Pension Fund Evaluations, Inc.

Allegations: LAWSUIT, HOMER L. AND CORA JOHNSON ET AL., V. BANK ONE, TEXAS, NA IN WHICH PENSION FUND EVALUATIONS, INC. WAS RECENTLY NAMES AS A "DOE" DEFENDANT. CLASS ACTION ALLEGES CLAIMS AGAINST VARIOUS BROKERS RELATING TO THE SALE OF CERTAIN SECURITIES. THE DEFENDAND, BANK ONE, TEXAS, NA HAS ASSERTED A THIRD PARTY CLAIM AGAISNT PFE FOR CONTRIBUTION AND INDEMNIFICATION, WHICH APPERS TO BE PREMISED ON A THORY OF VICARIOUS LIABILITY. Status: Final Summary: LAWSUIT, HOMER L. AND CORA JOHNSON ET AL., V. BANK ONE, TEXAS, NA IN WHICH PENSION FUND EVALUATIONS, INC. WAS RECENTLY NAMES AS A "DOE" DEFENDANT. CLASS ACTION ALLEGES CLAIMS AGAINST VARIOUS BROKERS RELATING TO THE SALE OF CERTAIN SECURITIES. THE DEFENDAND, BANK ONE, TEXAS, NA HAS ASSERTED A THIRD PARTY CLAIM AGAISNT PFE FOR CONTRIBUTION AND INDEMNIFICATION, WHICH APPERS TO BE PREMISED ON A THORY OF VICARIOUS LIABILITY.

Allegations: NOV. 1999 PLAINTIFF BROUGHT CIVIL ACTION AGAINST PENSION FUND EVALUATIONS, INC. FOR ALLEGED VIOLATION OF FIDUCIARY DUTIES UNDER 28 USC 1104. Status: Final Summary: DISMISSED WITH PREJUDICE ON OR ABOUT MAY 10, 2002. BOTH PARTIES AGREED TO AN AMICALBE SETTLEMENT.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, MR. PHILIPPS CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE FAILED TO TIMELY REPORT TWO FEDERAL TAX LIENS. Status: Final Sanction Detail: SUSPENSION FROM JULY 7, 2014 TO AUGUST 6, 2014 AND $2,500 FINE. Summary: FINE HAS BEEN PAID IN FULL AND MARY PELLICANI WILL TAKE OVER AS PRESIDENT AND CCO DURING MR. PHILIPP'S SUSPENSION.

