Mm Ascend Life Investor Services, Llc

Allegations: CONDUCTING INVESTMENT ADVISORY BUSINESS WITHOUT THE BENEFIT OF REGISTRATION OF AT LEAST ONE PRINCIPAL IN THE STATE OF FLORIDA. ACTION WAS UNRELATED TO THE OPERATIONS OF THE BROKER/DEALER. Status: Final Sanction Detail: TOTAL FINE OF $2,500.00 WAS PAID BY GREAT AMERICAN ADVISORS, INC. ("GAA") ON APRIL 27, 2004. Summary: GAA HAS BEEN A REGISTERED BROKER/DEALER IN THE STATE OF FLORIDA SINCE 1994 AND AN INVESTMENT ADVISER ("IA") FIRM SINCE 1998. THESE ALLEGATIONS RELATE TO GAA'S IA REGISTRATION. DURING THE 2003 CALENDAR YEAR THE STATE AMENDED ITS FILING REQUIREMENT WITH REGARD TO THE MAINTENANCE OF A QUALIFIED PRINCIPAL FOR IA FIRMS. THE STATE CLAIMS IT SENT NOTIFICATION LETTERS TO ALL FLORIDA IA FIRMS INSTRUCTING FIRMS TO SUBMIT AT LEAST ONE QUALIFIED PRINCIPAL FOR REGISTRATION ELECTRONICALLY VIA THE CRD/IARD. THIS CORRESPONDENCE WAS NEVER RECEIVED BY GAA, NOR DOES THE STATE HAVE ANY RECORD PROVIDING TRACKING OF THE CORRESPONDENCE. AFTER RECEIVING THE COMPLAINT, WE PROMPTLY SUBMITTED A QUALIFIED PRINCIPAL FOR IA REGISTRATION ON MARCH 26, 2004. ALTHOUGH WE DISAGREE WITH THE STATE'S POSITION ON PROVIDING NOTIFICATION REGARDING THE RULE AMENDMENT, WE SIGNED THE STIPULATION AND CONSENT ORDER AND PAID THE MONETARY FINE IN ORDER TO CONTINUE OUR IA REGISTRATION IN FLORIDA.

Allegations: ON SEPTEMBER 12, 2011, DEFENDANT, GREAT AMERICAN ADVISORS, INC. ("GAA" OR "DEFENDANT") ADMITTED TO VIOLATING CERTAIN RULES OF THE STATE CORPORATION COMMISSION ("RULES(S)"). THE ALLEGATIONS STEMMED FROM GAA'S PRIOR ASSOCIATION WITH FORMER AGENT, LELAND O. STEVENS. MR. STEVENS ADMITTED TO EFFECTING PRIVATE SECURITIES TRANSACTIONS IN SECURITIES ISSUED BY QUEEN SHOALS, LLC AND SELECT FUND, LLC THAT WERE NOT RECORDED ON THE DEFENDANT'S BOOKS OR RECORDS. THE ISSUERS ARE NOW KNOWN TO HAVE PURPORTED A PONZI-SCHEME FRAUD ON THE INVESTING PUBLIC IN MULTIPLE STATE JURISDICTIONS. IT WAS ALLEGED THAT THE DEFENDANT FAILED TO EXERCISE DILIGENT SUPERVISION OVER THE ACTIVITIES OF MR. STEVENS, AMONG OTHER THINGS, IN VIOLATION OF RULES 21 VAC 5-20-260 A&B. THE DEFENDANT ADMITTED THAT IT FAILED TO REVIEW/RETAIN CORRESPONDENCE WITH RESPECT TO MR. STEVENS' BUSINESS AT THE FIRM, IN VIOLATION OF RULE 21 VAC 5-20-240, PER SEC RULE 17A-4 B 4. GAA ADMITTED ANOTHER VIOLATION OF RULE 21 VAC 5-20-240 FOR FAILING TO SECURE THE FIRM'S RECORDS UPON MR. STEVENS' TERMINATION SO THAT IT COULD RETAIN CLOSED, CLIENT FILES FOR THE APPROPRIATE PERIOD OF TIME, PURSUANT TO SEC RULE 17A-4 C. IT WAS FURTHER ALLEGED, AND ADMITTED BY THE DEFENDANT, THAT GAA FAILED TO CONDUCT AND ANNUAL REVIEW OF MR. STEVENS' BUSINESS AFFAIRS IN 2007, IN VIOLATION OF RULE 21 VAC 5-20-260 E 2. AND REPORT AN ARBITRATION MATTER TO THE COMMISSION, IN VIOLATION OF 21 VAC 5-20-230 A 1. Status: Final Sanction Detail: GAA HAS PAID THE FINE AND THE COSTS OF THE INVESTIGATION AND HAS AGREED TO AMENDMENTS TO THE FIRM'S POLICIES AND PROCEDURES IN THE EVENT THAT GAA RE-ENTERS THE RETAIL BROKER DEALER BUSINESS IN VIRGINIA. Summary: THIS SITUATION WAS RELATED TO THE SELLING AWAY ACTIVITIES OF LELAND OTTO STEVENS, A FORMER REGISTERED REPRESENTATIVE OF THE FIRM WHO SOLD INTERESTS IN THE SELECT FUND LLC AND QUEEN SHOALS LLC WHICH WERE DEEMED TO BE UNREGISTERED SECURITIES. PRIOR TO THE COMMISSION'S INVESTIGATION, UPON LEARNING OF MR. STEVENS ACTIVITIES, GAA OPENED AN INTERNAL INVESTIGATION INTO MR. STEVENS' SELLING AWAY ACTIVITIES AND SUBSEQUENTLY TERMINATED MR. STEVENS FOR VIOLATIONS OF WRITTEN SUPERVISORY PROCEDURES. THOUGH GAA DISAGREES WITH THE COMMISSIONS' FINDINGS IN SOME CASES, GAA ADMITTED TO ALLEGATIONS 3.FAILING TO CONDUCT A PHYSICAL BRANCH OFFICE INSPECTION OF STEVENS' OFFICE IN 2007;4.FAILING TO MAINTAIN BOOKS AND RECORDS;AND 5.FAILING TO NOTIFY THE COMMISSION OF A PENDING ARBITRATION AND NEITHER ADMITS NOR DENIES REMAINING ALLEGATIONS.

