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BrokerCheck Report JAMES EDWARD BASHAW Section Title Report Summary Broker Qualifications Registration and Employment History Disclosure Events CRD# 1251491 1 2 - 4 6 - 8 9 Page(s)

JAMES EDWARD BASHAWia 09/2014 - 10/2014 wunderlich securities, inc. 2543 houston, tx ia 11/2001 - 10/2014 lpl financial llc 6413 houston, tx b 11/2001 - 10/2014 lpl financial llc 6413

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Page 1: JAMES EDWARD BASHAWia 09/2014 - 10/2014 wunderlich securities, inc. 2543 houston, tx ia 11/2001 - 10/2014 lpl financial llc 6413 houston, tx b 11/2001 - 10/2014 lpl financial llc 6413

BrokerCheck Report

JAMES EDWARD BASHAW

Section Title

Report Summary

Broker Qualifications

Registration and Employment History

Disclosure Events

CRD# 1251491

1

2 - 4

6 - 8

9

Page(s)

Page 2: JAMES EDWARD BASHAWia 09/2014 - 10/2014 wunderlich securities, inc. 2543 houston, tx ia 11/2001 - 10/2014 lpl financial llc 6413 houston, tx b 11/2001 - 10/2014 lpl financial llc 6413

About BrokerCheck®

BrokerCheck offers information on all current, and many former, registered securities brokers, and all current and formerregistered securities firms. FINRA strongly encourages investors to use BrokerCheck to check the background ofsecurities brokers and brokerage firms before deciding to conduct, or continue to conduct, business with them.

· What is included in a BrokerCheck report?· BrokerCheck reports for individual brokers include information such as employment history, professional

qualifications, disciplinary actions, criminal convictions, civil judgments and arbitration awards. BrokerCheckreports for brokerage firms include information on a firm’s profile, history, and operations, as well as many of thesame disclosure events mentioned above.

· Please note that the information contained in a BrokerCheck report may include pending actions orallegations that may be contested, unresolved or unproven. In the end, these actions or allegations may beresolved in favor of the broker or brokerage firm, or concluded through a negotiated settlement with no admissionor finding of wrongdoing.

· Where did this information come from?· The information contained in BrokerCheck comes from FINRA’s Central Registration Depository, or

CRD® and is a combination of: o information FINRA and/or the Securities and Exchange Commission (SEC) require brokers and

brokerage firms to submit as part of the registration and licensing process, and o information that regulators report regarding disciplinary actions or allegations against firms or brokers.

· How current is this information?· Generally, active brokerage firms and brokers are required to update their professional and disciplinary

information in CRD within 30 days. Under most circumstances, information reported by brokerage firms, brokersand regulators is available in BrokerCheck the next business day.

· What if I want to check the background of an investment adviser firm or investment adviserrepresentative?

· To check the background of an investment adviser firm or representative, you can search for the firm orindividual in BrokerCheck. If your search is successful, click on the link provided to view the available licensingand registration information in the SEC's Investment Adviser Public Disclosure (IAPD) website athttps://www.adviserinfo.sec.gov. In the alternative, you may search the IAPD website directly or contact your statesecurities regulator at http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/P455414.

· Are there other resources I can use to check the background of investment professionals?· FINRA recommends that you learn as much as possible about an investment professional before deciding

to work with them. Your state securities regulator can help you research brokers and investment adviserrepresentatives doing business in your state.

·Thank you for using FINRA BrokerCheck.

For more information aboutFINRA, visit www.finra.org.

Using this site/information meansthat you accept the FINRABrokerCheck Terms andConditions. A complete list ofTerms and Conditions can befound at

For additional information aboutthe contents of this report, pleaserefer to the User Guidance orwww.finra.org/brokercheck. Itprovides a glossary of terms and alist of frequently asked questions,as well as additional resources.

brokercheck.finra.org

Page 3: JAMES EDWARD BASHAWia 09/2014 - 10/2014 wunderlich securities, inc. 2543 houston, tx ia 11/2001 - 10/2014 lpl financial llc 6413 houston, tx b 11/2001 - 10/2014 lpl financial llc 6413

JAMES E. BASHAW

CRD# 1251491

Currently employed by and registered with thefollowing Firm(s):

INTERNATIONAL ASSETS INVESTMENTMANAGEMENT, LLC5701 WOODWAY DRIVESUITE 330HOUSTON, TX 77057CRD# 144426Registered with this firm since:

IA

INTERNATIONAL ASSETS ADVISORY,LLC5701 WOODWAY DRIVESUITE 330HOUSTON, TX 77057CRD# 10645Registered with this firm since: 10/29/2014

B

Report Summary for this Broker

This report summary provides an overview of the broker's professional background and conduct. Additionalinformation can be found in the detailed report.

Disclosure Events

All individuals registered to sell securities or provideinvestment advice are required to disclose customercomplaints and arbitrations, regulatory actions,employment terminations, bankruptcy filings, andcriminal or civil judicial proceedings.

