATIONS BEFORE AND AFTER DECEMBER 2008.THE FIRM FAILED TO: IMPLEMENT ADEQUATE WRITTEN PROCEDURES TOEVALUATE INVESTMENT ADVISER ACTIVITIES TO DETERMINE IF THEACTIVITY WAS AN OUTSIDE SECURITIES ACTIVITY; AND, DETECT ANDPREVENT AN INVESTMENT ADVISOR FROM ENGAGING IN PRIVATESECURITIES TRANSACTION IN A REGISTERED MUTUAL FUND AND RECORDCERTAIN TRANSACTIONS ON ITS BOOKS AND RECORDS.


Resolution:

Other Sanctions Ordered: NA

Sanction Details: NA

Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO DESCRIBED SANCTIONS AND ENTRY OF FINDINGS, DATED SEPTEMBER5, 2014.



Disclosure 4 of 8

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Allegations: NASD RULES 2110, 2440, 3010, NASD INTERPRETATIVE MATERIAL 2440: -WESTERN INTERNATIONAL SECURITIES PURCHASED OR SOLDCORPORATE BONDS FROM OR TO CUSTOMERS AND FAILED TOPURCHASE OR SELL THE BONDS AT A PRICE THAT WAS FAIR, TAKING INTOCONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKETCONDITIONS WITH RESPECT TO EACH BOND AT THE TIME OF THETRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WASENTITLED TO A PROFIT. THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDNASD RULES CONCERNING FAIR PRICES AND COMMISSIONS.








Initiated By: FINRA





Principal Product Type: Debt - Corporate


NASD RULES 2110, 2440, 3010, NASD INTERPRETATIVE MATERIAL 2440: -WESTERN INTERNATIONAL SECURITIES PURCHASED OR SOLDCORPORATE BONDS FROM OR TO CUSTOMERS AND FAILED TOPURCHASE OR SELL THE BONDS AT A PRICE THAT WAS FAIR, TAKING INTOCONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKETCONDITIONS WITH RESPECT TO EACH BOND AT THE TIME OF THETRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WASENTITLED TO A PROFIT. THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDNASD RULES CONCERNING FAIR PRICES AND COMMISSIONS.


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 $12,500, ORDERED TO PAY$2,199, PLUS INTEREST, IN RESTITUTION TO PUBLIC CUSTOMERS ANDREQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURESREGARDING FAIR PRICES AND COMMISSIONS WITHIN 30 BUSINESS DAYSOF ACCEPTANCE OF THIS AWC BY THE NATIONAL ADJUDICATORYCOUNCIL (NAC). A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMITSATISFACTORY PROOF OF PAYMENT OF RESTITUTION OR OFREASONABLE AND DOCUMENTED EFFORTS 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 ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED.


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 $12,500, ORDERED TO PAY$2,199, PLUS INTEREST, IN RESTITUTION TO PUBLIC CUSTOMERS ANDREQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURESREGARDING FAIR PRICES AND COMMISSIONS WITHIN 30 BUSINESS DAYSOF ACCEPTANCE OF THIS AWC BY THE NATIONAL ADJUDICATORYCOUNCIL (NAC). A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMITSATISFACTORY PROOF OF PAYMENT OF RESTITUTION OR OFREASONABLE AND DOCUMENTED EFFORTS 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 ABANDONEDPROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMER LASTRESIDED.


Initiated By: FINRA


Censure


$12,500 FINE$2,199 CLIENT RESTITUTION


Docket/Case Number: 20060049769-AWC



Allegations: SIX TRANSACTIONS THAT WERE FOUND BY FINRA; FAILED TO HAVE BEENPURCHASED OR SOLD TO AND FROM CUSTOMERS AT A PRICE THAT WASFAIR, TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES,INCLUDING MARKET CONDITIONS.FIRM DID NOT PROVIDE ADEQUATE SUPERVISION TO ACHIEVECOMPLIANCE WITH RESPECT TO APPLICABLE SECURITIES LAWS ANDREGULATIONS, AND THE RULE OF FINRA.



Resolution:

Other Sanctions Ordered: RESTITUTION AMOUNT $2199.00

Sanction Details: -CENSURE-FINE IN THE AMOUNT $12,500.00 (PAID ON 12-4-08)-RESTITUTION TO ALL CLIENTS LISTED ON EXHIBIT A, 6 TRADES TOTALAMOUNT $2,199.00 (PAID ON 12-9-08)-UPDATED PROCEDURES IN FIRMS WRITTEN SUPERVISORYPROCEDURES. (UPDATED ON 6-24-08)



Disclosure 5 of 8

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Initiated By: NASD




Docket/Case Number: 20050001532-01



Allegations: NASD RULES 6230(C)(7), 6230(D)(1) - RESPONDENT MEMBER, ACTING ASPRINCIPAL, INCORRECTLY REPORTED A MARKUP/MARKDOWN AS ACOMMISSION TO THE TRADE REPORTING AND COMPLIANCE ENGINE(TRACE) FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES; FAILED TOREPORT TO TRACE THE CORRECT CAPACITY FOR TRANSACTIONS INTRACE-ELIGIBLE SECURITIES.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, WESTERNINTERNATIONAL SECURITIES, INC., CONSENTED TO THE DESCRIBEDSANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM ISCENSURED AND FINED $8,000.


