PIPER JAFFRAY CO. - FINRA JAFFRAY CO. CRD# 665 SEC# 8-15204 Main Office Location 800 NICOLLET MALL MINNEAPOLIS, MN 55402-7020 Regulated by FINRA Kansas City Office Mailing Address 800 NICOLLET MALL SUITE 1000

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BrokerCheck ReportPIPER JAFFRAY & CO.Section TitleReport SummaryFirm HistoryCRD# 66519Firm Profile 2 - 8Page(s)Firm Operations 10 - 20Disclosure Events 21http://www.finra.orgAbout BrokerCheckBrokerCheck 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, professionalqualifications, disciplinary actions, criminal convictions, civil judgments and arbitration awards. BrokerCheckreports for brokerage firms include information on a firms 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 noadmission or finding of wrongdoing. Where did this information come from? The information contained in BrokerCheck comes from FINRAs Central Registration Depository, orCRD and is a combination of: o information FINRA and/or the Securities and Exchange Commission (SEC) require brokers andbrokerage 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 disciplinaryinformation 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 yourstate securities 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 beforedeciding 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 atFor 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.orghttp://www.finra.orghttps://www.AdviserInfo.sec.govhttp://www.finra.org/Investors/ToolsCalculators/BrokerCheck/P455414http://www.finra.orghttp://brokercheck.finra.org/Support/TermsPIPER JAFFRAY & CO.CRD# 665SEC# 8-15204Main Office Location800 NICOLLET MALLMINNEAPOLIS, MN 55402-7020Regulated by FINRA Kansas City OfficeMailing Address800 NICOLLET MALLSUITE 1000MINNEAPOLIS, MN 55402-7020This firm is a brokerage firm and an investmentadviser firm. For more information aboutinvestment adviser firms, visit the SEC'sInvestment Adviser Public Disclosure website at:Business Telephone Number612-303-6000https://www.adviserinfo.sec.govReport Summary for this FirmThis report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.Disclosure EventsBrokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.Are there events disclosed about this firm? YesThe following types of disclosures have beenreported:Type CountRegulatory Event 134Civil Event 1Arbitration 55Firm ProfileThis firm is classified as a corporation.This firm was formed in Delaware on 07/28/1969.Its fiscal year ends in December.Firm HistoryInformation relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.Firm OperationsIs this brokerage firm currently suspended with anyregulator? NoThis firm conducts 16 types of businesses.This firm is affiliated with financial or investmentinstitutions.This firm has referral or financial arrangements withother brokers or dealers.This firm is registered with: the SEC 10 Self-Regulatory Organizations 53 U.S. states and territorieswww.finra.org/brokercheck User Guidance12018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.https://adviserinfo.sec.gov/IAPD/IAPDSummaryRouter.aspx?IndividualID=-1&FirmID=665&Source=Reporthttp://www.finra.orghttp://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportswww.finra.org/brokercheck User GuidanceThis firm is classified as a corporation.This firm was formed in Delaware on 07/28/1969.CRD#This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.Firm ProfileFirm Names and LocationsIts fiscal year ends in December.PIPER JAFFRAY & CO.SEC#6658-15204Main Office LocationMailing AddressBusiness Telephone NumberDoing business as PIPER JAFFRAY & CO.612-303-6000Regulated by FINRA Kansas City Office800 NICOLLET MALLMINNEAPOLIS, MN 55402-7020800 NICOLLET MALLSUITE 1000MINNEAPOLIS, MN 55402-7020Other Names of this FirmName Where is it usedHOPWOOD LANE, DIVISION OF PIPER JAFFRAY & CO. MN, NY, WASIMMONS & COMPANY INTERNATIONAL/ENERGY SPECIALISTS OFPIPER JAFFAK, AL, AR, AZ, CA,CO, CT, DC, DE, FL,GA, HI, IA, ID, IL, IN,KS, KY, LA, MA, MD,ME, MI, MN, MO,MS, MT, NC, ND, NE,NH, NJ, NM, NV, NY,OH, OK, OR, PA, RI,SC, SD, TN, TX, UT,VA, VT, WA, WI, WV,WY22018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceAK, AL, AR, AZ, CA,CO, CT, DC, DE, FL,GA, HI, IA, ID, IL, IN,KS, KY, LA, MA, MD,ME, MI, MN, MO,MS, MT, NC, ND, NE,NH, NJ, NM, NV, NY,OH, OK, OR, PA, RI,SC, SD, TN, TX, UT,VA, VT, WA, WI, WV,WY32018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportswww.finra.org/brokercheck User GuidanceThis section provides information relating to all direct owners and executive officers of the brokerage firm.Direct Owners and Executive OfficersFirm ProfilePositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?PIPER JAFFRAY COMPANIESPARENT75% or moreYesDomestic Entity12/2003YesIs this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):PositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?ABRAHAM, CHAD RICHARDCEO; BOARD MEMBERLess than 5%NoIndividual01/2018Yes2190836Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):PositionPercentage of OwnershipPosition Start DateCARTER, TIMOTHY LEECFO; BOARD MEMBERLess than 5%Individual01/20182676342Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):42018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceDirect Owners and Executive Officers (continued)Firm ProfilePercentage of OwnershipIs this a public reportingcompany?Does this owner direct themanagement or policies ofthe firm?Less than 5%NoYesPositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?DUFF, ANDREW SCOTTCHAIRMAN; BOARD MEMBERLess than 5%NoIndividual01/1996Yes719526Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):PositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?FAIRMAN, FRANCIS EVARTS IVHEAD OF PUBLIC FINANCE SERVICES; BOARD MEMBERLess than 5%NoIndividual07/2005Yes1171131Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):GEELAN, JOHN WILLIAM JR.4905460Legal Name & CRD# (if any):52018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceDirect Owners and Executive Officers (continued)Firm ProfilePositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?CHIEF LEGAL OFFICERLess than 5%NoIndividual01/2013Yes4905460Is this a domestic or foreignentity or an individual?PositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?LARUE, ROBERT SCOTTHEAD OF INVESTMENT BANKING; BOARD MEMBERLess than 5%NoIndividual01/2018Yes3185126Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):PositionPercentage of OwnershipPosition Start DateDoes this owner direct themanagement or policies ofthe firm?MCCAGUE, ANNCHARLOTTECHIEF COMPLIANCE OFFICERLess than 5%Individual12/2005Yes1108448Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):62018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceDirect Owners and Executive Officers (continued)Firm ProfileIs this a public reportingcompany?Does this owner direct themanagement or policies ofthe firm?NoYesPositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?SCHONEMAN, DEBBRA LYNNPRESIDENT; HEAD OF EQUITIES; BOARD MEMBERLess than 5%NoIndividual01/2018Yes1980635Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):PositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?WINGES, MARTIN BRADLEYHEAD OF FIXED INCOME SERVICES; BOARD MEMBERLess than 5%NoIndividual01/2009Yes1929509Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):72018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceThis section provides information relating to any indirect owners of the brokerage firm.Indirect OwnersFirm ProfileNo information reported.82018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceFirm HistoryThis section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.No information reported.92018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceFirm OperationsRegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.This firm is currently registered with the SEC, 10 SROs and 53 U.S. states and territories.SEC Registration QuestionsThis firm is registered with the SEC as:A broker-dealer:A broker-dealer and government securities broker or dealer:A government securities broker or dealer only:This firm has ceased activity as a government securities broker or dealer:YesYesNoNoFederal Regulator Status Date EffectiveSEC Approved 10/24/1969Self-Regulatory Organization Status Date EffectiveFINRA Approved 10/16/1936Cboe BYX Exchange, Inc. Approved 11/15/2012Cboe BZX Exchange, Inc. Approved 10/15/2008Cboe EDGA Exchange, Inc. Approved 05/14/2010Cboe EDGX Exchange, Inc. Approved 05/14/2010Investors' Exchange LLC Approved 08/10/2016NYSE American LLC Approved 02/25/1988NYSE Arca, Inc. Approved 04/09/2003Nasdaq Stock Market Approved 07/12/2006New York Stock Exchange Approved 11/17/1982102018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceFirm OperationsRegistrations (continued)U.S. States &TerritoriesStatus Date EffectiveAlabama Approved 10/24/1981Alaska Approved 08/10/1972Arizona Approved 03/10/1976Arkansas Approved 05/24/1985California Approved 01/02/1973Colorado Approved 02/01/1983Connecticut Approved 06/21/1976Delaware Approved 10/06/1981District of Columbia Approved 04/21/1983Florida Approved 04/27/1983Georgia Approved 09/22/1981Hawaii Approved 12/08/1980Idaho Approved 01/01/1971Illinois Approved 06/29/1970Indiana Approved 10/21/1981Iowa Approved 07/14/1983Kansas Approved 04/23/1975Kentucky Approved 07/16/1982Louisiana Approved 04/20/1983Maine Approved 04/27/1984Maryland Approved 10/03/1981Massachusetts Approved 07/31/1981Michigan Approved 02/03/1983Minnesota Approved 07/15/1982Mississippi Approved 04/20/1984Missouri Approved 07/18/1983Montana Approved 04/20/1983Nebraska Approved 10/08/1981Nevada Approved 07/18/1983New Hampshire Approved 08/02/1983New Jersey Approved 07/14/1983New Mexico Approved 10/07/1981New York Approved 01/02/1985U.S. States &TerritoriesStatus Date EffectiveNorth Carolina Approved 07/15/1982North Dakota Approved 10/21/1981Ohio Approved 07/16/1982Oklahoma Approved 07/17/1982Oregon Approved 10/24/1981Pennsylvania Approved 01/09/1980Puerto Rico Approved 06/04/1998Rhode Island Approved 05/07/1984South Carolina Approved 04/28/1982South Dakota Approved 07/15/1982Tennessee Approved 08/17/1981Texas Approved 07/25/1983Utah Approved 04/21/1983Vermont Approved 05/01/1984Virgin Islands Approved 06/09/2005Virginia Approved 09/22/1981Washington Approved 04/20/1983West Virginia Approved 11/07/1983Wisconsin Approved 08/29/1969Wyoming Approved 06/29/1965112018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceFirm OperationsTypes of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.Other Types of BusinessThis firm does not effect transactions in commodities, commodity futures, or commodity options.This firm does engage in other non-securities business.Non-Securities Business Description: APPLICANT ACTS AS A SWAP ADVISOR FOR THE PURPOSE OFENTERING INTO SWAP CONTRACTS ON A LIMITED BASIS.This firm currently conducts 16 types of businesses.Types of BusinessExchange member engaged in exchange commission business other than floor activitiesBroker or dealer making inter-dealer markets in corporation securities over-the-counterBroker or dealer retailing corporate equity securities over-the-counterBroker or dealer selling corporate debt securitiesUnderwriter or selling group participant (corporate securities other than mutual funds)Mutual fund retailerU S. government securities dealerU S. government securities brokerMunicipal securities dealerMunicipal securities brokerPut and call broker or dealer or option writerBroker or dealer selling securities of non-profit organizations (e.g., churches, hospitals)Investment advisory servicesTrading securities for own accountPrivate placements of securitiesBroker or dealer selling interests in mortgages or other receivables122018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceFirm OperationsClearing ArrangementsThis firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).Introducing ArrangementsThis firm does refer or introduce customers to other brokers and dealers.Name: PERSHING LLCBusiness Address: ONE PERSHING PLAZA10TH FLOORJERSEY CITY, NJ 07399CRD #: 7560Effective Date: 11/06/2015Description: FULLY DISCLOSED CORRESPONDENT CLEARING RELATIONSHIP;132018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceFirm OperationsIndustry ArrangementsThis firm does have books or records maintained by a third party.This firm does have accounts, funds, or securities maintained by a third party.This firm does have customer accounts, funds, or securities maintained by a third party.Name: BROADRIDGE FINANCIAL SOLUTIONS, INC.Business Address: 1981 MARCUS AVENUELAKE SUCCESS, NY 11042Effective Date: 09/07/2007Description: BOOKS AND RECORDS RETENTIONName: OMGEO LLCBusiness Address: 55 WATER STREETNEW YORK, NY 10041Effective Date: 03/01/2010Description: TO MAINTAIN AND PRESERVE CONFIRMATIONS FOR RECORDRETENTIONName: BNP PARIBAS PRIME BROKERAGE, INC.Business Address: 787 7TH AVENUENEW YORK, NY 100169CRD #: 24962Effective Date: 07/29/2016Description: PROPRIETARY PRIME BROKER ACCOUNT OF PIPER JAFFRAY & CO.HELD UNDER A PAB AGREEMENT.Name: PERSHING LLCBusiness Address: ONE PERSHING PLAZA10TH FLOORJERSEY CITY, NJ 07399CRD #: 7560Effective Date: 11/06/2015Description: FULLY DISCLOSED CORRESPONDENT CLEARING ARRANGEMENT.Name: PERSHING LLCCRD #: 7560142018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceFirm OperationsIndustry Arrangements (continued)This firm does not have individuals who control its management or policies through agreement.This firm does not have individuals who wholly or partly finance the firm's business.Control Persons/FinancingBusiness Address: ONE PERSHING PLAZA10TH FLOORJERSEY CITY, NJ 07399CRD #: 7560Effective Date: 11/06/2015Description: FULLY DISCLOSED CORRESPONDENT CLEARING RELATIONSHIPS.152018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceFirm OperationsOrganization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.This firm is, directly or indirectly: in control of controlled by or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.NoNoNo12/07/2017800 NICOLLET MALLSUITE 1000MINNEAPOLIS, MN 55402PIPER JAFFRAY FINANCE LLC is under common control with the firm.UNDER COMMON CONTROL BY PARENT HOLDING COMPANY PIPERJAFFRAY COMPANIESDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesNo07/06/2017800 NICOLLET MALLMINNEAPOLIS, MN 55402PIPER JAFFRAY FINANCIAL LLC is under common control with the firm.UNDER COMMON CONTROL BY PARENT HOLDING COMPANY PIPERJAFFRAY COMPANIESDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:800 NICOLLET MALLMINNEAPOLIS, MN 55402PIPER JAFFRAY FINANCIAL TRUST DEPOSITOR, LLC is under common control with the firm.Business Address: 162018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceFirm OperationsOrganization Affiliates (continued)NoYesNo07/06/2017800 NICOLLET MALLMINNEAPOLIS, MN 55402UNDER COMMON CONTROL BY PARENT HOLDING COMPANY PIPERJAFFRAY COMPANIESDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:YesNoGUERNSEYYes02/29/2016PO BOX 656,EAST WING, TRAFALGAR COURT, LES BANQUESST PETER PORT, GUERNSEY (UK) GY1 3PPPARALLEL GENERAL PARTNER LIMITED is under common control with the firm.UNDER COMMON CONTROL BY PARENT HOLDING COMPANY PIPERJAFFRAY COMPANIES. MERGED INTO PIPER JAFFRAY LTD AS OF MAY 1,2017Description:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesCHINAYes10/10/2012LEVEL 16, NEXXUS BUILDING41 CONNAUGHT RD., CENTRALHONG KONG, HONG KONGPIPER JAFFRAY HONG KONG LIMITED is under common control with the firm.Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:172018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceFirm OperationsOrganization Affiliates (continued)NoENTITY IS OWNED BY PIPER JAFFRAY COMPANIES, THE HOLDINGCOMPANY AND UNDER COMMON CONTROL WITH PIPER JAFFRAY & CO.Description:Investment AdvisoryActivities:YesNoNo11/30/2012800 NICOLLET MALLMINNEAPOLIS, MN 55402165620PJC CAPITAL PARTNERS LLC is under common control with the firm.UNDER COMMON CONTROL BY PARENT HOLDING COMPANY PIPERJAFFRAY COMPANIESDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:CRD #:YesNoNo03/01/2010180 N. STETSON AVECHICAGO, IL 60601108254ADVISORY RESEARCH INC is under common control with the firm.ADVISORY RESEARCH INC IS A FEDERALLY REGISTERED INVESTMENTADVISER WHICH IS UNDER COMMON CONTROL BY PARENT HOLDINGCOMPANY PIPER JAFFRAY COMPANIESDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:CRD #:145876PIPER JAFFRAY INVESTMENT MANAGEMENT, LLC is under common control with the firm.CRD #:182018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceFirm OperationsOrganization Affiliates (continued)YesNoNo05/12/2008800 NICOLLET MALLMINNEAPOLIS, MN 55402UNDER COMMON CONTROL BY PARENT HOLDING COMPANY PIPERJAFFRAY COMPANIESDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:YesYesUNITED KINGDOMYes10/06/200113TH FLOOR88 WOOD ST.LONDON EC2V 7RS, ENGLAND163758PIPER JAFFRAY LTD is under common control with the firm.BROKER-DEALER REGISTERED THROUGH THE FINANCIAL CONDUCTAUTHORITY WHICH IS UNDER COMMON CONTROL BY PARENT HOLDINGCOMPANY PIPER JAFFRAY COMPANIES.Description:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:CRD #:NoYesDELAWARENo03/14/1983800 NICOLLET MALLMINNEAPOLIS, MN 55402PIPER JAFFRAY VENTURES INC. is under common control with the firm.Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:192018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceFirm OperationsOrganization Affiliates (continued)NoORGANIZES AND MANAGES FUNDS FOR INVESTING IN PRIVATELY HELDCOMPANIES. PIPER JAFFRAY VENTURES, INC IS UNDER COMMONCONTROL BY PARENT HOLDING COMPANY PIPER JAFFRAY COMPANIESDescription:Investment AdvisoryActivities:This firm is not directly or indirectly, controlled by the following: bank holding company national bank state member bank of the Federal Reserve System state non-member bank savings bank or association credit union or foreign bank202018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceDisclosure EventsAll firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.Final On AppealPendingRegulatory Event 0 134 0Civil Event 0 1 0Arbitration N/A 55 N/A212018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceDisclosure Event DetailsWhat you should know about reported disclosure events:1. BrokerCheck provides details for any disclosure event that was reported in CRD. It also includessummary information regarding FINRA arbitration awards in cases where the brokerage firm wasnamed as a respondent.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 brokerage firm is required to disclose aparticular criminal event.3. Disclosure events in BrokerCheck reports come from different sources: o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firmand a regulator report information for the same event, both versions of the event will appear in theBrokerCheck report. The different versions will be separated by a solid line with the reporting sourcelabeled.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" 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 currentlybeing 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 partycharged with some alleged wrongdoing. A "settled" matter generally involves an agreement by the parties to resolve the matter.Please note that firms may choose to settle customer disputes or regulatory matters forbusiness or other reasons. A "resolved" matter usually involves no payment to the customer and no finding ofwrongdoing on the part of the individual broker. Such matters generally involve customerdisputes.5. You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure events contained in this BrokerCheck report.Regulatory - FinalThis type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission,foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation orsuspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federalcontractor.Disclosure 1 of 134Reporting Source: RegulatorAllegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT UNTIMELYSUBMITTED DOCUMENTS RELATING TO PRIMARY OFFERINGS OFMUNICIPAL SECURITIES TO THE ELECTRONIC MUNICIPAL MARKET ACCESSDATABASE (EMMA). THE FINDINGS STATED THAT THE UNTIMELYSUBMISSIONS RESULTED FROM TURNOVER IN THE FIRM'S DEPARTMENTTHAT HANDLED THE DOCUMENTS, A SITUATION THAT THE FIRM'S WSPSDID NOT ADEQUATELY ADDRESS.Current Status: Final222018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:N/ADate Initiated: 07/07/2016Docket/Case Number: 2015043589201Principal Product Type: OtherOther Product Type(s): PRIMARY OFFERINGS OF MUNICIPAL SECURITIESAllegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT UNTIMELYSUBMITTED DOCUMENTS RELATING TO PRIMARY OFFERINGS OFMUNICIPAL SECURITIES TO THE ELECTRONIC MUNICIPAL MARKET ACCESSDATABASE (EMMA). THE FINDINGS STATED THAT THE UNTIMELYSUBMISSIONS RESULTED FROM TURNOVER IN THE FIRM'S DEPARTMENTTHAT HANDLED THE DOCUMENTS, A SITUATION THAT THE FIRM'S WSPSDID NOT ADEQUATELY ADDRESS.Resolution Date: 07/07/2016Resolution:Other Sanctions Ordered:Sanction Details: THE FIRM WAS CENSURED AND FINED $12,500. FINE PAID IN FULL ONAUGUST 8, 2016.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $12,500.00Acceptance, Waiver & Consent(AWC)iReporting Source: FirmAllegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT UNTIMELYSUBMITTED DOCUMENTS RELATING TO PRIMARY OFFERINGS OFMUNICIPAL SECURITIES TO THE ELECTRONIC MUNICIPAL MARKET ACCESSDATABASE (EMMA). THE FINDINGS STATED THAT THE UNTIMELYSUBMISSIONS RESULTED FROM TURNOVER IN THE FIRM'S DEPARTMENTTHAT HANDLED THE DOCUMENTS, A SITUATION THAT THE FIRM'S WSPSDID NOT ADEQUATELY ADDRESS.Current Status: Final232018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2015043589201www.finra.org/brokercheck User GuidanceInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:N/ADate Initiated: 07/07/2016Docket/Case Number: 2015043589201Principal Product Type: OtherOther Product Type(s): PRIMARY OFFERINGS OF MUNICIPAL SECURITIESWITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT UNTIMELYSUBMITTED DOCUMENTS RELATING TO PRIMARY OFFERINGS OFMUNICIPAL SECURITIES TO THE ELECTRONIC MUNICIPAL MARKET ACCESSDATABASE (EMMA). THE FINDINGS STATED THAT THE UNTIMELYSUBMISSIONS RESULTED FROM TURNOVER IN THE FIRM'S DEPARTMENTTHAT HANDLED THE DOCUMENTS, A SITUATION THAT THE FIRM'S WSPSDID NOT ADEQUATELY ADDRESS.Resolution Date: 07/07/2016Resolution:Other Sanctions Ordered:Sanction Details: THE FIRM WAS CENSURED AND FINED $12,500Sanctions Ordered: CensureMonetary/Fine $12,500.00Acceptance, Waiver & Consent(AWC)Disclosure 2 of 134iReporting Source: RegulatorAllegations: SEC ADMIN RELEASES 33-9837; 34-75231, JUNE 18, 2015: THE SECURITIESAND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESISTPROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST PIPERJAFFRAY & CO. ("RESPONDENT"). RESPONDENT WILLFULLY VIOLATEDSECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVESVIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERAL SECURITIESLAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITING OF CERTAINMUNICIPAL SECURITIES OFFERINGS. RESPONDENT, A REGISTEREDBROKER-DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAINOFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASISFOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIALREPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTIONWITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENT OFFERINGAND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLYMISLEADING DISCLOSURE DOCUMENTS.THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THECOMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION(MCDC) INITIATIVE.Current Status: Final242018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2015043589201www.finra.org/brokercheck User GuidanceInitiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSIONPrincipal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:Date Initiated: 06/18/2015Docket/Case Number: 3-16630Principal Product Type: Debt - MunicipalOther Product Type(s):SEC ADMIN RELEASES 33-9837; 34-75231, JUNE 18, 2015: THE SECURITIESAND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESISTPROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST PIPERJAFFRAY & CO. ("RESPONDENT"). RESPONDENT WILLFULLY VIOLATEDSECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVESVIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERAL SECURITIESLAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITING OF CERTAINMUNICIPAL SECURITIES OFFERINGS. RESPONDENT, A REGISTEREDBROKER-DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAINOFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASISFOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIALREPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTIONWITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENT OFFERINGAND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLYMISLEADING DISCLOSURE DOCUMENTS.THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THECOMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION(MCDC) INITIATIVE.Resolution Date: 06/18/2015Resolution:Other Sanctions Ordered: UNDERTAKINGSSanction Details: THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION17(A)(2)OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THEAMOUNT OF $500,000 AND COMPLY WITH THE UNDERTAKINGSENUMERATED IN THE OFFER OF SETTLEMENT.Regulator Statement IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER")WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THEFOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INRESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THATRESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OFTHE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THISORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THESECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENTCONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES ANDPROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIESUNDERWRITING DUE DILIGENCE.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?YesSanctions Ordered: Monetary/Fine $500,000.00Cease and Desist/InjunctionOrder252018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceIN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER")WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THEFOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INRESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THATRESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OFTHE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THISORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THESECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENTCONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES ANDPROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIESUNDERWRITING DUE DILIGENCE.iReporting Source: FirmInitiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSIONDate Initiated: 06/18/2015Allegations: SEC ADMIN RELEASES 33-9837; 34-75231, JUNE 18, 2015: THE SECURITIESAND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESISTPROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST PIPERJAFFRAY & CO. ("RESPONDENT"). RESPONDENT WILLFULLY VIOLATEDSECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVESVIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERAL SECURITIESLAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITING OF CERTAINMUNICIPAL SECURITIES OFFERINGS. RESPONDENT, A REGISTEREDBROKER-DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAINOFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASISFOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIALREPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTIONWITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENT OFFERINGAND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLYMISLEADING DISCLOSURE DOCUMENTS. THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THE COMMISSION PURSUANT TO THEDIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIESCONTINUING DISCLOSURE COOPERATION (MCDC) INITIATIVE.Current Status: Final262018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:Date Initiated: 06/18/2015Docket/Case Number: 3-16630Principal Product Type: Debt - MunicipalOther Product Type(s):Resolution Date: 06/18/2015Resolution:Other Sanctions Ordered:Sanction Details: THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION17(A)(2)OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THEAMOUNT OF $500,000 AND COMPLY WITH THE UNDERTAKINGSENUMERATED IN THE OFFER OF SETTLEMENT.Firm Statement IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER")WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THEFOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INRESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THATRESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OFTHE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THISORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THESECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENTCONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES ANDPROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIESUNDERWRITING DUE DILIGENCE.Sanctions Ordered: Monetary/Fine $500,000.00Cease and Desist/InjunctionOrder272018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceIN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER")WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THEFOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THEPUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO INRESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THATRESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OFTHE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THISORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 TO THESECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENTCONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES ANDPROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIESUNDERWRITING DUE DILIGENCE.Disclosure 3 of 134iReporting Source: RegulatorInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 02/02/2015Docket/Case Number: 2013038311001Principal Product Type: Debt - MunicipalOther Product Type(s):Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITINACCURATELY REPORTED THE M020 SPECIAL CONDITION INDICATOR TOTHE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN REPORTSOF TRANSACTIONS IN MUNICIPAL SECURITIES. THE FINDINGS STATEDTHAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHRESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS ANDTHE RULES OF THE MUNICIPAL SECURITIES RULEMAKING BOARD (MSRB)CONCERNING THE ACCURATE REPORTING OF SPECIAL CONDITIONINDICATOR CODES.Current Status: FinalResolution Date: 02/02/2015Resolution:Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $15,000.00Acceptance, Waiver & Consent(AWC)282018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2013038311001www.finra.org/brokercheck User GuidanceOther Sanctions Ordered:Sanction Details: THE FIRM WAS CENSURED AND FINED $15,000.FINE PAID IN FULL ON FEBRUARY 25, 2015.iReporting Source: FirmInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:MONETARY FINEDate Initiated: 02/02/2015Docket/Case Number: 2013038311001Principal Product Type: Debt - MunicipalOther Product Type(s):Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITINACCURATELY REPORTED THE M020 SPECIAL CONDITION INDICATOR TOTHE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN REPORTSOF TRANSACTIONS IN MUNICIPAL SECURITIES. THE FINDINGS STATEDTHAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHRESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS ANDTHE RULES OF THE MUNICIPAL SECURITIES RULEMAKING BOARD (MSRB)CONCERNING THE ACCURATE REPORTING OF SPECIAL CONDITIONINDICATOR CODES.Current Status: FinalResolution Date: 02/02/2015Resolution:Other Sanctions Ordered:Sanction Details: THE FIRM WAS CENSURED AND FINED $15,000.Sanctions Ordered: CensureMonetary/Fine $15,000.00Acceptance, Waiver & Consent(AWC)Disclosure 4 of 134i292018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2013038311001www.finra.org/brokercheck User GuidanceDisclosure 4 of 134Reporting Source: RegulatorInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 05/01/2014Docket/Case Number: 2013038861401Principal Product Type: OtherOther Product Type(s): SECURITIZED PRODUCTSAllegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS WITHIN THETIME REQUIRED BY FINRA RULE 6730(A).Current Status: FinalResolution Date: 05/01/2014Resolution:Other Sanctions Ordered:Sanction Details: SEE ABOVERegulator Statement FINE PAID IN FULL MAY 16, 2014.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: Monetary/Fine $5,000.00Acceptance, Waiver & Consent(AWC)iReporting Source: FirmAllegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS WITHIN THETIME REQUIRED BY FINRA RULE 6730(A).Current Status: Final302018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2013038861401www.finra.org/brokercheck User GuidanceInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:MONETARY FINEDate Initiated: 05/01/2014Docket/Case Number: 2013038861401Principal Product Type: OtherOther Product Type(s): SECURITIZED PRODUCTSWITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS WITHIN THETIME REQUIRED BY FINRA RULE 6730(A).Resolution Date: 05/01/2014Resolution:Other Sanctions Ordered:Sanction Details: TOTAL AMOUNT: $5,000.00; 100% LEVIED AGAINST THE APPLICANT.Sanctions Ordered: Monetary/Fine $5,000.00Acceptance, Waiver & Consent(AWC)Disclosure 5 of 134iReporting Source: RegulatorInitiated By: FINRADate Initiated: 03/04/2014Docket/Case Number: 2013037791201Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)THE CORRECT TIME OF TRADE EXECUTION FOR S1 TRANSACTIONS INTRACE-ELIGIBLE AGENCY DEBT SECURITIES; FAILED TO REPORT TOTRACE S1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15MINUTES OF THE TIME OF EXECUTION; FAILED TO SHOW THE CORRECTTIME OF EXECUTION ON THE MEMORANDUM OF BROKERAGE ORDERS;AND FAILED TO REPORT TO TRACE THE CORRECT TIME OF TRADEEXECUTION FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZEDPRODUCTS.Current Status: Final312018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2013038861401https://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2013037791201www.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Docket/Case Number: 2013037791201Principal Product Type: OtherOther Product Type(s): AGENCY DEBT SECURITIESResolution Date: 03/04/2014Resolution:Other Sanctions Ordered:Sanction Details: SEE ABOVEDoes the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $17,500.00Acceptance, Waiver & Consent(AWC)iReporting Source: FirmInitiated By: FINRADate Initiated: 03/04/2014Docket/Case Number: 2013037791201Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)THE CORRECT TIME OF TRADE EXECUTION FOR S1 TRANSACTIONS INTRACE-ELIGIBLE AGENCY DEBT SECURITIES; FAILED TO REPORT TOTRACE S1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15MINUTES OF THE TIME OF EXECUTION; FAILED TO SHOW THE CORRECTTIME OF EXECUTION ON THE MEMORANDUM OF BROKERAGE ORDERS;AND FAILED TO REPORT TO TRACE THE CORRECT TIME OF TRADEEXECUTION FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZEDPRODUCTS.Current Status: Final322018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2013037791201https://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2013037791201www.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:FINEDocket/Case Number: 2013037791201Principal Product Type: OtherOther Product Type(s): AGENCY DEBT SECURITIESResolution Date: 03/04/2014Resolution:Other Sanctions Ordered:Sanction Details: FINE $17,500.00Sanctions Ordered: CensureMonetary/Fine $17,500.00Acceptance, Waiver & Consent(AWC)Disclosure 6 of 134iReporting Source: RegulatorAllegations: SEC ADMIN RELEASES 33-9472, 34-70804, NOVEMBER 5, 2013: THESECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT") AND SECTIONS 15(B) AND 15(B)(C)(2) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST PIPERJAFFRAY & CO. ("PIPER").THE COMMISSION FOUND THAT IN 2011, A MUNICIPAL CORPORATION("DISTRICT") DEFAULTED ON $41.77 MILLION IN BOND ANTICIPATIONNOTES ("BANS") IT HAD ISSUED IN NOVEMBER 2008 TO FINANCE A MULTI-USE ARENA AND ICE HOCKEY RINK (THE "REGIONAL CENTER") LOCATEDIN THE CITY OF WENATCHEE, WASHINGTON (THE "CITY"). PIPER SERVEDAS SOLE UNDERWRITER FOR THE BANS. THE OFFICIAL STATEMENT FORTHE BANS WAS MATERIALLY FALSE AND MISLEADING.PIPER WAS HIRED BY THE DISTRICT AS UNDERWRITER AS A LAST MINUTEREPLACEMENT FOR A PREDECESSOR UNDERWRITING FIRM("PREDECESSOR"). THE PREDECESSOR HAD BEEN WORKING WITH THEDISTRICT FOR OVER A YEAR AND HAD COMPLETED A PRELIMINARYOFFICIAL STATEMENT FOR LONG-TERM BONDS WHICH HAD RECEIVED ANINVESTMENT GRADE RATING. THAT PREDECESSOR WITHDREW INSEPTEMBER 2008 AFTER THE GLOBAL FINANCIAL CRISIS PREVENTEDACCESS TO THE BOND MARKET AND THE FIRM WAS UNABLE TOCOMPLETE THE FINANCING. PIPER'S ENGAGEMENT WITH THE DISTRICTSTARTED ON OCTOBER 27, 2008. BY THE TIME PIPER BECAME THEUNDERWRITER ON THE DEAL, THE CITY AND THE DISTRICT WEREDESPERATE TO FIND FINANCING FOR THE REGIONAL CENTER WITHIN AMONTH BECAUSE OF ONEROUS LEASE PAYMENTS BEING DEMANDED BYTHE CONSTRUCTION LENDER. PIPER SUGGESTED SEVERAL FINANCINGOPTIONS, ALTHOUGH ONLY ONE, SHORT-TERM BANS, WAS CONSIDEREDVIABLE. THE DISTRICT DETERMINED TO ISSUE THREE YEAR BANS THATWOULD MATURE IN 2011, WITH THE PRINCIPAL OF THE BANS TO BEREPAID SOLELY THROUGH THE ISSUANCE OF LONG-TERM BONDS.PIPER CONDUCTED INADEQUATE DUE DILIGENCE AND, AS A RESULT,FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THETRUTHFULNESS AND COMPLETENESS OF MATERIAL STATEMENTS IN THEOFFICIAL STATEMENT. THE OFFICIAL STATEMENT FOR THE BANS WAS ALIGHTLY REVISED VERSION OF THE PRELIMINARY OFFICIAL STATEMENTPREPARED BY THE PREDECESSOR AND THE DISTRICT'S BOND COUNSELTHAT INCLUDED SIMILAR DISCLOSURES AND RELIED ON THE SAMEPROJECTIONS FOR THE REGIONAL CENTER PROVIDED BY THE COMPANY("COMPANY") HIRED TO DEVELOP AND MANAGE THE REGIONAL CENTER.PIPER CONDUCTED A CURSORY INQUIRY INTO THE PROJECTIONSPROVIDED BY THE COMPANY, DID NOT INQUIRE ABOUT PRIORPROJECTIONS OR REVISIONS, AND DID NOT ASK TO SEE ANINDEPENDENT CONSULTANT'S REVIEW OF THE PROJECTIONS DESPITEBEING MADE AWARE OF ITS EXISTENCE, DEPRIVING BAN PURCHASERSOF MATERIAL INFORMATION RELATING TO THE REVENUE PROJECTIONS,THE FIRST SOURCE OF PAYMENT FOR THE MAJORITY OF THE BANS.AN INDEPENDENT CONSULTANT HAD BEEN ASKED TO REVIEW THECOMPANY'S EARLIER PROJECTIONS AND HAD RAISED QUESTIONS ABOUTTHE REGIONAL CENTER'S ECONOMIC VIABILITY. DESPITE TWO SEPARATEREVIEWS OF PRIOR COMPANY PROJECTIONS BY THE INDEPENDENTCONSULTANT, THE OFFICIAL STATEMENT PRESENTED THE MOST RECENTVERSION OF THE COMPANY'S PROJECTIONS ALONG WITH A FALSE ANDMISLEADING STATEMENT TO THE EFFECT THAT NO FINANCIAL ADVISOR,ACCOUNTING OR OTHER FIRM HAD EXAMINED THOSE PROJECTIONS TOVERIFY THE REASONABLENESS OF THE COMPANY'S ASSUMPTIONS ORITS CONCLUSIONS.PIPER WAS UNAWARE THAT THE PROJECTIONS IN THE OFFICIALSTATEMENT HAD BEEN REVISED UPWARD FROM PROJECTIONSGENERATED A FEW MONTHS EARLIER AFTER A CLAIM BY THE CITY'SFORMER MAYOR AND THE DISTRICT'S CONTRACT MANAGER THAT THECOMPANY'S PROJECTIONS WERE INCONSISTENT WITH ITS PRIORPROJECTIONS AND NOT SUFFICIENTLY OPTIMISTIC. DURING ACONFERENCE CALL WITH THE COMPANY'S PRESIDENT AND THECOMPANY'S FINANCIAL CONSULTANT, THE CITY'S FORMER MAYOR MADEAN IMPASSIONED ARGUMENT THAT THEY KNEW THE LOCAL CITIZENSBETTER THAN THE COMPANY, (CONTINUED IN COMMENT)Current Status: Final332018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2013037791201www.finra.org/brokercheck User GuidanceSEC ADMIN RELEASES 33-9472, 34-70804, NOVEMBER 5, 2013: THESECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT") AND SECTIONS 15(B) AND 15(B)(C)(2) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST PIPERJAFFRAY & CO. ("PIPER").THE COMMISSION FOUND THAT IN 2011, A MUNICIPAL CORPORATION("DISTRICT") DEFAULTED ON $41.77 MILLION IN BOND ANTICIPATIONNOTES ("BANS") IT HAD ISSUED IN NOVEMBER 2008 TO FINANCE A MULTI-USE ARENA AND ICE HOCKEY RINK (THE "REGIONAL CENTER") LOCATEDIN THE CITY OF WENATCHEE, WASHINGTON (THE "CITY"). PIPER SERVEDAS SOLE UNDERWRITER FOR THE BANS. THE OFFICIAL STATEMENT FORTHE BANS WAS MATERIALLY FALSE AND MISLEADING.PIPER WAS HIRED BY THE DISTRICT AS UNDERWRITER AS A LAST MINUTEREPLACEMENT FOR A PREDECESSOR UNDERWRITING FIRM("PREDECESSOR"). THE PREDECESSOR HAD BEEN WORKING WITH THEDISTRICT FOR OVER A YEAR AND HAD COMPLETED A PRELIMINARYOFFICIAL STATEMENT FOR LONG-TERM BONDS WHICH HAD RECEIVED ANINVESTMENT GRADE RATING. THAT PREDECESSOR WITHDREW INSEPTEMBER 2008 AFTER THE GLOBAL FINANCIAL CRISIS PREVENTEDACCESS TO THE BOND MARKET AND THE FIRM WAS UNABLE TOCOMPLETE THE FINANCING. PIPER'S ENGAGEMENT WITH THE DISTRICTSTARTED ON OCTOBER 27, 2008. BY THE TIME PIPER BECAME THEUNDERWRITER ON THE DEAL, THE CITY AND THE DISTRICT WEREDESPERATE TO FIND FINANCING FOR THE REGIONAL CENTER WITHIN AMONTH BECAUSE OF ONEROUS LEASE PAYMENTS BEING DEMANDED BYTHE CONSTRUCTION LENDER. PIPER SUGGESTED SEVERAL FINANCINGOPTIONS, ALTHOUGH ONLY ONE, SHORT-TERM BANS, WAS CONSIDEREDVIABLE. THE DISTRICT DETERMINED TO ISSUE THREE YEAR BANS THATWOULD MATURE IN 2011, WITH THE PRINCIPAL OF THE BANS TO BEREPAID SOLELY THROUGH THE ISSUANCE OF LONG-TERM BONDS.PIPER CONDUCTED INADEQUATE DUE DILIGENCE AND, AS A RESULT,FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THETRUTHFULNESS AND COMPLETENESS OF MATERIAL STATEMENTS IN THEOFFICIAL STATEMENT. THE OFFICIAL STATEMENT FOR THE BANS WAS ALIGHTLY REVISED VERSION OF THE PRELIMINARY OFFICIAL STATEMENTPREPARED BY THE PREDECESSOR AND THE DISTRICT'S BOND COUNSELTHAT INCLUDED SIMILAR DISCLOSURES AND RELIED ON THE SAMEPROJECTIONS FOR THE REGIONAL CENTER PROVIDED BY THE COMPANY("COMPANY") HIRED TO DEVELOP AND MANAGE THE REGIONAL CENTER.PIPER CONDUCTED A CURSORY INQUIRY INTO THE PROJECTIONSPROVIDED BY THE COMPANY, DID NOT INQUIRE ABOUT PRIORPROJECTIONS OR REVISIONS, AND DID NOT ASK TO SEE ANINDEPENDENT CONSULTANT'S REVIEW OF THE PROJECTIONS DESPITEBEING MADE AWARE OF ITS EXISTENCE, DEPRIVING BAN PURCHASERSOF MATERIAL INFORMATION RELATING TO THE REVENUE PROJECTIONS,THE FIRST SOURCE OF PAYMENT FOR THE MAJORITY OF THE BANS.AN INDEPENDENT CONSULTANT HAD BEEN ASKED TO REVIEW THECOMPANY'S EARLIER PROJECTIONS AND HAD RAISED QUESTIONS ABOUTTHE REGIONAL CENTER'S ECONOMIC VIABILITY. DESPITE TWO SEPARATEREVIEWS OF PRIOR COMPANY PROJECTIONS BY THE INDEPENDENTCONSULTANT, THE OFFICIAL STATEMENT PRESENTED THE MOST RECENTVERSION OF THE COMPANY'S PROJECTIONS ALONG WITH A FALSE ANDMISLEADING STATEMENT TO THE EFFECT THAT NO FINANCIAL ADVISOR,ACCOUNTING OR OTHER FIRM HAD EXAMINED THOSE PROJECTIONS TOVERIFY THE REASONABLENESS OF THE COMPANY'S ASSUMPTIONS ORITS CONCLUSIONS.PIPER WAS UNAWARE THAT THE PROJECTIONS IN THE OFFICIALSTATEMENT HAD BEEN REVISED UPWARD FROM PROJECTIONSGENERATED A FEW MONTHS EARLIER AFTER A CLAIM BY THE CITY'SFORMER MAYOR AND THE DISTRICT'S CONTRACT MANAGER THAT THECOMPANY'S PROJECTIONS WERE INCONSISTENT WITH ITS PRIORPROJECTIONS AND NOT SUFFICIENTLY OPTIMISTIC. DURING ACONFERENCE CALL WITH THE COMPANY'S PRESIDENT AND THECOMPANY'S FINANCIAL CONSULTANT, THE CITY'S FORMER MAYOR MADEAN IMPASSIONED ARGUMENT THAT THEY KNEW THE LOCAL CITIZENSBETTER THAN THE COMPANY, (CONTINUED IN COMMENT)342018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSIONPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 11/05/2013Docket/Case Number: 3-15603Principal Product Type: Debt - MunicipalOther Product Type(s): BOND ANTICIPATION NOTESSEC ADMIN RELEASES 33-9472, 34-70804, NOVEMBER 5, 2013: THESECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT") AND SECTIONS 15(B) AND 15(B)(C)(2) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST PIPERJAFFRAY & CO. ("PIPER").THE COMMISSION FOUND THAT IN 2011, A MUNICIPAL CORPORATION("DISTRICT") DEFAULTED ON $41.77 MILLION IN BOND ANTICIPATIONNOTES ("BANS") IT HAD ISSUED IN NOVEMBER 2008 TO FINANCE A MULTI-USE ARENA AND ICE HOCKEY RINK (THE "REGIONAL CENTER") LOCATEDIN THE CITY OF WENATCHEE, WASHINGTON (THE "CITY"). PIPER SERVEDAS SOLE UNDERWRITER FOR THE BANS. THE OFFICIAL STATEMENT FORTHE BANS WAS MATERIALLY FALSE AND MISLEADING.PIPER WAS HIRED BY THE