Colliers Securities Llc

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM DID NOT ADEQUATELY SUPERVISE A REGISTERED REPRESENTATIVE WHO (A) PLACED TRADES FOR TWO CUSTOMERS WITHOUT FIRST CONTACTING THEM, AND (B) MADE UNSUITABLE RECOMMENDATIONS. Status: Final Sanction Detail: FIRM WAS CENSURED, FINED $140,000, AND REQUIRED TO PAY $78,910 IN RESTITUTION TO A CUSTOMER. FINE WAS PAID ON 12/09/2016; RESTITUTION WAS SENT TO CUSTOMER ON 10/20/2016.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO MAKE TIMELY SUBMISSIONS OR TO SUBMIT ACCURATE INFORMATION REGARDING THE RESULT OF AN INTEREST RATE RESET FOR VARIABLE RATE DEMAND OBLIGATIONS (VRDOS) TO THE MUNICIPAL SECURITIES RULEMAKING BOARD'S (MSRB) SHORT-TERM OBLIGATION RATE TRANSPARENCY (SHORT) SYSTEM. THE FINDINGS STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES (WSPS), REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE FIRM'S OBLIGATION TO MAKE ACCURATE AND TIMELY SUBMISSIONS TO THE SHORT SYSTEM. Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED $25,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES (WSPS) WITH RESPECT TO THE AREAS RELATING TO THE DEFICIENCIES IN THE AWC. THE FINE WAS PAID IN FULL ON OCTOBER 23, 2019.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT PROVIDED UNDERWRITING SERVICES FOR ISSUERS WITH WHICH IT HAD ACTIVE "BLANKET" FINANCIAL ADVISORY AGREEMENTS. THE FINDINGS STATED THAT THE BLANKET AGREEMENTS WERE NOT LIMITED BY TIME OR SPECIFIC ISSUANCES OF BONDS. RATHER, THE AGREEMENTS OUTLINED THE FIRM'S RESPONDSIBILITIES AS FINANCIAL ADVISOR FOR ALL "PROJECTS THAT REQUIRE THE ISSUANCE OF OBLIGATIONS." THE FIRM'S RESPONSIBILITIES TO THE ISSUERS INCLUDED RECOMMENDING THE TYPE OR TYPES OF BONDS TO BE UTILIZED, ASSISTING IN DETERMING THE AMOUNT OF FINANCING REQUIRED AND RECOMMENDING FINANCING OR REFINANCING PROGRAMS TO FIT THE ISSUERS' RESOURCES AND REQUIREMENTS. IN EXCHANGE FOR FINANCIAL ADVISORY SERVICES, THE FIRM WOULD HAVE RECEIVED A FEE FOR EACH SPECIFIC BOND ISSUE. DESPITE THSE BLANKET FINANCIAL ADVISORY AGREEMENTS, THE FIRM PROVIDED MUNICIPAL UNDERWRITING SERVICES TO THE MUNICIPAL ISSUERS WITH WHICH IT HAD BLANKET FINANCIAL ADVISORY AGREEMENTS. THE FIRM WAS COMPENSATED ONLY AS AN UNDERWRITER FOR THOSE ISSUANCES. Status: Final Sanction Detail: FIRM WAS CENSURED AND FINED $50000.00

Allegations: SEC ADMIN RELEASES 33-9822; 34-75216/JUNE 18, 2015: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE AND DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST DOUGHERTY & COMPANY LLC ("RESPONDENT"). RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVES VIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITING OF CERTAIN MUNICIPAL SECURITIES OFFERINGS. RESPONDENT, A REGISTERED BROKER-DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAIN OFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIAL REPESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENT OFFERING AND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLY MISLEADING DISCLOSURE DOCUMENTS. THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THE COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S ("THE DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION (MCDC) INITIATIVE. Status: Final Sanction Detail: RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $250,000.00 AND WILL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. THE CIVIL MONEY PENALTY WAS PAID BY DOUGHERTY & COMPANY LLC ON JUNE 25, 2015. Summary: IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, RESPONDENT CONSENTS TO THE ENTRY OF THS ORDER INSTITUTING ADMINISTRATIVE AND CEASE AND DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE AND DESIST ORDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN RESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THAT RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2) OF THE SECURITIES ACT, WITHIN TEN (10) DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $250,000.00 TO THE SECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES AND PROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE.