Axiom Investment Management Llc

Allegations: FROM 7/1/03-9/30/04, AXIOM CAPITAL MANAGEMENT, INC. TRANSMITTED TO OATS REPORTS THAT CONTAINED INNACCURATE, INCOMPLETE OR IMPROPERLY FROMATTED DATE IN THAT IT REPORTED TO OATS ROUTE OR COMBINED ORDER/ROUTE REPORTS THAT THE OATS SYSTEM WAS UNABLE TO LINK TO THE RELATED ORDER IN SUPERMONTAGE OR SELECTNET Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AXIOM CONSENTED TO A FINE OF $6000 AND A CENSURE. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AXIOM CONSENTED TO A FINE OF $6000 AND A CENSURE.

Allegations: FROM 1/1/05-1/4/06, AXIOM FAILED TO DESIGNATE A CROP WHILE ENGAGING IN OPTIONS TRADING, WHO HAD NO SALES FUNCTIONS. FROM 2/6/04-9/2/05 AXIOM FAILED TO MAINTAIN MUNICIPAL SECURITIES ORDER MEMORANDA CONTAINING THE REQUIRED TIME STAMPS AND IN 25 MUNICIPAL ORDER TICKETS AXIOM FAILED TO RECORD THE TIME OF EXECUTION IN 6 INSTANCES AND FAILED TO ACCURATELY RECORD THE TIMES OF ORDER RECEIPT AND ORDER ENTRY IN 1 ADDITIONAL INSTANCE. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, AXIOM CAPITAL MANAGEMENT CONSENTED TO THE DESCRIED SANCTIONS AND TO THE ENTRY OF THE FINDINGS. THEREFORE AXIOM CAPITAL MANAGEMENT WAS FINED $10,000 AND CENSURED. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, AXIOM CAPITAL MANAGEMENT CONSENTED TO THE DESCRIED SANCTIONS AND TO THE ENTRY OF THE FINDINGS. THEREFORE AXIOM CAPITAL MANAGEMENT WAS FINED $10,000 AND CENSURED.

Allegations: NOVEMBER 20, 2000 THROUGH NOVEMBER 28, 2000 60 ORDERS FAILED TO RECORD THE ACCURATE ORDER EXECUTION TIMES. NOVEMBER 20, 2000 THROUGH NOVEMBER 27, 2000 THE FIRM FAILED TO PROPERLY REPORT 11 SHORT SALES THROUGH THE AUTOMATED TRANSACTION SERVICE BY LEAVING OFF THE SHORT SALE MODIFER. Status: Final Sanction Detail: FIRM CENSURED AND FINED $6000.00. Summary: THE FIRM HAD CONTACTED THE VENDOR OF THEIR TIME CLOCKS AND A SERVICE PREPRESENATTIVE WAS NOT SENT TO THE FIRM FOR THREE WEEKS.

Allegations: DISCLOSURE OF COMMISSIONS AND TIME STAMPING TRANSACTIONS Status: Final Sanction Detail: NONE Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AXIOM CONSENTED TO A FINE OF $15,000.00 AND CENSURE.

Allegations: EMPLOYMENT AS A CONSULTANT AND SECRETARY OF AN INDIVIDUAL SUBJECT TO A STATUTORY DISQUALIFICATION. NO ACTUAL OR ALLEGED DAMAMGES OR CLAIMS. Status: Final Sanction Detail: FIRM CENSURED AND FINED $7500.00. Summary: THE FIRM AND MR. DALTON WERE ADVISED BY LEGAL COUNSEL THAT ALTHOUGH THE INDIVIDUAL WAS SUBJECT TO AN INJUNCTION, AN APPEAL WAS PENDING AND THERE WAS NOT YET A "STATUTORY DISQUALIFICATION." AS SOON AS THE APPEAL WAS DECIDED THE FIRM TERMINATED THE INDIVIDUAL. THE NASD FOUND THAT THE FIRM AND THE CONTROL AFFILIATE HAD RELIED ON THIS INACCURATE ADVICE, THAT THEY HAD NO RELEVANT DISCIPLINARY HISTORY AND THAT THE INDIVIDUAL'S ACTIVITIES FOR THE FIRM WERE LIMITED AND HE DID NOT TRANSACT BUSINESS WITH PUBLIC CUSTOMERS. CONTROL AFFILIATE SHOULD NOT BE LISTED ON THIS FORM BD AS NOT REPORTABLE ON FORM U4.

