&Partners

Allegations: MSRB RULE G-14 WILEY BROS-AINTREE CAPITAL, LLC FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL; THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCH TRANSACTIONS WITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRS PORTAL Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDING, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINIGS, THEREFORE THE FIRM IS CENSURED AND FINED 7500.00 Summary: DURING THE REVIEW PERIOD, THE FIRM FAILED TO REPORT INFORMATION REGARDING PURCHASE AND SALE TRANSACTIONS EFFECTED IN MUNI SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM RTRS IN THE MANNER PRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USER MANUAL

Allegations: ADVISER FAILED TO TIMELY REPORT TO THE OHIO DEPARTMENT OF INSURANCE TWO FINRA ADMINISTRATIVE PENALTIES IMPOSED ON ADVISER, ONE IN 2010 AND ONE IN 2015. ON NOVEMBER 24, 2004, ADVISER INACCURATELY MARKED "NO" WHEN ASKED IF IT HAD BEEN INVOLVED IN AN ADMINISTRATIVE ACTION AND IN 2012, 2013, AND 2015, ADVISER INACCURATELY MARKED "NO" WHEN ASKED IF IT HAS BEEN INVOLVED IN AN ADMINISTRATIVE ACTION THAT HAD NOT BEEN PREVIOUSLY REPORTED TO THE DEPARTMENT. Status: Final Sanction Detail: ADVISER WAS ORDERED TO PAY A FINE OF $400 AND ADMINISTRATIVE COSTS OF $100. ADVISER PAID THE FINE AND THE COSTS IN FULL ON AUGUST 30, 2016. Summary: ADVISER EXECUTED A CONSENT ORDER RELATING TO THE ABOVE DESCRIBED ALLEGATIONS WITH THE OHIO DEPARTMENT OF INSURANCE DATED JUNE 6, 2016 AND PAID THE $400 FINE AND $100 ADMINISTRATIVE CHARGE TO THE DEPARTMENT ON AUGUST 30, 2016.