Allegations: ON MAY 7, 2007, THE FIRM ENTERED INTO A VOLUNTARY ACCEPTANCE WAIVER AND CONSENT WITH THE NASD. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE IMPOSITION OF AN INDIVIDUAL FINE OF $18,500 AND A JOINT AND SEVERAL FINE WITH GREGORY PHILIPPS OF $7,500 FOR THE FOLLOWING: 1) THE FIRM PERMITTED GREGORY PHILLIPS TO ACT IN A REGISTERED CAPACITY WHILE MR. PHILIPPS' REGISTRATION WAS INACTIVE FROM OCTOBER 21, 2005 TO DECEMBER 29, 2005 AS A RESULT OF HIS UNTIMELY COMPLETION OF HIS FIRM ELEMENT CONTINUING EDUCATION. THIS CONDUCT WAS IN VIOLATION OF NASD MEMBERSHIP AND REGISTRATION RULE 1120 AND NASD CONDUCT RULE 2110; 2) THE FIRM, THROUGH MR. PHILIPPS PERMITTED A REGISTERED INDIVIDUAL TO MAINTAIN THEIR REGISTRATION AS A GENERAL SECURITIES REPRESENTATIVE WITH THE FIRM WHEN THAT PERSON WAS NOT ACTIVELY INVOLVED IN THE FIRM'S DAY-TO-DAY BUSINESS. THIS CONDUCT WAS IN VIOLATION OF NASD MEMBERSHIP AND REGISTRATION RULE 1031 AND NASD CONDUCT RULE 2110; 3) THE FIRM DID NOT PROPERLY ACCRUE OUTSIDE ACCOUNTING, LEGAL AND SETTLEMENT EXPENSES RESULTING IN NET CAPITAL DEFICIENCIES FOR THE PERIOD BETWEEN OCTOBER 30, 2005 TO JANUARY 31, 2006. THIS CONDUCT WAS IN VIOLATION OF NASD CONDUCT RULE 2110; 4) THE FIRM VIOLATED NASD CONDUCT RULES 3011 AND 2110 BY NO DEVELOPING AN ANTI-MONEY-LAUNDERING PROGRAM WHICH WAS REASONABLY DESIGNED TO ACHIEVE AND MONITOR COMPLIANCE WITH THE BANK SECRECY ACT; 5) THE FIRM VIOLATED NASD CONDUCT RULES 3010(A), 3010(B)(1) AND 2110 BY FAILING TO ESTABLISH MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES TO FOR ANNUAL COMPLIANCE MEETINGS, CUSTOMER COMPLAINT REPORTING, DESIGNATION OF TITLES, REGISTRATION STATUS AND LOCATIONS OF SUPERVISORY PERSONNEL, PRIVATE SECURITIES TRANSACTIONS, OUTSIDE BUSINESS ACTIVITIES AND THE REVIEW OF CORRESPONDENCE; AND 6) THE FIRM VIOLATED SEC RULE 17A-4 AND NASD CONDUCT RULES 3110 AND 2110 BY NOT HAVING A SYSTEM TO RETAIN E-MAILS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, PENSION FUND EVALUATIONS, INC. CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS THEREFORE THE FIRM IS CENSURED AND FINED $7,500, JOINTLY AND SEVERALLY. THE FIRM IS ALSO FINED AN ADDITIONAL $18,500.

Allegations: FOR CALENDAR YEAR 1996, PFE, ACTING THROUGH GEORGE PHILIPPS FAILED TO COMPLETE A TRAINING NEEDS ANALYSIS AND TO DEVELOP AND IMPLEMENT WRITTEN TRAINING PLANS CONCERNING THE FIRM ELEMENT OF THE CONTINUING EDUCATION PROGRAM IN CONTRAVENTION OF NASD MEMEBERSHIP AND REGISTRATION RULE 1120. ADDITIONALLY, THE MEMEBER, ACTING THROUGH PHILIPPS, FAILED TO MAINTAIN BOOKS AND RECORDS TO DEMONSTRATE COMPLIANCE WITH THE FIRM ELEMENT, THE MATERIALS USED IN TRAINING AND A LIST OF DATES OF TRAINING SESSIONS. Status: Final Sanction Detail: NONE Summary: FOR CALENDAR YEAR 1996, PFE, ACTING THROUGH GEORGE PHILIPPS FAILED TO COMPLETE A TRAINING NEEDS ANALYSIS AND TO DEVELOP AND IMPLEMENT WRITTEN TRAINING PLANS CONCERNING THE FIRM ELEMENT OF THE CONTINUING EDUCATION PROGRAM IN CONTRAVENTION OF NASD MEMEBERSHIP AND REGISTRATION RULE 1120. ADDITIONALLY, THE MEMEBER, ACTING THROUGH PHILIPPS, FAILED TO MAINTAIN BOOKS AND RECORDS TO DEMONSTRATE COMPLIANCE WITH THE FIRM ELEMENT, THE MATERIALS USED IN TRAINING AND A LIST OF DATES OF TRAINING SESSIONS.

Allegations: FAILURE TO MAINTAIN MINIMUM NET CAPITAL AS REQUIRED BY SEC RULE 15C3-1 AND IN VIOLATION OF NASD CONDUCT RULE 2110 Status: Final Sanction Detail: THE FINE AT ISSURE WAS PAID IN FULL BY THE REGISTRANT BY CHECK DATED JANUARY 12, 2005 Summary: THE MATTER IS CONCLUDED