DISTRICT AS UNDERWRITER AS A LAST MINUTEREPLACEMENT FOR A PREDECESSOR UNDERWRITING FIRM("PREDECESSOR"). THE PREDECESSOR HAD BEEN WORKING WITH THEDISTRICT FOR OVER A YEAR AND HAD COMPLETED A PRELIMINARYOFFICIAL STATEMENT FOR LONG-TERM BONDS WHICH HAD RECEIVED ANINVESTMENT GRADE RATING. THAT PREDECESSOR WITHDREW INSEPTEMBER 2008 AFTER THE GLOBAL FINANCIAL CRISIS PREVENTEDACCESS TO THE BOND MARKET AND THE FIRM WAS UNABLE TOCOMPLETE THE FINANCING. PIPER'S ENGAGEMENT WITH THE DISTRICTSTARTED ON OCTOBER 27, 2008. BY THE TIME PIPER BECAME THEUNDERWRITER ON THE DEAL, THE CITY AND THE DISTRICT WEREDESPERATE TO FIND FINANCING FOR THE REGIONAL CENTER WITHIN AMONTH BECAUSE OF ONEROUS LEASE PAYMENTS BEING DEMANDED BYTHE CONSTRUCTION LENDER. PIPER SUGGESTED SEVERAL FINANCINGOPTIONS, ALTHOUGH ONLY ONE, SHORT-TERM BANS, WAS CONSIDEREDVIABLE. THE DISTRICT DETERMINED TO ISSUE THREE YEAR BANS THATWOULD MATURE IN 2011, WITH THE PRINCIPAL OF THE BANS TO BEREPAID SOLELY THROUGH THE ISSUANCE OF LONG-TERM BONDS.PIPER CONDUCTED INADEQUATE DUE DILIGENCE AND, AS A RESULT,FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THETRUTHFULNESS AND COMPLETENESS OF MATERIAL STATEMENTS IN THEOFFICIAL STATEMENT. THE OFFICIAL STATEMENT FOR THE BANS WAS ALIGHTLY REVISED VERSION OF THE PRELIMINARY OFFICIAL STATEMENTPREPARED BY THE PREDECESSOR AND THE DISTRICT'S BOND COUNSELTHAT INCLUDED SIMILAR DISCLOSURES AND RELIED ON THE SAMEPROJECTIONS FOR THE REGIONAL CENTER PROVIDED BY THE COMPANY("COMPANY") HIRED TO DEVELOP AND MANAGE THE REGIONAL CENTER.PIPER CONDUCTED A CURSORY INQUIRY INTO THE PROJECTIONSPROVIDED BY THE COMPANY, DID NOT INQUIRE ABOUT PRIORPROJECTIONS OR REVISIONS, AND DID NOT ASK TO SEE ANINDEPENDENT CONSULTANT'S REVIEW OF THE PROJECTIONS DESPITEBEING MADE AWARE OF ITS EXISTENCE, DEPRIVING BAN PURCHASERSOF MATERIAL INFORMATION RELATING TO THE REVENUE PROJECTIONS,THE FIRST SOURCE OF PAYMENT FOR THE MAJORITY OF THE BANS.AN INDEPENDENT CONSULTANT HAD BEEN ASKED TO REVIEW THECOMPANY'S EARLIER PROJECTIONS AND HAD RAISED QUESTIONS ABOUTTHE REGIONAL CENTER'S ECONOMIC VIABILITY. DESPITE TWO SEPARATEREVIEWS OF PRIOR COMPANY PROJECTIONS BY THE INDEPENDENTCONSULTANT, THE OFFICIAL STATEMENT PRESENTED THE MOST RECENTVERSION OF THE COMPANY'S PROJECTIONS ALONG WITH A FALSE ANDMISLEADING STATEMENT TO THE EFFECT THAT NO FINANCIAL ADVISOR,ACCOUNTING OR OTHER FIRM HAD EXAMINED THOSE PROJECTIONS TOVERIFY THE REASONABLENESS OF THE COMPANY'S ASSUMPTIONS ORITS CONCLUSIONS.PIPER WAS UNAWARE THAT THE PROJECTIONS IN THE OFFICIALSTATEMENT HAD BEEN REVISED UPWARD FROM PROJECTIONSGENERATED A FEW MONTHS EARLIER AFTER A CLAIM BY THE CITY'SFORMER MAYOR AND THE DISTRICT'S CONTRACT MANAGER THAT THECOMPANY'S PROJECTIONS WERE INCONSISTENT WITH ITS PRIORPROJECTIONS AND NOT SUFFICIENTLY OPTIMISTIC. DURING ACONFERENCE CALL WITH THE COMPANY'S PRESIDENT AND THECOMPANY'S FINANCIAL CONSULTANT, THE CITY'S FORMER MAYOR MADEAN IMPASSIONED ARGUMENT THAT THEY KNEW THE LOCAL CITIZENSBETTER THAN THE COMPANY, (CONTINUED IN COMMENT)Resolution Date: 11/05/2013Resolution:Other Sanctions Ordered: UNDERTAKINGSSanction Details: THE COMMISSION DEEMED IT APPROPRIATE, IN THE PUBLIC INTEREST,AND FOR THE PROTECTION OF INVESTORS TO IMPOSE THE SANCTIONSAGREED TO IN PIPER'S OFFER. ACCORDINGLY, PURSUANT SECTION 8A OFTHE SECURITIES ACT AND SECTIONS 15(B) AND 15(B)(C) OF THEEXCHANGE ACT, IT IS HEREBY ORDERED THAT PIPER SHALL CEASE ANDDESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANYFUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND (3) OF THE SECURITIESACT. PIPER IS CENSURED. PIPER SHALL PAY A CIVIL MONEY PENALTY INTHE AMOUNT OF $300,000. PIPER SHALL COMPLY WITH THEUNDERTAKINGS ENUMERATED IN THE ORDER.Regulator Statement (CONTINUED FROM #7) AND THOSE CITIZENS WOULD ULTIMATELYSUPPORT THE REGIONAL CENTER EVEN THOUGH THE COMPANY WASEXPERIENCING WEAK TICKET SALES AND OTHER TROUBLING INDICATORSREGARDING ANTICIPATED REVENUE. THE COMPANY REVISED ITSPROJECTIONS UPWARD AND THE MORE OPTIMISTIC REVISEDPROJECTIONS WERE INCLUDED IN THE OFFICIAL STATEMENT, WITHOUTDISCLOSING THAT THE CITY'S FORMER MAYOR OR THE DISTRICT'SCONTRACT MANAGER HAD QUESTIONED THE ASSUMPTIONS UNDERLYINGTHE PRIOR SET OF PROJECTIONS, OR THAT THE COMPANY HAD RELIEDON THE FORMER MAYOR'S VERBAL ASSERTIONS OF FUTURE COMMUNITYSUPPORT.PIPER STATED THAT THEY FOCUSED THEIR DUE DILIGENCE EFFORTS ONA CONTINGENT LOAN AGREEMENT ENTERED INTO BY THE CITY THATOPERATED AS A BACKSTOP FOR THE PAYMENT OF THE INTEREST (BUTNOT THE PRINCIPAL) ON THE BANS, AND THE CITY'S ABILITY TO MAKEPAYMENTS IF NECESSARY. UNDER THAT CONTINGENT LOAN AGREEMENT,THE CITY WAS OBLIGATED TO LOAN TO THE DISTRICT FUNDS TO PAYINTEREST ON THE BANS IN THE EVENT THE DISTRICT'S REVENUES WEREINSUFFICIENT. NONETHELESS, A PARAGRAPH IN THE BODY OF THEPREDECESSOR'S PRELIMINARY OFFICIAL STATEMENT THAT HIGHLIGHTEDHOW THE CITY'S LOW REMAINING DEBT CAPACITY CONSTRAINED ITSOBLIGATIONS UNDER THAT CONTINGENT LOAN AGREEMENT WASDELETED FROM THE BODY OF THE OFFICIAL STATEMENT FOR THE BANS,THEREBY MISLEADING BAN PURCHASERS CONCERNING THE LIKELIHOODOF PERMANENT FINANCING.THE REGIONAL CENTER'S FINANCIAL RESULTS FOR 2008 THROUGH 2011WERE WORSE THAN THE COMPANY'S MOST PESSIMISTIC PROJECTIONS,WITH THE REGIONAL CENTER OPERATING AT A SIGNIFICANT NETOPERATING LOSS. MOREOVER, AFTER THE CITY FILED A VALIDATIONPROCEEDING, THE CHELAN COUNTY, WASHINGTON, SUPERIOR COURTRULED IN 2011 THAT OBLIGATIONS UNDER A CONTINGENT LOANAGREEMENT CONSTITUTED "INDEBTEDNESS" WITHIN THE MEANING OFTHE STATE CONSTITUTION AND THEREFORE WOULD BE LIMITED TO THECITY'S REMAINING DEBT CAPACITY OF $19.3 MILLION, AS THE DELETEDDISCLOSURE LANGUAGE HAD WARNED. CONSEQUENTLY, THE DISTRICTWAS UNABLE TO ISSUE LONG-TERM BONDS, AND THE DISTRICTDEFAULTED ON THE PAYMENT OF PRINCIPAL ON THE BANS IN DECEMBER2011.THE WASHINGTON STATE LEGISLATURE SUBSEQUENTLY PASSEDLEGISLATION TO HELP THE DISTRICT CURE ITS DEFAULT BY ALLOWINGTHE CITY TO IMPOSE AN ADDITIONAL SALES TAX WITHOUT VOTERAPPROVAL AND FURTHER ALLOWING THE DISTRICT TO SUBMIT TOVOTERS A PROPOSITION TO IMPOSE AN ADDITIONAL SALES TAX. THEVOTERS OF THE DISTRICT LATER APPROVED AN ADDITIONAL SALES TAX.ON SEPTEMBER 28, 2012, THE DISTRICT SOLD LONG-TERM BONDSSECURED SOLELY BY SALES TAX REVENUES TO REFINANCE THE BANS.AS A RESULT OF THE NEGLIGENT CONDUCT, PIPER WILLFULLY VIOLATEDSECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT.IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS, PIPERSUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THECOMMISSION DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED,PIPER CONSENTED TO THE ENTRY OF THE ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTIONS 15(B) AND15(B)(C) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS,AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER("ORDER").Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $300,000.00Cease and Desist/InjunctionOrder352018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceRegulator Statement (CONTINUED FROM #7) AND THOSE CITIZENS WOULD ULTIMATELYSUPPORT THE REGIONAL CENTER EVEN THOUGH THE COMPANY WASEXPERIENCING WEAK TICKET SALES AND OTHER TROUBLING INDICATORSREGARDING ANTICIPATED REVENUE. THE COMPANY REVISED ITSPROJECTIONS UPWARD AND THE MORE OPTIMISTIC REVISEDPROJECTIONS WERE INCLUDED IN THE OFFICIAL STATEMENT, WITHOUTDISCLOSING THAT THE CITY'S FORMER MAYOR OR THE DISTRICT'SCONTRACT MANAGER HAD QUESTIONED THE ASSUMPTIONS UNDERLYINGTHE PRIOR SET OF PROJECTIONS, OR THAT THE COMPANY HAD RELIEDON THE FORMER MAYOR'S VERBAL ASSERTIONS OF FUTURE COMMUNITYSUPPORT.PIPER STATED THAT THEY FOCUSED THEIR DUE DILIGENCE EFFORTS ONA CONTINGENT LOAN AGREEMENT ENTERED INTO BY THE CITY THATOPERATED AS A BACKSTOP FOR THE PAYMENT OF THE INTEREST (BUTNOT THE PRINCIPAL) ON THE BANS, AND THE CITY'S ABILITY TO MAKEPAYMENTS IF NECESSARY. UNDER THAT CONTINGENT LOAN AGREEMENT,THE CITY WAS OBLIGATED TO LOAN TO THE DISTRICT FUNDS TO PAYINTEREST ON THE BANS IN THE EVENT THE DISTRICT'S REVENUES WEREINSUFFICIENT. NONETHELESS, A PARAGRAPH IN THE BODY OF THEPREDECESSOR'S PRELIMINARY OFFICIAL STATEMENT THAT HIGHLIGHTEDHOW THE CITY'S LOW REMAINING DEBT CAPACITY CONSTRAINED ITSOBLIGATIONS UNDER THAT CONTINGENT LOAN AGREEMENT WASDELETED FROM THE BODY OF THE OFFICIAL STATEMENT FOR THE BANS,THEREBY MISLEADING BAN PURCHASERS CONCERNING THE LIKELIHOODOF PERMANENT FINANCING.THE REGIONAL CENTER'S FINANCIAL RESULTS FOR 2008 THROUGH 2011WERE WORSE THAN THE COMPANY'S MOST PESSIMISTIC PROJECTIONS,WITH THE REGIONAL CENTER OPERATING AT A SIGNIFICANT NETOPERATING LOSS. MOREOVER, AFTER THE CITY FILED A VALIDATIONPROCEEDING, THE CHELAN COUNTY, WASHINGTON, SUPERIOR COURTRULED IN 2011 THAT OBLIGATIONS UNDER A CONTINGENT LOANAGREEMENT CONSTITUTED "INDEBTEDNESS" WITHIN THE MEANING OFTHE STATE CONSTITUTION AND THEREFORE WOULD BE LIMITED TO THECITY'S REMAINING DEBT CAPACITY OF $19.3 MILLION, AS THE DELETEDDISCLOSURE LANGUAGE HAD WARNED. CONSEQUENTLY, THE DISTRICTWAS UNABLE TO ISSUE LONG-TERM BONDS, AND THE DISTRICTDEFAULTED ON THE PAYMENT OF PRINCIPAL ON THE BANS IN DECEMBER2011.THE WASHINGTON STATE LEGISLATURE SUBSEQUENTLY PASSEDLEGISLATION TO HELP THE DISTRICT CURE ITS DEFAULT BY ALLOWINGTHE CITY TO IMPOSE AN ADDITIONAL SALES TAX WITHOUT VOTERAPPROVAL AND FURTHER ALLOWING THE DISTRICT TO SUBMIT TOVOTERS A PROPOSITION TO IMPOSE AN ADDITIONAL SALES TAX. THEVOTERS OF THE DISTRICT LATER APPROVED AN ADDITIONAL SALES TAX.ON SEPTEMBER 28, 2012, THE DISTRICT SOLD LONG-TERM BONDSSECURED SOLELY BY SALES TAX REVENUES TO REFINANCE THE BANS.AS A RESULT OF THE NEGLIGENT CONDUCT, PIPER WILLFULLY VIOLATEDSECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT.IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS, PIPERSUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THECOMMISSION DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED,PIPER CONSENTED TO THE ENTRY OF THE ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTIONS 15(B) AND15(B)(C) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS,AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER("ORDER").362018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User Guidance(CONTINUED FROM #7) AND THOSE CITIZENS WOULD ULTIMATELYSUPPORT THE REGIONAL CENTER EVEN THOUGH THE COMPANY WASEXPERIENCING WEAK TICKET SALES AND OTHER TROUBLING INDICATORSREGARDING ANTICIPATED REVENUE. THE COMPANY REVISED ITSPROJECTIONS UPWARD AND THE MORE OPTIMISTIC REVISEDPROJECTIONS WERE INCLUDED IN THE OFFICIAL STATEMENT, WITHOUTDISCLOSING THAT THE CITY'S FORMER MAYOR OR THE DISTRICT'SCONTRACT MANAGER HAD QUESTIONED THE ASSUMPTIONS UNDERLYINGTHE PRIOR SET OF PROJECTIONS, OR THAT THE COMPANY HAD RELIEDON THE FORMER MAYOR'S VERBAL ASSERTIONS OF FUTURE COMMUNITYSUPPORT.PIPER STATED THAT THEY FOCUSED THEIR DUE DILIGENCE EFFORTS ONA CONTINGENT LOAN AGREEMENT ENTERED INTO BY THE CITY THATOPERATED AS A BACKSTOP FOR THE PAYMENT OF THE INTEREST (BUTNOT THE PRINCIPAL) ON THE BANS, AND THE CITY'S ABILITY TO MAKEPAYMENTS IF NECESSARY. UNDER THAT CONTINGENT LOAN AGREEMENT,THE CITY WAS OBLIGATED TO LOAN TO THE DISTRICT FUNDS TO PAYINTEREST ON THE BANS IN THE EVENT THE DISTRICT'S REVENUES WEREINSUFFICIENT. NONETHELESS, A PARAGRAPH IN THE BODY OF THEPREDECESSOR'S PRELIMINARY OFFICIAL STATEMENT THAT HIGHLIGHTEDHOW THE CITY'S LOW REMAINING DEBT CAPACITY CONSTRAINED ITSOBLIGATIONS UNDER THAT CONTINGENT LOAN AGREEMENT WASDELETED FROM THE BODY OF THE OFFICIAL STATEMENT FOR THE BANS,THEREBY MISLEADING BAN PURCHASERS CONCERNING THE LIKELIHOODOF PERMANENT FINANCING.THE REGIONAL CENTER'S FINANCIAL RESULTS FOR 2008 THROUGH 2011WERE WORSE THAN THE COMPANY'S MOST PESSIMISTIC PROJECTIONS,WITH THE REGIONAL CENTER OPERATING AT A SIGNIFICANT NETOPERATING LOSS. MOREOVER, AFTER THE CITY FILED A VALIDATIONPROCEEDING, THE CHELAN COUNTY, WASHINGTON, SUPERIOR COURTRULED IN 2011 THAT OBLIGATIONS UNDER A CONTINGENT LOANAGREEMENT CONSTITUTED "INDEBTEDNESS" WITHIN THE MEANING OFTHE STATE CONSTITUTION AND THEREFORE WOULD BE LIMITED TO THECITY'S REMAINING DEBT CAPACITY OF $19.3 MILLION, AS THE DELETEDDISCLOSURE LANGUAGE HAD WARNED. CONSEQUENTLY, THE DISTRICTWAS UNABLE TO ISSUE LONG-TERM BONDS, AND THE DISTRICTDEFAULTED ON THE PAYMENT OF PRINCIPAL ON THE BANS IN DECEMBER2011.THE WASHINGTON STATE LEGISLATURE SUBSEQUENTLY PASSEDLEGISLATION TO HELP THE DISTRICT CURE ITS DEFAULT BY ALLOWINGTHE CITY TO IMPOSE AN ADDITIONAL SALES TAX WITHOUT VOTERAPPROVAL AND FURTHER ALLOWING THE DISTRICT TO SUBMIT TOVOTERS A PROPOSITION TO IMPOSE AN ADDITIONAL SALES TAX. THEVOTERS OF THE DISTRICT LATER APPROVED AN ADDITIONAL SALES TAX.ON SEPTEMBER 28, 2012, THE DISTRICT SOLD LONG-TERM BONDSSECURED SOLELY BY SALES TAX REVENUES TO REFINANCE THE BANS.AS A RESULT OF THE NEGLIGENT CONDUCT, PIPER WILLFULLY VIOLATEDSECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT.IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS, PIPERSUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THECOMMISSION DETERMINED TO ACCEPT. SOLELY FOR THEPURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGSBROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THECOMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THEFINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT ANDTHE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED,PIPER CONSENTED TO THE ENTRY OF THE ORDER INSTITUTINGADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TOSECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTIONS 15(B) AND15(B)(C) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS,AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER("ORDER").iReporting Source: FirmAllegations: SEC ADMIN RELEASES 33-9472, 34-70804, NOVEMBER 5, 2013: THESECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT") AND SECTIONS 15(B) AND 15(B)(C)(2) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST PIPERJAFFRAY & CO. ("PIPER"). THE COMMISSION FOUND THAT IN 2011, AMUNICIPAL CORPORATION ("DISTRICT") DEFAULTED ON $41.77 MILLION INBOND ANTICIPATION NOTES ("BANS") IT HAD ISSUED IN NOVEMBER 2008TO FINANCE A MULTI-USE ARENA AND ICE HOCKEY RINK (THE "REGIONALCENTER") LOCATED IN THE CITY OF WENATCHEE, WASHINGTON (THE "CITY"). PIPER SERVED AS SOLE UNDERWRITER FOR THE BANS. THEOFFICIAL STATEMENT FOR THE BANS WAS MATERIALLY FALSE ANDMISLEADING. PIPER WAS HIRED BY THE DISTRICT AS UNDERWRITER AS ALAST MINUTE REPLACEMENT FOR A PREDECESSOR UNDERWRITING FIRM("PREDECESSOR"). THE PREDECESSOR HAD BEEN WORKING WITH THEDISTRICT FOR OVER A YEAR AND HAD COMPLETED A PRELIMINARYOFFICIAL STATEMENT FOR LONG-TERM BONDS WHICH HAD RECEIVED ANINVESTMENT GRADE RATING. THAT PREDECESSOR WITHDREW INSEPTEMBER 2008 AFTER THE GLOBAL FINANCIAL CRISIS PREVENTEDACCESS TO THE BOND MARKET AND THE FIRM WAS UNABLE TOCOMPLETE THE FINANCING. PIPER'S ENGAGEMENT WITH THE DISTRICTSTARTED ON OCTOBER 27, 2008. BY THE TIME PIPER BECAME THEUNDERWRITER ON THE DEAL, THE CITY AND THE DISTRICT WEREDESPERATE TO FIND FINANCING FOR THE REGIONAL CENTER WITHIN AMONTH BECAUSE OF ONEROUS LEASE PAYMENTS BEING DEMANDED BYTHE CONSTRUCTION LENDER. PIPER SUGGESTED SEVERAL FINANCINGOPTIONS, ALTHOUGH ONLY ONE, SHORT-TERM BANS, WAS CONSIDEREDVIABLE. THE DISTRICT DETERMINED TO ISSUE THREE YEAR BANS THATWOULD MATURE IN 2011, WITH THE PRINCIPAL OF THE BANS TO BEREPAID SOLELY THROUGH THE ISSUANCE OF LONG-TERM BONDS. PIPERCONDUCTED INADEQUATE DUE DILIGENCE AND, AS A RESULT, FAILED TOFORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS ANDCOMPLETENESS OF MATERIAL STATEMENTS IN THE OFFICIAL STATEMENT.THE OFFICIAL STATEMENT FOR THE BANS WAS A LIGHTLY REVISEDVERSION OF THE PRELIMINARY OFFICIAL STATEMENT PREPARED BY THEPREDECESSOR AND THE DISTRICT'S BOND COUNSEL THAT INCLUDEDSIMILAR DISCLOSURES AND RELIED ON THE SAME PROJECTIONS FORTHE REGIONAL CENTER PROVIDED BY THE COMPANY ("COMPANY") HIREDTO DEVELOP AND MANAGE THE REGIONAL CENTER. PIPER CONDUCTED ACURSORY INQUIRY INTO THE PROJECTIONS PROVIDED BY THE COMPANY,DID NOT INQUIRE ABOUT PRIOR PROJECTIONS OR REVISIONS, AND DIDNOT ASK TO SEE AN INDEPENDENT CONSULTANT'S REVIEW OF THEPROJECTIONS DESPITE BEING MADE AWARE OF ITS EXISTENCE,DEPRIVING BAN PURCHASERS OF MATERIAL INFORMATION RELATING TOTHE REVENUE PROJECTIONS, THE FIRST SOURCE OF PAYMENT FOR THEMAJORITY OF THE BANS. AN INDEPENDENT CONSULTANT HAD BEENASKED TO REVIEW THE COMPANY'S EARLIER PROJECTIONS AND HADRAISED QUESTIONS ABOUT THE REGIONAL CENTER'S ECONOMICVIABILITY. DESPITE TWO SEPARATE REVIEWS OF PRIOR COMPANYPROJECTIONS BY THE INDEPENDENT CONSULTANT, THE OFFICIALSTATEMENT PRESENTED THE MOST RECENT VERSION OF THECOMPANY'S PROJECTIONS ALONG WITH A FALSE AND MISLEADINGSTATEMENT TO THE EFFECT THAT NO FINANCIAL ADVISOR, ACCOUNTINGOR OTHER FIRM HAD EXAMINED THOSE PROJECTIONS TO VERIFY THEREASONABLENESS OF THE COMPANY'S ASSUMPTIONS OR ITSCONCLUSIONS. PIPER WAS UNAWARE THAT THE PROJECTIONS IN THEOFFICIAL STATEMENT HAD BEEN REVISED UPWARD FROM PROJECTIONSGENERATED A FEW MONTHS EARLIER AFTER A CLAIM BY THE CITY'SFORMER MAYOR AND THE DISTRICT'S CONTRACT MANAGER THAT THECOMPANY'S PROJECTIONS WERE INCONSISTENT WITH ITS PRIORPROJECTIONS AND NOT SUFFICIENTLY OPTIMISTIC. DURING ACONFERENCE CALL WITH THE COMPANY'S PRESIDENT AND THECOMPANY'S FINANCIAL CONSULTANT, THE CITY'S FORMER MAYOR MADEAN IMPASSIONED ARGUMENT THAT THEY KNEW THE LOCAL CITIZENSBETTER THAN THE COMPANY, (CONTINUED IN COMMENT)Current Status: Final372018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceSEC ADMIN RELEASES 33-9472, 34-70804, NOVEMBER 5, 2013: THESECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT") AND SECTIONS 15(B) AND 15(B)(C)(2) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST PIPERJAFFRAY & CO. ("PIPER"). THE COMMISSION FOUND THAT IN 2011, AMUNICIPAL CORPORATION ("DISTRICT") DEFAULTED ON $41.77 MILLION INBOND ANTICIPATION NOTES ("BANS") IT HAD ISSUED IN NOVEMBER 2008TO FINANCE A MULTI-USE ARENA AND ICE HOCKEY RINK (THE "REGIONALCENTER") LOCATED IN THE CITY OF WENATCHEE, WASHINGTON (THE "CITY"). PIPER SERVED AS SOLE UNDERWRITER FOR THE BANS. THEOFFICIAL STATEMENT FOR THE BANS WAS MATERIALLY FALSE ANDMISLEADING. PIPER WAS HIRED BY THE DISTRICT AS UNDERWRITER AS ALAST MINUTE REPLACEMENT FOR A PREDECESSOR UNDERWRITING FIRM("PREDECESSOR"). THE PREDECESSOR HAD BEEN WORKING WITH THEDISTRICT FOR OVER A YEAR AND HAD COMPLETED A PRELIMINARYOFFICIAL STATEMENT FOR LONG-TERM BONDS WHICH HAD RECEIVED ANINVESTMENT GRADE RATING. THAT PREDECESSOR WITHDREW INSEPTEMBER 2008 AFTER THE GLOBAL FINANCIAL CRISIS PREVENTEDACCESS TO THE BOND MARKET AND THE FIRM WAS UNABLE TOCOMPLETE THE FINANCING. PIPER'S ENGAGEMENT WITH THE DISTRICTSTARTED ON OCTOBER 27, 2008. BY THE TIME PIPER BECAME THEUNDERWRITER ON THE DEAL, THE CITY AND THE DISTRICT WEREDESPERATE TO FIND FINANCING FOR THE REGIONAL CENTER WITHIN AMONTH BECAUSE OF ONEROUS LEASE PAYMENTS BEING DEMANDED BYTHE CONSTRUCTION LENDER. PIPER SUGGESTED SEVERAL FINANCINGOPTIONS, ALTHOUGH ONLY ONE, SHORT-TERM BANS, WAS CONSIDEREDVIABLE. THE DISTRICT DETERMINED TO ISSUE THREE YEAR BANS THATWOULD MATURE IN 2011, WITH THE PRINCIPAL OF THE BANS TO BEREPAID SOLELY THROUGH THE ISSUANCE OF LONG-TERM BONDS. PIPERCONDUCTED INADEQUATE DUE DILIGENCE AND, AS A RESULT, FAILED TOFORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS ANDCOMPLETENESS OF MATERIAL STATEMENTS IN THE OFFICIAL STATEMENT.THE OFFICIAL STATEMENT FOR THE BANS WAS A LIGHTLY REVISEDVERSION OF THE PRELIMINARY OFFICIAL STATEMENT PREPARED BY THEPREDECESSOR AND THE DISTRICT'S BOND COUNSEL THAT INCLUDEDSIMILAR DISCLOSURES AND RELIED ON THE SAME PROJECTIONS FORTHE REGIONAL CENTER PROVIDED BY THE COMPANY ("COMPANY") HIREDTO DEVELOP AND MANAGE THE REGIONAL CENTER. PIPER CONDUCTED ACURSORY INQUIRY INTO THE PROJECTIONS PROVIDED BY THE COMPANY,DID NOT INQUIRE ABOUT PRIOR PROJECTIONS OR REVISIONS, AND DIDNOT ASK TO SEE AN INDEPENDENT CONSULTANT'S REVIEW OF THEPROJECTIONS DESPITE BEING MADE AWARE OF ITS EXISTENCE,DEPRIVING BAN PURCHASERS OF MATERIAL INFORMATION RELATING TOTHE REVENUE PROJECTIONS, THE FIRST SOURCE OF PAYMENT FOR THEMAJORITY OF THE BANS. AN INDEPENDENT CONSULTANT HAD BEENASKED TO REVIEW THE COMPANY'S EARLIER PROJECTIONS AND HADRAISED QUESTIONS ABOUT THE REGIONAL CENTER'S ECONOMICVIABILITY. DESPITE TWO SEPARATE REVIEWS OF PRIOR COMPANYPROJECTIONS BY THE INDEPENDENT CONSULTANT, THE OFFICIALSTATEMENT PRESENTED THE MOST RECENT VERSION OF THECOMPANY'S PROJECTIONS ALONG WITH A FALSE AND MISLEADINGSTATEMENT TO THE EFFECT THAT NO FINANCIAL ADVISOR, ACCOUNTINGOR OTHER FIRM HAD EXAMINED THOSE PROJECTIONS TO VERIFY THEREASONABLENESS OF THE COMPANY'S ASSUMPTIONS OR ITSCONCLUSIONS. PIPER WAS UNAWARE THAT THE PROJECTIONS IN THEOFFICIAL STATEMENT HAD BEEN REVISED UPWARD FROM PROJECTIONSGENERATED A FEW MONTHS EARLIER AFTER A CLAIM BY THE CITY'SFORMER MAYOR AND THE DISTRICT'S CONTRACT MANAGER THAT THECOMPANY'S PROJECTIONS WERE INCONSISTENT WITH ITS PRIORPROJECTIONS AND NOT SUFFICIENTLY OPTIMISTIC. DURING ACONFERENCE CALL WITH THE COMPANY'S PRESIDENT AND THECOMPANY'S FINANCIAL CONSULTANT, THE CITY'S FORMER MAYOR MADEAN IMPASSIONED ARGUMENT THAT THEY KNEW THE LOCAL CITIZENSBETTER THAN THE COMPANY, (CONTINUED IN COMMENT)382018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSIONPrincipal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:MONETARY/FINE, CENSURE, UNDERTAKINGSDate Initiated: 11/05/2013Docket/Case Number: 3-15603Principal Product Type: Debt - MunicipalOther Product Type(s): BOND ANTICIPATION NOTESSEC ADMIN RELEASES 33-9472, 34-70804, NOVEMBER 5, 2013: THESECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTEDPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933("SECURITIES ACT") AND SECTIONS 15(B) AND 15(B)(C)(2) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST PIPERJAFFRAY & CO. ("PIPER"). THE COMMISSION FOUND THAT IN 2011, AMUNICIPAL CORPORATION ("DISTRICT") DEFAULTED ON $41.77 MILLION INBOND ANTICIPATION NOTES ("BANS") IT HAD ISSUED IN NOVEMBER 2008TO FINANCE A MULTI-USE ARENA AND ICE HOCKEY RINK (THE "REGIONALCENTER") LOCATED IN THE CITY OF WENATCHEE, WASHINGTON (THE "CITY"). PIPER SERVED AS SOLE UNDERWRITER FOR THE BANS. THEOFFICIAL STATEMENT FOR THE BANS WAS MATERIALLY FALSE