Raymond James (Usa) Ltd

Allegations: SEC RULE 17A-4 REQUIRES THAT BROKERAGE FIRMS MAINTAIN AND PRESERVE, FOR A PERIOD OF NOT LESS THAN THREE YEARS, ELECTROIC COMMUNICATIONS RELATING TO THE FIRM'S BUSINESS AS A BROKER-DEALER. IN NOTICE TO MEMBERS 01-80 AMD 03-33, NASD COMMUNICATED TO MEMBERS THEIR RECORDKEEPING AND SUPERVISORY OBLIGATIONS WITH RESPECT TO ELECTRONIC COMMUNICATIONS, INCLUDING E-MIAL AND INSTANT MESSAGING. FROM DECEMBER 2003 THROUGH APRIL 2005, RAYMOND JAMES LTD. STORED ELECTRONIC COMMUNICATIONS ON VARIOUS COMPUTER SERVERS. ELECTRONIC COMMUNICATIONS STORED ON CERTAIN OF THOSE SERVERS, HOWEVER, ARE NO LONGER RETRIEVABLE. AS A RESULT, THE FIRM DID NOT MAINTAIN AND PRESERVE ALL ELECTRONIC COMMUNICATIONS AS REQUIRED BY SEC RULE 17A-4. THIS CONDUCT CONSTITUES SEPARATE AND DISTINCT VIOLATIONS OF SEC RULE 17A-4 AND NASD CONDUCT RULES 3110 AND 2110. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $50000.00. FIRM IS AWAITING PAYMENT ARRANGEMENTS OR PAYMENT DETAILS FORM THE NASD FINANCE DEPARTMENT. THE FIRM SIGNED THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT, ON APRIL 27TH, 2006 AND ACCEPTED BY NASD MAY 9TH, 2006. PAYMENT FOR $50,000 US WAS SUBMITTED BY CHEQUE ON MAY 12, 2006.

Allegations: SEC RULE 17A-4 REQUIRES THAT BROKERAGE FIRMS MAINTAIN AND PRESERVE, FOR A PERIOD OF NOT LESS THAN THREE YEARS, ELECTROIC COMMUNICATIONS RELATING TO THE FIRM'S BUSINESS AS A BROKER-DEALER. IN NOTICE TO MEMBERS 01-80 AMD 03-33, NASD COMMUNICATED TO MEMBERS THEIR RECORDKEEPING AND SUPERVISORY OBLIGATIONS WITH RESPECT TO ELECTRONIC COMMUNICATIONS, INCLUDING E-MIAL AND INSTANT MESSAGING. FROM DECEMBER 2003 THROUGH APRIL 2005, RAYMOND JAMES LTD. STORED ELECTRONIC COMMUNICATIONS ON VARIOUS COMPUTER SERVERS. ELECTRONIC COMMUNICATIONS STORED ON CERTAIN OF THOSE SERVERS, HOWEVER, ARE NO LONGER RETRIEVABLE. AS A RESULT, THE FIRM DID NOT MAINTAIN AND PRESERVE ALL ELECTRONIC COMMUNICATIONS AS REQUIRED BY SEC RULE 17A-4. THIS CONDUCT CONSTITUES SEPARATE AND DISTINCT VIOLATIONS OF SEC RULE 17A-4 AND NASD CONDUCT RULES 3110 AND 2110. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $50000.00. FIRM IS AWAITING PAYMENT ARRANGEMENTS OR PAYMENT DETAILS FORM THE NASD FINANCE DEPARTMENT. THE FIRM SIGNED THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT, ON APRIL 27TH, 2006 AND ACCEPTED BY NASD MAY 9TH, 2006. PAYMENT FOR $50,000 US WAS SUBMITTED BY CHEQUE ON MAY 12, 2006. Summary: THE FIRM SIGNED THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT, ON APRIL 27TH, 2006 AND ACCEPTED BY NASD MAY 9TH, 2006. PAYMENT FOR $50,000 US WAS SUBMITTED BY CHEQUE ON MAY 12, 2006.

Allegations: IN THE PERIOD FEBRUARY 2003 TO FEBRUARY 2005, RAYMOND JAMES LTD CONTRAVENED RS INC UNIVERSAL MARKET INTEGRITY RULES ("UMIR") RELATING TO CLIENT PRIORITY, FAILURE TO RECORD CLIENT CONSENTORDER MAKINGAND AUDIT TRAIL ON NUMEROUS OCCASIONS. IN THE PERIOD JULY 2003 TO FEBRUARY 2005, RAYMOND JAMES LTD. FAILED TO COMPLY WITH ITS TRADING SUPERVISION OBLIGATIONS UNDER UMIR 7.1 (1) AND POLICY 7.1 Status: Final Sanction Detail: FINE OF $400,000.00 PAYABLE BY RAYMOND JAMES LTD TO MARKET REGULATION SERVICES INC. ("RS") COSTS OF $125,000.00 PAYABLE TO RS TOTAL FINE AND COSTS $525,000.00 AS INDICATED ABOVE Summary: THE DISPLINARY NOTICE HAS BEEN SETTLED AND NO FURTHER ACTION TAKEN AS STATED ABOVE. TOTAL FINE PLUS COSTS OF $525,000.00