Rbc Securities, Inc.

Allegations: NASD RULES 2110, 2210, 2211, 3010 AND MSRB RULES G-17, G-21 AND G-27: RESPONDENT'S COMMUNICATIONS WITH THE PUBLIC, INCLUDING CUSTOMERS AND PROSPECTIVE CUSTOMERS, IN ITS MARKETING AND SALE OF AUCTION RATE SECURITIES (ARS) WAS NOT FAIR AND BALANCED AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATING THE FACTS IN REGARDS TO THE PURCHASE OF AUCTION RATE SECURITIES (ARS). FOR EXAMPLE, THE COMMUNICATIONS DISTRIBUTED TO POTENTIAL ARS CUSTOMERS DESCRIBED THE POTENTIAL ADVANTAGES OF ARS IN MAINTAINING SHORT-TERM LIQUIDITY AND AS AN INVESTMENT TO MANAGE DAY-TO-DAY CASH NEEDS. THERE WAS NO DISCLOSURE ABOUT THE POTENTIAL FOR ILLIQUIDITY WITH AN ARS IN THE EVENT OF AN UNSUCCESSFUL AUCTION. THE FIRM'S INTERNAL MATERIALS USED BY REGISTERED REPRESENTATIVES DESCRIBED ARS AS LOW RISK, HIGH QUALITY, AND SHORT-TERM INVESTMENT ALTERNATIVES TO TRADITIONAL CASH MANAGEMENT INVESTMENTS THAT WOULD ALLOW INVESTORS TO MANAGE DAY-TO-DAY CASH NEEDS AND MAINTAIN LIQUIDITY. THESE INTERNAL MATERIALS ALSO FAILED TO ADEQUATELY DISCLOSE THE POTENTIAL FOR ILLIQUIDITY. RESPONDENT FAILED TO ESTABLISH AND MAINTAIN PROCEDURES REASONABLY DESIGNED TO ENSURE THAT IT MARKETED AND SOLD ARS IN COMPLIANCE WITH THE SECURITIES LAWS AND APPLICABLE NASD AND MSRB RULES, SUCH AS MAINTAINING PROCEDURES REASONABLY DESIGNED TO ENSURE THAT ITS REGISTERED REPRESENTATIVES ACCURATELY DESCRIBED ARS TO CUSTOMERS DURING SALES PRESENTATIONS AND THAT REPRESENTATIVES PROVIDED CUSTOMERS WITH ADEQUATE DISCLOSURE OF THE RISKS OF ARS, INCLUDING THE RISK THAT THE ARS AUCTIONS COULD FAIL AND THAT INVESTMENTS IN ARS COULD THEREFORE BECOME ILLIQUID. [CONTINUED IN COMMENTS] Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, RESPONDENT IS CENSURED, FINED $315,000 AND REQUIRED TO SUBMIT TO A BUYBACK OFFER TO PURCHASE AT PAR AUCTION RATE SECURITIES (ARS) SUBJECT TO AUCTION THAT HAVE NOT BEEN SUCESSFUL AS OF OCTOBER 21, 2008 AND ARE NOT SUBJECT TO CURRENT CALLS OR REDEMPTIONS (ELIGIBLE ARS) FROM ALL INVESTORS WHO PURCHASE ELIGIBLE ARS BETWEEN MAY 31, 2006 AND FEBRUARY 28, 2008 (RELEVANT CLASS). NO LATER THAN SIX MONTHS FROM THE DATE OF THE AWC, THE FIRM SHALL MAKE ITS BEST EFFORTS TO PROVIDE LIQUIDITY TO ALL OTHER INVESTORS NOT IN THE RELEVANT CLASS BUT WHO PURCHASED ELIGIBLE ARS FROM THE FIRM AT ANY TIME BETWEEN MAY 31, 2006 AND FEBRUARY 28, 2008. THE FIRM SHALL REASONABLY IDENTIFY INVESTORS WHO SOLD ELIGIBLE ARS BELOW PAR BETWEEN CERTAIN DATES AND PAY THEM THE DIFFERENCE BETWEEN PAR AND THE PRICE AT WHICH THEY SOLD THE ARS. THE FIRM SHALL ARBITRATE CLAIMS FOR CONSEQUENTIAL DAMAGES FILED BY INVESTORS IN THE RELEVANT CLASS RELATING TO ELIGIBLE ARS AND PROVIDE FINRA WITH A REPORT FOLLOWING THE COMPLETION OF THE BUYBACK CONCERNING COMPLIANCE WITH THE SETTLEMENT. Summary: [CONTINUED]: RESPONDENT ALSO FAILED TO PROVIDE ADEQUATE TRAINING TO ITS REGISTERED REPRESENTATIVES REGARDING THE FEATURES AND CHARACTERISTICS OF ARS AND THE DIFFERENCES BETWEEN ARS AND OTHER INVESTMENTS. RESPONDENT FAILED TO ESTABLISH AND MAINTAIN PROCEDURES THAT WERE REASONABLY DESIGNED TO ENSURE THAT THE WRITTEN MATERIALS IT USED IN CONNECTION WITH THE MARKETING AND SALE OF ARS COMPLIED WITH THE APPROPRIATE DISCLOSURE STANDARDS IN NASD RULE 2210, 2211 AND MSRB RULE G-21. AMENDED AWC ISSUED JULY 28,2009.