Are there events disclosed about this broker? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 1

Customer Dispute 3

Termination 1

Financial 1

Judgment/Lien 1

Broker Qualifications

This broker is registered with:

1 Self-Regulatory Organization

4 U.S. states and territories

This broker has passed:

2 Principal/Supervisory Exams

4 General Industry/Product Exams

2 State Securities Law Exams

Registration History

This broker was previously registered with thefollowing securities firm(s):

INTERNATIONAL ASSETS INVESTMENTMANAGEMENT, LLCCRD# 144426ORLANDO, FL04/2015 - 12/2015

IA

WUNDERLICH SECURITIES, INC.CRD# 2543HOUSTON, TX09/2014 - 10/2014

B

WUNDERLICH SECURITIES, INC.CRD# 2543MEMPHIS, TN09/2014 - 10/2014

IA

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1�2020 FINRA. All rights reserved. Report about JAMES E. BASHAW.

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Broker Qualifications

Registrations

This section provides the self-regulatory organizations (SROs) and U.S. states/territories the broker is currently registered and licensed with, thecategory of each license, and the date on which it became effective. This section also provides, for every brokerage firm with which the broker iscurrently employed, the address of each branch where the broker works.

This individual is currently registered with 1 SRO and is licensed in 4 U.S. states and territories through his or her employer.

Employment 1 of 2Firm Name:

Main Office Address:

Firm CRD#:

INTERNATIONAL ASSETS ADVISORY, LLC

10645

390 NORTH ORANGE AVENUESTE 750ORLANDO, FL 32801

SRO Category Status Date

B FINRA General Securities Representative APPROVED 10/29/2014

B FINRA General Securities Sales Supervisor APPROVED 10/29/2014

B FINRA Municipal Securities Principal APPROVED 10/29/2014

B FINRA Municipal Securities Representative APPROVED 10/29/2014

BU.S. State/ Territory Category Status Date

B Georgia Agent APPROVED 06/30/2015

B Maryland Agent APPROVED 10/29/2014

B Pennsylvania Agent APPROVED 04/03/2015

B Texas Agent APPROVED 04/01/2015

Branch Office Locations

INTERNATIONAL ASSETS ADVISORY, LLC5701 WOODWAY DRIVESUITE 330HOUSTON, TX 77057

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Broker Qualifications

Employment 2 of 2Firm Name:

Main Office Address:

Firm CRD#:

INTERNATIONAL ASSETS INVESTMENT MANAGEMENT, LLC

144426

390 NORTH ORANGE AVENUESUITE 750ORLANDO, FL 32801

BU.S. State/ Territory Category Status Date

IA Texas Investment Adviser Representative APPROVED 01/07/2016

Branch Office Locations

This individual does not have any registered Branch Office where the individual is located.

3�2020 FINRA. All rights reserved. Report about JAMES E. BASHAW.

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Broker Qualifications

Industry Exams this Broker has Passed

This individual has passed 2 principal/supervisory exams, 4 general industry/product exams, and 2 state securities law exams.

This section includes all securities industry exams that the broker has passed. Under limited circumstances, a broker may attain a registrationafter receiving an exam waiver based on exams the broker has passed and/or qualifying work experience. Any exam waivers that the broker hasreceived are not included below.

Exam Category Date

Principal/Supervisory Exams

Municipal Securities Principal Examination 03/13/2006Series 53B

General Securities Sales Supervisor Examination (Options Module &General Module)

05/30/1997Series 8B

Exam Category Date

General Industry/Product Exams

General Securities Representative Examination 10/02/2019Series 7TOB

Securities Industry Essentials Examination 10/01/2018SIEB

National Commodity Futures Examination 02/07/2001Series 3B

General Securities Representative Examination 06/16/1984Series 7B

Exam Category Date

State Securities Law Exams

Uniform Investment Adviser Law Examination 05/12/1997Series 65IA

Uniform Securities Agent State Law Examination 06/26/1984Series 63B

Additional information about the above exams or other exams FINRA administers to brokers and other securities professionals can be found atwww.finra.org/brokerqualifications/registeredrep/.

4�2020 FINRA. All rights reserved. Report about JAMES E. BASHAW.

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Broker Qualifications

Professional Designations

This section details that the representative has reported 0 professional designation(s).

No information reported.

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Registration and Employment History

Registration History

Registration Dates Firm Name CRD# Branch Location

The broker previously was registered with the following firms:

IA 04/2015 - 12/2015 INTERNATIONAL ASSETS INVESTMENTMANAGEMENT, LLC

144426 HOUSTON, TX

B 09/2014 - 10/2014 WUNDERLICH SECURITIES, INC. 2543 HOUSTON, TX

IA 09/2014 - 10/2014 WUNDERLICH SECURITIES, INC. 2543 HOUSTON, TX

IA 11/2001 - 10/2014 LPL FINANCIAL LLC 6413 HOUSTON, TX

B 11/2001 - 10/2014 LPL FINANCIAL LLC 6413 HOUSTON, TX

IA 06/2005 - 07/2013 JAMES E.BASHAW & CO. 129320 HOUSTON, TX

B 08/2000 - 11/2001 UBS PAINEWEBBER INC. 8174 WEEHAWKEN, NJ

B 04/1998 - 08/2000 J.C. BRADFORD & CO. 1287 NEW YORK, NY

B 04/1994 - 04/1998 SUNTRUST EQUITABLE SECURITIES 6271 ATLANTA, GA

B 08/1991 - 04/1994 AUGUSTA SECURITIES CORP. 23669 HOUSTON, TX

B 03/1990 - 09/1991 FIRST AMERICA EQUITIES CORP. 7652

B 01/1991 - 07/1991 THOMAS F. WHITE & CO., INCORPORATED 7661 SAN FRANCISCO, CA

B 10/1986 - 06/1988 KIDDER, PEABODY & CO. INCORPORATED 7613

B 06/1984 - 10/1986 MERRILL LYNCH, PIERCE, FENNER &SMITH INCORPORATED

7691

Employment History

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Registration and Employment History

Employment History, continued

Employment Employer Name Investment RelatedPosition Employer Location

This section provides up to 10 years of an individual broker's employment history as reported by the individual broker on the most recently filedForm U4.

Please note that the broker is required to provide this information only while registered with FINRA or a national securities exchangeand the information is not updated via Form U4 after the broker ceases to be registered. Therefore, an employment end date of"Present" may not reflect the broker's current employment status.

10/2014 - Present INTERNATIONAL ASSETS ADVISORY REGISTERED REP Y ORLANDO, FL, UnitedStates

10/2014 - Present INTERNATIONAL ASSETS INVESTMENTMANAGEMENT, LLC

INVESTMENTADVISORREPRESENTATIVE

Y HOUSTON, TX, UnitedStates

09/2014 - 10/2014 WUNDELRICH SECURITIES, INC. FINANCIAL ADVISOR Y MEMPHIS, TN, United States

11/2001 - 09/2014 LPL FINANCIAL, LLC REGISTEREDREPRESENTATIVE

Y HOUSTON, TX, UnitedStates

07/2006 - 07/2013 JAMES E. BASHAW & CO. IAR Y HOUSTON, TX, UnitedStates

Other Business Activities

This section includes information, if any, as provided by the broker regarding other business activities the broker is currently engaged in either asa proprietor, partner, officer, director, employee, trustee, agent or otherwise. This section does not include non-investment related activity that isexclusively charitable, civic, religious or fraternal and is recognized as tax exempt.

1) JAMES E BASHAW & CO - 5200 SAN FELIPE, HOUSTON, TX 77056 - DBA FOR IAA BUSINESS - CEO SINCE 11/2001 - APPROX 160HRS/MO - COMMISSIONS2) JEB & CO. 5200 SAN FELIPE, HOUSTON, TX 77056 - DBA FOR IAA BUSINESS - CEO SINCE 7/2017 - APPROX 160 HRS/MO -COMMISSIONS3) INTERNATIONAL ASSETS INVESTMENT MANAGEMENT 390 N ORANGE AVE STE 750 ORLANDO, FL 32801 - RIA AFFILIATE OFINTERNATIONAL ASSETS ADVISORS - ADVISOR SINCE 10/2014 - APPROX 80 HRS/MO - COMPENSATED FROM FEES4) CATHOLIC ENDOWMENT FOUNDTION GALVESTON-HOUSTON 1700 SAN JACINTO, HOUSTON, TX 77002 - DIRECTOR OFINVESTMENT COMMITTEE - ADVISE PRO BONO FOR THE CEFGH SINCE 1999 - APPROX 2 HRS/MO - NO COMPENSATION5) JAMES E BASHAW & CO. 5200 SAN FELIPE, HOUSTON, TX 77056 - SELL EXCESS WATER TREATMENT CAPACITY FORDEVELOPMENT IN HORTON TO DEVELOPERS - 100% OWNER SINCE 10/2016 - APPROX 2 HRS/MO - FEE FOR SELLING PERMITTING6) DON ALEX HANNA II, TRUSTEE OF THE DON ALEX HANNA GST EXEMPT TRUST 70 EAST BROAD OAKS LANE HORTON, TX 77050 -NON INVESTMENT RELATED - OWNER OF WASTEWATER CAPACITY - SELLER OF WASTEWATER CAPACITY SINCE 10/2016 - APPROX 2HRS/MO - COMMISSION BASED COMPENSATION7) BSK LEASE MANAGEMENT US HIGHWAY 77 WEST, DEFUGIO, TX 78377 - MANAGER OF HUNTING LEASE SINCE 8/2018 - APPROX 5HRS/MO - NO COMPENSATION8) ESTATE OF BROTHER-IN-LAW 5214 PINEFOREST, HOUSTON, TX 77056 - SUCCESSOR EXECUTOR SINCE 4/15/19 - APPROX 2HRS/MO - NO COMPENSATION9) BSG&L FINANCIAL SERVICES, LLC 1900 WEST 2000 SOUTH, SUITE 1150, HOUSTON, TX 77027 - RIA - VICE PRESIDENT - CLIENTSERVICES/50% OWNER SINCE 11/2019 - APPROX 40 HRS/MO - FEE BASED COMPENSATION 10) CONSULTANT 504 ASBURY,HOUSTON, TX 77007 - INTRODUCE COMMERCE BANK TO FORTUNE 1000 COMPANIES FOR AP SOLUTIONS - CONSULTANT SINCE1/2020 - APPROX 4 HRS/MO - FEE/MEETING11) HOUSTON LIVESTOCK AUCTION COMMITTEE 504 ASBURY, HOUSTON, TX 77007 - NOT FOR PROFIT SERVING CHILDREN - STEERSALES/COMMITTEEMAN SINCE 1/2020 - APPROX 4 HRS/MO - NO COMPENSATION12) TRUMP FOR PRESIDENT P.O. BOX 340069 - POLITICAL CAMPAIGN - VOLUNTEER SINCE 2/2020 - APPROX 2 HRS/MO - NOCOMPENSATION13) CATHOLIC CHARITIES 2900 LOUISIANA STREET, HOUSTON, TX 77006 - ADVISORY DIRECTOR/VOLUNTEER SINCE 1/2008 - APPROX1 HR/MO - NO COMPENSATION

7�2020 FINRA. All rights reserved. Report about JAMES E. BASHAW.

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Registration and Employment History

Other Business Activities, continued

1) JAMES E BASHAW & CO - 5200 SAN FELIPE, HOUSTON, TX 77056 - DBA FOR IAA BUSINESS - CEO SINCE 11/2001 - APPROX 160HRS/MO - COMMISSIONS2) JEB & CO. 5200 SAN FELIPE, HOUSTON, TX 77056 - DBA FOR IAA BUSINESS - CEO SINCE 7/2017 - APPROX 160 HRS/MO -COMMISSIONS3) INTERNATIONAL ASSETS INVESTMENT MANAGEMENT 390 N ORANGE AVE STE 750 ORLANDO, FL 32801 - RIA AFFILIATE OFINTERNATIONAL ASSETS ADVISORS - ADVISOR SINCE 10/2014 - APPROX 80 HRS/MO - COMPENSATED FROM FEES4) CATHOLIC ENDOWMENT FOUNDTION GALVESTON-HOUSTON 1700 SAN JACINTO, HOUSTON, TX 77002 - DIRECTOR OFINVESTMENT COMMITTEE - ADVISE PRO BONO FOR THE CEFGH SINCE 1999 - APPROX 2 HRS/MO - NO COMPENSATION5) JAMES E BASHAW & CO. 5200 SAN FELIPE, HOUSTON, TX 77056 - SELL EXCESS WATER TREATMENT CAPACITY FORDEVELOPMENT IN HORTON TO DEVELOPERS - 100% OWNER SINCE 10/2016 - APPROX 2 HRS/MO - FEE FOR SELLING PERMITTING6) DON ALEX HANNA II, TRUSTEE OF THE DON ALEX HANNA GST EXEMPT TRUST 70 EAST BROAD OAKS LANE HORTON, TX 77050 -NON INVESTMENT RELATED - OWNER OF WASTEWATER CAPACITY - SELLER OF WASTEWATER CAPACITY SINCE 10/2016 - APPROX 2HRS/MO - COMMISSION BASED COMPENSATION7) BSK LEASE MANAGEMENT US HIGHWAY 77 WEST, DEFUGIO, TX 78377 - MANAGER OF HUNTING LEASE SINCE 8/2018 - APPROX 5HRS/MO - NO COMPENSATION8) ESTATE OF BROTHER-IN-LAW 5214 PINEFOREST, HOUSTON, TX 77056 - SUCCESSOR EXECUTOR SINCE 4/15/19 - APPROX 2HRS/MO - NO COMPENSATION9) BSG&L FINANCIAL SERVICES, LLC 1900 WEST 2000 SOUTH, SUITE 1150, HOUSTON, TX 77027 - RIA - VICE PRESIDENT - CLIENTSERVICES/50% OWNER SINCE 11/2019 - APPROX 40 HRS/MO - FEE BASED COMPENSATION 10) CONSULTANT 504 ASBURY,HOUSTON, TX 77007 - INTRODUCE COMMERCE BANK TO FORTUNE 1000 COMPANIES FOR AP SOLUTIONS - CONSULTANT SINCE1/2020 - APPROX 4 HRS/MO - FEE/MEETING11) HOUSTON LIVESTOCK AUCTION COMMITTEE 504 ASBURY, HOUSTON, TX 77007 - NOT FOR PROFIT SERVING CHILDREN - STEERSALES/COMMITTEEMAN SINCE 1/2020 - APPROX 4 HRS/MO - NO COMPENSATION12) TRUMP FOR PRESIDENT P.O. BOX 340069 - POLITICAL CAMPAIGN - VOLUNTEER SINCE 2/2020 - APPROX 2 HRS/MO - NOCOMPENSATION13) CATHOLIC CHARITIES 2900 LOUISIANA STREET, HOUSTON, TX 77006 - ADVISORY DIRECTOR/VOLUNTEER SINCE 1/2008 - APPROX1 HR/MO - NO COMPENSATION

8�2020 FINRA. All rights reserved. Report about JAMES E. BASHAW.

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Disclosure Events

What you should know about reported disclosure events:

1. All individuals registered to sell securities or provide investment advice are required to disclose customer complaints and arbitrations,regulatory actions, employment terminations, bankruptcy filings, and criminal or civil judicial proceedings.