Allegations: ALLEGATIONS OF VIOLATIONS: CONNECTICUT UNIFORM SECURITIES ACT SECTION 36(B), UNREGISTERED AGENT OFFERED UNREGISTERED SECURITY, FAILURE TO APPEAR OR PRODUCE DOCUMENTS THROUGH COUNSEL. DURING 01-09 TO 09-15 SUSUPENSION FIRM FAILED TO IMPLEMENT PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH ORDER. Status: Final Sanction Detail: FIRM CONSENTED TO AN ORDER TO PAY $35,000 COSTS, IE FUND CONTRIBUTION AND ADW FINE, HAVE A CONSULTANT REVIEW/REPORT ON COMPLIANCE PROCEDURES; A SUSPENSION FROM SOLICITING/OPENING NEW ACCOUNTS; THE FIRM MAY EXECUTE UNSOLICITED TRANSACTIONS WITH EXISTING CT CUSTOMERS, SUCH COMMISSIONS CONTRIBUTED TO IE FUND. Summary: AGENT REGISTERED IN NY CONTACTED CUSTOMERS WHO WORKED IN NY. FIRM'S COUNSEL FAILED TO RESPOND TO REQUEST FOR INFORMATION IN A TIMELY MANNER.

Allegations: IT IS ALLEGED THAT AXIOM CAPITAL MANAGEMENT FAILED TO REASONABLY TO SUPERVISE A FORMERLY ASSOCIATED REGISTERED REPRESENTATIVE, IN CONNECTION WITH HIS SALE OF PRIVATE PLACEMENT OFFERINGS AND PRIVATE ISSUANCES OF PUBLIC ENTITIES FROM APPROXIMATELY JANUARY 2005 THROUGH AT LEAST SEPTEMBER 2006. THE REPRESENTATIVE IS ALLEGED TO HAVE VIOLATED SECTION 17(A) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT") AND SECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER BY, MAKING UNSUITABLE INVESTMENT RECOMMENDATIONS. IT IS ALSO ALLEGED THAT AXIOM FAILED REASONABLY TO SUPERVISE HIM BECAUSE IT FAILED TO DEVISE A REASONABLE SYSTEM TO IMPLEMENT THE FIRM'S POLICIES AND PROCEDURES REGARDING REVIEW FOR SUITABILITY OF PRIVATE PLACEMENT INVESTMENTS AND REVIEW OF SUBSEQUENT TRANSACTIONS TO DETERMINE SUITABILITY OF THE TRANSACTION IN LIGHT OF THE CUSTOMER'S CURRENT HOLDINGS. AS A RESULT, IT IS ALLEGED THAT AXIOM FAILED REASONABLY TO SUPERVISE HIM WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT. Status: Final Sanction Detail: AXIOM HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. WITHOUT ADMITTING OR DENYING THE FINDINGS, AXIOM CONSENTS TO THE ENTRY OF THE ORDER. THE ORDER STATES THAT AXIOM IS CENSURED AND SHALL PAY CIVIL PENALTIES OF $60,000 TO THE UNITED STATES TREASURY. AXIOM ALSO AGREED TO AN UNDERTAKING TO RETAIN THE SERVICES OF AN INDEPENDENT CONSULTANT (IC) TO REVIEW AXIOM'S WRITTEN SUPERVISORY POLICIES AND PROCEDURES CONCERNING SUITABILITY REVIEW OF PRIVATE PLACEMENTS; AND REVIEW AXIOM'S SYSTEMS TO IMPLEMENT ITS WRITTEN SUPERVISORY POLICIES AND PROCEDURES CONCERNING SUITABILITY REVIEW OF PRIVATE PLACEMENTS AND SUITABILITY REVIEWS SUBSEQUENT TO THE PURCHASE OF A PRIVATE PLACEMENT; AND REQUIRE THE IC, AT THE CONCLUSION OF THE REVIEW TO SUBMIT A REPORT TO AXIOM AND THE DIVISION. Summary: AXIOM HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. WITHOUT ADMITTING OR DENYING THE FINDINGS, AXIOM CONSENTS TO THE ENTRY OF THE ORDER. THE ORDER STATES THAT AXIOM IS CENSURED AND SHALL PAY CIVIL PENALTIES OF $60,000 TO THE UNITED STATES TREASURY. AXIOM ALSO AGREED TO AN UNDERTAKING TO RETAIN THE SERVICES OF AN INDEPENDENT CONSULTANT (IC) TO REVIEW AXIOM'S WRITTEN SUPERVISORY POLICIES AND PROCEDURES CONCERNING SUITABILITY REVIEW OF PRIVATE PLACEMENTS; AND REVIEW AXIOM'S SYSTEMS TO IMPLEMENT ITS WRITTEN SUPERVISORY POLICIES AND PROCEDURES CONCERNING SUITABILITY REVIEW OF PRIVATE PLACEMENTS AND SUITABILITY REVIEWS SUBSEQUENT TO THE PURCHASE OF A PRIVATE PLACEMENT; AND REQUIRE THE IC, AT THE CONCLUSION OF THE REVIEW TO SUBMIT A REPORT TO AXIOM AND THE DIVISION.