FINRA Broker Check: Richard Whitfield Brown

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• 1. BrokerCheck Report RICHARD WHITFIELD BROWN CRD# 1595628 Report #60715-26788 , data current as of Friday , September 06 , 2013 . Section Title Pagels) Report Summary Broker Qualifications 2-4 Registration and Employment History 5 Disclosure Events 6
• 2. About BrokerCheck® BrokerCheck offers information on all current-and many former-FINRA-registered securities brokers , and all current and former FINRA-registered securities firms. FINRA strongly encourages investors to use BrokerCheck to check the background of securities 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. BrokerCheck reports for brokerage firms include information on a firm ‘s profile, history, and operations, as well as many of the same disclosure events mentioned above. Please note that the information contained in a BrokerCheck report may include pending actions or allegations that may be contested , unresolved or unproven . In the end , these actions or allegations may be resolved in favor of the broker or brokerage firm, or concluded through a negotiated settlement with no admission or 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 , brokers and regulators is available in BrokerCheck the next business day . What if I want to check the background of an investment adviser firm or investment adviser representative? To check the background of an investment adviser firm or representative , you can search fo r the firm or individual in BrokerCheck. If your search is successful , click on the link provided to view the available licensing and registration information in the SEC’s Investment Adviser Public Disclosure (lAP D) website at http://www.adviserinfo.sec.gov. In the alternative, you may search the IAPD website directly or contact you r state securities regulator at http://www.nasaa .org . 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 adviser representatives doing business in your state. Thank you for using FINRA BrokerCheck. Using this site/information means that you accept the FINRA BrokerCheck Terms and Conditions. A complete list of Terms and Conditions can be found at brokercheck.finra .org For additional information about the contents of this report, please refer to the User Guidance or www.finra .org/brokercheck. lt provides a glossary of terms and a list of frequently asked questions, as well as additional resources . For more information about FINRA. visit www.finra.org.
• 3. www.linra .orq/brokercheck User Guidance RICHARD W. BROWN Report Summary for this Broker CRD# 1595628 Currently employed by and registered with the following FINRA Firm(s): SUMMIT BROKERAGE SERVICES, INC. 12830 UNIVERSITY DR STE 150 FORT MYERS, FL 33907 CRD# 34643 Registered with this firm since: 05/02/2003 This report summary provides an overview of the broker’s professional background and conduct. Additional information can be found in the detailed report. Broker Qualifications This broker is registered with: • 1 Self-Regulatory Organization .21 U.S. states and territories Is this broker currently suspended or inactive with any regulator? No Disclosure Events Disclosure events are certain criminal matters; regulatory actions; civil judicial proceedings; customer complaints , arbitrations , or civil litigations ; employment terminations ; and financial matters in which the broker has been involved. This broker has passed: • 1 Principal/Supervisory Exam • 1 General Industry/Product Exam • 1 State Securities Law Exam Registration History This broker was previously registered with FINRA at the following brokerage firms : MCDONALD INVESTMENTS INC. CRD# 566 CLEVELAND , OH 01/1999 – OS/2003 RA YMOND JAMES & ASSOCIATES, INC. CRD# 705 ST. PETERSBURG , FL 10/1988 – 12/1998 ©2013 FINRA. All rights reserved . Report# 60715-26788 about RICHARD W. BROWN. Data current as of Friday, September 06, 2013. Are there events disclosed about this broker? Yes The following types of disclosures have been reported: Type Customer Dispute Count 5