2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a broker is required to disclose a particular criminal event. o A customer dispute must involve allegations that a broker engaged in activity that violates certain rules or conduct governing the

industry and that the activity resulted in damages of at least $5,000. o

3. Disclosure events in BrokerCheck reports come from different sources: o As mentioned at the beginning of this report, information contained in BrokerCheck comes from brokers, brokerage firms and

regulators. When more than one of these sources reports information for the same disclosure event, all versions of the event willappear in the BrokerCheck report. The different versions will be separated by a solid line with the reporting source labeled.

o4. There are different statuses and dispositions for disclosure events:

o A disclosure event may have a status of pending, on appeal, or final.§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently being appealed.§ A "final" event has been concluded and its resolution is not subject to change.

o A final event generally has a disposition of adjudicated, settled or otherwise resolved.§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter, or (2) an administrative

panel in an action brought by a regulator that is contested by the party charged with some alleged wrongdoing.§ A "settled" matter generally involves an agreement by the parties to resolve the matter. Please note that brokers and

brokerage firms may choose to settle customer disputes or regulatory matters for business or other reasons.§ A "resolved" matter usually involves no payment to the customer and no finding of wrongdoing on the part of the

individual broker. Such matters generally involve customer disputes.

For your convenience, below is a matrix of the number and status of disclosure events involving this broker. Further informationregarding these events can be found in the subsequent pages of this report. You also may wish to contact the broker to obtain furtherinformation regarding these events.

Final On AppealPending

Regulatory Event 0 1 0

Customer Dispute 0 3 N/A

Termination N/A 1 N/A

Financial 1 0 N/A

Judgment/Lien 1 N/A N/A

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10�2020 FINRA. All rights reserved. Report about JAMES E. BASHAW.

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Disclosure Event Details

When evaluating this information, please keep in mind that a discloure event may be pending or involve allegations that are contested and havenot been resolved or proven. The matter may, in the end, be withdrawn, dismissed, resolved in favor of the broker, or concluded through anegotiated settlement for certain business reasons (e.g., to maintain customer relationships or to limit the litigation costs associated with disputingthe allegations) with no admission or finding of wrongdoing.

This report provides the information exactly as it was reported to CRD and therefore some of the specific data fields contained in the report maybe blank if the information was not provided to CRD.

Regulatory - Final

This type of disclosure event may involve (1) a final, formal proceeding initiated by a regulatory authority (e.g., a state securities agency, self-regulatory organization, federal regulatory such as the Securities and Exchange Commission, foreign financial regulatory body) for a violation ofinvestment-related rules or regulations; or (2) a revocation or suspension of a broker's authority to act as an attorney, accountant, or federalcontractor.

Disclosure 1 of 1

Reporting Source: Regulator

Regulatory Action InitiatedBy:

FINRA

Sanction(s) Sought:

Date Initiated: 04/23/2019

Docket/Case Number: 2014042876501

Employing firm when activityoccurred which led to theregulatory action:

LPL Financial LLC

Product Type: No Product

Allegations: Without admitting or denying the findings, Bashaw consented to the sanctions andto the entry of findings that he borrowed a total of approximately $200,000 from acustomer without seeking or obtaining prior approval of the loans from his memberfirm. The findings stated that Bashaw did not make repayment on the loans. Thefindings also stated that in annual compliance questionnaires, Bashaw falsely toldhis firm that he had not borrowed any money from another individual, which thequestionnaires identified as a prohibited activity.

Current Status: Final

Resolution: Acceptance, Waiver & Consent(AWC)

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

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Resolution Date: 04/23/2019

Sanctions Ordered:

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Civil and Administrative Penalty(ies)/Fine(s)RequalificationSuspension

If the regulator is the SEC,CFTC, or an SRO, did theaction result in a finding of awillful violation or failure tosupervise?

No

(1) willfully violated anyprovision of the SecuritiesAct of 1933, the SecuritiesExchange Act of 1934, theInvestment Advisers Act of1940, the InvestmentCompany Act of 1940, theCommodity Exchange Act, orany rule or regulation underany of such Acts, or any ofthe rules of the MunicipalSecurities Rulemaking Board,or to have been unable tocomply with any provision ofsuch Act, rule or regulation?

(2) willfully aided, abetted,counseled, commanded,induced, or procured theviolation by any person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any of suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board? or

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(2) willfully aided, abetted,counseled, commanded,induced, or procured theviolation by any person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any of suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board? or

(3) failed reasonably tosupervise another personsubject to your supervision,with a view to preventing theviolation by such person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board?

Capacities Affected: All Capacities

Duration: four months

Start Date: 05/20/2019

End Date: 09/19/2019

Sanction 1 of 1

Sanction Type: Suspension

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Regulator Statement Fines paid in full on May 9, 2019.

Length of time given torequalify:

n/a

Type of exam required : S7, General Securities Representative Examination

Has condition been satisfied: No

Requalification 1 of 1

Requalification Type: Requalification by Exam

Monetary Related Sanction: Civil and Administrative Penalty(ies)/Fine(s)

Total Amount: $5,000.00

Portion Levied againstindividual:

$5,000.00

Date Paid by individual: 05/09/2019

Was any portion of penaltywaived?

No

Amount Waived:

Monetary Sanction 1 of 1

Payment Plan:

Is Payment Plan Current:

iReporting Source: Broker

Regulatory Action InitiatedBy:

FINRA

Sanction(s) Sought:

Date Initiated: 04/23/2019

Docket/Case Number: 2014042876501

Employing firm when activityoccurred which led to theregulatory action:

LPL FINANCIAL LLC

Product Type: No Product

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, BASHAW CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HEBORROWED A TOTAL OF APPROXIMATELY $200,000 FROM A CUSTOMERWITHOUT SEEKING OR OBTAINING PRIOR APPROVAL FROM HIS MEMBERFIRM. THE FINDINGS STATED THAT IN ANNUAL COMPLIANCEQUESTIONNAIRES, BASHAW FALSELY TOLD HIS FIRM THAT HE HAD NOTBORROWED ANY MONEY FROM ANOTHER INDIVIDUTAL, WHICH THEQUESTIONNAIRES IDENTIFIED AS A PROHIBITED ACTIVITY.

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Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, BASHAW CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HEBORROWED A TOTAL OF APPROXIMATELY $200,000 FROM A CUSTOMERWITHOUT SEEKING OR OBTAINING PRIOR APPROVAL FROM HIS MEMBERFIRM. THE FINDINGS STATED THAT IN ANNUAL COMPLIANCEQUESTIONNAIRES, BASHAW FALSELY TOLD HIS FIRM THAT HE HAD NOTBORROWED ANY MONEY FROM ANOTHER INDIVIDUTAL, WHICH THEQUESTIONNAIRES IDENTIFIED AS A PROHIBITED ACTIVITY.

Current Status: Final

Resolution: Acceptance, Waiver & Consent(AWC)

Resolution Date: 04/23/2019

Sanctions Ordered:

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Civil and Administrative Penalty(ies)/Fine(s)RequalificationSuspension

Capacities Affected: ALL CAPACITIES

Duration: FOUR MONTHS

Start Date: 05/20/2019

End Date: 09/19/2019

Sanction 1 of 1

Sanction Type: Suspension

Length of time given torequalify:

N/A

Type of exam required : S7 GENERAL SECURITIES REPRESENTATIVE EXAMINATION

Has condition been satisfied: No

Requalification 1 of 1

Requalification Type: Requalification by Exam

Monetary Related Sanction: Civil and Administrative Penalty(ies)/Fine(s)

Total Amount: $5,000.00

Monetary Sanction 1 of 1

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Total Amount: $5,000.00

Portion Levied againstindividual:

$5,000.00

Date Paid by individual:

Was any portion of penaltywaived?

No

Amount Waived:

Payment Plan:

Is Payment Plan Current:

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Customer Dispute - Settled

This type of disclosure event involves a consumer-initiated, investment-related complaint, arbitration proceeding or civil suit containing allegationsof sale practice violations against the broker that resulted in a monetary settlement to the customer.

Disclosure 1 of 3

Reporting Source: Firm

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

LPL FINANCIAL, LLC

CLAIMANTS ALLEGE UNSUITABLE INVESTMENTS, BORROWING FROMCUSTOMERS, PRIVATE SECURITIES TRANSACTIONS, AND FAILURE TOSUPERVISE WITH RESPECT TO PROMISSORY NOTES PROVIDED BY MR.BASHAW AND MR. BASHAW'S RECOMMENDING INVESTMENTS IN TEXASAIR SHUTTLE, LLC. ACTIVITY PERIOD 12/18/09 - 5/1/15.

Product Type: Promissory NoteOther: PRIVATE SECURITIES TRANSACTION

Alleged Damages: $3,800,000.00

Date Complaint Received: 09/02/2016

Complaint Pending? No

Status:

Status Date: 11/30/2017

Settlement Amount: $1,900,000.00

Individual ContributionAmount:

$0.00

Customer Complaint Information

Settled

Is this an oral complaint? No

Is this a written complaint? No

Is this an arbitration/CFTCreparation or civil litigation?

Yes

Arbitration/Reparation forumor court name and location:

FINRA

Docket/Case #: 16-02452

Filing date ofarbitration/CFTC reparationor civil litigation:

08/18/2016

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Individual ContributionAmount:

$0.00

iReporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

LPL FINANCIAL, LLC

CLAIMANTS ALLEGE UNSUITABLE INVESTMENTS, BORROWING FROMCUSTOMERS, PRIVATE SECURITIES TRANSACTIONS, AND FAILURE TOSUPERVISE WITH RESPECT TO PROMISSORY NOTES PROVIDED BY MR.BASHAW AND MR. BASHAWS RECOMMENDING INVESTMENTS IN TEXASAIR SHUTTLE, LLC. ACTIVITY PERIOD 12/18/09-5/1/15.

Product Type: Futures-FinancialPromissory NoteOther: PRIVATE SECURITIES TRANSACTIONS

Alleged Damages: $3,800,000.00

Date Complaint Received: 09/02/2016

Complaint Pending? No

Status:

Status Date: 11/30/2017

Settlement Amount: $1,900,000.00

Individual ContributionAmount:

$0.00

Customer Complaint Information

Settled

Is this an oral complaint? No

Is this a written complaint? No

Is this an arbitration/CFTCreparation or civil litigation?

