Wilmington Capital Securities, Llc

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, BARNES CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE EXERCISED DISCRETION IN TRANSACTIONSIN CUSTOMER ACCOUNTS WITHOUT THE CUSTOMERS' WRITTEN AUTHORIZATION AND WITHOUT HIS MEMBER FIRM HAVING ACCEPTED THE ACCOUNTS AS DISCRETIONARY. THEFINDINGS STATED THAT EACH OF THE CUSTOMERS GAVE BARNES EXPRESS OR IMPLIED AUTHORIZATION TO EXERCISE DISCRETION IN HIS OR HER ACCOUNTS. Status: Final Sanction Detail: ONE MONTH SUSPENSION IN ALL CAPACITIES. START DATE 10/3/2022. END DATE 11/2/2022. CIVIL AND ADMINISTRATIVE PENALTY/FINE OF $5,000.00. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, BARNES CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE EXERCISED DISCRETION IN TRANSACTIONSIN CUSTOMER ACCOUNTS WITHOUT THE CUSTOMERS' WRITTEN AUTHORIZATION AND WITHOUT HIS MEMBER FIRM HAVING ACCEPTED THE ACCOUNTS AS DISCRETIONARY. THEFINDINGS STATED THAT EACH OF THE CUSTOMERS GAVE BARNES EXPRESS OR IMPLIED AUTHORIZATION TO EXERCISE DISCRETION IN HIS OR HER ACCOUNTS.

Allegations: ON AUGUST 25, 2020, THE BANKING COMMISSIONER ENTERED A CONSENT ORDER (NO. CO-20-202-91-S) WITH RESPECT TO WILMINGTON CAPITAL SECURITIES, LLC, A CONNECTICUT-REGISTERED BROKER-DEALER. THE CONSENT ORDER ALLEGED THAT THE FIRM ENGAGED IN DISHONEST OR UNETHICAL BUSINESS PRACTICES WITHIN THE MEANING OF SECTION 36B-31-15A(B) OF THE REGULATIONS UNDER THE CONNECTICUT UNIFORM SECURITIES ACT BY PAYING AN UNREGISTERED SALES ASSISTANT A PERCENTAGE OF THE COMMISSIONS EARNED BY THOSE BROKER-DEALER AGENTS THE SALES ASSISTANT SUPPORTED. THE CONSENT ORDER ALSO ALLEGED THAT THE FIRM VIOLATED SECTION 36B-31-6F(B) OF THE REGULATIONS BY FAILING TO ESTABLISH, ENFORCE AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS. Status: Final Sanction Detail: SEE RESPONSE TO ITEM 12.B. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT TO WAIVER OF ITS PROCEDURAL RIGHTS (I) ACKNOWLEDGING THE STATE OF CONNECTICUT COMMISSION OR SECURITIES ALLEGATIONS OF VIOLATIONS OF CT UNIFORM SECURITIES ACT SECTIONS 36B-31-6F(B) AND/OR 36B-31-15A(B) AND (II) CONSENTING TO PAY $11,275 IN FINES AND PAST DUE BROKER-DEALER AGENT REGISTRATION FEES. THE ALLEGATIONS WERE IN CONNECTION WITH A COMPENSATION STRUCTURE DEEMED NON-COMPLIANT BY CONNECTICUT FOR ONE OF WILMINGTON'S BACK-OFFICE, NON-REGISTERED EMPLOYEES. THERE WERE NO SALES PRACTICE VIOLATIONS ALLEGED AND NO CUSTOMERS WERE AFFECTED.