Allegations: CONDUCTING INVESTMENT ADVISORY BUSINESS WITHOUT THE BENEFIT OF REGISTRATION OF AT LEAST ONE PRINCIPAL IN THE STATE OF FLORIDA. ACTION WAS UNRELATED TO THE OPERATIONS OF THE BROKER/DEALER. Status: Final Sanction Detail: TOTAL FINE OF $2,500.00 WAS PAID BY GREAT AMERICAN ADVISORS, INC. ("GAA") ON APRIL 27, 2004. Summary: GAA HAS BEEN A REGISTERED BROKER/DEALER IN THE STATE OF FLORIDA SINCE 1994 AND AN INVESTMENT ADVISER ("IA") FIRM SINCE 1998. THESE ALLEGATIONS RELATE TO GAA'S IA REGISTRATION. DURING THE 2003 CALENDAR YEAR THE STATE AMENDED ITS FILING REQUIREMENT WITH REGARD TO THE MAINTENANCE OF A QUALIFIED PRINCIPAL FOR IA FIRMS. THE STATE CLAIMS IT SENT NOTIFICATION LETTERS TO ALL FLORIDA IA FIRMS INSTRUCTING FIRMS TO SUBMIT AT LEAST ONE QUALIFIED PRINCIPAL FOR REGISTRATION ELECTRONICALLY VIA THE CRD/IARD. THIS CORRESPONDENCE WAS NEVER RECEIVED BY GAA, NOR DOES THE STATE HAVE ANY RECORD PROVIDING TRACKING OF THE CORRESPONDENCE. AFTER RECEIVING THE COMPLAINT, WE PROMPTLY SUBMITTED A QUALIFIED PRINCIPAL FOR IA REGISTRATION ON MARCH 26, 2004. ALTHOUGH WE DISAGREE WITH THE STATE'S POSITION ON PROVIDING NOTIFICATION REGARDING THE RULE AMENDMENT, WE SIGNED THE STIPULATION AND CONSENT ORDER AND PAID THE MONETARY FINE IN ORDER TO CONTINUE OUR IA REGISTRATION IN FLORIDA.

Allegations: DURING THE REVIEW PERIOD INVOLVING BOND TRADES EXECUTED BETWEEN JAN 1, 2009 AND MAR 31, 2009 THE FIRM FAILED ON 11 INDIVIDUAL TRANSACTIONS INVOLVING THE SALE OF CORPORATE BONDS TO SELL SUCH BONDS AT A PRICE THAT WAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TO EACH BOND AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WAS ENTITLED TO A PROFIT. THE CONDUCT IN THE 11 TRANSACTIONS CONSTITUTED SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 2010, NASD RULE 2440 AND IM-2440. Status: Final Sanction Detail: FINRA ACCEPTED THE FIRM'S LETTER OF ACCEPTANCE, WAIVER AND CONSENT IN STAR # 20090198393, ACCEPTED THE PAYMENT OF $12,000.00 FINE AND ISSUED CAUTIONARY ACTION #2011-685. THE MATTER IS NOW CLOSED. Summary: FINRA ISSUED A CAUTIONARY ACTION NO. 2011-685 ALONG WITH ITS ACCEPTANCE OF THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT TENDERED BY THE FIRM. THE FIRM NOTED IN A CORRECTIVE ACTION STATEMENT SUBMITTED WITH THE SUBJECT AWC THAT IT HAS TAKEN STEPS TO MODIFY ITS PROCEDURES FOR EXECUTING BOND TRADES AND PROVIDED ADDITIONAL TRAINING TO THE SALES REPRESENTATIVES AND HOME OFFICE, TRADE DESK STAFF.