• 4. www.finra.orq/brokercheck User Guidance Broker Qualifications Registrations This section provides the self-regulatory organizations (SROs) and U.S. states/territories the broker is currently registered and licensed with , the category of each registration , and the date on which the registration became effective. This section also provides, for every brokerage firm with which the broker is currently employed , the address of each branch where the broker works . This individual is currently registered with 1 SRO and is licensed in 21 U.S. states and territories through his or her employer. Employment 1 of 1 Firm Name : SUMMIT BROKERAGE SERVICES, INC. Main Office Address : 595 S. FEDERAL HIGHWAY SUITE 500 BOCA RATON, FL 33432 Firm CRD#: 34643 SRO Ca~go~ Status Date FINRA General Securities Principal APPROVED OS/26/2004 FINRA General Securities Representative APPROVED 05/02/2003 Catego~ Status Date Massachusetts Agent APPROVED 05/15/2003 05/02/2003 Michigan Agent APPROVED 05/02/2003 APPROVED 06/26/2003 New Jersey Agent APPROVED 08/14/2006 Agent APPROVED 03/25/2008 New York Agent APPROVED 05/02/2003 Florida Agent APPROVED 05/02/2003 North Carolina Agent APPROVED 06/10/2003 Georgia Agent APPROVED 05/02/2003 Ohio Agent APPROVED 05/02/2003 Illinois Agent APPROVED 05/06/2003 Pennsylvania Agent APPROVED 05/02/2003 Indiana Agent APPROVED OS/23/2003 South Carolina Agent APPROVED 07/10/2003 Kansas Agent APPROVED 01/30/2004 Virginia Agent APPROVED 05/02/2003 Kentucky Agent APPROVED 02/06/2004 Louisiana Agent APPROVED 01/04/2008 Maryland Agent APPROVED 08/26/2003 U.S. Statel Territory Catego~ Arizona Agent APPROVED 10/24/2006 California Agent APPROVED Colorado Agent Connecticut Status Date U.S. Statel Territo~ ©2013 FINRA. All rights reserved. Report# 60715-26788 about RICHARD W. BROWN. Data current as of Friday, September 06 , 2013. 2
• 5. www.linra.orq/brokercheck User Guidance Broker Qualifications Employment 1 of 1, continued Branch Office Locations SUMMIT BROKERAGE SERVICES, INC. 12830 UNIVERSITY DR STE 150 FORT MYERS, FL 33907 ©201 3 FINRA. All rights reserved . Report# 60715-267 88 about RICHARD W. BROWN. Data current as of Friday, September 06, 201 3. 3
• 6. www.finra .orq/brokercheck User Guidance Broker Qualifications Industry Exams this Broker has Passed This section includes all securities industry exams that the broker has passed . Under limited circumstances , a broker may attain a registration after receiving an exam waiver based on exams the broker has passed and/or qualifying work experience. Any exam waivers that the broker has received are not included below. This individual has passed 1 principal/supervisory exam, 1 general industry/product exam, and 1 state securities law exam. Principal/Supervisory Exams Exam Category Date General Securities Principal Examination Series 24 OS/25/2004 Exam Category Date General Securities Representative Examination Series 7 10/15/1988 Exam Category Date Uniform Securities Agent State Law Examination Series 63 12/22/1988 Generallndustry/Product Exams State Securities Law Exams Additional information about the above exams or other exams FINRA administers to brokers and other securities professionals can be found at www.finra.org/brokerqualifications/registeredrep/. ©2013 FINRA. All rights reserved. Report# 60715-26788 about RICHARD W. BROWN. Data current as of Friday , September 06, 201 3. 4