ANDMISLEADING. PIPER WAS HIRED BY THE DISTRICT AS UNDERWRITER AS ALAST MINUTE REPLACEMENT FOR A PREDECESSOR UNDERWRITING FIRM("PREDECESSOR"). THE PREDECESSOR HAD BEEN WORKING WITH THEDISTRICT FOR OVER A YEAR AND HAD COMPLETED A PRELIMINARYOFFICIAL STATEMENT FOR LONG-TERM BONDS WHICH HAD RECEIVED ANINVESTMENT GRADE RATING. THAT PREDECESSOR WITHDREW INSEPTEMBER 2008 AFTER THE GLOBAL FINANCIAL CRISIS PREVENTEDACCESS TO THE BOND MARKET AND THE FIRM WAS UNABLE TOCOMPLETE THE FINANCING. PIPER'S ENGAGEMENT WITH THE DISTRICTSTARTED ON OCTOBER 27, 2008. BY THE TIME PIPER BECAME THEUNDERWRITER ON THE DEAL, THE CITY AND THE DISTRICT WEREDESPERATE TO FIND FINANCING FOR THE REGIONAL CENTER WITHIN AMONTH BECAUSE OF ONEROUS LEASE PAYMENTS BEING DEMANDED BYTHE CONSTRUCTION LENDER. PIPER SUGGESTED SEVERAL FINANCINGOPTIONS, ALTHOUGH ONLY ONE, SHORT-TERM BANS, WAS CONSIDEREDVIABLE. THE DISTRICT DETERMINED TO ISSUE THREE YEAR BANS THATWOULD MATURE IN 2011, WITH THE PRINCIPAL OF THE BANS TO BEREPAID SOLELY THROUGH THE ISSUANCE OF LONG-TERM BONDS. PIPERCONDUCTED INADEQUATE DUE DILIGENCE AND, AS A RESULT, FAILED TOFORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS ANDCOMPLETENESS OF MATERIAL STATEMENTS IN THE OFFICIAL STATEMENT.THE OFFICIAL STATEMENT FOR THE BANS WAS A LIGHTLY REVISEDVERSION OF THE PRELIMINARY OFFICIAL STATEMENT PREPARED BY THEPREDECESSOR AND THE DISTRICT'S BOND COUNSEL THAT INCLUDEDSIMILAR DISCLOSURES AND RELIED ON THE SAME PROJECTIONS FORTHE REGIONAL CENTER PROVIDED BY THE COMPANY ("COMPANY") HIREDTO DEVELOP AND MANAGE THE REGIONAL CENTER. PIPER CONDUCTED ACURSORY INQUIRY INTO THE PROJECTIONS PROVIDED BY THE COMPANY,DID NOT INQUIRE ABOUT PRIOR PROJECTIONS OR REVISIONS, AND DIDNOT ASK TO SEE AN INDEPENDENT CONSULTANT'S REVIEW OF THEPROJECTIONS DESPITE BEING MADE AWARE OF ITS EXISTENCE,DEPRIVING BAN PURCHASERS OF MATERIAL INFORMATION RELATING TOTHE REVENUE PROJECTIONS, THE FIRST SOURCE OF PAYMENT FOR THEMAJORITY OF THE BANS. AN INDEPENDENT CONSULTANT HAD BEENASKED TO REVIEW THE COMPANY'S EARLIER PROJECTIONS AND HADRAISED QUESTIONS ABOUT THE REGIONAL CENTER'S ECONOMICVIABILITY. DESPITE TWO SEPARATE REVIEWS OF PRIOR COMPANYPROJECTIONS BY THE INDEPENDENT CONSULTANT, THE OFFICIALSTATEMENT PRESENTED THE MOST RECENT VERSION OF THECOMPANY'S PROJECTIONS ALONG WITH A FALSE AND MISLEADINGSTATEMENT TO THE EFFECT THAT NO FINANCIAL ADVISOR, ACCOUNTINGOR OTHER FIRM HAD EXAMINED THOSE PROJECTIONS TO VERIFY THEREASONABLENESS OF THE COMPANY'S ASSUMPTIONS OR ITSCONCLUSIONS. PIPER WAS UNAWARE THAT THE PROJECTIONS IN THEOFFICIAL STATEMENT HAD BEEN REVISED UPWARD FROM PROJECTIONSGENERATED A FEW MONTHS EARLIER AFTER A CLAIM BY THE CITY'SFORMER MAYOR AND THE DISTRICT'S CONTRACT MANAGER THAT THECOMPANY'S PROJECTIONS WERE INCONSISTENT WITH ITS PRIORPROJECTIONS AND NOT SUFFICIENTLY OPTIMISTIC. DURING ACONFERENCE CALL WITH THE COMPANY'S PRESIDENT AND THECOMPANY'S FINANCIAL CONSULTANT, THE CITY'S FORMER MAYOR MADEAN IMPASSIONED ARGUMENT THAT THEY KNEW THE LOCAL CITIZENSBETTER THAN THE COMPANY, (CONTINUED IN COMMENT)Resolution Date: 11/05/2013Resolution:Other Sanctions Ordered: UNDERTAKINGSSanction Details: PIPER JAFFRAY & CO. SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS17(A)(2) AND (3) OF THE SECURITIES ACT. PIPER IS CENSURED. PIPERSHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $300,000; ANDCOMPLY WITH UNDERTAKINGSFirm Statement (CONTINUED FROM #7) AND THOSE CITIZENS WOULD ULTIMATELYSUPPORT THE REGIONAL CENTER EVEN THOUGH THE COMPANY WASEXPERIENCING WEAK TICKET SALES AND OTHER TROUBLING INDICATORSREGARDING ANTICIPATED REVENUE. THE COMPANY REVISED ITSPROJECTIONS UPWARD AND THE MORE OPTIMISTIC REVISEDPROJECTIONS WERE INCLUDED IN THE OFFICIAL STATEMENT, WITHOUTDISCLOSING THAT THE CITY'S FORMER MAYOR OR THE DISTRICT'SCONTRACT MANAGER HAD QUESTIONED THE ASSUMPTIONS UNDERLYINGTHE PRIOR SET OF PROJECTIONS, OR THAT THE COMPANY HAD RELIEDON THE FORMER MAYOR'S VERBAL ASSERTIONS OF FUTURE COMMUNITYSUPPORT. PIPER STATED THAT THEY FOCUSED THEIR DUE DILIGENCEEFFORTS ON A CONTINGENT LOAN AGREEMENT ENTERED INTO BY THECITY THAT OPERATED AS A BACKSTOP FOR THE PAYMENT OF THEINTEREST (BUT NOT THE PRINCIPAL) ON THE BANS, AND THE CITY'SABILITY TO MAKE PAYMENTS IF NECESSARY. UNDER THAT CONTINGENTLOAN AGREEMENT, THE CITY WAS OBLIGATED TO LOAN TO THE DISTRICTFUNDS TO PAY INTEREST ON THE BANS IN THE EVENT THE DISTRICT'SREVENUES WERE INSUFFICIENT. NONETHELESS, A PARAGRAPH IN THEBODY OF THE PREDECESSOR'S PRELIMINARY OFFICIAL STATEMENT THATHIGHLIGHTED HOW THE CITY'S LOW REMAINING DEBT CAPACITYCONSTRAINED ITS OBLIGATIONS UNDER THAT CONTINGENT LOANAGREEMENT WAS DELETED FROM THE BODY OF THE OFFICIALSTATEMENT FOR THE BANS, THEREBY MISLEADING BAN PURCHASERSCONCERNING THE LIKELIHOOD OF PERMANENT FINANCING. THEREGIONAL CENTER'S FINANCIAL RESULTS FOR 2008 THROUGH 2011 WEREWORSE THAN THE COMPANY'S MOST PESSIMISTIC PROJECTIONS, WITHTHE REGIONAL CENTER OPERATING AT A SIGNIFICANT NET OPERATINGLOSS. MOREOVER, AFTER THE CITY FILED A VALIDATION PROCEEDING,THE CHELAN COUNTY, WASHINGTON, SUPERIOR COURT RULED IN 2011THAT OBLIGATIONS UNDER A CONTINGENT LOAN AGREEMENTCONSTITUTED "INDEBTEDNESS" WITHIN THE MEANING OF THE STATECONSTITUTION AND THEREFORE WOULD BE LIMITED TO THE CITY'SREMAINING DEBT CAPACITY OF $19.3 MILLION, AS THE DELETEDDISCLOSURE LANGUAGE HAD WARNED. CONSEQUENTLY, THE DISTRICTWAS UNABLE TO ISSUE LONG-TERM BONDS, AND THE DISTRICTDEFAULTED ON THE PAYMENT OF PRINCIPAL ON THE BANS IN DECEMBER2011. THE WASHINGTON STATE LEGISLATURE SUBSEQUENTLY PASSEDLEGISLATION TO HELP THE DISTRICT CURE ITS DEFAULT BY ALLOWINGTHE CITY TO IMPOSE AN ADDITIONAL SALES TAX WITHOUT VOTERAPPROVAL AND FURTHER ALLOWING THE DISTRICT TO SUBMIT TOVOTERS A PROPOSITION TO IMPOSE AN ADDITIONAL SALES TAX. THEVOTERS OF THE DISTRICT LATER APPROVED AN ADDITIONAL SALES TAX.ON SEPTEMBER 28, 2012, THE DISTRICT SOLD LONG-TERM BONDSSECURED SOLELY BY SALES TAX REVENUES TO REFINANCE THE BANS.AS A RESULT OF THE NEGLIGENT CONDUCT, PIPER WILLFULLY VIOLATEDSECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT. IN ANTICIPATION OFTHE INSTITUTION OF THE PROCEEDINGS, PIPER SUBMITTED AN OFFEROF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION DETERMINEDTO ACCEPT. SOLELY FOR THE PURPOSE OF THE PROCEEDINGS AND ANYOTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THECOMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUTADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THECOMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THEPROCEEDINGS, WHICH ARE ADMITTED, PIPER CONSENTED TO THE ENTRYOF THE ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESISTPROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF1933 AND SECTIONS 15(B) AND 15(B)(C) OF THE SECURITIES EXCHANGEACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONSAND A CEASE-AND-DESIST ORDER ("ORDER").Sanctions Ordered: CensureMonetary/Fine $300,000.00Cease and Desist/InjunctionOrder392018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User Guidance(CONTINUED FROM #7) AND THOSE CITIZENS WOULD ULTIMATELYSUPPORT THE REGIONAL CENTER EVEN THOUGH THE COMPANY WASEXPERIENCING WEAK TICKET SALES AND OTHER TROUBLING INDICATORSREGARDING ANTICIPATED REVENUE. THE COMPANY REVISED ITSPROJECTIONS UPWARD AND THE MORE OPTIMISTIC REVISEDPROJECTIONS WERE INCLUDED IN THE OFFICIAL STATEMENT, WITHOUTDISCLOSING THAT THE CITY'S FORMER MAYOR OR THE DISTRICT'SCONTRACT MANAGER HAD QUESTIONED THE ASSUMPTIONS UNDERLYINGTHE PRIOR SET OF PROJECTIONS, OR THAT THE COMPANY HAD RELIEDON THE FORMER MAYOR'S VERBAL ASSERTIONS OF FUTURE COMMUNITYSUPPORT. PIPER STATED THAT THEY FOCUSED THEIR DUE DILIGENCEEFFORTS ON A CONTINGENT LOAN AGREEMENT ENTERED INTO BY THECITY THAT OPERATED AS A BACKSTOP FOR THE PAYMENT OF THEINTEREST (BUT NOT THE PRINCIPAL) ON THE BANS, AND THE CITY'SABILITY TO MAKE PAYMENTS IF NECESSARY. UNDER THAT CONTINGENTLOAN AGREEMENT, THE CITY WAS OBLIGATED TO LOAN TO THE DISTRICTFUNDS TO PAY INTEREST ON THE BANS IN THE EVENT THE DISTRICT'SREVENUES WERE INSUFFICIENT. NONETHELESS, A PARAGRAPH IN THEBODY OF THE PREDECESSOR'S PRELIMINARY OFFICIAL STATEMENT THATHIGHLIGHTED HOW THE CITY'S LOW REMAINING DEBT CAPACITYCONSTRAINED ITS OBLIGATIONS UNDER THAT CONTINGENT LOANAGREEMENT WAS DELETED FROM THE BODY OF THE OFFICIALSTATEMENT FOR THE BANS, THEREBY MISLEADING BAN PURCHASERSCONCERNING THE LIKELIHOOD OF PERMANENT FINANCING. THEREGIONAL CENTER'S FINANCIAL RESULTS FOR 2008 THROUGH 2011 WEREWORSE THAN THE COMPANY'S MOST PESSIMISTIC PROJECTIONS, WITHTHE REGIONAL CENTER OPERATING AT A SIGNIFICANT NET OPERATINGLOSS. MOREOVER, AFTER THE CITY FILED A VALIDATION PROCEEDING,THE CHELAN COUNTY, WASHINGTON, SUPERIOR COURT RULED IN 2011THAT OBLIGATIONS UNDER A CONTINGENT LOAN AGREEMENTCONSTITUTED "INDEBTEDNESS" WITHIN THE MEANING OF THE STATECONSTITUTION AND THEREFORE WOULD BE LIMITED TO THE CITY'SREMAINING DEBT CAPACITY OF $19.3 MILLION, AS THE DELETEDDISCLOSURE LANGUAGE HAD WARNED. CONSEQUENTLY, THE DISTRICTWAS UNABLE TO ISSUE LONG-TERM BONDS, AND THE DISTRICTDEFAULTED ON THE PAYMENT OF PRINCIPAL ON THE BANS IN DECEMBER2011. THE WASHINGTON STATE LEGISLATURE SUBSEQUENTLY PASSEDLEGISLATION TO HELP THE DISTRICT CURE ITS DEFAULT BY ALLOWINGTHE CITY TO IMPOSE AN ADDITIONAL SALES TAX WITHOUT VOTERAPPROVAL AND FURTHER ALLOWING THE DISTRICT TO SUBMIT TOVOTERS A PROPOSITION TO IMPOSE AN ADDITIONAL SALES TAX. THEVOTERS OF THE DISTRICT LATER APPROVED AN ADDITIONAL SALES TAX.ON SEPTEMBER 28, 2012, THE DISTRICT SOLD LONG-TERM BONDSSECURED SOLELY BY SALES TAX REVENUES TO REFINANCE THE BANS.AS A RESULT OF THE NEGLIGENT CONDUCT, PIPER WILLFULLY VIOLATEDSECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT. IN ANTICIPATION OFTHE INSTITUTION OF THE PROCEEDINGS, PIPER SUBMITTED AN OFFEROF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION DETERMINEDTO ACCEPT. SOLELY FOR THE PURPOSE OF THE PROCEEDINGS AND ANYOTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THECOMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUTADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THECOMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THEPROCEEDINGS, WHICH ARE ADMITTED, PIPER CONSENTED TO THE ENTRYOF THE ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESISTPROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF1933 AND SECTIONS 15(B) AND 15(B)(C) OF THE SECURITIES EXCHANGEACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONSAND A CEASE-AND-DESIST ORDER ("ORDER").402018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceDisclosure 7 of 134iReporting Source: FirmInitiated By: STATE OF INDIANAPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:CONSENT AGREEMENTDate Initiated: 05/10/2012Docket/Case Number: 12-0162 CAPrincipal Product Type: No ProductOther Product Type(s):Allegations: DELINQUENT SUBMISSION OF INDIANA COMPLIANCE REPORT FILINGCurrent Status: FinalResolution Date: 05/21/2012Resolution:Other Sanctions Ordered:Sanction Details: $1000; 100% LEVIDED AGAINST PIPER JAFFRAY & CO.; PAID 05/16/2012Firm Statement A. PIPER JAFFRAY HEREBY WAIVES ITS RIGHT TO A HEARING PURSUANTTO IND. CODE 23-19-6- 4(B); B. PIPER JAFFRAY WAIVES ITS RIGHT TO ANAPPEALPURSUANT TO IND. CODE 23-19-6-9; C. PIPER JAFFRAY SHALL PAYPENALTIES AND COSTS OF INVESTIGATION IN THE AGGREGATE AMOUNTOF ONETHOUSAND DOLLARS ($1,000); AND,D. PIPER JAFFRAY AGREES NOT TOVIOLATE THE PROVISIONS OF THE INDIANA UNIFORM SECURITIES ACT("ACT"), IND.CODE 23-19-1, AND THE PROVISIONS OF ,THE INDIANA ADMINISTRATIVECODE IN THE FUTURE.Sanctions Ordered: Monetary/Fine $1,000.00ConsentDisclosure 8 of 134iReporting Source: RegulatorCurrent Status: Final412018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:N/ADate Initiated: 04/11/2012Docket/Case Number: 2008015745501Principal Product Type: Equity Listed (Common & Preferred Stock)Other Product Type(s):Allegations: SECTION 12(K)(4) OF THE SECURITIES EXCHANGE ACT OF 1934 AND NASDRULE 2110: FROM SEPTEMBER 23 THROUGH OCTOBER 8, 2008, THE FIRMENGAGED IN NUMEROUS SHORT SALES OF THE COMMON STOCK OF ACOMPANY AT A TIME WHEN SHORT SALES IN THAT SECURITY WEREPROHIBITED BY AN EMERGENCY ORDER OF THE SECURITIES ANDEXCHANGE COMMISSION (THE "COMMISSION") ISSUED ON SEPTEMBER18, 2008 (THE "EMERGENCY ORDER"). WHEN THE COMMISSIONANNOUNCED THE EMERGENCY ORDER, THE FIRM CREATED ASPREADSHEET TO KEEP TRACK OF THE COMPANIES COVERED BY THEORDER. ON SEPTEMBER 21, 2008, THE COMMISSION AMENDED THEEMERGENCY ORDER TO DELEGATE TO NATIONAL SECURITIESEXCHANGES THE AUTHORITY TO ADD OR REMOVE SECURITIES FROM THECOVERAGE OF THE ORDER. ON SEPTEMBER 23, 2008, THE NYSE MADECERTAIN CHANGES TO THE LIST OF STOCKS COVERED BY THEEMERGENCY ORDER, INCLUDING REMOVING THE COMMON STOCK OF ANINVESTMENT BANKING AND ALTERNATIVE ASSET MANAGEMENT FIRM. ONTHE SAME DAY, THE FIRM UPDATED ITS SPREADSHEET TO REFLECT,AMONG OTHERS, THIS CHANGE TO THE EMERGENCY ORDER. IN DOINGSO, HOWEVER, THE TICKER SYMBOL FOR THE COMPANY WASINCORRECTLY REMOVED FROM THE SPREADSHEET RATHER THAN THETICKER SYMBOL FOR THE INVESTMENT BANKING AND ALTERNATIVEASSET MANAGEMENT FIRM. THE NYSE HAD NOT REMOVED THE STOCK OFTHE COMPANY FROM THE EMERGENCY ORDER. AS A RESULT OF THEINCORRECT REMOVAL OF THE COMPANY FROM THE FIRM'SSPREADSHEET, THE FIRM, ENTERED AND EXECUTED SHORT SALEORDERS FOR NUMEROUS OF SHARES OF THE PROHIBITED COMPANYSECURITIES. THESE TRANSACTIONS OCCURRED OVER THE COURSE OFSEVERAL TRADING DAYS AND THROUGH MULTIPLE EXECUTIONS. UPONDISCOVERING THESE FACTS, THE FIRM REPORTED THEM TO FINRA.Current Status: FinalResolution Date: 04/11/2012Resolution: Acceptance, Waiver & Consent(AWC)422018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2008015745501www.finra.org/brokercheck User GuidanceResolution Date: 04/11/2012Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED AND FINED $30,000.FINE PAID IN FULL APRIL 16, 2012.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $30,000.00iReporting Source: FirmAllegations: SECTION 12(K)(4) OF THE SECURITIES EXCHANGE ACT OF 1934 AND NASDRULE 2110: FROM SEPTEMBER 23 THROUGH OCTOBER 8, 2008, THE FIRMENGAGED IN NUMEROUS SHORT SALES OF THE COMMON STOCK OF ACOMPANY AT A TIME WHEN SHORT SALES IN THAT SECURITY WEREPROHIBITED BY AN EMERGENCY ORDER OF THE SECURITIES ANDEXCHANGE COMMISSION (THE "COMMISSION") ISSUED ON SEPTEMBER18, 2008 (THE "EMERGENCY ORDER"). WHEN THE COMMISSIONANNOUNCED THE EMERGENCY ORDER, THE FIRM CREATED ASPREADSHEET TO KEEP TRACK OF THE COMPANIES COVERED BY THEORDER. ON SEPTEMBER 21, 2008, THE COMMISSION AMENDED THEEMERGENCY ORDER TO DELEGATE TO NATIONAL SECURITIESEXCHANGES THE AUTHORITY TO ADD OR REMOVE SECURITIES FROM THECOVERAGE OF THE ORDER. ON SEPTEMBER 23, 2008, THE NYSE MADECERTAIN CHANGES TO THE LIST OF STOCKS COVERED BY THEEMERGENCY ORDER, INCLUDING REMOVING THE COMMON STOCK OF ANINVESTMENT BANKING AND ALTERNATIVE ASSET MANAGEMENT FIRM. ONTHE SAME DAY, THE FIRM UPDATED ITS SPREADSHEET TO REFLECT,AMONG OTHERS, THIS CHANGE TO THE EMERGENCY ORDER. IN DOINGSO, HOWEVER, THE TICKER SYMBOL FOR THE COMPANY WASINCORRECTLY REMOVED FROM THE SPREADSHEET RATHER THAN THETICKER SYMBOL FOR THE INVESTMENT BANKING AND ALTERNATIVEASSET MANAGEMENT FIRM. THE NYSE HAD NOT REMOVED THE STOCK OFTHE COMPANY FROM THE EMERGENCY ORDER. AS A RESULT OF THEINCORRECT REMOVAL OF THE COMPANY FROM THE FIRM'SSPREADSHEET, THE FIRM, ENTERED AND EXECUTED SHORT SALEORDERS FOR NUMEROUS OF SHARES OF THE PROHIBITED COMPANYSECURITIES. THESE TRANSACTIONS OCCURRED OVER THE COURSE OFSEVERAL TRADING DAYS AND THROUGH MULTIPLE EXECUTIONS. UPONDISCOVERING THESE FACTS, THE FIRM REPORTED THEM TO FINRA.Current Status: Final432018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:N/ADate Initiated: 04/11/2012Docket/Case Number: 2008015745501Principal Product Type: Equity Listed (Common & Preferred Stock)Other Product Type(s):SECTION 12(K)(4) OF THE SECURITIES EXCHANGE ACT OF 1934 AND NASDRULE 2110: FROM SEPTEMBER 23 THROUGH OCTOBER 8, 2008, THE FIRMENGAGED IN NUMEROUS SHORT SALES OF THE COMMON STOCK OF ACOMPANY AT A TIME WHEN SHORT SALES IN THAT SECURITY WEREPROHIBITED BY AN EMERGENCY ORDER OF THE SECURITIES ANDEXCHANGE COMMISSION (THE "COMMISSION") ISSUED ON SEPTEMBER18, 2008 (THE "EMERGENCY ORDER"). WHEN THE COMMISSIONANNOUNCED THE EMERGENCY ORDER, THE FIRM CREATED ASPREADSHEET TO KEEP TRACK OF THE COMPANIES COVERED BY THEORDER. ON SEPTEMBER 21, 2008, THE COMMISSION AMENDED THEEMERGENCY ORDER TO DELEGATE TO NATIONAL SECURITIESEXCHANGES THE AUTHORITY TO ADD OR REMOVE SECURITIES FROM THECOVERAGE OF THE ORDER. ON SEPTEMBER 23, 2008, THE NYSE MADECERTAIN CHANGES TO THE LIST OF STOCKS COVERED BY THEEMERGENCY ORDER, INCLUDING REMOVING THE COMMON STOCK OF ANINVESTMENT BANKING AND ALTERNATIVE ASSET MANAGEMENT FIRM. ONTHE SAME DAY, THE FIRM UPDATED ITS SPREADSHEET TO REFLECT,AMONG OTHERS, THIS CHANGE TO THE EMERGENCY ORDER. IN DOINGSO, HOWEVER, THE TICKER SYMBOL FOR THE COMPANY WASINCORRECTLY REMOVED FROM THE SPREADSHEET RATHER THAN THETICKER SYMBOL FOR THE INVESTMENT BANKING AND ALTERNATIVEASSET MANAGEMENT FIRM. THE NYSE HAD NOT REMOVED THE STOCK OFTHE COMPANY FROM THE EMERGENCY ORDER. AS A RESULT OF THEINCORRECT REMOVAL OF THE COMPANY FROM THE FIRM'SSPREADSHEET, THE FIRM, ENTERED AND EXECUTED SHORT SALEORDERS FOR NUMEROUS OF SHARES OF THE PROHIBITED COMPANYSECURITIES. THESE TRANSACTIONS OCCURRED OVER THE COURSE OFSEVERAL TRADING DAYS AND THROUGH MULTIPLE EXECUTIONS. UPONDISCOVERING THESE FACTS, THE FIRM REPORTED THEM TO FINRA.Resolution Date: 04/11/2012Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED AND FINED $30,000.Sanctions Ordered: CensureMonetary/Fine $30,000.00Acceptance, Waiver & Consent(AWC)Disclosure 9 of 134iReporting Source: FirmInitiated By: STATE OF NORTH DAKOTA SECURITIES DEPARTMENTAllegations: PURSUANT TO N.D.C.C. 10-04-10.3 AND N.D.A.C. 73-02-07-01, EVERYBROKERDEALER AND AGENT CONDUCTING BUSINESS IN THIS STATE AREREQUIRED TO MAINTAIN CERTAIN BOOKS AND RECORDS AS DESCRIBEDTHEREIN. A MUTUAL FUND TRANSACTION LETTER SHOULD HAVE BEENCREATED BY OR THROUGH MR. VOLLMERS (A FORMER REGISTEREDREPRESENTATIVE) AND SHOULD HAVE BEEN MAINTAINED BY PIPERJAFFRAY. PIPER JAFFRAY'S FAILURE TO PRODUCE THE REQUIREDMUTUAL FUND TRANSACTION LETTER AS REQUESTED BY THESECURITIES DEPARTMENT CONSTITUTES A VIOLATION OF THESEPROVISIONS.Current Status: Final442018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2008015745501www.finra.org/brokercheck User GuidanceInitiated By: STATE OF NORTH DAKOTA SECURITIES DEPARTMENTPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:PIPER JAFFRAY, SHALL MAINTAIN ITS BOOKS AND RECORDS INACCORDANCE WITH THE REQUIREMENT OF N.D.C.C. 10-04-10.3(1) ANDREGULATIONS PROMULGATED BY THE COMMISSIONER THEREUNDER.Date Initiated: 01/13/2012Docket/Case Number:Principal Product Type: Mutual Fund(s)Other Product Type(s):Resolution Date: 02/16/2012Resolution:Other Sanctions Ordered: PIPER JAFFRAY, SHALL MAINTAIN ITS BOOKS AND RECORDS INACCORDANCE WITH THE REQUIREMENT OF N.D.C.C. 10-04-10.3(1) ANDREGULATIONS PROMULGATED BY THE COMMISSIONER THEREUNDER.Sanction Details: $2,000.00 PAID TO THE STATE OF NORTH DAKOTA ON 02/08/2012.Firm Statement PIPER JAFFRAY & CO. NEITHER ADMITS NOR DENIES THE FACTUALDETERMINATIONS OF THE COMMISSIONER, AS SET FORTH IN THEFOREGOING CONSENT ORDER, BUT IT IS PRECLUDED FROM DENYINGTHOSE DETERMINATIONS IN ANY FORUM, PUBLIC OR OTHERWISE. PIPERJAFFRAY & CO. CONSENTS TO ENTRY OF THE FOREGOING CONSENTORDER BY THE SECURITIES COMMISSIONER AND DOES SO WILLINGLYFOR THE PURPOSE OF RESOLVING THE ISSUES DESCRIBED IN THEFOREGOING CONSENT ORDER.Sanctions Ordered: Monetary/Fine $2,000.00ConsentDisclosure 10 of 134iReporting Source: RegulatorAllegations: SEC RULES 10B-10, 17A-3, NASD RULE 3110, MSRB RULES G-14, G-14(B)(II) -PIPER JAFFRAY & CO. FAILED TO SHOW THE TERMS AND CONDITIONS ONBROKERAGE ORDER MEMORANDA. THE FIRM FAILED TO PROVIDEWRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THAT THETRANSACTION WAS EXECUTED AT AN AVERAGE PRICE; FAILED TOPROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THAT "FURTHER DETAILS WERE AVAILABLE UPON REQUEST" AS A RESULT OFMULTIPLE COMPENSATION TYPES; AND ON TWO OCCASIONS PROVIDESWRITTEN NOTIFICATION THAT INCORRECTLY DISCLOSED TO ITSCUSTOMER THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGEPRICE. THE FIRM FAILED TO REPORT THE CORRECT TRADE TIME TO THEREAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN REPORTS OFTRANSACTIONS IN MUNICIPAL SECURITIES. THE FIRM FAILED TO REPORTINFORMATION REGARDING PURCHASE AND SALE TRANSACTIONSEFFECTED IN MUNICIPAL SECURITIES TO THE RTRS IN THE MANNERPRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERSMANUAL; THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCHTRANSACTIONS WITHIN 15 MINUTES OF TRADE TIME TO AN RTRS PORTAL.Current Status: Final452018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2008015745501www.finra.org/brokercheck User GuidanceInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 10/21/2011Docket/Case Number: 2009017013201Principal Product Type: Debt - MunicipalOther Product Type(s):SEC RULES 10B-10, 17A-3, NASD RULE 3110, MSRB RULES G-14, G-14(B)(II) -PIPER JAFFRAY & CO. FAILED TO SHOW THE TERMS AND CONDITIONS ONBROKERAGE ORDER MEMORANDA. THE FIRM FAILED TO PROVIDEWRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THAT THETRANSACTION WAS EXECUTED AT AN AVERAGE PRICE; FAILED TOPROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THAT "FURTHER DETAILS WERE AVAILABLE UPON REQUEST" AS A RESULT OFMULTIPLE COMPENSATION TYPES; AND ON TWO OCCASIONS PROVIDESWRITTEN NOTIFICATION THAT INCORRECTLY DISCLOSED TO ITSCUSTOMER THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGEPRICE. THE FIRM FAILED TO REPORT THE CORRECT TRADE TIME TO THEREAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN REPORTS OFTRANSACTIONS IN MUNICIPAL SECURITIES. THE FIRM FAILED TO REPORTINFORMATION REGARDING PURCHASE AND SALE TRANSACTIONSEFFECTED IN MUNICIPAL SECURITIES TO THE RTRS IN THE MANNERPRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERSMANUAL; THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCHTRANSACTIONS WITHIN 15 MINUTES OF TRADE TIME TO AN RTRS PORTAL.Resolution Date: 10/21/2011Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $22,500, $12,500 OFWHICH WAS FOR MSRB RULE VIOLATIONS.