Yes

Arbitration/Reparation forumor court name and location:

FINRA

Docket/Case #: 16-02452

Filing date ofarbitration/CFTC reparationor civil litigation:

08/18/2016

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Individual ContributionAmount:

$0.00

Broker Statement The [CUSTOMER NAME] parties never complained, suggested, or accused FA ofunsuitable investments or private securitiestransactions until LPL Financial submitted and issued defamatory statements toFINRA and the media in September of2014. FA did not recommend any investment in Texas Air Shuttle and the multi-million-dollar sophisticated lenderinvested in FA's company (and several unrelated companies and enterprises) inthe regular course of its business inthe pursuit of above-market gains over a course of 15 years or more. FA repaidhundreds of thousands of dollars onthe notes between 2011 and his termination by LPL Financial. LPL Financialbelatedly used the [CUSTOMER NAME] business loan, that its President [THIRDPARTY NAME] approved and that FA disclosed to LPL Financial auditors yearsbefore his termination, in order to terminate him and seize his employees,representatives, and clients. In doing so, LPL Financial prevented FA from fullysatisfying his obligations to a highly sophisticated long-time friend and LPLFinancial client that LPL Financial itself injured with its strategic termination of FAwithout just cause or notice. FA's Company never denied its repayment obligationsand it made substantial ongoing payments until LPL Financial destroyed FA'sCompany.

Disclosure 2 of 3

i

Reporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

LPL FINANCIAL

THAT UITS PURCHASED IN 2011 WERE UNSUITABLE.

Product Type: Unit Investment Trust

Alleged Damages: $20,804.28

Date Complaint Received: 04/26/2012

Complaint Pending?

Customer Complaint Information

Is this an oral complaint? No

Is this a written complaint? Yes

Is this an arbitration/CFTCreparation or civil litigation?

No

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Complaint Pending? No

Status:

Status Date: 07/31/2012

Settlement Amount: $10,000.00

Individual ContributionAmount:

$10,000.00

Settled

Disclosure 3 of 3

i

Reporting Source: Firm

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

KIDDER PEABODY & CO.

BREACH OF FIDUCIARY DUTY-CHURNING, OJBECTIVESNOT FOLLOWED CLAIM-$620,000 ACTUAL $1,000,000. PUNITIVE

Product Type:

Alleged Damages: $620,000.00

Date Complaint Received:

Complaint Pending? No

Status:

Status Date:

Settlement Amount:

Individual ContributionAmount:

Arbitration/Reparation Claimfiled with and Docket/CaseNo.:

National Association of Securities Dealers, Inc.; 89-1613

Date Notice/Process Served: 06/28/1988

Arbitration Pending? No

Disposition: Settled

Disposition Date: 12/01/1990

Customer Complaint Information

Arbitration Information

Arbitration/Reparation

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Disposition Date: 12/01/1990

Monetary CompensationAmount:

$200,000.00

Firm Statement KIDDER, PEABODY PAID $200,000. IN SETTLEMENTPREVIOUSLY REPORTED AS A WRITTEN CUSTOMERCOMPLAINT FILED WITH KIDDER, PEABODY ON 06/28/883

Individual ContributionAmount:

$0.00

iReporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

KIDDER PEABODY & CO.

BREACH OF FIDUCIARY DUTY, CHURNING OBJECTIVES NOT FOLLOWED.CLAIM $620,000 ACTUAL DAMAGES AND $1,000,000PUNITIVE DAMAGES.

Product Type: Other

Alleged Damages: $620,000.00

Date Complaint Received: 06/28/1988

Complaint Pending? No

Status:

Status Date: 01/07/1991

Settlement Amount:

Individual ContributionAmount:

Arbitration/Reparation Claimfiled with and Docket/CaseNo.:

NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.; 89-1613

Date Notice/Process Served: 06/28/1988

Arbitration Pending? No

Disposition: Settled

Customer Complaint Information

Arbitration Information

Arbitration/Reparation

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Disposition Date: 12/01/1990

Monetary CompensationAmount:

$200,000.00

Broker Statement KIDDER PEABODY SETTLED THE CLAIM FOR $200,000 PRIOR TOARBITRATION. [CUSTOMER] WAS LONG TIME FAMILY FRIEND AND CLIENT.HE OWNED A SEAT ON THE MEXICAN STOCK MARKET,VOLKSWAGEN DEALERSHIPS, RANCHES, BANKS, AND HOTELS. ONOCTOBER 19, 1987 HIS ACCOUNT WAS HEAVILY MNARGINED ANDSUFFERED A DROP IN MARKET VALUE DUE TO BLACK MONDAY. HEREFUSED TO COVER AND THE FIRM SOLD OUT HIS POSITIONS TO COVERHIS MARGION CALL. SUBSEQUENTLY, HE FILE SUIT AND FORGOT HE KNEWHOW TO SPEAK ENGLISH.

Individual ContributionAmount:

$0.00

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Employment Separation After Allegations

This type of disclosure event involves a situation where the broker voluntarily resigned, was discharged, or was permitted to resign after beingaccused of (1) violating investment-related statutes, regulations, rules or industry standards of conduct; (2) fraud or the wrongful taking ofproperty; or (3) failure to supervise in connection with investment-related statutes, regulations, rules, or industry standards of conduct.

Disclosure 1 of 1

Reporting Source: Firm

Employer Name: LPL FINANCIAL LLC

Termination Type: Discharged

Termination Date: 09/24/2014

Allegations: REPRESENTATIVE DISCHARGED FOR (A) PARTICIPATING IN PRIVATESECURITIES TRANSACTIONS WITHOUT PROVIDING WRITTEN DISCLOSURETO AND OBTAINING WRITTEN APPROVAL FROM THE FIRM, (B) BORROWINGFROM A CLIENT, AND (C) ENGAGING IN A BUSINESS TRANSACTION THATCREATED A POTENTIAL CONFLICT OF INTEREST WITHOUT PROVIDINGWRITTEN DISCLOSURE TO AND OBTAINING WRITTEN APPROVAL FROMTHE FIRM.

Product Type: Mutual FundOther: PRIVATE PLACEMENTS

iReporting Source: Broker

Employer Name: LPL FINANCIAL

Termination Type: Discharged

Termination Date: 09/24/2014

Allegations: FAILURE TO FOLLOW FIRM POLICIES AND INDUSTRY REGULATIONS

Product Type: No Product

Broker Statement FA Bashaw contests the accuracy, validity, and motive for the purported reasonsfor termination. As such, FA Bashaw has brought a legal action against LPLFinancial and its President, Mark S. Casady, alleging misrepresentation,defamation, raiding, breach of fiduciary duty, and business interference. FABashaw is also seeking expungement of this disclosure. The loans at issue wereverbally approved by LPL Financial's President, Mark S. Casady, and were issuedto FA Bashaw's Company by a multi-million-dollar lender Blackwell (and BPMInvestments, Inc.) that invested in various entities in its regular course of business.The loans were disclosed to LPL Financial during LPL's routine audit of JebCo. in2011 - 2012. LPL Financial's home office supervised FA Bashaw and all of thetransactions at issue were conducted through LPL's e-mail server and informationconcerning the transactions was available for review during multiple internal LPLFinancial audits. FA Bashaw did not engage in any private securities transactions.Moreover, the transactions at issue were non-compensatory. Tellingly, LPLFinancial did not offer recession to any investors in accord with industry standards.Any alleged potential conflict of interest three years prior to the termination wasfacilitated by LPL Financial and its President, to their benefit. Finally, there were nocustomer complaints for any of the above and LPL Financial avoided asking FABashaw a single question before or after the termination, even though FA Bashawwas with President Mark S. Casady's at his home on Cape Cod just weeks beforethe termination.

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FA Bashaw contests the accuracy, validity, and motive for the purported reasonsfor termination. As such, FA Bashaw has brought a legal action against LPLFinancial and its President, Mark S. Casady, alleging misrepresentation,defamation, raiding, breach of fiduciary duty, and business interference. FABashaw is also seeking expungement of this disclosure. The loans at issue wereverbally approved by LPL Financial's President, Mark S. Casady, and were issuedto FA Bashaw's Company by a multi-million-dollar lender Blackwell (and BPMInvestments, Inc.) that invested in various entities in its regular course of business.The loans were disclosed to LPL Financial during LPL's routine audit of JebCo. in2011 - 2012. LPL Financial's home office supervised FA Bashaw and all of thetransactions at issue were conducted through LPL's e-mail server and informationconcerning the transactions was available for review during multiple internal LPLFinancial audits. FA Bashaw did not engage in any private securities transactions.Moreover, the transactions at issue were non-compensatory. Tellingly, LPLFinancial did not offer recession to any investors in accord with industry standards.Any alleged potential conflict of interest three years prior to the termination wasfacilitated by LPL Financial and its President, to their benefit. Finally, there were nocustomer complaints for any of the above and LPL Financial avoided asking FABashaw a single question before or after the termination, even though FA Bashawwas with President Mark S. Casady's at his home on Cape Cod just weeks beforethe termination.

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Financial - Pending

This type of disclosure event involves a pending bankruptcy, compromise with one or more creditors, or Securities Investor Protection Corporationliquidation involving the broker or an organization/brokerage firm the broker controlled that occurred within the last 10 years.

Disclosure 1 of 1

Reporting Source: Broker

Action Type: Bankruptcy

Action Date: 11/29/2017

Organization Investment-Related?

Action Pending? Yes

Bankruptcy: Chapter 11

Type of Court: Federal Court

Name of Court: UNITED STATES BANKRUPTCY COURT

Location of Court: SOUTHERN DISTRICT OF TEXAS, HOUSTON

Docket/Case #: 17-36431

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Judgment / Lien

This type of disclosure event involves an unsatisfied and outstanding judgments or liens against the broker.

Disclosure 1 of 1

Reporting Source: Broker

Judgment/Lien Amount: $1,900,000.00

Judgment/Lien Holder: BLACKWELL MANAGEMENT TRUST OF 2009

Judgment/Lien Type: Civil

Date Filed with Court: 02/10/2017

Judgment/Lien Outstanding? Yes

Type of Court: Federal Court

Name of Court: DISTRICT COURT OF HARRIS COUNTY

Location of Court: HARRIS COUNTY, TEXAS

Docket/Case #: 2016-27497

Date Individual Learned: 02/10/2017

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