United Planners' Financial Services Of America A Limited Partner

Allegations: FINRA RULES 2010, 2330(D), NASD RULES 2110, 2330(C), 2330(D), 3010 - UNITED PLANNERS FINANCIAL SERVICES OF AMERICA, A LIMITED PARTNERSHIP FAILED TO HAVE IN PLACE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, PROCEDURES AND NASD RULES WITH RESPECT TO VARIABLE ANNUITY (VA) TRANSACTIONS OF FIELD OFFICE OF SUPERVISORY JURISDICTION (OSJ) SUPERVISORS. THE FIRM PERMITTED SUCH SUPERVISORS TO SELF-APPROVE THEIR OWN SALE OF VA AND ITS SYSTEM OF POST-TRANSACTION REVIEW WAS INADEQUATE. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRN IS FINED $200,000.00 Summary: THE FIRM HAS ADOPTED NEW POLICIES AND PROCEDURES IN ACCORDANCE WITH APPLICABLE SECURITIES LAWS.

Allegations: FINRA PROVIDED NOTIFICATION OF AN INVESTIGATION, AND THAT IT MADE A PRLIMINARY DETERMINATION TO RECOMMEND DISCIPLINARY ACTION. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS FINED $200,000.00 Summary: PLEASE REMOVE THIS DRP SINCE THIS IS A DUPLICATE ENTRY RELATED TO THE AWC AND THE REGULATORY ACTION DRP DATED 07/26/2012

Allegations: ALLEGATIONS OF VIOLATION OF ARTICLE III, SECTION I OF THE ASSOCIATIONS RULES OF FAIR PRACTICE IN FAILING TO COMPLY WITH PROVISION OF THE INTERPRETATION OF THE BOARD OF GOVENORS ENTITLED "FREERIDING & WITHHOLDING". Status: Final Sanction Detail: FINE WAS PAID BY APPLICANT ON 6/23/1995

Allegations: THE FIRM'S SUPERVISORY SYSTEMS AND PROCEDURES WERE INSUFFICIENT TO SUPERVISE THE USE OF CONSOLIDATED STATEMENTS WITH THE PUBLIC. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE THE FIRM WAS FINED $225,000.

Allegations: THE NASD ALLEGED THAT THE FIRM FAILED TO: INSPECT CERTAIN OFFICES OF SUPERVISORY JURISDICTION ANNUALLY AND TO ESTABLISH A SCHEDULE FOR THE INSPECTION OF OFFICES (CONDUCT RULE 3010(C); CONDUCT ANNUAL COMPLIANCE INTERVIEW WITH CERTAIN REGISTERED REPRESENTATIVES [CR 3010(A)(7)] TO REPORT FIVE CUSTOMER COMPLAINTS AND TWO ARBITRATIONS [CR 3070]; TO PREPARE A NEEDS ANALYSIS AND WRITTEN TRAINING PLAN ANNUALLY AND IMPLEMENT THE FIRM ELEMENT PROGRAM [CR 1120]. Status: Final Sanction Detail: CENSURE AND FINE IN THE AMOUNT OF $50,000.00 TO UNITED PLANNERS. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATONS, UNITED PLANNERS' FINANCIAL SERVICES OF AMERICA A LIMITED PARTNER, ENTERED INTO AN AGREEMENT WITH THE NASD FOR FAILURE TO: INSPECT CERTAIN OFFICES OF SUPERVISORY JURISDICTION ANNUALLY AND TO ESTABLISH A SCHEDULE FOR THE INSPECTION OF OFFICES; CONDUCT ANNUAL COMPLIANCE INTERVIEW WITH CERTAIN REGISTERED REPRESENTATIVES TO REPORT FIVE CUSTOMER COMPLAINTS AND TWO ARBITRATIONS; TO PREPARE A NEEDS ANALYSIS AND WRITTEN TRAINING PLAN ANNUALLY AND IMPLEMENT THE FIRM ELEMENT PROGRAM.

Allegations: ALLEGED VIOLATION OF FINRA RULE 2010 BY OMITTING MATERIAL FACTS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS FINED OF $40,000 AND IS TO PAY PARTIAL RESTITUTION OF $37,125 PLUS INTEREST.

Allegations: THE FIRM FILED A FINRA AWC ON FORM BD; HOWEVER INADVERTENTLY FORGOT TO NOTIFY NIPR AT THAT SAME TIME (WITHIN 30 DAYS). THIS WAS SUBSEQUENTLY FOUND BY THE FIRM; HOWEVER IT WAS AFTER THE 30 DAYS. Status: Final Sanction Detail: MONETARY FINE IMPOSED $500.00 WAS PAID IN FULL 8-22-17. Summary: VOLUNTARY SETTLEMENT AGREEMENT

Allegations: FAILURE TO SUPERVISE. Status: Final Sanction Detail: ADMINISTRATIVE FINE OF $50,000.00 AND RESTITUTION AMOUNT OF $1,059,823.82 PAID ON 7-18-2024. Summary: UNITED PLANNERS FINANCIAL SERVICES OF AMERICA A LIMITED PARTNER SETTLED WITH THE STATE OF ARIZONA WITHOUT ADMITTING OR DENYING VIOLATIONS.

Allegations: THE STATE ALLEGES UNITED PLANNERS FINANCIAL SERVICES OF AMERICA A LIMITED PARTNER VIOLATED MASS. GEN.LAWS CH. 110A § 204(A)(2)(G) AND MASS. GEN.LAWS CH. 110A § 204(A)(2)(J). Status: Final Sanction Detail: ADMINISTRATIVE FINE OF $100,000.00 PAID ON 10/01/2024. RESTITUTION AMOUNT OF $68,257.99 TO BE PAID TO MASACHUSETTS CLIENTS WITHIN 45 DAYS. INDEPENDENT CONSULTANT TO BE RETAINED FOR REVIEW OF WRITTEN POLICIES AND PROCEDURES WITHIN 90 DAYS AND FINDINGS REPORT TO BE PROVIDED TO THE MASSACHUSETTS SECURITIES DIVISION WITHIN 180 DAYS. WITHIN 60 DAYS OF THE REPORT COMPLIANCE TRAINING IS TO BE PROVIDED AND TRAINING REPORT IS TO BE SUBMITTED WITHIN 30 DAYS OF TRAINING TO THE MASSACHUSETTS SECURITIES DIVISION. Summary: UNITED PLANNERS' FINANCIAL SERVICES OF AMERICA A LIMITED PARTNER SETTLED WITH THE STATE OF MASSACHUSETTS WITHOUT ADMITTING OR DENYING VIOLATIONS OF MASS. GEN.LAWS CH. 110A § 204(A)(2)(G) OR MASS. GEN.LAWS CH. 110A § 204(A)(2)(J).

Allegations: THE STATE ALLEGES UNITED PLANNERS' FINANCIAL SERVICES OF AMERICA A LIMITED PARTNER FAILED IN ITS DUTY TO SUPERVISE THE OUTSIDE BUSINESS ACTIVITIES OF A REPRESENTATIVE. Status: Final Sanction Detail: ADMINISTRATIVE FINE PAID ON 02/22/201 Summary: UNITED PLANNERS' FINANCIAL SERVICES OF AMERICA A LIMITED PARTNER SETTLED WITH THE STATE OF MASSACHUSETTS WITHOUT ADMITTING OR DENYING VIOLATIONS OF MASS. GEN.LAWS CH. 110A § 204(A)(2)(J)