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $22,500.00Acceptance, Waiver & Consent(AWC)iReporting Source: Firm462018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2009017013201www.finra.org/brokercheck User GuidanceInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 10/21/2011Docket/Case Number: 2009017013201Principal Product Type: Debt - MunicipalOther Product Type(s):Allegations: SEC RULES 10B-10, 17A-3, NASD RULE 3110, MSRB RULES G-14, G-14(B)(II) -PIPER JAFFRAY & CO. FAILED TO SHOW THE TERMS AND CONDITIONS ONBROKERAGE ORDER MEMORANDA. THE FIRM FAILED TO PROVIDEWRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THAT THETRANSACTION WAS EXECUTED AT AN AVERAGE PRICE; FAILED TOPROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THAT "FURTHER DETAILS WERE AVAILABLE UPON REQUEST" AS A RESULT OFMULTIPLE COMPENSATION TYPES; AND ON TWO OCCASIONS PROVIDESWRITTEN NOTIFICATION THAT INCORRECTLY DISCLOSED TO ITSCUSTOMER THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGEPRICE. THE FIRM FAILED TO REPORT THE CORRECT TRADE TIME TO THEREAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN REPORTS OFTRANSACTIONS IN MUNICIPAL SECURITIES. THE FIRM FAILED TO REPORTINFORMATION REGARDING PURCHASE AND SALE TRANSACTIONSEFFECTED IN MUNICIPAL SECURITIES TO THE RTRS IN THE MANNERPRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERSMANUAL; THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCHTRANSACTIONS WITHIN 15 MINUTES OF TRADE TIME TO AN RTRS PORTAL.Current Status: FinalResolution Date: 10/21/2011Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $22,500, $12,500 OFWHICH WAS FOR MSRB RULE VIOLATIONS.Sanctions Ordered: CensureMonetary/Fine $22,500.00Acceptance, Waiver & Consent(AWC)472018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2009017013201www.finra.org/brokercheck User GuidanceDisclosure 11 of 134iReporting Source: RegulatorInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 05/24/2010Docket/Case Number: 2009019779501Principal Product Type: No ProductOther Product Type(s):Allegations: SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE17A-4 THEREUNDER, FINRA RULE 2010, NASD RULES 2110, 3010 AND3110(A), AND NYSE RULE 351: DURING THE PERIOD NOVEMBER 16, 2002THROUGH AT LEAST DECEMBER 31, 2008, RESPONDENT PIPER JAFFRAY &CO. FAILED TO MAINTAIN ALL ELECTRONIC MAIL COMMUNICATIONS.DURING THE PERIOD APRIL 7, 2003 THROUGH AT LEAST DECEMBER 31,2008, THE FIRM FAILED TO DISCLOSE TO FINRA THAT IT WASEXPERIENCING INTERMITTENT PROBLEMS WITH THE RETENTION AND/ORRETRIEVAL OF ELECTRONIC COMMUNICATIONS WHICH IMPACTED ITSABILITY TO MAKE A COMPLETE PRODUCTION OF ELECTRONICCOMMUNICATIONS RESPONSIVE TO FINRA REQUESTS, THEREBYPOTENTIALLY HINDERING FINRA'S INVESTIGATIONS. DURING THE PERIODNOVEMBER 16, 2002 THROUGH AT LEAST DECEMBER 31, 2008, THE FIRMFAILED TO ESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS ANDPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHTHE REQUIREMENTS OF SEC, NASD AND NYSE RULES, DETECT ANDREMEDY DEFICIENCIES IN ITS EMAIL RETENTION AND REVIEW SYSTEMS,AND PERFORM A SUPERVISORY REVIEW OF ALL REQUIRED EMAILS.DURING THE PERIOD OF APRIL 7, 2003 THROUGH OCTOBER 7, 2008, THEFIRM FAILED TO PROMPTLY REPORT TO THE NEW YORK STOCKEXCHANGE THAT IT VIOLATED PROVISIONS OF SECURITIES LAWS ORREGULATIONS AND/OR RULES OF A SELF-REGULATORY ORGANIZATIONWHICH REQUIRED THE RETENTION OF ELECTRONIC COMMUNICATIONS INTHAT THE FIRM'S SYSTEMS AND PROCEDURES FAILED TO RETAIN ALLELECTRONIC COMMUNICATIONS REQUIRED TO BE RETAINED.Current Status: FinalResolution: Acceptance, Waiver & Consent(AWC)482018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2009019779501www.finra.org/brokercheck User GuidanceResolution Date: 05/24/2010Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $700,000.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $700,000.00Acceptance, Waiver & Consent(AWC)iReporting Source: FirmAllegations: SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE17A-4 THEREUNDER, FINRA RULE 2010, NASD RULES 2110, 3010 AND3110(A), AND NYSE RULE 351: DURING THE PERIOD NOVEMBER 16, 2002THROUGH AT LEAST DECEMBER 31, 2008, RESPONDENT PIPER JAFFRAY &CO. FAILED TO MAINTAIN ALL ELECTRONIC MAIL COMMUNICATIONS.DURING THE PERIOD APRIL 7, 2003 THROUGH AT LEAST DECEMBER 31,2008, THE FIRM FAILED TO DISCLOSE TO FINRA THAT IT WASEXPERIENCING INTERMITTENT PROBLEMS WITH THE RETENTION AND/ORRETRIEVAL OF ELECTRONIC COMMUNICATIONS WHICH IMPACTED ITSABILITY TO MAKE A COMPLETE PRODUCTION OF ELECTRONICCOMMUNICATIONS RESPONSIVE TO FINRA REQUESTS, THEREBYPOTENTIALLY HINDERING FINRA'S INVESTIGATIONS. DURING THE PERIODNOVEMBER 16, 2002 THROUGH AT LEAST DECEMBER 31, 2008, THE FIRMFAILED TO ESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS ANDPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHTHE REQUIREMENTS OF SEC, NASD AND NYSE RULES, DETECT ANDREMEDY DEFICIENCIES IN ITS EMAIL RETENTION AND REVIEW SYSTEMS,AND PERFORM A SUPERVISORY REVIEW OF ALL REQUIRED EMAILS.DURING THE PERIOD OF APRIL 7, 2003 THROUGH OCTOBER 7, 2008, THEFIRM FAILED TO PROMPTLY REPORT TO THE NEW YORK STOCKEXCHANGE THAT IT VIOLATED PROVISIONS OF SECURITIES LAWS ORREGULATIONS AND/OR RULES OF A SELF-REGULATORY ORGANIZATIONWHICH REQUIRED THE RETENTION OF ELECTRONIC COMMUNICATIONS INTHAT THE FIRM'S SYSTEMS AND PROCEDURES FAILED TO RETAIN ALLELECTRONIC COMMUNICATIONS REQUIRED TO BE RETAINED.Current Status: Final492018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:MONETARY FINE.Date Initiated: 05/24/2010Docket/Case Number: 2009019779501Principal Product Type: No ProductOther Product Type(s):SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE17A-4 THEREUNDER, FINRA RULE 2010, NASD RULES 2110, 3010 AND3110(A), AND NYSE RULE 351: DURING THE PERIOD NOVEMBER 16, 2002THROUGH AT LEAST DECEMBER 31, 2008, RESPONDENT PIPER JAFFRAY &CO. FAILED TO MAINTAIN ALL ELECTRONIC MAIL COMMUNICATIONS.DURING THE PERIOD APRIL 7, 2003 THROUGH AT LEAST DECEMBER 31,2008, THE FIRM FAILED TO DISCLOSE TO FINRA THAT IT WASEXPERIENCING INTERMITTENT PROBLEMS WITH THE RETENTION AND/ORRETRIEVAL OF ELECTRONIC COMMUNICATIONS WHICH IMPACTED ITSABILITY TO MAKE A COMPLETE PRODUCTION OF ELECTRONICCOMMUNICATIONS RESPONSIVE TO FINRA REQUESTS, THEREBYPOTENTIALLY HINDERING FINRA'S INVESTIGATIONS. DURING THE PERIODNOVEMBER 16, 2002 THROUGH AT LEAST DECEMBER 31, 2008, THE FIRMFAILED TO ESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS ANDPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHTHE REQUIREMENTS OF SEC, NASD AND NYSE RULES, DETECT ANDREMEDY DEFICIENCIES IN ITS EMAIL RETENTION AND REVIEW SYSTEMS,AND PERFORM A SUPERVISORY REVIEW OF ALL REQUIRED EMAILS.DURING THE PERIOD OF APRIL 7, 2003 THROUGH OCTOBER 7, 2008, THEFIRM FAILED TO PROMPTLY REPORT TO THE NEW YORK STOCKEXCHANGE THAT IT VIOLATED PROVISIONS OF SECURITIES LAWS ORREGULATIONS AND/OR RULES OF A SELF-REGULATORY ORGANIZATIONWHICH REQUIRED THE RETENTION OF ELECTRONIC COMMUNICATIONS INTHAT THE FIRM'S SYSTEMS AND PROCEDURES FAILED TO RETAIN ALLELECTRONIC COMMUNICATIONS REQUIRED TO BE RETAINED.Resolution Date: 05/24/2010Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $700,000.Sanctions Ordered: CensureMonetary/Fine $700,000.00Acceptance, Waiver & Consent(AWC)Disclosure 12 of 134iReporting Source: RegulatorAllegations: NASD RULES 2110, 6130(B), 6955(A), MSRB RULE G-14 - PIPER JAFFRAY &CO. FAILED TO ACCEPT OR DECLINE IN THE NASDAQ MARKET CENTERTRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTEREXECUTION THAT THE FIRM HAD AN OBLIGATION TO ACCEPT OR DECLINEAS THE ORDER ENTRY IDENTIFIER. THE FIRM TRANSMITTED TO THEORDER AUDIT TRAIL SYSTEM (OATS) REPORTABLE ORDER EVENTS(ROES) THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAXERRORS AND THE FIRM DID NOT REPAIR ANY OF THE REJECTED ROES.THE FIRM FAILED TO REPORT INFORMATION REGARDING PURCHASE ANDSALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNERPRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERSMANUAL; THE FIRM FAILED TO REPORT INFORMATION ABOUT THETRANSACTIONS WITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRSPORTAL.Current Status: Final502018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2009019779501www.finra.org/brokercheck User GuidanceInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 04/27/2009Docket/Case Number: 2006004109201Principal Product Type: Debt - MunicipalOther Product Type(s): REPORTABLE SECURITIESNASD RULES 2110, 6130(B), 6955(A), MSRB RULE G-14 - PIPER JAFFRAY &CO. FAILED TO ACCEPT OR DECLINE IN THE NASDAQ MARKET CENTERTRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTEREXECUTION THAT THE FIRM HAD AN OBLIGATION TO ACCEPT OR DECLINEAS THE ORDER ENTRY IDENTIFIER. THE FIRM TRANSMITTED TO THEORDER AUDIT TRAIL SYSTEM (OATS) REPORTABLE ORDER EVENTS(ROES) THAT WERE REJECTED BY OATS FOR CONTEXT OR SYNTAXERRORS AND THE FIRM DID NOT REPAIR ANY OF THE REJECTED ROES.THE FIRM FAILED TO REPORT INFORMATION REGARDING PURCHASE ANDSALE TRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNERPRESCRIBED BY RULE G-14 RTRS PROCEDURES AND THE RTRS USERSMANUAL; THE FIRM FAILED TO REPORT INFORMATION ABOUT THETRANSACTIONS WITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRSPORTAL.Resolution Date: 04/27/2009Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $17,500.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $17,500.00Acceptance, Waiver & Consent(AWC)iReporting Source: FirmAllegations: NASD RULES 2110, 6130(B), 6955(A), MSRB RULE G-14 - PIPER JAFFRAY &CO. FAILED TO ACCEPT OR DECLINE IN THE NASDAQ MARKET CENTERTRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTEREXECUTION THAT THE FIRM HAD AN OBLIGATION TO ACCEPT OR DECLINEAS THE ORDER ENTRY IDENTIFIER. THE FIRM TRANSMITTED TO THEORDER AUDIT TRAIL SYSTEM (OATS) REPORTABLE ORDER EVENTS THATWERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND THEFIRM DID NOT REPAIR ANY OF THE REJECTED ROES. THE FIRM FAILED TOREPORT INFORMATION REGARDING PURCHASE AND SALETRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIMETRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBEDBY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL; THEFIRM FAILED TO REPORT INFORMATION ABOUT THE TRANSACTIONSWITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRS PORTAL.Current Status: Final512018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2006004109201www.finra.org/brokercheck User GuidanceInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 04/27/2009Docket/Case Number: 2006004109201Principal Product Type: Debt - MunicipalOther Product Type(s): REPORTABLE SECURITIESNASD RULES 2110, 6130(B), 6955(A), MSRB RULE G-14 - PIPER JAFFRAY &CO. FAILED TO ACCEPT OR DECLINE IN THE NASDAQ MARKET CENTERTRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTEREXECUTION THAT THE FIRM HAD AN OBLIGATION TO ACCEPT OR DECLINEAS THE ORDER ENTRY IDENTIFIER. THE FIRM TRANSMITTED TO THEORDER AUDIT TRAIL SYSTEM (OATS) REPORTABLE ORDER EVENTS THATWERE REJECTED BY OATS FOR CONTEXT OR SYNTAX ERRORS AND THEFIRM DID NOT REPAIR ANY OF THE REJECTED ROES. THE FIRM FAILED TOREPORT INFORMATION REGARDING PURCHASE AND SALETRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIMETRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBEDBY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL; THEFIRM FAILED TO REPORT INFORMATION ABOUT THE TRANSACTIONSWITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRS PORTAL.Resolution Date: 04/27/2009Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $17,500.Sanctions Ordered: CensureMonetary/Fine $17,500.00Acceptance, Waiver & Consent(AWC)Disclosure 13 of 134iReporting Source: RegulatorAllegations: SEC RULE 17A-3, NASD RULES 2110, 2320, 3010, 3110, 6230(C)(2), 6230(C)(8)- PIPER JAFFRAY & CO., IN ITS FIXED INCOME AREA, GENERALLY FAILEDTO SHOW THE CORRECT TIME OF EXECUTION ON BROKERAGE ORDERMEMORANDA. THE FIRM FAILED TO SHOW THE TIME OF ENTRY FORORDERS THAT RESULTED IN EXECUTIONS ON BROKERAGE ORDERMEMORANDA AND FAILED TO CREATE AND MAINTAIN BROKERAGE ORDERMEMORANDA FOR ORDERS THAT DID NOT RESULT IN EXECUTIONS. THEFIRM GENERALLY FAILED TO REPORT TO THE TRADE REPORTING ANDCOMPLIANCE ENGINE (TRACE)THE CORRECT TIME OF TRADE EXECUTIONFOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES AND GENERALLYFAILED TO REPORT TO TRACE THE CORRECT NUMBER OF BONDS WHENTHE BONDS HAD A FACTOR OTHER THAN ONE FOR TRANSACTIONS INTRACE-ELIGIBLE SECURITIES. THE FIRM'S SUPERVISORY SYSTEM DIDNOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDNASD RULES CONCERNING RECORDKEEPING AND TRACE TRADEREPORTING. IN TRANSACTIONS FOR OR WITH CUSTOMERS, THE FIRMFAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THATTHE RESULTANT PRICE TO ITS CUSTOMERS WAS AS FAVORABLE ASPOSSIBLE UNDER PREVAILING MARKET CONDITIONS.Current Status: Final522018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2006004109201www.finra.org/brokercheck User GuidanceInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 09/24/2008Docket/Case Number: 2005000167502Principal Product Type: Debt - CorporateOther Product Type(s):SEC RULE 17A-3, NASD RULES 2110, 2320, 3010, 3110, 6230(C)(2), 6230(C)(8)- PIPER JAFFRAY & CO., IN ITS FIXED INCOME AREA, GENERALLY FAILEDTO SHOW THE CORRECT TIME OF EXECUTION ON BROKERAGE ORDERMEMORANDA. THE FIRM FAILED TO SHOW THE TIME OF ENTRY FORORDERS THAT RESULTED IN EXECUTIONS ON BROKERAGE ORDERMEMORANDA AND FAILED TO CREATE AND MAINTAIN BROKERAGE ORDERMEMORANDA FOR ORDERS THAT DID NOT RESULT IN EXECUTIONS. THEFIRM GENERALLY FAILED TO REPORT TO THE TRADE REPORTING ANDCOMPLIANCE ENGINE (TRACE)THE CORRECT TIME OF TRADE EXECUTIONFOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES AND GENERALLYFAILED TO REPORT TO TRACE THE CORRECT NUMBER OF BONDS WHENTHE BONDS HAD A FACTOR OTHER THAN ONE FOR TRANSACTIONS INTRACE-ELIGIBLE SECURITIES. THE FIRM'S SUPERVISORY SYSTEM DIDNOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDNASD RULES CONCERNING RECORDKEEPING AND TRACE TRADEREPORTING. IN TRANSACTIONS FOR OR WITH CUSTOMERS, THE FIRMFAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THATTHE RESULTANT PRICE TO ITS CUSTOMERS WAS AS FAVORABLE ASPOSSIBLE UNDER PREVAILING MARKET CONDITIONS.Resolution Date: 09/24/2008Resolution:Other Sanctions Ordered: UNDERTAKINGSanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $167,500 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDINGRECORDKEEPING AND TRACE TRADE REPORTING WITHIN 30 BUSINESSDAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. THE FIRM IS ALSOORDERED TO PAY $6,758.78, PLUS INTEREST, IN RESTITUTION TOINVESTORS. A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMITSATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OFREASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECTRESTITUTION, NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THISAWC. ANY UNDISTRIBUTED RESTITUTION AND INTEREST SHALL BEFORWARDED TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY ORABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMERLAST RESIDED.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $167,500.00Disgorgement/RestitutionAcceptance, Waiver & Consent(AWC)532018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2005000167502www.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $167,500 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDINGRECORDKEEPING AND TRACE TRADE REPORTING WITHIN 30 BUSINESSDAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. THE FIRM IS ALSOORDERED TO PAY $6,758.78, PLUS INTEREST, IN RESTITUTION TOINVESTORS. A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMITSATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OFREASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECTRESTITUTION, NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THISAWC. ANY UNDISTRIBUTED RESTITUTION AND INTEREST SHALL BEFORWARDED TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY ORABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMERLAST RESIDED.iReporting Source: FirmInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Date Initiated: 09/24/2008Docket/Case Number: 2005000167502Principal Product Type: Debt - CorporateOther Product Type(s):Allegations: SEC RULE 17A-3, NASD RULES 2110,2320,3010,3110,6230(C)(2), 6230(C)(8) --PIPER JAFFRAY & CO., IN ITS FIXED INCOME AREA, GENERALLY FAILED TOSHOW THE CORRECT TIME OF EXECUTION ON BROKERAGE ORDERMEMORANDA. THE FIRM FAILED TO SHOW THE TIME OF ENTRY THATRESULTED IN EXECUTIONS ON BROKERAGE ORDER MEMORANDA ANDFAILED TO CREATE AND MAINTAIN BROKERAGE ORDER MEMORANDA FORORDERS THAT DID NOT RESULT IN EXECUTIONS. THE FIRM GENERALLYFAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE(TRACE) THE CORRECT TIME OF TRADE EXECUTION FOR TRANSACTIONSIN TRACE-ELIGIBLE SECURITIES AND GENERALLY FAILED TO REPORT TOTRACE THE CORRECT NUMBER OF BONDS WHEN THE BONDS HAD AFACTOR OTHER THAN ONE FOR TRANSACTIONS IN TRACE-ELIGIBLESECURITIES. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULESCONCERNING RECORDKEEPING AND TRACE TRADE REPORTING. INTRANSACTIONS FOR OR WITH CUSTOMERS, THE FIRM FAILED TO USEREASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALERMARKET AND FAILED TO BUY OR SELL IN SUCH MARKET SO THAT THERESULTANT PRICE TO ITS CUSTOMERS WAS AS FAVORABLE AS POSSIBLEUNDER PREVAILING MARKET CONDITIONS.Current Status: Final542018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2005000167502www.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Resolution Date: 09/24/2008Resolution:Other Sanctions Ordered: UNDERTAKINGSanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $167,500.00 AND REQUIREDTO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDINGRECORDKEEPING AND TRACE TRADE REPORTING WITHIN 30 BUSINESSDAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. THE FIRM IS ALSOORDERED TO PAY $6,758.78 PLUS INTEREST, IN RESTITUTION TOINVESTORS. A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMITSATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION, OR OFREASONABLE AND DOCUMENTED EFFORTS UNDERTAKEN TO EFFECTRESTITUTION, NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THISAWC. ANY UNDISTRIBUTED RESTITUTION AND INTEREST SHALL BEFORWARDED TO THE APPROPRIATE ESCHEAT, UNCLAIMED PROPERTY ORABANDONED PROPERTY FUND FOR THE STATE IN WHICH THE CUSTOMERLAST RESIDED.Sanctions Ordered: CensureMonetary/Fine $167,500.00Disgorgement/RestitutionAcceptance, Waiver & Consent(AWC)Disclosure 14 of 134iReporting Source: RegulatorInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Date Initiated: 08/18/2008Docket/Case Number: 20050017474-01Principal Product Type: OtherOther Product Type(s): UNKNOWN TYPE OF SECURITIESAllegations: NASD RULE 6130 - PIPER JAFFRAY & CO. EFFECTED CUSTOMER SHORTSALE TRANSACTIONS AND FAILED TO REPORT THE TRANSACTIONS TOTHE NASDAQ MARKET CENTER WITH A SHORT SALE MODIFIER.Current Status: Final552018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Resolution Date: 08/18/2008Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $7,500.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $7,500.00Acceptance, Waiver & Consent(AWC)iReporting Source: FirmInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 08/18/2008Docket/Case Number: 20050017474-01Principal Product Type: Equity - OTCOther Product Type(s):Allegations: NASD RULE 6130 - PIPER JAFFRAY & CO. EFFECTED CUSTOMER SHORTSALE TRANSACTIONS AND FAILED TO REPORT TO THE NASDAQ MARKETCENTER WITH A SHORT SALE MODIFIER.Current Status: FinalResolution Date: 08/18/2008Resolution: Acceptance, Waiver & Consent(AWC)562018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceResolution Date: 08/18/2008Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE THE FIRM IS CENSURED AND FINED $7,500.00Sanctions Ordered: CensureMonetary/Fine $7,500.00Disclosure 15 of 134iReporting Source: RegulatorInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 06/13/2008Docket/Case Number: 2007007125401Principal Product Type: OtherOther Product Type(s): MUNICIPAL SECURITIESAllegations: MSRB RULE G-36 - IN CONNECTION WITH OFFERINGS OF MUNICIPALSECURITIES, RESPONDENT FAILED TO SUBMIT G-36 FORMS WITH THEMSRB IN A TIMELY MANNER.Current Status: FinalResolution Date: 06/13/2008Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, PIPER JAFFRAY & CO.,CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $10,000.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $10,000.00Acceptance, Waiver & Consent(AWC)572018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2007007125401www.finra.org/brokercheck User GuidanceSanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, PIPER JAFFRAY & CO.,CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $10,000.iReporting Source: FirmInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 06/13/2008Docket/Case Number: 20070071254-01Principal Product Type: OtherOther Product Type(s): MUNICIPAL SECURITIESAllegations: MSRB RULE G-36 -- IN CONNECTION WITH OFFERINGS OF MUNICIPALSECURITIES, RESPONDENT FAILED TO SUBMIT G-36 FORMS WITH THEMSRB IN A TIMELY MANNER.Current Status: FinalResolution Date: 06/13/2008Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, PIPER JAFFRAY & CO.,CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $10,000.00.Sanctions Ordered: CensureMonetary/Fine $10,000.00Acceptance, Waiver & Consent(AWC)Disclosure 16 of 134iReporting Source: RegulatorAllegations: MSRB RULES G-27, G-37(B) - A MUNICIPAL FINANCE PROFESSIONAL WITHPIPER JAFFRAY & CO. MADE POLITICAL CONTRIBUTIONS TO A STATEOFFICIAL AND THE FIRM ENGAGED IN MUNICIPAL SECURITIES BUSINESSWITH AGENCIES OVER WHICH THE OFFICIAL HAD AUTHORITY BY ACTINGAS AN UNDERWRITER OF MUNICIPAL SECURITIES OFFERED BY THEAGENCIES WITHIN TWO YEARS OF THE POLITICAL CONTRIBUTIONS INVIOLATION OF MSRB RULE G-37(B). THE FIRM FAILED TO HAVE AREASONABLE SUPERVISORY SYSTEM TO ADEQUATELY MONITOR THEPOLITICAL CONTRIBUTIONS OF ITS MUNICIPAL FINANCE PROFESSIONALSTO ENSURE COMPLIANCE WITH MSRB RULES.Current Status: Final582018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 03/14/2008Docket/Case Number: E042005008101Principal Product Type: Debt - MunicipalOther Product Type(s):MSRB RULES G-27, G-37(B) - A MUNICIPAL FINANCE PROFESSIONAL WITHPIPER JAFFRAY & CO. MADE POLITICAL CONTRIBUTIONS TO A STATEOFFICIAL AND THE FIRM ENGAGED IN MUNICIPAL SECURITIES BUSINESSWITH AGENCIES OVER WHICH THE OFFICIAL HAD AUTHORITY BY ACTINGAS AN UNDERWRITER OF MUNICIPAL SECURITIES OFFERED BY THEAGENCIES WITHIN TWO YEARS OF THE POLITICAL CONTRIBUTIONS INVIOLATION OF MSRB RULE G-37(B). THE FIRM FAILED TO HAVE AREASONABLE SUPERVISORY SYSTEM TO ADEQUATELY MONITOR THEPOLITICAL CONTRIBUTIONS OF ITS MUNICIPAL FINANCE PROFESSIONALSTO ENSURE COMPLIANCE WITH MSRB RULES.Resolution Date: 03/14/2008Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCEIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $25,000 AND ORDERED TODISGORGE PROFITS OF $260,157.89 FOR THE PROHIBITED MUNICIPALUNDERWRITINGS IN WHICH THE FIRM ENGAGED DURING THE TWO-YEARPERIOD PRESCRIBED BY MSRB RULE G-37(B).Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $25,000.00Disgorgement/RestitutionAcceptance, Waiver & Consent(AWC)iReporting Source: FirmAllegations: MSRB RULES G-27, G-37(B) - A MUNICIPAL FINANCE PROFESSIONAL WITHPIPER JAFFRAY & CO. MADE POLITICAL CONTRIBUTIONS TO A STATEOFFICIAL AND THE FIRM ENGAGED IN MUNICIPAL SECURITIES BUSINESSWITH AGENCIES OVER WHICH THE OFFICIAL HAD AUTHORITY BY ACTINGAS AN UNDERWRITER OF MUNICIPAL SECURITIES OFFERED BY THEAGENCIES WITHIN TWO YEARS OF THE POLITICAL CONTRIBUTIONS INVIOLATION OF MSRB G-37(B). THE FIRM FAILED TO HAVE A REASONABLESUPERVISORY SYSTEM TO ADEQUATELY MONITOR THE POLITICALCONTRIBUTIONS OF ITS MUNICIPAL FINANCE PROFESSIONALS TOENSURE COMPLIANCE WITH MSRB RULES.Current Status: Final592018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=e042005008101www.finra.org/brokercheck User GuidanceInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 03/14/2008Docket/Case Number: E0420050081-01Principal Product Type: Debt - MunicipalOther Product Type(s):Allegations: MSRB RULES G-27, G-37(B) - A MUNICIPAL FINANCE PROFESSIONAL WITHPIPER JAFFRAY & CO. MADE POLITICAL CONTRIBUTIONS TO A STATEOFFICIAL AND THE FIRM ENGAGED IN MUNICIPAL SECURITIES BUSINESSWITH AGENCIES OVER WHICH THE OFFICIAL HAD AUTHORITY BY ACTINGAS AN UNDERWRITER OF MUNICIPAL SECURITIES OFFERED BY THEAGENCIES WITHIN TWO YEARS OF THE POLITICAL CONTRIBUTIONS INVIOLATION OF MSRB G-37(B). THE FIRM FAILED TO HAVE A REASONABLESUPERVISORY SYSTEM TO ADEQUATELY MONITOR THE POLITICALCONTRIBUTIONS OF ITS MUNICIPAL FINANCE PROFESSIONALS TOENSURE COMPLIANCE WITH MSRB RULES.Resolution Date: 03/14/2008Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $25,000 AND ORDERED TODISGORGE PROFITS OF $260,157.89 FOR THE PROHIBITED MUNICIPALUNDERWRITINGS IN WHICH THE FIRM ENGAGED DURING THE TWO-YEARPERIOD PRESCRIBED BY MSRB G-37(B).Sanctions Ordered: CensureMonetary/Fine $25,000.00Disgorgement/RestitutionAcceptance, Waiver & Consent(AWC)Disclosure 17 of 134iReporting Source: RegulatorAllegations: NASD RULES 2110, 3010, 3310 - PIPER JAFFRAY & CO.'S AGGREGATETRADE VOLUME (BUY AND SELL) FOR EQUITY SECURITIES ADVERTISED INPRIVATE SERVICE PROVIDERS FOR ONE MONTH SUBSTANTIALLYEXCEEDED THE FIRM'S EXECUTED TRADE VOLUME FOR THE SAMESECURITIES. THE FIRM FAILED TO DETERMINE WHETHER THE TRADEVOLUME THAT IT ADVERTISED IN THESE SERVICES ACCURATELYREFLECTED ITS EXECUTED TRADE VOLUME. THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS AND NASD RULES CONCERNING NASD RULE 3310 - THEIDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISIONWITH RESPECT TO THE ADVERTISED TRADE VOLUME ON SUBSCRIBERSERVICES AND APPLICABLE RULES. THE FIRM DID NOT SUPERVISE THETRADE VOLUME THAT IT ADVERTISED IN THESE SYSTEMS.Current Status: Final602018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 12/18/2007Docket/Case Number: 2006006755701Principal Product Type: Equity Listed (Common & Preferred Stock)Other Product Type(s):Allegations: NASD RULES 2110, 3010, 3310 - PIPER JAFFRAY & CO.'S AGGREGATETRADE VOLUME (BUY AND SELL) FOR EQUITY SECURITIES ADVERTISED INPRIVATE SERVICE PROVIDERS FOR ONE MONTH SUBSTANTIALLYEXCEEDED THE FIRM'S EXECUTED TRADE VOLUME FOR THE SAMESECURITIES. THE FIRM FAILED TO DETERMINE WHETHER THE TRADEVOLUME THAT IT ADVERTISED IN THESE SERVICES ACCURATELYREFLECTED ITS EXECUTED TRADE VOLUME. THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS AND NASD RULES CONCERNING NASD RULE 3310 - THEIDENTIFICATION OF THE PERSON(S) RESPONSIBLE FOR SUPERVISIONWITH RESPECT TO THE ADVERTISED TRADE VOLUME ON SUBSCRIBERSERVICES AND APPLICABLE RULES. THE FIRM DID NOT SUPERVISE THETRADE VOLUME THAT IT ADVERTISED IN THESE SYSTEMS.Resolution Date: 12/18/2007Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $100,000.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $100,000.00Acceptance, Waiver & Consent(AWC)iReporting Source:612018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2006006755701www.finra.org/brokercheck User GuidanceReporting Source: FirmInitiated By: FINRAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CENSUREDate Initiated: 12/18/2007Docket/Case Number: 20060067557-01Principal Product Type: Equity Listed (Common & Preferred Stock)Other Product Type(s):Allegations: NASD RULES 2110, 3010, 3310 - PIPER JAFFRAY & CO.'S AGGREGATETRADE VOLUME (BUY AND SELL) FOR EQUITY SECURITIES ADVERTISED INPRIVATE SERVICE PROVIDERS FOR ONE MONTH SUBSTANTIALLYEXCEEDED THE FIRM'S EXECUTED TRADE VOLUME FOR THE SAMESECURITIES. THE FIRM FAILED TO DETERMINE WHETHER THE TRADEVOLUME THAT IT ADVERTISED IN THESE SERVICES ACCURATELYREFLECTED ITS EXECUTED TRADE VOLUME. THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS AND NASD RULES CONCERNING NASD RULE 3310-THEIDENTIFICATION OF THE PERSON(S) RESPONSBILE FOR SUPERVISIONWITH RESPECT TO THE ADVERTISED TRADE VOLUME ON SUBSCRIBERSERVICES AND APPLICABLE RULES. THE FIRM DID NOT SUPERVISE THETRADE VOLUME THAT IT ADVERTISED IN THESE SYSTEMS.Current Status: FinalResolution Date: 12/18/2007Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE THE FIRM IS CENSURED AND FINED $100,000. FINE WAS PAIDON DECEMBER 27, 2007.Sanctions Ordered: CensureMonetary/Fine $100,000.00Acceptance, Waiver & Consent(AWC)Disclosure 18 of 134i622018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceReporting Source: RegulatorInitiated By: NASDPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 07/11/2007Docket/Case Number: 20050009139-02Principal Product Type: No ProductOther Product Type(s):Allegations: SEC RULE 604 OF REGULATION NMS - RESPONDENT FIRM FAILED TODISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIESIN ITS PUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICETHAT WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCHSECURITY OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BIDOR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCHSECURITY AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DEMINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'SBID OR OFFER IN EACH SECURITY.Current Status: FinalResolution Date: 07/11/2007Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, PIPER JAFFRAY & CO.,CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OFFINDINGS, THEREFORE, THE FIRM IS FINED $5,000.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: Monetary/Fine $5,000.00Acceptance, Waiver & Consent(AWC)iReporting Source: Firm632018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 07/11/2007Docket/Case Number: 20050009139-02Principal Product Type: No ProductOther Product Type(s):Allegations: SEC RULE 604 OF REGULATION NMS - ALLEGES PIPER JAFFRAY & CO.FAILED TO DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN NASDAQSECURITIES IN ITS PUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS ATA PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER INEACH SUCH SECURITY OR WHEN THE ORDER WAS PRICED EQUAL TO THEFIRM'S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACHSUCH SECURITY AND THE SIZE OF THE ORDER REPRESENTED MORETHAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITHTHE FIRM'S BID OR OFFER IN EACH SECURITY.Current Status: FinalResolution Date: 07/11/2007Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, PIPER JAFFRAY & CO.CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OFFINDINGS, THEREFORE, THE FIRM IS FINED $5,000.Sanctions Ordered: Monetary/Fine $5,000.00Acceptance, Waiver & Consent(AWC)Disclosure 19 of 134iReporting Source: RegulatorAllegations: **5/4/07** STIPULATION OF FACTS AND CONSENT TO PENALTY FILED BYTHE NYSE REGULATION'S DIVISION OF ENFORCEMENT AND PENDING.CONSENTED TO FINDINGS: 1.VIOLATED RULE 203(B)(1) OF REGULATIONSHO IN THAT THE FIRM, ON ONE OR MORE OCCASIONS, EFFECTED SHORTSALE ORDERS IN SECURITIES WITHOUT HAVING BORROWED THESECURITY, WITHOUT ENTERING INTO AN ARRANGEMENT TO BORROW THESECURITY OR WITHOUT HAVING REASONABLE GROUNDS TO BELIEVETHAT THE SECURITIES COULD BE BORROWED. 2.VIOLATED RULE 200(G)OF REGULATION SHO IN THAT, ON ONE OR MORE OCCASIONS, IT FAILEDTO MARK CERTAIN SHORT SELL ORDERS AS "SHORT EXEMPT."3.VIOLATEDRULE 203(B)(3)(1) OF REGULATION SHO IN THAT, ON ONE OR MOREOCCASIONS, IT FAILED TO TIMELY CLOSE OUT FAIL TO DELIVERPOSITIONS IN THRESHOLD SECURITIES BY PURCHASING SECURITIES OFA LIKE KIND AND QUANTITY. 4.VIOLATED SECTION 15(C) OF THEEXCHANGE ACT AND EXCHANGE ACT RULE 15C3-3, AS INTERPRETED BY15C3-3(C)(1)/07, IN THAT, ON ONE OR MORE OCCASIONS, IT INACCURATELYTREATED NON-SETTLED, NON-DELIVERED SECURITIES AS IF IN ITSPOSSESSION AND CONTROL. 5.VIOLATED NYSE RULE 342, IN THAT THEFIRM FAILED TO ESTABLISH ADEQUATE POLICIES AND PROCEDURES,INCLUDING A SYSTEM OF FOLLOW UP AND REVIEW, FOR COMPLIANCEWITH REGULATION SHO AND FOR COMPLIANCE WITH THE "ANTICIPATEDDELIVERY PROGRAM" OF THE NATIONAL SECURITIES CLEARING CORP.CONSENTED TO PENALTY: CENSURE AND FINE IN THE AMOUNT OF$150,000Current Status: Final642018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENTPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 05/04/2007Docket/Case Number: HBD# 07-82Principal Product Type: OtherOther Product Type(s):**5/4/07** STIPULATION OF FACTS AND CONSENT TO PENALTY FILED BYTHE NYSE REGULATION'S DIVISION OF ENFORCEMENT AND PENDING.CONSENTED TO FINDINGS: 1.VIOLATED RULE 203(B)(1) OF REGULATIONSHO IN THAT THE FIRM, ON ONE OR MORE OCCASIONS, EFFECTED SHORTSALE ORDERS IN SECURITIES WITHOUT HAVING BORROWED THESECURITY, WITHOUT ENTERING INTO AN ARRANGEMENT TO BORROW THESECURITY OR WITHOUT HAVING REASONABLE GROUNDS TO BELIEVETHAT THE SECURITIES COULD BE BORROWED. 2.VIOLATED RULE 200(G)OF REGULATION SHO IN THAT, ON ONE OR MORE OCCASIONS, IT FAILEDTO MARK CERTAIN SHORT SELL ORDERS AS "SHORT EXEMPT."3.VIOLATEDRULE 203(B)(3)(1) OF REGULATION SHO IN THAT, ON ONE OR MOREOCCASIONS, IT FAILED TO TIMELY CLOSE OUT FAIL TO DELIVERPOSITIONS IN THRESHOLD SECURITIES BY PURCHASING SECURITIES OFA LIKE KIND AND QUANTITY. 4.VIOLATED SECTION 15(C) OF THEEXCHANGE ACT AND EXCHANGE ACT RULE 15C3-3, AS INTERPRETED BY15C3-3(C)(1)/07, IN THAT, ON ONE OR MORE OCCASIONS, IT INACCURATELYTREATED NON-SETTLED, NON-DELIVERED SECURITIES AS IF IN ITSPOSSESSION AND CONTROL. 5.VIOLATED NYSE RULE 342, IN THAT THEFIRM FAILED TO ESTABLISH ADEQUATE POLICIES AND PROCEDURES,INCLUDING A SYSTEM OF FOLLOW UP AND REVIEW, FOR COMPLIANCEWITH REGULATION SHO AND FOR COMPLIANCE WITH THE "ANTICIPATEDDELIVERY PROGRAM" OF THE NATIONAL SECURITIES CLEARING CORP.CONSENTED TO PENALTY: CENSURE AND FINE IN THE AMOUNT OF$150,000Resolution Date: 06/26/2007Resolution:Other Sanctions Ordered:Sanction Details: **5/31/07** DECISION NO. 07-82 ISSUED BY NYSE HEARING BOARDDECISION: VIOLATED RULE 203(B)(1) OF REGULATION SHO BY EFFECTINGSHORT SALE ORDERS IN SECURITIES WITHOUT HAVING BORROWEDSECURITY, WITHOUT ENTERING INTO AN ARRANGEMENT TO BORROWSECURITY OR WITHOUT HAVING REASONABLE GROUNDS TO BELIEVETHAT SECURITIES COULD BE BORROWED; VIOLATED RULE 200(G) OFREGULATION SHO BY FAILING TO MARK CERTAIN SHORT SELL ORDERS AS "SHORT EXEMPT;"VIOLATED RULE 203(B)(3)(1) OF REGULATION SHO BYFAILING TO TIMELY CLOSE OUT FAIL TO DELIVER POSITIONS INTHRESHOLD SECURITIES BY PURCHASING SECURITIES OF A LIKE KINDAND QUANTITY; VIOLATED SECTION 15(C) OF THE EXCHANGE ACT ANDRULE 15C3-3 THEREUNDER, AS INTERPRETED BY PARAGRAPH 15C3-3(C)(1)/07 OF NYSE INTERPRETATION HANDBOOK, BY INACCURATELYTREATING NON-SETTLED, NON-DELIVERED SECURITIES AS IF INPOSSESSION AND CONTROL; VIOLATED NYSE RULE 342,BY FAILING TOESTABLISH ADEQUATE POLICIES AND PROCEDURES, INCLUDING ASYSTEM OF FOLLOW UP AND REVIEW, FOR COMPLIANCE WITHREGULATION SHO AND FOR COMPLIANCE WITH THE "ANTICIPATEDDELIVERY PROGRAM" OF THE NATIONAL SECURITIES CLEARING CORP.CONSENTED TO A CENSURE AND A $150,000 FINE.Sanctions Ordered: CensureMonetary/Fine $150,000.00Decision652018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User Guidance**5/31/07** DECISION NO. 07-82 ISSUED BY NYSE HEARING BOARDDECISION: VIOLATED RULE 203(B)(1) OF REGULATION SHO BY EFFECTINGSHORT SALE ORDERS IN SECURITIES WITHOUT HAVING BORROWEDSECURITY, WITHOUT ENTERING INTO AN ARRANGEMENT TO BORROWSECURITY OR WITHOUT HAVING REASONABLE GROUNDS TO BELIEVETHAT SECURITIES COULD BE BORROWED; VIOLATED RULE 200(G) OFREGULATION SHO BY FAILING TO MARK CERTAIN SHORT SELL ORDERS AS "SHORT EXEMPT;"VIOLATED RULE 203(B)(3)(1) OF REGULATION SHO BYFAILING TO TIMELY CLOSE OUT FAIL TO DELIVER POSITIONS INTHRESHOLD SECURITIES BY PURCHASING SECURITIES OF A LIKE KINDAND QUANTITY; VIOLATED SECTION 15(C) OF THE EXCHANGE ACT ANDRULE 15C3-3 THEREUNDER, AS INTERPRETED BY PARAGRAPH 15C3-3(C)(1)/07 OF NYSE INTERPRETATION HANDBOOK, BY INACCURATELYTREATING NON-SETTLED, NON-DELIVERED SECURITIES AS IF INPOSSESSION AND CONTROL; VIOLATED NYSE RULE 342,BY FAILING TOESTABLISH ADEQUATE POLICIES AND PROCEDURES, INCLUDING ASYSTEM OF FOLLOW UP AND REVIEW, FOR COMPLIANCE WITHREGULATION SHO AND FOR COMPLIANCE WITH THE "ANTICIPATEDDELIVERY PROGRAM" OF THE NATIONAL SECURITIES CLEARING CORP.CONSENTED TO A CENSURE AND A $150,000 FINE.Regulator Statement **6/26/07** THE DECISION BECAME FINAL AS OF THE CLOSE OF BUSINESSON JUNE 25, 2007 AND YOUR FINE BECAME PAYABLE ON THAT SAME DATE.CONTACT: PEGGY GERMINO 212-656-8450.iReporting Source: FirmAllegations: ALLEGED PIPER JAFFRAY VIOLATED RULE 203(B)(1) OF REGULATION SHOIN THAT THE FIRM, ON ONE OR MORE OCCASIONS, EFFECTED SHORTSALE ORDERS IN SECURITIES WITHOUT HAVING BORROWED THESECURITY, WITHOUT ENTERING INTO AN ARRANGEMENT TO BORROW THESECURITY OR WITHOUT HAVING RESONABLE GROUNDS TO BELIEVE THATTHE SECURITIES COULD BE BORROWED. ALLEGED THE FIRM VIOLATEDRULE 200(G) OF REGULATION SHO IN THAT, ON ONE OR MOREOCCASIONS, IT FAILED TO MAKE CERTAIN SHORT SELL ORDERS AS "SHORT EXEMPT". ALLEGED THAT THE FIRM VIOLATED RULE 203(B)(3)(1)OF REGULATION SHO IN THAT, ON ONE OR MORE OCCASIONS, IT FAILEDTO TIMELY CLOSE OUT FAIL TO DELIVER POSITIONS IN THRESHOLDSECURITIES BY PURCHASING SECURITIES OF A LIKE KIND AND QUANTITY.ALLEGED THAT THE FIRM VIOLATED SECTION 15(C) OF THE EXCHANGEACT AND EXCHANGE ACT RULE 15C3-3, AS INTERPRETED BY 15C3-3(C)(1)/07, IN THAT, ON ONE OR MORE OCCASIONS, IT INACCURATELYTREATED NON-SETTLED, NON-DELIVERED SECURITIES AS IF IN ITSPOSSESSION AND CONTROL. ALLEGED THAT THE FIRM VIOLATED NYSERULE 342, IN THAT FIRM FAILED TO ESTABLISH ADEQUATE POLICIES ANDPROCEDURES, INCLUDING A SYSTEM OF FOLLOW UP AND REVIEW, FORCOMPLIANCE WITH REGULATION SHO AND FOR COMPLIANCE WITH THE "ANTICIPATED DELIVERY PROGRAM" OF THE NATIONAL SECURITIESCLEARING CORP.Current Status: Final662018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NEW YORK STOCK EXCHANGEPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CENSUREDate Initiated: 05/04/2007Docket/Case Number: HBD 07-82Principal Product Type: Equity - OTCOther Product Type(s):ALLEGED PIPER JAFFRAY VIOLATED RULE 203(B)(1) OF REGULATION SHOIN THAT THE FIRM, ON ONE OR MORE OCCASIONS, EFFECTED SHORTSALE ORDERS IN SECURITIES WITHOUT HAVING BORROWED THESECURITY, WITHOUT ENTERING INTO AN ARRANGEMENT TO BORROW THESECURITY OR WITHOUT HAVING RESONABLE GROUNDS TO BELIEVE THATTHE SECURITIES COULD BE BORROWED. ALLEGED THE FIRM VIOLATEDRULE 200(G) OF REGULATION SHO IN THAT, ON ONE OR MOREOCCASIONS, IT FAILED TO MAKE CERTAIN SHORT SELL ORDERS AS "SHORT EXEMPT". ALLEGED THAT THE FIRM VIOLATED RULE 203(B)(3)(1)OF REGULATION SHO IN THAT, ON ONE OR MORE OCCASIONS, IT FAILEDTO TIMELY CLOSE OUT FAIL TO DELIVER POSITIONS IN THRESHOLDSECURITIES BY PURCHASING SECURITIES OF A LIKE KIND AND QUANTITY.ALLEGED THAT THE FIRM VIOLATED SECTION 15(C) OF THE EXCHANGEACT AND EXCHANGE ACT RULE 15C3-3, AS INTERPRETED BY 15C3-3(C)(1)/07, IN THAT, ON ONE OR MORE OCCASIONS, IT INACCURATELYTREATED NON-SETTLED, NON-DELIVERED SECURITIES AS IF IN ITSPOSSESSION AND CONTROL. ALLEGED THAT THE FIRM VIOLATED NYSERULE 342, IN THAT FIRM FAILED TO ESTABLISH ADEQUATE POLICIES ANDPROCEDURES, INCLUDING A SYSTEM OF FOLLOW UP AND REVIEW, FORCOMPLIANCE WITH REGULATION SHO AND FOR COMPLIANCE WITH THE "ANTICIPATED DELIVERY PROGRAM" OF THE NATIONAL SECURITIESCLEARING CORP.Resolution Date: 06/26/2007Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $150,000.Sanctions Ordered: CensureMonetary/Fine $150,000.00DecisionDisclosure 20 of 134iReporting Source: RegulatorInitiated By: NASDDate Initiated: 05/03/2007Docket/Case Number: 2006005166301Principal Product Type: OtherAllegations: SEC RULE 606 OF REGULATION NMS, NASD RULES 2110, 3010 - FOR ITSALGORITHMIC AND PROGRAM TRADING BUSINESS, PIPER JAFFRAY & CO.FAILED TO MAKE PUBLICLY AVAILABLE QUARTERLY REPORTS FOR A YEARON ITS ROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITIESDURING THOSE QUARTERS. THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH APPLICABLE SECURITIES LAWS, REGULATIONS ANDNASD RULES CONCERNING SEC RULE 606.Current Status: Final672018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2006005166301www.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Principal Product Type: OtherOther Product Type(s): COVERED SECURITIESResolution Date: 05/03/2007Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $25,000.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $25,000.00Acceptance, Waiver & Consent(AWC)iReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Date Initiated: 05/03/2007Docket/Case Number: 20060051663-01Principal Product Type: OtherOther Product Type(s): COVERED SECURITIESAllegations: SEC RULE 606 FEGULATION MMS, NASD RULES 2110, 3010 - ALLEGES FORITS ALGORITHMIC AND PROGRAM TRADING BUSINESS, PIPER JAFFRAY &CO. FAILED TO MAKE PUBLICLY AVAILABLE QUARTERLY REPORTS FOR AYEAR ON ITS ROUTING OF NON-DIRECTED ORDERS IN COVEREDSECURITIES DURING THOSE QUARTERS. THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS AND NASD RULES CONCERNING SEC RULE 606.Current Status: Final682018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CENSUREResolution Date: 05/03/2007Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $25,000. THEFINE OF $25,000 WAS PAID ON MAY 16, 2007.Sanctions Ordered: CensureMonetary/Fine $25,000.00Acceptance, Waiver & Consent(AWC)Disclosure 21 of 134iReporting Source: RegulatorInitiated By: NORTH DAKOTAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CONSENT ORDER CONSISTING OF CEASE AND DESIST LANGUAGE.Date Initiated: 12/04/2006Docket/Case Number:URL for Regulatory Action:Principal Product Type: No ProductOther Product Type(s): SUPERVISION AND BOOKS AND RECORDS.Allegations: PIPER'S AGENTS IMPROPERLY MARKED TRADE TICKETS AS UNSOLICITED.PIPER PROVIDED INADEQUATE SUPERVISION.Current Status: FinalResolution Date: 12/04/2006Resolution:Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?YesConsent692018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions Ordered:Sanction Details: SIGNED CONSENT ORDER.