• 7. www.fima.orq/brokercheck User Guidance Registration and Employment History Registration History This broker previously was registered with FINRA at the following firms: Registration Dates Firm Name CRD# Branch Location 01/1999 – 05/2003 MCDONALD INVESTMENTS INC. 566 CLEVELAND , OH 10/1988 – 12/1998 RAYMOND JAMES & ASSOCIATES , INC. 705 ST. PETERSBURG , FL Employment History Below is the broker’s employment history for up to the last 10 years. Please note that the broker is required to provide this information only while registered with FINRA and the information is not updated after the broker ceases to be registered. Therefore, an employment end date of “Present” may not reflect the broker’s current employment status. Employment Dates Employer Name Employer Location 05/2003 – Present SUMMIT BROKERAGE SERVICES INC FT MEYERS , FL 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 as a proprietor, partner, officer, director, employee , trustee , agent or otherwise . This section does not include non-investment related activity that is exclusively charitable , civic, religious or fraternal and is recognized as tax exempt. FIXED AND VARIABLE INSURANCE SALES TO CLIENTS ALONG WITH SECURITIES BUSINESS. ©2013 FINRA. All rights reserved. Report# 60715-26788 about RICHARD W. BROWN. Data current as of Friday, September 06, 201 3. 5
• 8. www.finra.orq/brokercheck User Guidance Disclosure Events What you should know about reported disclosure events: 1. Disclosure events are certain criminal matters; regulatory actions ; civil judicial proceedings; customer complaints , arbitrations , or civil litigations; employment terminations ; and financial matters in which the broker has been involved . 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 report 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 . 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 will appear in the BrokerCheck report. The different versions will be separated by a solid line with the reporting source labeled . 4 . 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” disclosure event involves allegations that have not been proven or formally adjudicated. • A disclosure event that is “on appeal” involves allegations that have been adjudicated but are currently being appealed. • A “final” disclosure event has been concluded and its resolution is not subject to change. o A final disclosure 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 represents a disposition wherein the parties involved in a dispute reach an agreement 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 includes a disposition wherein no payment is made to the customer or there is 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 information regarding these disclosure events can be found in the subsequent pages of this report. You also may wish to contact the broker to obtain further information regarding the disclosure events. ©201 3 FINRA. All rights reserved. Report# 60715-26788 about RICHARD W. BROWN . Data current as of Friday, September 06, 201 3. 6
• 9. www.finra.orq/brokercheck User Guidance Pending Customer Dispute ©2013 FINRA. All rights reserved . Final On Appeal o 5 N/A Report# 60715-26788 about RICHARD W. BROWN . Data current as of Friday, September 06, 2013 . 7
• 10. www.finra.orq/brokercheck User Guidance 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 have not been resolved or proven . The disclosure event may, in the end , be withdrawn , dismissed , resolved in favor of the broker, or concluded through a negotiated settlement for certain business reasons (e.g ., to maintain customer relationships or to limit the litigation costs associated with disputing the 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 may be blank if the information was not provided to CRD . Customer Dispute – Settled This type of disclosure event involves a consumer-initiated , investment-related complaint, arbitration proceeding or civil suit containing allegations of sale practice violations against the broker that resulted in a monetary settlement to the customer. Disclosure 1 of 2 Reporting Source: Firm Employing firm when activities occurred which led to the complaint: RAYMOND JAMES & ASSOCIATES , INC . Allegations: CLAIMANT ALLEGES VIOLATION OF CHAPTER 517, FLORIDA STATUTES, NEGLIGENCE, COMMON LAW FRAUD, AND VIOLATION OF FEDERAL SECURITIES LAWS. CLAIMINT ALLEGES HER ORIGINAL “GOOD QUALITY” INVESTMENTS WERE LIQUIDATED AND HER ACCOUNTS WERE TRADED ACTIVELY AND UNSUITABLY . Product Type: Equity Listed (Common & Preferred Stock) Alleged Damages: $100 ,000.00 Customer Complaint Information Date Complaint Received: 07/23/1999 Complaint Pending? No Status: Arbitration/Reparation Status Date: 07/23/1999 Settlement Amount: Individual Contribution Amount: ©201 3 FINRA. All rights reserved. Report# 60715-26788 about RICHARD W. BROWN. Data current as of Friday, September 06,201 3. 8