Allegations: APPLICANT FAILED TO TIMELY REPORT TO THE OHIO DEPARTMENT OF INSURANCE TWO FINRA ADMINISTRATIVE PENALTIES IMPOSED ON APPLICANT, ONE IN 2010 AND ONE IN 2015. ON NOVEMBER 24, 2004, APPLICANT INACCURATELY MARKED "NO" WHEN ASKED IF IT HAD BEEN INVOLVED IN AN ADMINISTRATIVE ACTION AND IN 2012, 2013 AND 2015 APPLICANT INACCURATELY MARKED "NO" WHEN ASKED IF IT HAD BEEN INVOLVED IN AN ADMINISTRATIVE ACTION THAT HAD NOT BEEN PREVIOUSLY REPORTED TO THE DEPARTMENT. Status: Final Sanction Detail: APPLICANT WAS ORDERED TO PAY A FINE OF $400 AND ADMINISTRATIVE COSTS OF $100. APPLICANT PAID THE FINE AND THE COSTS IN FULL ON AUGUST 29, 2016. Summary: APPLICANT EXECUTED A CONSENT ORDER RELATING TO THE ABOVE DESCRIBED ALLEGATIONS WITH THE DEPARTMENT OF INSURANCE DATED JUNE 6, 2016 AND PAID THE $400 FINE AND THE $100 ADMINISTRATIVE CHARGE TO THE DEPARTMENT ON AUGUST 29, 2016.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND ADEQUATE WRITTEN SUPERVISORY CONTROL PROCEDURES REASONABLY DESIGNED TO REVIEW AND MONITOR THE TRANSMITTALS OF FUNDS FROM CUSTOMER ACCOUNTS TO EMPLOYEES OF THE FIRM. A REGISTERED SALES ASSISTANT CONVERTED FUNDS FROM A TRUST ACCOUNT FOR WHICH HER BOSS WAS THE BENFICIARY, AND WITH WHOM SHE HAD WORKED AT AN INDEPENDENT LOCATION AND HAD WORKED WITH FOR 18 YEARS AT MULTIPLE FIRMS. THE FINDINGS STATED THAT A REGISTERED SALES ASSISTANT AT THE FIRM CONVERTED APPROXIMATELY $147,000 FROM A FIRM CUSTOMER BY USING BLANK, PRE-SIGNED LETTERS OF AUTHORIZATION (LOA) TO REQUEST AND OBTAIN CHECKS PAYABLE TO HERSELF. THE REGISTERED SALES ASSISTANT ALSO REQUESTED FIVE CHECKS PAYABLE TO THE CUSTOMER, CLAIMING THAT SHE WOULD HAND-DELIVER THE CHECKS TO HIM, BUT THEREAFTER FORGED THE ENDORSEMENTS ON THE CHECKS TO HERSELF AND CONVERTED THE FUNDS. THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY CONTROL SYSTEM IN THIS AREA FAILED TO INCLUDE A POLICY OR PROCEDURES REQUIRING A REVIEW TO DETECT OR PREVENT TRANSMITTALS OF FUNDS FROM CUSTOMERS TO EMPLOYEES OF THE FIRM AND THAT THE FIRM FAILED TO ENFORCE ITS OWN WRITTEN SUPERVISORY PROCEDURES (WSPS) RELATED TO HAND-DELIVERY OF CHECKS. FINRA FOUND THAT AS A RESULT OF THE FIRM'S FAILURE TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND ADEQUATE WRITTEN SUPERVISORY CONTROL PROCEDURES THE REGISTERED SALES ASSISTANT WAS ABLE TO CONVERT THE FUNDS AS DESCRIBED ABOVE. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $35,000. Summary: THE BOSS OF KATHERINE PARK, A REGISTERED SALES ASSISTANT AT WILEY BROS.-AINTREE CAPITAL, LLC ("WBAC")WAS THE BENEFICIARY OF THE CUSTOMER ACCOUNT THAT WAS SUBJECT TO THE CONVERSION. MS PARK HAD BEEN EMPLOYED AS A SALES ASSISTANT FOR HER BOSS FOR OVER 18 YEARS AT MULTIPLE FIRMS. SHE AND HER BOSS WERE LOCATED AT AN INDEPENDENT BRANCH OFFICE OF THE FIRM. HER BOSS' FATHER WAS THE TRUSTEE OF THE ACCOUNT. UPON DISCOVERY OF MS. PARK'S THEFT OF FUNDS, WBAC IMMEDIATELY REPORTED MS. PARK AND THE INCIDENT TO FINRA AND THE LOCAL LAW ENFORCEMENT AUTHORITIES; TERMINATED HER EMPLOYMENT WITH THE FIRM; AND HAS REPAID THE CUSTOMER. PURSUANT TO WBAC'S HANDLING OF THE SITUATION, MS. PARK HAS BEEN BARRED FROM ASSOCIATING WITH ANY FINRA FIRM IN ANY CAPACITY AND WAS FOUND GUILTY OF CRIMINAL CHARGES RELATED TO THE THEFT.

Allegations: WILEY BROS.-AINTREE CAPITAL (WBAC) FAILED TO TIMELY REPORT TO THE NORTH CAROLINA DEPARTMENT OF INSURANCE TWO FINRA ADMINISTRATIVE PENALTIES IMPOSED ON WBAC, ONE IN 2010 AND ONE IN 2015. WBAC INACCURATELY MARKED "NO" ON THE NORTH CAROLINA LICENSE RENEWAL APPLICATION FOR THE YEARS 2012 THROUGH 2016 REGARDING WHETHER WBAC HAD BEEN NAMED OR INVOLVED AS A PARTY IN AN ADMINISTRATIVE PROCEEDING REGARDING ANY PROFESSIONAL OR OCCUPATIONAL LICENSE, OR REGISTRATION THAT WAS NOT PREVIOUSLY REPORTED TO THE NORTH CAROLINA DEPARTMENT OF INSURANCE. Status: Final Sanction Detail: WBAC WAS ORDERED TO PAY A CIVIL PENALTY OF $1,250. WBAC PAID THE FINE IN FULL ON JANUARY 13, 2017 (REC'D BY NORTH CAROLINA ON JANUARY 18,2017) Summary: WBAC EXECUTED A VOLUNTARY SETTLEMENT AGREEMENT RELATING TO THE ABOVE DESCRIBED ALLEGATIONS WITH NORTH CAROLINA DEPARTMENT OF INSURANCE DATED JANUARY 23, 2017 AND PAID THE $1,250 CIVIL PENALTY TO THE DEPARTMENT ON JANUARY 13, 2017 (REC'D ON JANUARY 18, 2017.