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?YesSanctions Ordered: Monetary/Fine $229,000.00Cease and Desist/InjunctioniReporting Source: FirmInitiated By: STATE OF NORTH DAKOTA, SECURITIES DEPARTMENTPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 12/04/2006Docket/Case Number: UNKNOWNPrincipal Product Type: OtherOther Product Type(s): VARIOUS PRODUCTSAllegations: ALLEGES SEVERAL OF PIPER JAFFRAY'S NORTH DAKOTA AGENTSIMPROPERLY MARKED A SUBSTANTIAL NUMBER OF TRADE TICKETS AS "UNSOLICITED" WHEN THOSE TRANSACTIONS WERE, IN FACT, SOLICITED.ALLEGES INSUFFICIENT TRAINING OF THE AGENTS AND INADEQUATESUPERVISION AT THE CORPORATE OFFICE AND BRANCH OFFICELOCATION.Current Status: FinalResolution Date: 12/04/2006Resolution:Other Sanctions Ordered: DONATION OF $100,000 PAYABLE TO THE NORTH DAKOTA INVESTOREDUCATION AND TECHNOLOGY FUND. IN THE CONTEXT OF ANY CIVILACTION OR ARBITRATION INITIATED BY A NORTH DAKOTA RESIDENTBASED ON SECURITIES TRANSACTIONS CONDUCTED THROUGH ONE OFITS NORTH DAKOTA OFFICES BEFORE JULY 1, 2005, PIPER JAFFRAY ISSPECIFICALLY PRECLUDED FROM USING ANY TRADE TICKETS ASEVIDENCE THAT ANY PARTICULAR TRANSACTION WAS, IN FACT,UNSOLICITED.Sanctions Ordered: Monetary/Fine $129,000.00Cease and Desist/InjunctionOrder702018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceDONATION OF $100,000 PAYABLE TO THE NORTH DAKOTA INVESTOREDUCATION AND TECHNOLOGY FUND. IN THE CONTEXT OF ANY CIVILACTION OR ARBITRATION INITIATED BY A NORTH DAKOTA RESIDENTBASED ON SECURITIES TRANSACTIONS CONDUCTED THROUGH ONE OFITS NORTH DAKOTA OFFICES BEFORE JULY 1, 2005, PIPER JAFFRAY ISSPECIFICALLY PRECLUDED FROM USING ANY TRADE TICKETS ASEVIDENCE THAT ANY PARTICULAR TRANSACTION WAS, IN FACT,UNSOLICITED.Sanction Details: PAYMENT OF $129,000 AND $100,000 WERE PAID ON NOVEMBER 27, 2006.Disclosure 22 of 134iReporting Source: FirmInitiated By: COMMONWEALTH OF MASSACHUSETTSPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 10/08/2003Docket/Case Number: E-2003-44Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED M.G.L. C.110A BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATED ORMAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKINGDEPARTMENT OVER RESEARCH ANALYSTS THEREFORE IMPOSINGCONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS & FAILING TOMANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER;B)THREATENING TO DROP RESEARCH COVERAGE IF THE FIRM WAS NOTSELECTED AS A LEAD MANAGER IN AN INVESTMENT BANKINGTRANSACTION; C)ISSUING RESEARCH REPORTS ON ESPERIONTHERAPEUTICS INC. & TRITON NETWORK SYSTEMS THAT DID NOTPROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDING THOSECOMPANIES & THEIR BUSINESS PROSPECTS; CONTAINED EXAGGERATEDOR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; D)MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WRE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final712018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanction(s)/ReliefSought:CEASE AND DESISTResolution Date: 10/08/2003Resolution:Other Sanctions Ordered: $244,602 TO THE COMMONWEALTH OF MASSACHUSETTSSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND MULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTS REACHEDJOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THE FIRM ISREQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OF THESEMATTERS AND HAS AGREED TO CEASE AND DESIST IN THE FUTURE FROMTHE ALLEGED IMPROPER CONDUCT. PURSUANT TO THE SETTLEMENTDOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BE DESIGNATED AS ACIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BE DESIGNATED ASDISGORGEMENT OF COMMISSIONS AND FEES, AND $7,500,000 OF THISAMOUNT SHALL BE USED TO FUND THE PROCUREMENT OF INDEPENDENTRESEARCH. AMOUNTS PAID TO THE VARIOUS STATES, INCLUDING THE$244,602 TO THE COMMONWEALTH OF MASSACHUSETTS PURSUANT TOTHE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCE THE AMOUNTOF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THE PAYMENT OF$244,602 TO THE COMMONWEALTH OF MASSACHUSETTS WAS MADE ONOCTOBER 7, 2003. THE $12,500,000 DISGORGEMENT AMOUNT DESCRIBEDABOVE IS TO BE PAID TO THE UNITED STATES DISTRICT COURT WITHINTEN (10) DAYS OF COURT APPROVAL OF THE SEC SETTLEMENT ANDENTRY OF FINAL JUDGMENT IN THAT MATTER. THE $7,500,000 TOPROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITED INTOESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrderDisclosure 23 of 134iReporting Source: RegulatorAllegations: SECURITIES EXCHANGE ACT RULE 10B-10, NASD RULES 2320, 6130(D),6420(A), 6955(A) - PIPER JAFFRAY & CO. FAILED, WITHIN 90 SECONDSAFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OFTRANSACTIONS IN ELIGIBLE SECURITIES AND FAILED TO DESIGNATETHROUGH ACT SOME OF THE LAST SALE REPORTS AS LATE; FAILED TOREPORT TO ACT THE CORRECT SYMBOL INDICATING WHETHER ATRANSACTION WAS A BUY, SELL, SELL SHORT, SELL SHORT EXEMPT, ORCROSS FOR TRANSACTIONS IN ELIGIBLE SECURITIES; TRANSMITTED TOOATS REPORTS THAT CONTAINED INACCURATE, INCOMPLETE ORIMPROPERLY FORMATTED DATA THAT CONTAINED INACCURATE ORDERIDENTIFIERS OR AN INCORRECT TIME ASSOCIATED WITH THETRANSACTION; FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSINGTO ITS CUSTOMERS THAT TRANSACTIONS WERE EXECUTED AT ANAVERAGE PRICE; AND, IN TRANSACTIONS FOR OR WITH A CUSTOMER,THE FIRM FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THEBEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCHMARKET SO THAT THE RESULTANT PRICE TO ITS CUSTOMER WAS ASFAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS.Current Status: Final722018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NASDPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 06/06/2006Docket/Case Number: 2005000100701Principal Product Type: OtherOther Product Type(s): ELIGIBLE SECURITIESSECURITIES EXCHANGE ACT RULE 10B-10, NASD RULES 2320, 6130(D),6420(A), 6955(A) - PIPER JAFFRAY & CO. FAILED, WITHIN 90 SECONDSAFTER EXECUTION, TO TRANSMIT THROUGH ACT LAST SALE REPORTS OFTRANSACTIONS IN ELIGIBLE SECURITIES AND FAILED TO DESIGNATETHROUGH ACT SOME OF THE LAST SALE REPORTS AS LATE; FAILED TOREPORT TO ACT THE CORRECT SYMBOL INDICATING WHETHER ATRANSACTION WAS A BUY, SELL, SELL SHORT, SELL SHORT EXEMPT, ORCROSS FOR TRANSACTIONS IN ELIGIBLE SECURITIES; TRANSMITTED TOOATS REPORTS THAT CONTAINED INACCURATE, INCOMPLETE ORIMPROPERLY FORMATTED DATA THAT CONTAINED INACCURATE ORDERIDENTIFIERS OR AN INCORRECT TIME ASSOCIATED WITH THETRANSACTION; FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSINGTO ITS CUSTOMERS THAT TRANSACTIONS WERE EXECUTED AT ANAVERAGE PRICE; AND, IN TRANSACTIONS FOR OR WITH A CUSTOMER,THE FIRM FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THEBEST INTER-DEALER MARKET AND FAILED TO BUY OR SELL IN SUCHMARKET SO THAT THE RESULTANT PRICE TO ITS CUSTOMER WAS ASFAVORABLE AS POSSIBLE UNDER PREVAILING MARKET CONDITIONS.Resolution Date: 06/06/2006Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $26,000.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $26,000.00Acceptance, Waiver & Consent(AWC)732018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=2005000100701www.finra.org/brokercheck User GuidanceiReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CENSUREDate Initiated: 06/02/2006Docket/Case Number: AWAC NO. 20050001007-01Principal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGES VIOLATIONS OF NASD CONDUCT RULE 2320. FROM APRIL 1, 2004THROUGH JUNE 30, 2004, IN 28 TRANSACTIONS FOR OR WITH ACUSTOMER, THE FIRM FAILED TO USE REASONABLE DILIGENCE TOASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY ORSELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITSCUSTOMER WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILINGMARKET CONDITIONS.Current Status: FinalResolution Date: 06/02/2006Resolution:Other Sanctions Ordered:Sanction Details: $3,000 FOR LATE REPORTING VIOLATIONS; $5,000 FOR SHORT SALEREPORTING VIOLATIONS; $5,000 FOR OATS VIOLATIONS; $3,000 FOR 10B-10 VIOLATIONS; AND $10,000 FOR BEST EXECUTION VIOLATIONS.Sanctions Ordered: CensureMonetary/Fine $26,000.00Acceptance, Waiver & Consent(AWC)Disclosure 24 of 134iReporting Source: RegulatorInitiated By: MONTANADate Initiated: 05/17/2006Allegations: UNSUITABLE MUTUAL FUND SWITCHING.Current Status: Final742018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:RestitutionOther Sanction(s)/ReliefSought:FINES, IMPOSITION OF SPECIAL SUPERVISORY REQUIREMENTSREGARDING SECURITIES SALESPERSON MARGIE AGUIRREDate Initiated: 05/17/2006Docket/Case Number: I 04-19-06-216URL for Regulatory Action:Principal Product Type: Mutual Fund(s)Other Product Type(s):Resolution Date: 05/17/2006Resolution:Other Sanctions Ordered: RESTITUTION OF $345,000. STRICT SUPERVISION REGARDINGSECURITIES SALESPERSON MARGIE AGUIRRE.Sanction Details: RESTITUTION OF $345,000. STRICT SUPERVISION REGARDINGSECURITIES SALESPERSON MARGIE AGUIRRE.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: Disgorgement/RestitutionOrderiReporting Source: FirmInitiated By: STATE OF MONTANAPrincipal Sanction(s)/ReliefSought:RestitutionOther Sanction(s)/ReliefSought:FINES, IMPOSITION OF SPECIAL SUPERVISORY REQUIREMENTSREGARDING SECURITIES SALESPERSON IN BUTTE, MT OFFICEDate Initiated: 05/17/2006Docket/Case Number: I 04-19-06-216Principal Product Type: Mutual Fund(s)Other Product Type(s):Allegations: ALLEGES UNSUITABLE MUTUAL FUND SWITCHINGCurrent Status: Final752018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanction(s)/ReliefSought:FINES, IMPOSITION OF SPECIAL SUPERVISORY REQUIREMENTSREGARDING SECURITIES SALESPERSON IN BUTTE, MT OFFICEResolution Date: 05/17/2006Resolution:Other Sanctions Ordered: RESTITUTION OF $345,000. STRICT SUPERVISION REGARDING SECURITIESSALESPERSON IN BUTTE, MT OFFICESanction Details: RESTITUTION OF $345,000. STRICT SUPERVISION REGARDING SECURITIESSALESPERSON IN BUTTE, MT OFFICESanctions Ordered: Disgorgement/RestitutionOrderDisclosure 25 of 134iReporting Source: RegulatorInitiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSIONPrincipal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:CENSURE, CIVIL PENALTIESDate Initiated: 05/31/2006Docket/Case Number: 3-12310Principal Product Type: Equity Listed (Common & Preferred Stock)Other Product Type(s): MUNICIPAL BONDS, CORPORATE BONDSAllegations: SEC ADMINISTRATIVE PROCEEDING RELEASE 33-8684, 34-53888, DATEDMAY 31, 2006, THE SECURITIES AND EXCHANGE COMMISSION COMPLAINTALLEGES THAT RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OFTHE SECURITIES ACT. AS PART OF ITS BROKER-DEALER BUSINESS,RESPONDENT UNDERWRITE, AND MANAGE AUCTIONS FOR, AUCTIONRATE SECURITIES. FROM AT LEAST JANUARY 1, 2003 THROUGH JUNE 30,2004, IN CONNECTION WITH CERTAIN AUCTIONS, RESPONDENT ENGAGEDIN ONE OR MORE OF THE FOLLOWING PRACTICES VIOLATIONS:COMPLETION OF OPEN OR MARKET BIDS, INTERVENTION IN AUCTIONS,BIDS TO PREVENT FAILED AUCTIONS, BIDS TO A SET A "MARKET" RATE,BIDS TO PREVENT ALL-HOLD AUCTIONS, PRIORITIZATION OF BIDS,SUBMISSION OR REVISION OF BIDS AFTER DEADLINES, ALLOCATION OFSECURITIES, PARTIAL ORDERS, EXPRESS OR TACTIC UNDERSTANDING TOPROVIDE HIGHER RETURNS, AND PRICE TALK.Current Status: Final762018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceResolution Date: 05/31/2006Resolution:Other Sanctions Ordered: NOT LATER THAN 6 MONTHS AFTER THE ENTRY OF THIS ORDER,RESPONDENT SHALL PROVIDE ALL OF ITS CUSTOMERS WHO HOLDAUCTION RATE SECURITIES ("HOLDERS") AND THE ISSUERS OF SUCHSECURITIES ("ISSUERS") WITH A WRITTEN DESCRIPTION OF THERESPONDENT'S MATERIAL AUCTION PRACTICES AND PROCEDURES.FURTHERMORE, COMMENCING NOT LATER THAN 3 MONTHS AFTER THEENTRY OF THIS ORDER, RESPONDENT SHALL AT ALL TIMES MAKE ADESCRIPTION OF ITS THEN-CURRENT MATERIAL AUCTION PRACTICESAND PROCEDURES AVAILABLE TO (1) ALL CUSTOMERS AND BROKER-DEALERS WHO ARE PARTICIPATING THROUGH SUCH RESPONDENT IN ANAUCTION OF AUCTION RATE SECURITIES ON THE PORTION OF ITSWEBSITE THAT IS ACCESSIBLE TO SUCH CUSTOMERS AND BROKER-DEALERS AND IS RELATED TO SUCH AUCTION AND (2) THE GENERALPUBLIC ON ANOTHER PORTION OF ITS WEBSITE ACCESSIBLE TO THEGENERAL PUBLIC. NOT LATER THAN 6 MONTHS AFTER THE DATE OF THISORDER, UNLESS OTHERWISE EXTENDED BY THE STAFF OF THECOMMISSION FOR GOOD CAUSE SHOWN, RESPONDENT'S CHIEFEXECUTIVE OFFICER OR GENERAL COUNSEL SHALL CERTIFY IN WRITINGTO THE STAFF OF THE COMMISSION THAT RESPONDENT HASIMPLEMENTED PROCEDURES THAT ARE REASONABLY DESIGNED TOPREVENT AND DETECT FAILURES BY RESPONDENT TO CONDUCT THEAUCTION PROCESS IN ACCORDANCE WITH THE AUCTION PROCEDURESDISCLOSED IN THE DISCLOSURE DOCUMENTS AND ANY SUPPLEMENTALDISCLOSURES AND THAT THE RESPONDENT IS IN COMPLIANCE WITH THISORDER.Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENTCONSENTED TO THE ENTRY OF THIS ORDER; ACCORDINGLY, PURSUANTTO SECTION 8A OF THE SECURITIES ACT AND SECTION 15(B) OF THEEXCHANGE ACT, IS ORDERED THAT RESPONDENT IS CENSURED, SHALLCEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONSAND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIESACT; AND SHALL, WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, PAY ACIVIL MONEY PENALTY OF $125,000 TO THE UNITED STATES TREASURY.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $125,000.00Cease and Desist/InjunctionOrder772018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENTCONSENTED TO THE ENTRY OF THIS ORDER; ACCORDINGLY, PURSUANTTO SECTION 8A OF THE SECURITIES ACT AND SECTION 15(B) OF THEEXCHANGE ACT, IS ORDERED THAT RESPONDENT IS CENSURED, SHALLCEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONSAND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIESACT; AND SHALL, WITHIN 10 DAYS OF THE ENTRY OF THIS ORDER, PAY ACIVIL MONEY PENALTY OF $125,000 TO THE UNITED STATES TREASURY.iReporting Source: FirmInitiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSIONPrincipal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:CENSURE, CIVIL PENALTIESDate Initiated: 05/31/2006Docket/Case Number: 3-12310Principal Product Type: Equity Listed (Common & Preferred Stock)Other Product Type(s): MUNICIPAL BONDS, CORPORATE BONDSAllegations: ALLEGES PIPER VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT.FROM AT LEAST JANUARY 1, 2003 THROUGH JUNE 30, 2004, INCONNECTION WITH CERTAIN AUCTIONS, PIPER ENGAGED IN ONE ORMORE OF THE FOLLOWING PRACTICES VIOLATIONS: COMPLETION OFOPEN OR MARKET BIDS, INTERVENTION IN AUCTIONS, BIDS TO PREVENTFAILED AUCTIONS, BIDS TO SET A "MARKET" RATE, BIDS TO PREVENT ALL-HOLD AUCTIONS, PRIORITIZATION OF BIDS, SUBMISSION OR REVISION OFBIDS AFTER DEADLINES, ALLOCATION OF SECURITIES, PARTIAL ORDERS,EXPRESS OR TACTIC UNDERSTANDING TO PROVIDE HIGHER RETURNS,AND PRICE TALK.Current Status: FinalResolution Date: 05/31/2006Resolution:Other Sanctions Ordered: NOT LATER THAN 6 MONTHS AFTER THE ENTRY OF THIS ORDER, PIPERSHALL PROVIDE ALL OF ITS CUSTOMERS WHO HOLD AUCTION RATESECURITIES ("HOLDERS") AND THE ISSUERS OF SUCH SECURITIES("ISSUERS") WITH A WRITTEN DESCRIPTION OF THE FIRM'S MATERIALAUCTION PRACTICES AND PROCEDURES. FURTHERMORE, COMMENCINGNOT LATER THAN 3 MONTHS AFTER THE ENTRY OF THIS ORDER, PIPERSHALL AT ALL TIMES MAKE A DESCRIPTION OF ITS THEN-CURRENTMATERIAL AUCTION PRACTICES AND PROCEDURES AVAILABLE TO (1) ALLCUSTOMERS AND BROKER-DELAERS WHO ARE PARTICIPATING THROUGHPIPER IN AN AUCTION OF AUCTION RATE SECURITIES ON THE PORTION OFITS WEBSITE THAT IS ACCESSIBLE TO SUCH CUSTOMERS AND BROKER-DEALERS AND IS RELATED TO SUCH AUCTION AND (2) THE GENERALPUBLIC ON ANOTHER PORTION OF ITS WEBSITE ACCESSIBLE TO THEGENERAL PUBLIC. NOT LATER THAN 6 MONTHS AFTER THE DATE OF THISORDER, UNLESS OTHERWISE EXTENDED BY THE STAFF OF THECOMMISSION FOR GOOD CAUSE SHOWN, THE FIRM'S CHIEF EXECUTIVEOFFICER OR GENERAL COUNSEL SHALL CERTIFY IN WRITING TO THESTAFF OF THE COMMISSION THAT THE FIRM HAS IMPLEMENTEDPROCEDURES THAT ARE REASONABLY DESIGNED TO PREVENT ANDDETECT FAILURES BY THE FIRM TO CONDUCT THE AUCTION PROCESS INACCORDANCE WITH THE AUCTION PROCEDURES DISCLOSED IN THEDISCLOSURE DOCUMENTS AND ANY SUPPLEMENTAL DISCLOSURES ANDTHAT THE FIRM IS IN COMPLIANCE WITH THIS ORDER.Sanctions Ordered: CensureMonetary/Fine $125,000.00Cease and Desist/InjunctionOrder782018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceNOT LATER THAN 6 MONTHS AFTER THE ENTRY OF THIS ORDER, PIPERSHALL PROVIDE ALL OF ITS CUSTOMERS WHO HOLD AUCTION RATESECURITIES ("HOLDERS") AND THE ISSUERS OF SUCH SECURITIES("ISSUERS") WITH A WRITTEN DESCRIPTION OF THE FIRM'S MATERIALAUCTION PRACTICES AND PROCEDURES. FURTHERMORE, COMMENCINGNOT LATER THAN 3 MONTHS AFTER THE ENTRY OF THIS ORDER, PIPERSHALL AT ALL TIMES MAKE A DESCRIPTION OF ITS THEN-CURRENTMATERIAL AUCTION PRACTICES AND PROCEDURES AVAILABLE TO (1) ALLCUSTOMERS AND BROKER-DELAERS WHO ARE PARTICIPATING THROUGHPIPER IN AN AUCTION OF AUCTION RATE SECURITIES ON THE PORTION OFITS WEBSITE THAT IS ACCESSIBLE TO SUCH CUSTOMERS AND BROKER-DEALERS AND IS RELATED TO SUCH AUCTION AND (2) THE GENERALPUBLIC ON ANOTHER PORTION OF ITS WEBSITE ACCESSIBLE TO THEGENERAL PUBLIC. NOT LATER THAN 6 MONTHS AFTER THE DATE OF THISORDER, UNLESS OTHERWISE EXTENDED BY THE STAFF OF THECOMMISSION FOR GOOD CAUSE SHOWN, THE FIRM'S CHIEF EXECUTIVEOFFICER OR GENERAL COUNSEL SHALL CERTIFY IN WRITING TO THESTAFF OF THE COMMISSION THAT THE FIRM HAS IMPLEMENTEDPROCEDURES THAT ARE REASONABLY DESIGNED TO PREVENT ANDDETECT FAILURES BY THE FIRM TO CONDUCT THE AUCTION PROCESS INACCORDANCE WITH THE AUCTION PROCEDURES DISCLOSED IN THEDISCLOSURE DOCUMENTS AND ANY SUPPLEMENTAL DISCLOSURES ANDTHAT THE FIRM IS IN COMPLIANCE WITH THIS ORDER.Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, PIPER CONSENTED TOTHE ENTRY OF THIS ORDER; ACCORDINGLY, PURSUANT TO SECTION 8AOF THE SECURITIES ACT AND SECTION 15(B) OF THE EXCHANGE ACT, ISORDERED THAT PIPER IS CENSURED, SHALL CEASE AND DESIST FROMCOMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONSOF SECTION 17(A)(2) OF THE SECURITIES ACT; AND HAS PAID A CIVILMONEY PENALTY OF $125,000 ON JUNE 8, 2006.Disclosure 26 of 134iReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:ProhibitionOther Sanction(s)/ReliefSought:Date Initiated: 11/30/2005Docket/Case Number: NONEPrincipal Product Type: No ProductOther Product Type(s):Allegations: ALLEGES THE FIRM ENGAGED IN MUNICIPAL SECURITIES BUSINESSWHILE PROHIBITING FROM DOING SO DUE TO POLITICAL CONTRIBUTIONSIN EXCESS OF THE LIMITS PROVIDED BY MSRB RULE G-37.Current Status: FinalAppealed To and Date AppealFiled:NASD 12/13/05792018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanction(s)/ReliefSought:Resolution Date: 05/17/2006Resolution:Other Sanctions Ordered: THE FIRM IS RESTRICTED FROM PARTICIPATING IN SELECT TYPES OFBOND ISSUES WITH THE STATE OF MINNESOTA OR ITS AGENCIES UNTILAPRIL 19, 2007.Sanction Details: THE FIRM IS RESTRICTED FROM PARTICIPATING IN SELECT TYPES OFBOND ISSUES WITH THE STATE OF MINNESOTA OR ITS AGENCIES UNTILAPRIL 19, 2007.Firm Statement ON MAY 17, 2006 THE NATIONAL ADJURATORY COUNCIL DENIED AREQUEST FOR EXCEPTIVE RELIEF FROM A PROHIBITION OF ENGAGING INMUNICIPAL SECURITIES BUSINESS DUE TO POLITICAL CONTRIBUTIONS INEXCESS OF THE LIMITS PROVIDED FOR BY MSRB RULE G-37.Sanctions Ordered:DecisionDisclosure 27 of 134iReporting Source: RegulatorInitiated By: PACIFIC STOCK EXCHANGEPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:PIPER JAFFRAY WILL AMEND ITS OPERATIONAL AND SUPERVISORYPROCEDURES TO GREATLY REDUCE IF NOT ELIMINATE PIPER JAFFRAY'SFUTURE VIOLATION OF ITS MARKET MAKER OBLIGATION TO MAINTAINCONTINUOUS TWO-SIDED Q ORDERS.Date Initiated: 07/01/2004Docket/Case Number: 05-23Principal Product Type: Equity Listed (Common & Preferred Stock)Other Product Type(s):Allegations: MEMBER FIRM VIOLATED PCXE RULE 7.23(A)(1) WHEN IT FAILED TOMAINTAIN CONTINUOUS TWO-SIDED Q ORDERS FOR ISSUES IN WHICH ITIS REGISTERED AS A MARKET MAKER.Current Status: FinalResolution Date: 09/08/2005Resolution: Decision & Order of Offer of Settlement802018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceResolution Date: 09/08/2005Other Sanctions Ordered: PIPER JAFFRAY WILL AMEND ITS OPERATIONAL AND SUPERVISORYPROCEDURES TO GREATLY REDUCE IF NOT ELIMINATE PIPER JAFFRAY'SFUTURE VIOLATION OF ITS MARKET MAKER OBLIGATION TO MAINTAINCONTINUOUS TWO-SIDED Q ORDERS.Sanction Details: $18,450.00 FINE LEVIED AGAINST PIPER JAFFRAY WAS PAID ON OCTOBER10, 2005.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: Monetary/Fine $18,450.00iReporting Source: FirmInitiated By: PCX EQUITIES, INC.Principal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:UNDERTAKINGDate Initiated: 09/27/2005Docket/Case Number: 05-23Principal Product Type: Equity Listed (Common & Preferred Stock)Other Product Type(s):Allegations: ALLEGES VIOLATION OF PCXE RULE 7.23(A)(1). PIPER JAFFRAY FAILED ONNUMEROUS OCCASIONS TO MAINTAIN CONTINUOUS, TWO-SIDED QORDERS IN NUMEROUS SECURITIES IN WHIC PIPER WAS REGISTERED TOTRADE AS A MARKET MAKER.Current Status: FinalResolution Date: 09/27/2005Resolution:Other Sanctions Ordered: AN UNDERTAKING WHEREBY PIPER SHALL DEMONSTRATE TO THESATISFACTION OF THE PCXE DIRECTOR OF MARKET REGULATION NOLATER THAN 30 CALENDAR DAYS AFTER THE DATE THIS OFFER ISAPPROVED BY THE BCC THAT PIPER HAS AMENDED ITS OPERATIONALAND SUPERVISORY PROCEDURES TO GREATLY REDUCE IF NOTELIMINATE PIPER'S FUTURE VIOLATION OF ITS MARKET MAKEROBLIGATION TO MAINTAIN CONTINUOUS TWO-SIDED Q ORDERS.Sanctions Ordered: Monetary/Fine $18,450.00Decision & Order of Offer of Settlement812018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceAN UNDERTAKING WHEREBY PIPER SHALL DEMONSTRATE TO THESATISFACTION OF THE PCXE DIRECTOR OF MARKET REGULATION NOLATER THAN 30 CALENDAR DAYS AFTER THE DATE THIS OFFER ISAPPROVED BY THE BCC THAT PIPER HAS AMENDED ITS OPERATIONALAND SUPERVISORY PROCEDURES TO GREATLY REDUCE IF NOTELIMINATE PIPER'S FUTURE VIOLATION OF ITS MARKET MAKEROBLIGATION TO MAINTAIN CONTINUOUS TWO-SIDED Q ORDERS.Sanction Details: PIPER'S ACCOUNT WILL BE DEBITED FOR THE $18,450.00 FINE.Disclosure 28 of 134iReporting Source: RegulatorInitiated By: NORTH DAKOTAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 08/29/2005Docket/Case Number:URL for Regulatory Action:Principal Product Type: Annuity(ies) - VariableOther Product Type(s): MUTUAL FUNDSAllegations: RESPONDENT, THROUGH ITS AGENT, BRADY VOLLMERS, ENGAGED INUNSUITABLE TRANSACTIONS IN THE ACCOUNT OF A NORTH DAKOTARESIDENT. SEVERAL OF THE TRANSACTIONS WERE ALSO IMPROPERLYMARKED "UNSOLICITED".Current Status: FinalResolution Date: 06/28/2006Resolution:Other Sanctions Ordered:Sanction Details: DISGORGEMENT OF $7,203.66 TO INVESTOR RESTITUTION FUND, FORRETURN TO INVESTORS. PENALTY AND DISGORGEMENT COLLECTED.