• 11. www .finra.orq /brokercheck User Guidance Arbitration Information Arbitration/Reparation Claim filed with and Docket/Case No.: NASD ARBITRATION # 99-03176 Date Notice/Process Served: 07/23/1999 Arbitration Pending? No Disposition: Settled Disposition Date: 03/22/2000 Monetary Compensation Amount: $32 ,500 .00 Individual Contribution Amount: $0.00 Summary: RAYMOND JAMES AGREED TO SETTLE FOR $32 ,500 .00 IN EXCHANGE FOR RELEASE OF ALL CLAIMS. Reporting Source: Broker Employing firm when activities occurred which led to the complaint: RAYMOND JAMES & ASSOCIATE Allegations: CLAIMANT ALEGES VIOLATION OF CHAPTER 517 FLORIDA STATUTES , NEGLEGENCE , COMMON LAW FRAUD . AN VIOLATION OF FEDERAL SECURITIES LAWS . CLAIMANT ALLEGES HER “GOOD QULAITY” ENVESTMETNS WERE LIQUIDATED AND HER ACCOUNTS WERE TRADED ACTIVITY AND UNSUITABLY. Product Type: Equity Listed (Common & Preferred Stock) Alleged Damages: $100 ,000.00 Customer Complaint Information Date Complaint Received: 07/08/1999 Complaint Pending? No Status: Arbitration/Reparation Status Date: 07/23/1999 Settlement Amount: $0 .00 ©2 01 3 FINRA. All rights reserved. Report# 60715-267 88 about RICHARD W. BROWN . Data current as of Friday , September 06 , 201 3. 9
• 12. www.finra.orq/brokercheck User Guidance Individual Contribution Amount: $0.00 Arbitration Information Arbitration/Reparation Claim filed with and Docket/Case No.: NASD , ARB #99-03176 Date Notice/Process Served: 07/23/1999 Arbitration Pending? No Disposition: Settled Disposition Date: 03/22/2000 Monetary Compensation Amount: $32 ,500.00 Individual Contribution Amount: $0.00 Summary: RAYMOND JAMES AGREED TO SETTLE FOR $32,500 .00 IN EXCHANGE FOR RELEASE OF ALL CALI MS. Disclosure 2 of 2 Reporting Source: Firm Employing firm when activities occurred which led to the complaint: RAYMOND JAMES & ASSOCIATES, INC Allegations: VIOLATION OF CHAPTER 517 ,F.S.” NEGLIGENCE, COMMON LAW FRAUD, RICO , AND VIOLATION OF FEDERAL SECURITIES LAWS. ALLEGED DAMAGES: UNSPECIFIED . Product Type: Equity Listed (Common & Preferred Stock) Alleged Damages: Customer Complaint Information Date Complaint Received: 02/19/1999 Complaint Pending? No Status: Arbitration/Reparation Status Date: 02/19/1999 Settlement Amount: ©2 013 FINRA. All rights reserved. Report# 60715-26788 about RICHARD W. BROWN. Data current as of Friday , September 06 , 201 3. 10
• 13. www.linra.orq/brokercheck User Guidance Individual Contribution Amount: Arbitration Information Arbitration/Reparation Claim filed with and Docket/Case No.: NASD-99-00440 Date Notice/Process Served: 02/19/1999 Arbitration Pending? No Disposition: Settled Disposition Date: 06/24/1999 Monetary Compensation Amount: $100,000 .00 Individual Contribution Amount: $22 ,500 .00 Summary: ALL CLAIMS RELEASED IN EXC HANGE FOR SETTLEMENT OF $100 ,000.00. Reporting Source: Broker Employing firm when activities occurred which led to the complaint: RAYMOND JAMES & ASSOCIATE Allegations: VIOLATION OF CHAPTER 517 , EGLIGENCE , COMMON LAW FRAUD , RICO, AND VIOLATION OF FEDERAL SECURITIES LAWS. ALL CLAIMS RELEASED IN EXCHANGE FOR SETTLEMENT OF $100 ,00 0. 00 N/A Product Type: Equity Listed (Common & Preferred Stock) Alleged Damages: $0.00 Customer Complaint Information Date Complaint Received: 02/19/1999 Complaint Pending? No Status: Arbitration/Reparation Status Date: 02/19/1999 Settlement Amount: $0 .00 ©2013 FINRA. All rights reserved . Report# 60715-26788 about RICHARD W. BROWN. Data cu rrent as of Friday, September 06, 201 3. 11