Allegations: CNS FAILED TO SUPERVISE A REGISTERED REPRESENTATIVE'S OUTSIDE BUSINESS ACTIVITY, PRIVATE SECURITIES TRANSACTIONS AND OUTSIDE ACCOUNTS. THE REPRESENTATIVE WAS EMPLOYED BY AN AFFILIATED RIA, WHILE ENGAGING IN THE ACTIVITY BUT CNS DID NOT ENSURE THAT THE ACTIVITY WAS PROPERLY DISCLOSED. CNS FAILED TO SUPERVISE THE ACTIVITY IN THE REPRESENTATIVE'S OUTSIDE ACCOUNTS, FAILED TO RECORD THE PRIVATE SECURITIES ON THEIR BOOKS AND RECORDS. THE SUPERVISOR SHOULD HAVE FOLLOWED UP ON ITEMS THAT WARRANTED FURTHER SCRUTINY. Status: Final Sanction Detail: THE CENSURE AND $250,000 FINE WERE THE TOTALITY OF THE SANCTIONS AGAINST CITY NATIONAL SECURITIES, INC. Summary: AWC WAS SIGNED WITHOUT ADMITTING OR DENYING THE FINDINGS. CNS CONSENTED TO THE IMPOSITION OF A CENSURE AND FINE. THE REPRESENTATIVE WAS REGISTERED WITH CITY NATIONAL SECURITIES ("CNS") SOLELY TO ACT AS A PLACEMENT AGENT FOR HIS AFFILIATED EMPLOYER'S PRIVATE FUNDS. KNOWLEDGE OF THE ACTIVITY WAS LIMITED ONLY TO THE CNS REGISTERED EMPLOYEES OF THAT AFFILIATED FIRM. THIS ITEM WAS IDENTIFIED AND SELF-REPORTED BY CNS TO FINRA UPON DISCOVERY OF THE ACTIVITY.

Allegations: THE OCC FOUND THAT THE BANK ENGAGED IN UNSAFE OR UNSOUND PRACTICES, INCLUDING ITS FAILURE TO ESTABLISH EFFECTIVE RISK MANAGEMENT AND INTERNAL CONTROLS. THIS FAILURE ALSO RESULTED IN NONCOMPLIANCE WITH 12 CFR PART 30, APPENDIX D, "OCC GUIDELINES ESTABLISHING HEIGHTENED STANDARDS FOR CERTAIN LARGE INSURED NATIONAL BANKS, INSURED FEDERAL SAVINGS ASSOCIATIONS, AND INSURED FEDERAL BRANCHES." THE BANK ALSO VIOLATED THE BANK SECRECY ACT (BSA) AND 12 CFR PART 9 - FIDUCIARY ACTIVITIES OF NATIONAL BANKS. Status: Final Sanction Detail: CITY NATIONAL BANK PAID THE PENALTY TO THE U.S. TREASURY. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE BANK CONSENTED TO THE ENTRY OF THE ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS AND IMPOSING A CEASE AND DESIST ORDER.

Allegations: ROYAL BANK OF CANADA IS ALLEGED TO HAVE VIOLATED SECTION 4C(A) OF THE COMMODITY EXCHANGE ACT, AND COMMISSION REGULATION 1.38(A), BY KNOWINGLY ENTERING INTO PURCHASES AND SALES OF SINGLE STOCK FUTURES AND NARROW-BASED INDEX FUTURES CONTRACTS OPPOSITE ITS SUBSIDIARIES WITH THE EXPRESS OR IMPLIED UNDERSTANDING THAT THE POSITION WOULD BE OFFSET OR DELIVERED OPPOSITE EACH OTHER. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED SECTION 4C(A) OF THE COMMODITY EXCHANGE ACT, AND COMMISSION REGULATION 1.38(A), BY KNOWINGLY ENTERING INTO PURCHASES AND SALES OF SINGLE STOCK FUTURES AND NARROW-BASED INDEX FUTURES CONTRACTS OPPOSITE ITS SUBSIDIARIES WITH THE EXPRESS OR IMPLIED UNDERSTANDING THAT THE POSITIONS WOULD BE OFFSET OR DELIVERED OPPOSITE EACH OTHER; THEREFORE THE FIRM IS FINED $35,000,000.00 AND IS PERMANENTLY RESTRAINED, ENJOINED, AND PROHIBITED FROM DIRECTLY OR INDIRECTLY ENTERING INTO OR CONFIRMING THE EXECUTION OF A TRANSACTION THAT IS, IS OF THE CHARACTER OF, OR IS COMMONLY KNOWN TO THE TRADE AS A WASH SALE, OR IS A FICTITIOUS SALE. THE FIRM IS ALSO PERMANENTLY RESTRAINED, ENJOINED, AND PROHIBITED FROM DIRECTLY OR INDIRECTLY EXECUTING ANY NONCOMPETITIVE TRANSACTION. Summary: THE ACTION IS FINALIZED PER CONSENT ON 12/18/2014

Allegations: FAILURE TO MAKE AND KEEP BOOKS, RECORDS, AND ACCOUNTS, WHICH, IN REASONABLE DETAIL, ACCURATELY AND FAIRLY REFLECT THE TRANSACTIONS AND DISPOSITIONS OF THE ASSETS OF THE ISSUER. FAILURE TO DEVISE AND MAINTAIN A SYSTEM OF INTERNAL ACCOUNT CONTROLS SUFFICIENT TO PROVIDE REASONABLE ASSURANCE THAT TRANSACTIONS ARE RECORDED TO PERMIT PREPARATION OF FINANCIAL STATEMENTS IN CONFORMITY WITH GENERALLY ACCEPTED ACCOUNTING PRINCIPLES. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE ENTRY OF THE ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS AND IMPOSING A CEASE-AND-DESIST ORDER. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE ENTRY OF THE ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS AND IMPOSING A CEASE-AND-DESIST ORDER.

Allegations: FAILURE TO HAVE SUFFICIENT SUPERVISION AND CONTROLS IN ITS FX TRADING BUSINESS Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS.