Wesbanco Securities, Inc.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH A REASONABLE SUPERVISORY SYSTEM TO REVIEW ELECTRONIC CORRESPONDENCE. THE FINDINGS STATED THAT THE FIRM FAILED TO CONDUCT A MANUAL REVIEW OF SOME OF ITS EMAIL INVOLVING ITS REGISTERED REPRESENTATIVES. SPECIFICALLY, THE FIRM FAILED TO MANUALLY REVIEW A BATCH OF EMAILS THAT HAD BEEN RANDOMLY SELECTED. ADDITIONALLY, THE FIRM FAILED TO MANUALLY REVIEW THE "KEY WORD" AND "RANDOMLY SELECTED" EMAIL BATCHES FROM THE FIRM'S COMPUTERIZED EMAILS SURVEILLANCE SYSTEM. THE FIRM ALSO FAILED TO CONDUCT A MANUAL REVIEW OF ITS EMAILS INVOLVING ITS CHIEF COMPLIANCE OFFICER (CCO). SPECIFICALLY, THE FIRM FAILED TO MANUALLY REVIEW BOTH THE "KEY WORD" AND "RANDOMLY SELECTED" BATCHES OF EMAILS OF ITS CCO. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO TIMELY REPORT STATISTICAL AND SUMMARY INFORMATION REGARDING WRITTEN CUSTOMER COMPLAINTS. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO HAVE AN ADEQUATE SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES (WSPS) IN PLACE TO ENSURE THAT THE FIRM'S REGISTERED REPRESENTATIVES ACCURATELY DISCLOSED CERTAIN CHARGES RELATING TO VARIABLE ANNUITY EXCHANGES IN THE FIRM'S INVESTMENT EXCHANGE ACKNOWLEDGEMENT FORMS, THE VARIABLE ANNUITY SWITCH FORMS. THE FIRM'S WSPS FAILED TO DESCRIBE HOW THE DESIGNATED SUPERVISING PRINCIPAL WOULD VERIFY THAT CHARGES ASSOCIATED WITH EACH VARIABLE ANNUITY TRANSACTION, AS RECORDED ON THE VARIABLE ANNUITY SWITCH FORMS BY ITS REPRESENTATIVES, WERE ACCURATELY DISCLOSED TO THE CUSTOMER. NOR DID THE FIRM'S WSPS PROVIDE SUPERVISORS WITH ANY GUIDANCE OR TOOLS TO HELP THEM IN DECIDING HOW TO CONDUCT THEIR REVIEWS. AS A RESULT, THE FIRM FAILED TO DETECT THAT ONE OF THE FIRM'S REGISTERED REPRESENTATIVES PREPARED VARIABLE ANNUITY SWITCH FORMS THAT MISSTATED THE FEES ASSOCIATED WITH VARIABLE ANNUITY TRANSACTIONS. VIRTUALLY ALL OF THE FORMS DISCLOSED FEES THAT WERE HIGHER THAN THE ACTUAL AMOUNTS CHARGED. Status: Final Sanction Detail: FINE IN THE AMOUNT OF $45,000