• 14. www.finra .orq/brokercheck User Guidance Individual Contribution Amount: $0 .00 Arbitration Information Arbitration/Reparation Claim filed with and Docket/Case No.: NASD ARBITRATION , #99-00440 Date Notice/Process Served: 02/19/1999 Arbitration Pending? No Disposition: Settled Disposition Date: 06/24/1999 Monetary Compensation Amount: $100,000.00 Individual Contribution Amount: $22 ,500 .00 Summary: VIOLATION OF CHAPTER 517 , GEGLIGENCE , COMMON LAW FRAUD , RICO , AND VIOLATION OF FEDERAL SECURITIES LAWS. ALL CLAIMS RELEASED IN EXCHANGE FOR SETTLEMENT OF $100,000.00 NIA ©2013 FINRA. All rights reserved . Report# 60715-26788 about RICHARD W. BROWN . Data current as of Friday, September 06, 2013. 12
• 15. www.finra .orq/brokercheck User Guidance Customer Dispute – Closed-No ActionlWithdrawn/Dismissed/Denied This type of disclosure event involves (1) a consumer-initiated , investment-related arbitration or civil suit containing allegations of sales practice violations against the individual broker that was dismissed, withdrawn , or denied ; or (2) a consumer-initiated , investment-related written complaint containing allegations that the broker engaged in sales practice violations resulting in compensatory damages of at least $5 ,000; forgery , theft, or misappropriation ; or conversion of funds or securities that was closed without action , withdrawn , or denied. Disclosure 1 of 3 Reporting Source: Broker Employing firm when activities occurred which led to the complaint: SUMMIT BROKERAGE SERVICES INC Allegations: SUITABILITY Product Type: Real Estate Security Other: CLOSED END FUNDS Alleged Damages: $107 ,800.00 Is this an oral complaint? No Is this a written complaint? Yes Is this an arbitration/CFTC reparation or civil litigation? No Customer Complaint Information Date Complaint Received: 07/22/2013 Complaint Pending? No Status: Withdrawn Status Date: 08/01/2013 Settlement Amount: Individual Contribution Amount: Disclosure 2 of 3 Reporting Source: Broker Employing firm when activities occurred which led to the complaint: SUMMIT BROKERAGE SERVICES INC ©201 3 FINRA. All rights reserved . Report# 60715-26788 about RICHARD W. BROWN. Data current as of Friday, September 06, 2013. 13
• 16. www.linra .orq/brokercheck User Guidance Allegations: UNSUITABILITY – OVER CONCENTRATED Product Type: Annuity-Variable Other: REITS Alleged Damages: $0.00 Alleged Damages Amount Explanation (if amount not exact): EXACT AMOUNT NOT SPECIFIED Is this an oral complaint? No Is this a written complaint? Yes Is this an arbitration/CFTC reparation or civil litigation? No Customer Complaint Information Date Complaint Received: 09/25/2009 Complaint Pending? No Status: Closed/No Action Status Date: 03/10/20 10 Settlement Amount: Individual Contribution Amount: ______________________________________________________________________________ Disclosure 3 of 3 Reporting Source: Broker Employing firm when activities occurred which led to the complaint: RAYMOND JAMES Allegations: CUSTOMERS ALLEGE UNSUITABLE INVESTMENTS Product Type: Equity – OTC Alleged Damages: $100 ,000.00 Customer Complaint Information Date Complaint Received: 02/10/2000 Complaint Pending? No ©201 3 FINRA. All rights reserved . Report# 60715-26788 about RI CHARD W. BROWN . Data current as of Friday, September 06, 2013. 14
• 17. www.finra .orq/brokercheck User Guidance Status: Closed/No Action Status Date: 08/28/2002 Settlement Amount: Individual Contribution Amount: Summary: ©201 3 FINRA. All rights reserved. THE NYSE REVIEWED THIS COMPLAINT AND BASED ON THEIR INVESTIGATION , NO ACTION WILL BE TAKEN. Report# 60715-26788 about RICHARD W. BROWN. Data current as of Friday , September 06, 201 3. 15
• 18. www.finra. orq/brokercheck User Guidance End of Report This page is intentionally left blank. ©20 13 FINRA. All rights reserved . Report# 60715-26788 about RICHARD W. BROWN. Data current as of Friday, September 06, 2013. 16