No




Allegations: 288 INCORRECT TRACE REPORTS FROM 1/1/04 TO 3/31/04. MARKUPS /MARKDOWNS WERE INCORRECTLY REPORTED AS COMMISSIONS. 45INSTANCES WHERE THE INCORRECT CAPACITY WAS REPORTED (AGENCYVS. PRINCIPAL).







Initiated By: NASD


Censure


$8000 FINE


Docket/Case Number: 20050001532-01 AWC



Allegations: 288 INCORRECT TRACE REPORTS FROM 1/1/04 TO 3/31/04. MARKUPS /MARKDOWNS WERE INCORRECTLY REPORTED AS COMMISSIONS. 45INSTANCES WHERE THE INCORRECT CAPACITY WAS REPORTED (AGENCYVS. PRINCIPAL).


Resolution:


Sanction Details: FINE PAID 1/18/2006

Firm Statement 288 INCORRECT TRACE REPORTS FROM 1/1/04 TO 3/31/04. MARKUPS /MARKDOWNS WERE INCORRECTLY REPORTED AS COMMISSIONS. 45INSTANCES WHERE THE INCORRECT CAPACITY WAS REPORTED (AGENCYVS. PRINCIPAL).



Disclosure 6 of 8

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Reporting Source: Firm

Initiated By: STATE OF MINNESOTA, COMMISSIONER OF COMMERCE


Docket/Case Number: SE2008101/SGC

Allegations: WESTERN INDICATED IN THE LICENSE APPLICATION PROCESS THAT ITHAD NO MINNESOTA CLIENTS WHEN IN FACT THERE WERE FIVEMINNESOTA CLIENTS PRIOR TO LICENSURE. WESTERN CONTENDED THATIT WAS NOT AWARE OF THE ACCOUNTS DUE TO INACTIVITY.








Cease and Desist





Resolution:


Sanction Details: WESTERN SHALL CEASE AND DESIST FROM SELLING OR OFFERINGSECURITIES IN MINNESOTA UNTIL LICENSED AS A BROKER/DEALER WITHTHAT STATE SECURITIES COMMISSION. A FINE OF $3000.00 WAS PAID.

Firm Statement FOLLOWING ISSUANCE OF THE CEASE AND DESIST ORDER AND PAYMENTOF THE FINE, WESTERN IMMEDIATELY APPLIED FOR REGISTRATION AS ASECURITIES BROKER/DEALER IN THE STATE OF MINNESOTA AND WASAPPROVED AS SUCH ON MARCH 20, 2001.

Sanctions Ordered: Monetary/Fine $3,000.00Cease and Desist/Injunction

Consent

Disclosure 7 of 8

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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.




Docket/Case Number: C3A980017

Principal Product Type:


Allegations:


Resolution: Decision & Order of Offer of Settlement








Sanction Details:

Regulator Statement COMPLAINT NO. C3A980017 FILED APRIL 23, 1998, BY DISTRICT NO. 3AGAINST RESPONDENTS WESTERN INTERNATIONAL SECURITIES, INC.ANDCURTIS A. ROBERTS ALLEGING VIOLATIONS OF NASD RULE 2110 IN THATRESPONDENT MEMBER, ACTING THROUGH RESPONDENT ROBERTS,CONDUCTEDA SECURITIES BUSINESS WHILE IN VIOLATION OF THE MINIMUM NETCAPITAL REQUIREMENT OF SEC RULE 15c3-1; AND, FAILED TO TIMELYFILE A FORM BD AMENDMENT DISCLOSING AN OWNERSHIP CHANGE, ANDTHE FORM BD AMENDMENT FALSELY DISCLOSED THAT THE OWNERSHIPCHANGE OCCURRED DURING JULY 1997 RATHER THANAUGUST/SEPTEMBER1996.

ON AUGUST 24, 1998, THE DECISION AND ORDER OF ACCEPTANCE OFOFFER OF SETTLEMENT SUBMITTED BY RESPONDENTS WESTERNINTERNATIONAL SECURITIES, INC. AND CURTIS A. ROBERTS WASISSUED; THEREFORE, THEY ARE CENSURED AND FINED $7,500, JOINTLYAND SEVERALLY.

**$7,500 PAID J&S ON 9/24/98, INVOICE #98-3A-717**



Initiated By: NASD REGULATION, INC.


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





Allegations: FAILURE TO MAINTAIN NET CAPITAL ON 05/29/97 AND 06/03/97; FAILURE TOREPORT CHANGES IN OWNERSHIP IN A TIMELY MANNER AND INACCURATEREPORTING OF THE DATE OF CHANGE IN OWNERSHIP.










CENSURE


Resolution:


Sanction Details: WESTERN INTERNATIONAL SECURITIES, INC. AND CURTIS ROBERTS,PRIMARY PRINCIPAL, WERE CENSURED AND FINED $7500 JOINTLY ANDSEVERALLY.



Disclosure 8 of 8

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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.





Principal Product Type:


Allegations:



Resolution:


Sanction Details:

Regulator Statement ON APRIL 1, 1997, DISTRICT NO. 3 NOTIFIED WESTERN INTERNATIONALSECURITIES, INC. AND CURTIS A. ROBERTS THAT THE LETTER OFACCEPTANCE, WAIVER AND CONSENT NO. C3A970013 WAS ACCEPTED;THEREFORE, THEY ARE CENSURED AND FINED $1,000, JOINTLY ANDSEVERALLY - (NASD RULE 2110 - RESPONDENT MEMBER, ACTINGTHROUGHRESPONDENT ROBERTS, CONDUCTED A SECURITIES BUSINESS WHILEFAILING TO MAINTAIN ITS REQUIRED NET CAPITAL).

***$1,000.00 PAID J&S ON 5/12/97, INVOICE #97-3A-257***








Regulator Statement ON APRIL 1, 1997, DISTRICT NO. 3 NOTIFIED WESTERN INTERNATIONALSECURITIES, INC. AND CURTIS A. ROBERTS THAT THE LETTER OFACCEPTANCE, WAIVER AND CONSENT NO. C3A970013 WAS ACCEPTED;THEREFORE, THEY ARE CENSURED AND FINED $1,000, JOINTLY ANDSEVERALLY - (NASD RULE 2110 - RESPONDENT MEMBER, ACTINGTHROUGHRESPONDENT ROBERTS, CONDUCTED A SECURITIES BUSINESS WHILEFAILING TO MAINTAIN ITS REQUIRED NET CAPITAL).

***$1,000.00 PAID J&S ON 5/12/97, INVOICE #97-3A-257***


Initiated By: NASD REGULATION, INC.




CENSURE





Allegations: FAILURE TO MAINTAIN NET CAPITAL OF $100,000 AS REQUIRED FROM09/24/1996 TO 10/02/1996.



Resolution:


Sanction Details: WESTERN INTERNATIONAL SECURITIES, INC. WAS CENSURED AND FINED$1000.00.

Sanctions Ordered: Monetary/Fine $1,000.00







Regulatory - Pending

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

Disclosure 1 of 1

Reporting Source: Firm

Initiated By: FINRA







Allegations: VIOLATION OF ARTICLE V, SECTION 2(C) OF FINRA'S BY-LAWS AND FINRARULE 2010 - FAILURE TO TIMELY DISCLOSE FINANCIAL EVENTS ON FORMU4; AND,VIOLATION OF FINRA 3110(A) AND FINRA RULE 2010 - FAILURE TOESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEMINCLUDING WRITTEN SUPERVISORY PROCEDURES TO ENSURE THATFORM U4S WERE AMENDED, OR TIMELY AMENDED, TO DISCLOSEREPORTABLE FINANCIAL EVENTS OF REGISTERED REPRESENTATIVES.

Current Status: Pending






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 5


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

10/07/2003

03-06962

ACCOUNT ACTIVITY-MANIPULATION; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE

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

$82,256.00

AWARD AGAINST PARTY

08/13/2004

$75,129.00

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

Disclosure 2 of 5

i



Arbitration Forum:

Allegations:

FINRA

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-BREACH OFCONTRACT; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCE





www.finra.org/awardsonline

https://www.finra.org/arbitration-mediation/arbitration-awards-online?search=03-06962


Case Initiated:

Case Number:



Disposition:

Disposition Date:


02/22/2013

13-00467

MUTUAL FUNDS; OTHER TYPES OF SECURITIES

$1,935,230.00

AWARD AGAINST PARTY

04/07/2014

$200,000.01


Disclosure 3 of 5

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

03/11/2013

13-00612

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-OTHER; ACCOUNTACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING;ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

Unspecified Damages

AWARD AGAINST PARTY

10/21/2014

$100,250.01


Disclosure 4 of 5

i










Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


FINRA

03/07/2014

14-00575

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE

EXCHANGE-TRADED FUNDS; MUTUAL FUNDS

$850,000.00

AWARD AGAINST PARTY

03/21/2017

$1,042,769.01


Disclosure 5 of 5

i



Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

06/16/1998

98-01640

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

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

$3,673.63

AWARD AGAINST PARTY

01/25/1999

$62.50









End of Report

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