M Holdings Securities, Inc.

Status: Final Sanction Detail: MONETARY FINE Summary: ON JULY 9, 2018, WITHOUT ADMITTING OR DENYING THE FINDINGS, OUR BROKER DEALER CONSENTED TO SANCTIONS EQUAL TO $135,000 AND TO THE ENTRY OF FINDINGS FROM DECEMBER 2013 TO JUNE 2017, THAT SPECIFIED IT DID NOT ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO SUPERVISE REGISTERED REPRESENTATIVES' USE OF CONSOLIDATED REPORTS. THE FINDINGS STATED THAT DURING THIS PERIOD, ASSOCIATED PERSONS OF M SECURITIES CREATED AND DISSEMINATED CONSOLIDATED REPORTS TO CUSTOMERS, YET IT HAD NO PROCEDURES DIRECTLY ADDRESSING THE SUPERVISION OF CONSOLIDATED REPORTS. IN RESPONSE, WE CREATED PROCEDURES ADDRESSING THE USE AND DISSEMINATION OF CONSOLIDATED REPORTS BY OUR REPRESENTATIVES.

Allegations: ALLEGATIONS THAT RESPONDENT MADE AN UNSUITABLE LIFE INSURANCE SALE TO MINNESOTA CONSUMER AND PROVIDED INACCURATE INFORMATION ABOUT THE POLICY'S FUNDING TO THE ISSUING INSURANCE CARRIER. Status: Final Sanction Detail: RESTITUION OF $10,000, CIVIL PENALTY OF $4,000, MONETARY PENALTY OF $225. ALL PAID 1/13/2020. Summary: IN ORDER TO AVOID THE TIME AND EXPENSE OF LITIGATION, REPRESENTATIVE CONSENTED WITH THE INSURANCE COMMISSIONER TO INFORMAL DISPOSITION FOLLOWING A CLIENT'S ALLEGATION REGARDING THE SALE OF A LIFE INSURANCE PRODUCT.

Allegations: ON MARCH 11, 2019, THE SECURITIES AND EXCHANGE COMMISSION (SEC) PUBLISHED IA RELEASE NO. 5193, AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE AND DESIST PROCEEDINGS, PURSUANT TO SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT), AGAINST M HOLDINGS SECURITIES, INC. (RESPONDENT). RESPONDENT SELF-REPORTED THE VIOLATIONS TO THE SEC. THE PROCEEDINGS ARISE OUT OF BREACHES OF FIDUCIARY DUTY AND INADEQUATE DISCLOSURES BY RESPONDENT IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE 12B-1 FEES IT AND/OR ITS ASSOCIATED PERSONS RECEIVED. AT TIMES DURING THE RELEVANT PERIOD, RESPONDENT PURCHASED FOR, RECOMMENDED TO, OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. RESPONDENT FAILED TO DISCLOSE IN ITS FORM ADV OR OTHERWISE CONFLICTS OF INTEREST RELATED TO THE COLLECTION OF SUCH FEES. AS A RESULT OF THE CONDUCT, RESPONDENT WILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. Status: Final Sanction Detail: RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT PLUS INTEREST OF $1,022,048.49 AND SHALL COMPLY WITH THE UNDERTAKINGS DESCRIBED IN THE OFFER OF SETTLEMENT. Summary: WITHIN 30 DAYS OF THE ORDER'S ISSUANCE, M SECURITIES IS REQUIRED TO: DEPOSIT THE MONEY IN AN ESCROW ACCOUNT, UPDATE ITS DISCLOSURES, UPDATE ITS POLICIES AND PROCEDURES, CONVERT ELIGIBLE FUNDS TO A LOWER-COST SHARE CLASS AND PROVIDE AFFECTED CLIENTS WITH NOTIFICATION.