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?YesSanctions Ordered: Monetary/Fine $10,000.00Disgorgement/RestitutionConsent822018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceSanction Details: DISGORGEMENT OF $7,203.66 TO INVESTOR RESTITUTION FUND, FORRETURN TO INVESTORS. PENALTY AND DISGORGEMENT COLLECTED.iReporting Source: FirmInitiated By: STATE OF NORTH DAKOTAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 08/29/2005Docket/Case Number: UNKNOWNPrincipal Product Type: Annuity(ies) - VariableOther Product Type(s): MUTUAL FUNDSAllegations: ALLEGES PIPER JAFFRAY, THROUGH ONE OF ITS AGENTS, ENGAGED INUNSUITABLE TRANSACTIONS IN THE ACCOUNT OF A NORTH DAKOTARESIDENT. SEVERAL OF THE TRANSACTIONS WERE ALSO IMPROPERLYMARKED "UNSOLICITED".Current Status: FinalResolution Date: 06/28/2006Resolution:Other Sanctions Ordered: $4,537.62 AS DISGORGEMENT TO THE INVESTOR RESTITUTION FUND AND$2,666.04 TO THE INVESTOR RESTITUTION FUND - THOSE FUNDS WILL BEPAID TO THE CLIENT. PIPER JAFFRAY SHALL PROPERLY SUPERVISE THEACTIVITIES OF ITS AGENTS WITH REGARD TO ALL SECURITIES-RELATEDACTIVITY IN NORTH DAKOTA.Sanction Details: FUNDS WERE PAID ON JUNE 26, 2006.Sanctions Ordered: Monetary/Fine $10,000.00Disgorgement/RestitutionOrderDisclosure 29 of 134iReporting Source: RegulatorAllegations: **9/28/05**STIPULATION AND CONSENT TO PENALTY FILED BY NYSEDIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS:1.VIOLATED EXCHANGE RULE 410A BY FAILING TO SUBMIT ACCURATETRADING INFORMATION THROUGH THE SUBMISSION OF ELECTRONICBLUE SHEETS IN RESPONSE TO ONE OR MORE REQUESTS FOR SUCHINFORMATION BY THE EXCHANGE;2.VIOLATED EXCHANGE RULE 401 BYFAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICEIN THE CONDUCT OF THEIR BUSINESS AFFAIRS IN THAT IT SUBMITTEDINACCURATE TRADING INFORMATION ON ELECTRONIC BLUE SHEETS INRESPONSE TO ONE OR MORE REQUESTS FOR SUCH INFORMATION BYTHE EXCHANGE; AND 3.VIOLATED EXCHANGE RULES 342 BY FAILING TOESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS AND PROCEDURESFOR THE SUPERVISION AND CONTROL OF AREAS RESPONSIBLE FORCOMPLYING WITH ELECTRONIC BLUE SHEET REPORTINGREQUIREMENTS, AND FAILED TO ESTABLISH A SEPARATE SYSTEM OFFOLLOW-UP AND REVIEW TO REASONABLY ENSURE COMPLIANCE WITHEXCHANGE RULES RELATING TO THE PREPARATION AND SUBMISSION OFELECTRONIC BLUE SHEETS.STIPULATED SANCTION: THE IMPOSITION BY THE EXCHANGE OF ACENSURE, A $300,000 FINE AND A REQUIREMENT THAT RESPONDENT WILLCONDUCT A VALIDATION OF ALL REQUIRED BLUE SHEET DATA ELEMENTSIN ACCORDANCE WITH ISG REGULATORY MEMORANDUM, ISG 2005-01.Current Status: Final832018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENTPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 09/28/2005Docket/Case Number: HPD# 05-154Principal Product Type: OtherOther Product Type(s):**9/28/05**STIPULATION AND CONSENT TO PENALTY FILED BY NYSEDIVISION OF ENFORCEMENT AND PENDING CONSENTED TO FINDINGS:1.VIOLATED EXCHANGE RULE 410A BY FAILING TO SUBMIT ACCURATETRADING INFORMATION THROUGH THE SUBMISSION OF ELECTRONICBLUE SHEETS IN RESPONSE TO ONE OR MORE REQUESTS FOR SUCHINFORMATION BY THE EXCHANGE;2.VIOLATED EXCHANGE RULE 401 BYFAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESS PRACTICEIN THE CONDUCT OF THEIR BUSINESS AFFAIRS IN THAT IT SUBMITTEDINACCURATE TRADING INFORMATION ON ELECTRONIC BLUE SHEETS INRESPONSE TO ONE OR MORE REQUESTS FOR SUCH INFORMATION BYTHE EXCHANGE; AND 3.VIOLATED EXCHANGE RULES 342 BY FAILING TOESTABLISH AND MAINTAIN APPROPRIATE SYSTEMS AND PROCEDURESFOR THE SUPERVISION AND CONTROL OF AREAS RESPONSIBLE FORCOMPLYING WITH ELECTRONIC BLUE SHEET REPORTINGREQUIREMENTS, AND FAILED TO ESTABLISH A SEPARATE SYSTEM OFFOLLOW-UP AND REVIEW TO REASONABLY ENSURE COMPLIANCE WITHEXCHANGE RULES RELATING TO THE PREPARATION AND SUBMISSION OFELECTRONIC BLUE SHEETS.STIPULATED SANCTION: THE IMPOSITION BY THE EXCHANGE OF ACENSURE, A $300,000 FINE AND A REQUIREMENT THAT RESPONDENT WILLCONDUCT A VALIDATION OF ALL REQUIRED BLUE SHEET DATA ELEMENTSIN ACCORDANCE WITH ISG REGULATORY MEMORANDUM, ISG 2005-01.Resolution Date: 02/17/2006Resolution:Other Sanctions Ordered:Sanction Details: **1/5/06** DECISION 05-154 ISSUED BY NYSE HEARING PANELDECISION: VIOLATED NYSE RULE 410A BY FAILING TO SUBMIT ACCURATETRADING INFORMATION THROUGH THE SUBMISSION OF ELECTRONICBLUE SHEETS; VIOLATED NYSE RULE 401 BY SUBMITTING INACCURATETRADING INFORMATION ON ELECTRONIC BLUE SHEETS; VIOLATED NYSERULE 342 BY FAILING TO ESTABLISH AND MAINTAIN APPROPRIATESYSTEMS AND PROCEDURES FOR THE SUPERVISION AND CONTROL OFAREAS RESPONSIBLE FOR COMPLYING WITH ELECTRONIC BLUE SHEETREPORTING REQUIREMENTS AND FAILING TO ESTABLISH A SEPARATESYSTEM OF FOLLOW-UP AND REVIEW TO REASONABLY ENSURECOMPLIANCE WITH NYSE RULES RELATING TO THE PREPARATION ANDSUBMISSION OF ELECTRONIC BLUE SHEETS. -CONSENT TO CENSURE,FINE OF $300,000, AND A REQUIREMENT TO CONDUCT VALIDATION OF ALLREQUIRED BLUE SHEET DATA ELEMENTS, AND UNDERTAKING TO INFORMNYSE IN WRITING THAT VALIDATION HAS BEEN COMPLETED.Sanctions Ordered: CensureMonetary/Fine $300,000.00Decision842018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User Guidance**1/5/06** DECISION 05-154 ISSUED BY NYSE HEARING PANELDECISION: VIOLATED NYSE RULE 410A BY FAILING TO SUBMIT ACCURATETRADING INFORMATION THROUGH THE SUBMISSION OF ELECTRONICBLUE SHEETS; VIOLATED NYSE RULE 401 BY SUBMITTING INACCURATETRADING INFORMATION ON ELECTRONIC BLUE SHEETS; VIOLATED NYSERULE 342 BY FAILING TO ESTABLISH AND MAINTAIN APPROPRIATESYSTEMS AND PROCEDURES FOR THE SUPERVISION AND CONTROL OFAREAS RESPONSIBLE FOR COMPLYING WITH ELECTRONIC BLUE SHEETREPORTING REQUIREMENTS AND FAILING TO ESTABLISH A SEPARATESYSTEM OF FOLLOW-UP AND REVIEW TO REASONABLY ENSURECOMPLIANCE WITH NYSE RULES RELATING TO THE PREPARATION ANDSUBMISSION OF ELECTRONIC BLUE SHEETS. -CONSENT TO CENSURE,FINE OF $300,000, AND A REQUIREMENT TO CONDUCT VALIDATION OF ALLREQUIRED BLUE SHEET DATA ELEMENTS, AND UNDERTAKING TO INFORMNYSE IN WRITING THAT VALIDATION HAS BEEN COMPLETED.Regulator Statement **2/17/06**THE DECISION IS NOW FINAL AND EFFECTIVEIMMEDIATELY.CONTACT:PEGGY GERMINO AT 212-656-8450iReporting Source: FirmInitiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENTPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CENSUREDate Initiated: 09/28/2005Docket/Case Number: 05-154Principal Product Type: OtherOther Product Type(s):Allegations: ALLEGES THAT PIPER JAFFRAY 1. VIOLATED EXCHANGE RULE 410A BYFAILING TO SUBMIT ACCURATE TRADING INFORMATION THROUGH THESUBMISSION OF ELECTRONIC BLUE SHEETS IN RESPONSE TO ONE ORMORE REQUESTS FOR SUCH INFORMATION BY THE EXCHANGE; 2.VIOLATED EXCHANGE RULE 401 BY FAILING TO ADHERE TO THEPRINCIPLES OF GOOD BUSINESS PRACTICE IN THE CONDUCT OF THEIRBUSINESS AFFAIRS IN THAT IT SUBMITTED INACCURATE TRADINGINFORMATION ON ELECTRONIC BLUE SHEETS IN RESPONSE TO ONE ORMORE REQUESTS FOR SUCH INFORMATION BY THE EXCHANGE; AND 3.VIOLATED EXCHANGE RULES 342 BY FAILING TO ESTABLISH AND MAINTAINAPPROPRIATE SYSTEMS AND PROCEDURES FOR THE SUPERVISION ANDCONTROL OF AREAS RESPONSIBLE FOR COMPLYING WITH ELECTRONICBLUE SHEET REPORTING REQUIREMENTS, AND FAILED TO ESTABLISH ASEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO REASONABLYENSURE COMPLIANCE WITH EXCHANGE RULES RELATING TO THEPREPARATION AND SUBMISSION OF ELECTRONIC BLUE SHEETS.Current Status: Final852018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanction(s)/ReliefSought:CENSUREResolution Date: 01/03/2006Resolution:Other Sanctions Ordered: UNDERTAKINGSanction Details: REQUIREMENT TO CONDUCT VALIDATION OF ALL REQUIRED BLUE SHEETDATA ELEMENTS, AND UNDERTAKING TO INFORM NYSE IN WRITING THATVALIDATION HAS BEEN COMPLETED. FINE WAS PAID ON MARCH 10, 2006.Sanctions Ordered: CensureMonetary/Fine $300,000.00ConsentDisclosure 30 of 134iReporting Source: RegulatorInitiated By: NASDPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 06/28/2005Docket/Case Number: C0420050022Principal Product Type: Debt - MunicipalOther Product Type(s):Allegations: MSRB RULES G-14 & G-27 - PIPER JAFFRAY & CO OVER-REPORTEDAND/OR FAILED TO TIMELY REPORT MUNICIPAL SECURITIESTRANSACTIONS WITH PUBLIC CUSTOMERS THAT IS REPORTED TO MSRB.THE FIRM FAILED TO TIMELY REPORT AND/OR OVER-REPORTED ITSINTER-DEALER MUNICIPAL SECURITIES TRANSACTIONS TO THE MSRB.PIPER JAFFRAY ALSO FAILED TO MONITOR ITS TRADE REPORTING FORMUNICIPAL SECURITIES TRANSACTIONS TO ENSURE COMPLIANCE WITHMSRB RULE G-14.Current Status: FinalResolution Date: 06/28/2005Resolution:Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoAcceptance, Waiver & Consent(AWC)862018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=c0420050022www.finra.org/brokercheck User GuidanceOther Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, PIPER JAFFRAY &CO CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE THE FIRM IS CENSURED AND FINED $280,000.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $280,000.00iReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CENSUREDate Initiated: 03/01/2005Docket/Case Number: AWAC NO. C04050022Principal Product Type: Debt - MunicipalOther Product Type(s):Allegations: ALLEGES THAT FROM JANUARY 1, 2003 THROUGH OCTOBER 31, 2004,PIPER FAILED TO TIMELY REPORT AND/OR OVER-REPORTED TO THEMUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") MUNICIPALTRANSACTIONS WITH CUSTOMERS AND DEALERS.Current Status: FinalResolution Date: 06/03/2005Resolution:Other Sanctions Ordered:Sanction Details: CHECK FOR FINE WAS MAILED ON 6/30/05Sanctions Ordered: CensureMonetary/Fine $280,000.00Acceptance, Waiver & Consent(AWC)872018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceDisclosure 31 of 134iReporting Source: RegulatorInitiated By: NORTH DAKOTA SECURITIES DEPARTMENTPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 05/05/2005Docket/Case Number:URL for Regulatory Action:Principal Product Type: Mutual Fund(s)Other Product Type(s):Allegations: RESPONDENT, THROUGH ITS AGENT, TERRY MILLNER, ENGAGED INUNAUTHORIZED TRANSACTIONS AND UNSUITABLE TRANSACTIONS IN THEACCOUNT OF A NORTH DAKOTA RESIDENT. FURTHER, RESPONDENT ANDMILLNER MISMARKED TRADE CONFIRMATION STATEMENTS AS "UNSOLICITED".Current Status: FinalResolution Date: 05/05/2005Resolution:Other Sanctions Ordered:Sanction Details: PENALTY IS JOINT AND SEVERAL WITH MILLNER. SETTLEMENT WITH THENORTH DAKOTA RESIDENT WAS REACHED THROUGH A SEPARATEAGREEMENT.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?YesSanctions Ordered: Monetary/Fine $30,000.00ConsentiReporting Source: Firm882018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF NORTH DAKOTAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 05/05/2005Docket/Case Number: UNKNOWNPrincipal Product Type: Debt - MunicipalOther Product Type(s):Allegations: ALLEGES RESPONDENTS VIOLATED SECTIONS 73-02-09-02(4-5)N.D.A.C. &73-02-09-03(6)N.D.A.C. AND SECTION 10-04-15 N.D.C.C. BY EXERCISINGDISCRETION IN A CLIENT ACCOUNT WHEN NOT AUTHORIZED TO DO SO.ALLEGES RESPONDENTS CONDUCTED TRANSACTIONS BASED ON THEINVESTMENT OBJECTIVES, RISK TEMPERMENT AND INVESTMENT TIMEHORIZON OF THE INVESTOR.Current Status: FinalResolution Date: 05/05/2005Resolution:Other Sanctions Ordered: 1.NOT CONDUCT SECURITIES TRANSACTIONS IN NORTH DAKOTA UNLESSTHE TRANSACTIONS ARE AUTHORIZED BY THE CLIENT OR THE CLIENTHAS PROVIDED WRITTEN AUTHORIZATION TO EXERCISE DISCRETION INTHAT CLIENT'S ACCOUNT 2.NOT MARK ANY TRADE CONFIRMATIONS AS "UNSOLICITED" UNLESS THE CLIENT INITIATED THE TRANSACTION ANDNO AGENT OF PJ SOLICITED THE TRANSACTION 3.NOT ENGAGE INUNSUITABLE INVESTMENTS IN THE ACCOUNT A NORTH DAKOTA RESIDENTCLIENT.Sanction Details: THE CIVIL PENALTY OF $30,000 WAS PAID ON MAY 2, 2005.Sanctions Ordered: Monetary/Fine $30,000.00OrderDisclosure 32 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SECTION8.E.(1)(B) OF THE ILLINOIS SECURITIES LAW OF 1953 BY: A)ENGAGING INACTS & PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATEINFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVERRESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OF INTERESTON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESE CONFLICTS INAN ADEQUATE OR APPROPRIATE MANNER; B)THREATENING TO DROPRESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS A LEADMANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final892018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF ILLINOISPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 03/24/2005Docket/Case Number: 0400034Principal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SECTION8.E.(1)(B) OF THE ILLINOIS SECURITIES LAW OF 1953 BY: A)ENGAGING INACTS & PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATEINFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVERRESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OF INTERESTON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESE CONFLICTS INAN ADEQUATE OR APPROPRIATE MANNER; B)THREATENING TO DROPRESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS A LEADMANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 04/01/2005Resolution:Other Sanctions Ordered: $478,461 TO THE STATE OF ILLINOISSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $478,461 PAID TO THE STATE OFILLINOIS PURSUANT TO THE ADMINISTRATIVE CONSENT ORDER, SHALL BEAPPLIED TO AND REDUCE THE AMOUNT OF THE $12,500,000 CIVILPENALTY DESCRIBED ABOVE. THE PAYMENT OF $478,461 WAS MADE ONMARCH 24, 2005. THE $12,500,000 DISGORGMENT AMOUNT DESCRIBEDABOVE IS TO BE PAID TO THE UNITED STATES DISTRICT COURT WITHINTEN (10) DAYS OF COURT APPROVAL OF THE SEC SETTLEMENT ANDENTRY OF FINAL JUDGMENT IN THAT MATTER. THE $7,500,000 TOPROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITED INTOESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder902018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $478,461 PAID TO THE STATE OFILLINOIS PURSUANT TO THE ADMINISTRATIVE CONSENT ORDER, SHALL BEAPPLIED TO AND REDUCE THE AMOUNT OF THE $12,500,000 CIVILPENALTY DESCRIBED ABOVE. THE PAYMENT OF $478,461 WAS MADE ONMARCH 24, 2005. THE $12,500,000 DISGORGMENT AMOUNT DESCRIBEDABOVE IS TO BE PAID TO THE UNITED STATES DISTRICT COURT WITHINTEN (10) DAYS OF COURT APPROVAL OF THE SEC SETTLEMENT ANDENTRY OF FINAL JUDGMENT IN THAT MATTER. THE $7,500,000 TOPROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITED INTOESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINAL JUDGMENT.Disclosure 33 of 134iReporting Source: RegulatorInitiated By: NORTH DAKOTAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 10/13/2004Docket/Case Number:URL for Regulatory Action:Principal Product Type: Equity - OTCOther Product Type(s):Allegations: RESPONDENT, THROUGH ITS AGENT, DREW LIKNESS, ENGAGED INUNSUITABLE TRADING IN A CUSTOMER ACCOUNT. THE TRADING ALSOINVOLVED UNAUTHORIZED TRADING. AT LEAST SEVEN OF THE TRADECONFIRMATION STATEMENTS WERE IMPROPERLY MARKED "UNSOLICITED".Current Status: Final912018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanction(s)/ReliefSought:Resolution Date: 10/13/2004Resolution:Other Sanctions Ordered: RESPONDENT WAS ORDERED TO SUPERVISE ITS AGENTS.Sanction Details: RESPONDENT WAS FINED $20,000 AND ORDERED TO SUPERVISE ITSAGENTS IN THE FUTURE.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?YesSanctions Ordered: Monetary/Fine $20,000.00ConsentiReporting Source: FirmInitiated By: STATE OF NORTH DAKOTAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 09/01/2004Docket/Case Number: NONEPrincipal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGES PIPER JAFFRAY DID NOT PROPERLY SUPERVISE ONE ITSAGENTS REGARDING ACTIVITY IN A CLIENT'S ACCOUNT IN VIOLATION OFSECTION 10-04-11(1)(M)N.D.C.C.Current Status: FinalResolution Date: 10/13/2004Resolution:Other Sanctions Ordered: 1. PIPER JAFFRAY SHALL NOT ENGAGE IN ANY VIOLATIONS OF THE NORTHDAKOTA SECURITIES ACT, OR ADMINISTRATIVE RULES PROMULGATEDUNDER THE SECURITIES ACT, OR ENGAGE IN ANY FRAUDULENT CONDUCTIN NORTH DAKOTA IN VIOLATION OF SECTION 10-04-15 N.D.C.C.2. PIPER JAFFRAY SHALL PROPERLY SUPERVISE THE ACTIVITIES OF ITSAGENTS WITH REGARD TO ALL SECURITIES RELATED ACTIVITY IN NORTHDAKOTA.Sanctions Ordered: Monetary/Fine $20,000.00Order922018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions Ordered: 1. PIPER JAFFRAY SHALL NOT ENGAGE IN ANY VIOLATIONS OF THE NORTHDAKOTA SECURITIES ACT, OR ADMINISTRATIVE RULES PROMULGATEDUNDER THE SECURITIES ACT, OR ENGAGE IN ANY FRAUDULENT CONDUCTIN NORTH DAKOTA IN VIOLATION OF SECTION 10-04-15 N.D.C.C.2. PIPER JAFFRAY SHALL PROPERLY SUPERVISE THE ACTIVITIES OF ITSAGENTS WITH REGARD TO ALL SECURITIES RELATED ACTIVITY IN NORTHDAKOTA.Sanction Details: THE CIVIL PENALTY OF $20,000 WAS PAID ON OCTOBER 11, 2004.Disclosure 34 of 134iReporting Source: RegulatorInitiated By: NORTH DAKOTAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 10/25/2004Docket/Case Number:URL for Regulatory Action:Principal Product Type: Debt - MunicipalOther Product Type(s):Allegations: RESPONDENT, THROUGH ITS AGENT, JASON MILLNER, CONDUCTED NINEUNAUTHORIZED TRADES IN A CLIENT ACCOUNT. 8 OF THE TRADES WEREIMPROPERLY MARKED "UNSOLICITED".Current Status: FinalResolution Date: 10/25/2004Resolution:Other Sanctions Ordered: RESPONDENT ORDERED TO NOT CONDUCT UNAUTHORIZED TRADES INCLIENT ACCOUNTS. RESPONDENT ORDERED TO NOT MAKR TRADECONFIRMATION STATEMENTS AS "UNSOLICITED" WHEN THETRANSACTIONS WERE NOT INITIATED BY THE CLIENT.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?YesSanctions Ordered: Monetary/Fine $17,000.00Consent932018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceRESPONDENT ORDERED TO NOT CONDUCT UNAUTHORIZED TRADES INCLIENT ACCOUNTS. RESPONDENT ORDERED TO NOT MAKR TRADECONFIRMATION STATEMENTS AS "UNSOLICITED" WHEN THETRANSACTIONS WERE NOT INITIATED BY THE CLIENT.Sanction Details: PENALTY IS JOINT AND SEVERAL WITH THE AGENT, JASON MILLNER.iReporting Source: FirmInitiated By: STATE OF NORTH DAKOTAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 06/29/2004Docket/Case Number: UNKNOWNPrincipal Product Type: Debt - MunicipalOther Product Type(s):Allegations: ALLEGES RESPONDENTS VIOLATED SECTIONS 73-02-09-02(4-5) N.D.A.C.AND SECTION 10-04-15 N.D.C.C. BY EXERCISING DISCRETION IN A CLIENTACCOUNT WHEN NOT AUTHORIZED TO DO SO. ALLEGES RESPONDENTSIMPROPERLY MARKED EIGHT OR NINE TRADE CONFIRMATIONSTATEMENTS AS "UNSOLICITED".Current Status: FinalResolution Date: 10/25/2004Resolution:Other Sanctions Ordered: 1. NOT CONDUCT SECURITIES TRANSACTIONS IN NORTH DAKOTA UNLESSTHE TRANSACTIONS ARE AUTHORIZED BY THE CLIENT OR THE CLIENTHAS PROVIDED WRITTEN AUTHORIZATION TO EXERCISE DISCRETION INTHAT CLIENT'S ACCOUNT. 2. NOT MARK ANY TRADE CONFIRMATIONS AS "UNSOLICITED" UNLESS THE CLIENT INITIATED THE TRANSACTION ANDNO AGENT OF PJ SOLICITED THE TRANSACTION.Sanction Details: THE CIVIL PENALTY OF $17,000 WAS PAID ON OCTOBER 4, 2004.Sanctions Ordered: Monetary/Fine $17,000.00OrderDisclosure 35 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED ACT 35-1-520(1)(B)(VII) & ACT 35-1-520(2)(B)(I) BY: A)ENGAGING IN ACTS & PRACTICESTHAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final942018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF SOUTH CAROLINAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 06/11/2004Docket/Case Number: 03089Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED ACT 35-1-520(1)(B)(VII) & ACT 35-1-520(2)(B)(I) BY: A)ENGAGING IN ACTS & PRACTICESTHAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 06/29/2004Resolution:Other Sanctions Ordered: $154,565 TO THE STATE OF SOUTH CAROLINASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $154,565 PAID TO THE STATE OF SOUTHCAROLINA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $154,565 WAS MADE ON JUNE 11,2004. THE $12,500,000 DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TOBE PAID TO THE UNITED STATES DISTRICT COURT WITHIN TEN (10) DAYSOF COURT APPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINALJUDGMENT IN THAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENTRESEARCH SHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30)DAYS OF ENTRY OF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder952018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $154,565 PAID TO THE STATE OF SOUTHCAROLINA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $154,565 WAS MADE ON JUNE 11,2004. THE $12,500,000 DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TOBE PAID TO THE UNITED STATES DISTRICT COURT WITHIN TEN (10) DAYSOF COURT APPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINALJUDGMENT IN THAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENTRESEARCH SHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30)DAYS OF ENTRY OF THE FINAL JUDGMENT.Disclosure 36 of 134iReporting Source: RegulatorInitiated By: NASDDate Initiated: 01/27/2005Docket/Case Number: CE3050002Principal Product Type: Mutual Fund(s)Allegations: NASD RULES 2110 AND 2830(K) - RESPONDENT FIRM MAINTAINED A "PREFERRED PARTNER" PROGRAM IN WHICH PARTICIPATING MUTUALFUND COMPLEXES PAID A FEE IN RETURN FOR PREFERENTIALTREATMENT BY RESPONDENT FIRM. THESE BENEFITS WERE NOTAVAIALBE TO NON-PARTICIPATING FUND COMPLEXES. THREE OF THEFUND COMPLEXES PAID THEIR FEES FOR PARTICIPATING IN THEPROGRAM, IN PART, BY DIRECTING BROKERAGE COMMISSIONS TORESPONDENT FIRM. RESPONDENT FIRM RECEIVED DIRECTEDBROKERAGE COMMISSIONS FROM MUTUAL FUNDS AS PAYMENT FORPARTICIPATION IN ITS PREFERRED PARTNER PROGRAM.Current Status: Final962018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/industry/disciplinary-actions/finra-disciplinary-actions-online?search=ce3050002www.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Principal Product Type: Mutual Fund(s)Other Product Type(s):Resolution Date: 01/27/2005Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $275,000.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $275,000.00Acceptance, Waiver & Consent(AWC)iReporting Source: FirmAllegations: ALLEGES PIPER JAFFRAY VIOLATED NASD CONDUCT RULE 2830(K)(1),(2) &(6)(B) BY FAVORING THE SALE OF CERTAIN MUTUAL FUNDS ON THE BASISOF BROKERAGE COMMISSIONS RECEIVED OR EXPECTED FROM THOSEFUNDS (TIME PERIOD 1/1/98-12/31/03); VIOLATED NASD CONDUCT RULE2830(6)(A) BY PROVIDING AN INCENTIVE FOR THE SALE OF SHARES OFSPECIFIED INVESTMENT COMPANIES BASED ON THE AMOUNT OFBROKERAGE COMMISSIONS RECEIVED OR EXPECTED FROM ANYSOURCE (TIME PERIOD 1998, 1999 & SECOND QUARTER OF 2003);VIOLATED NASD CONDUCT RULE 2110 BY VIRTUE OF VIOLATING SECTION17(A)(2) OF THE EXCHANGE ACT OF 1933 BY FAILING TO DISCLOSE THAT ITRECEIVED PAYMENTS FROM CERTAIN MUTUAL FUNDS IN EXCHANGE FORHEIGHTENED VISIBILITY WITHIN PIPER'S DISTRIBUTION NETWORK, AND BYFAILING TO DISCLOSE THAT IT RECEIVED DIRECTED BROKERAGE FROMCERTAIN MUTUAL FUNDS FOR SUCH HEIGHTENED VISIBILITY; VIOLATEDSECTION 10(B) OF THE EXCHANGE ACT OF 1934, RULE 10B-10PROMULGATED THEREUNDER, AND NASD CONDUCT RULE 2230 IS BASEDUPON PIPER'S FAILURE TO DISCLOSE TO CUSTOMERS IN TRANSACTIONCONFIRMATIONS THAT IT WAS RECEIVING PAYMENTS FROM CERTAINMUTUAL FUNDS IN EXCHANGE FOR HEIGHTENED VISIBILITY WITHINPIPER'S DISTRIBUTION NETWORK AND ITS FAILURE TO DISCLOSE THAT ITRECEIVED DIRECTED BROKERAGE FROM CERTAIN MUTUAL FUNDS FORSUCH HEIGHTENED VISIBILITY (TIME PERIOD 1/1/98-12/31/03); VIOLATEDNASD CONDUCT RULES 3010(A)&(B) BY FAILING TO ESTABLISH, MAINTAINAND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORYPROCEDURES THAT WERE REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH NASD CONDUCT RULE 283(K).Current Status: Final972018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 08/02/2004Docket/Case Number: AWAC NO. CE3050002Principal Product Type: Mutual Fund(s)Other Product Type(s):ALLEGES PIPER JAFFRAY VIOLATED NASD CONDUCT RULE 2830(K)(1),(2) &(6)(B) BY FAVORING THE SALE OF CERTAIN MUTUAL FUNDS ON THE BASISOF BROKERAGE COMMISSIONS RECEIVED OR EXPECTED FROM THOSEFUNDS (TIME PERIOD 1/1/98-12/31/03); VIOLATED NASD CONDUCT RULE2830(6)(A) BY PROVIDING AN INCENTIVE FOR THE SALE OF SHARES OFSPECIFIED INVESTMENT COMPANIES BASED ON THE AMOUNT OFBROKERAGE COMMISSIONS RECEIVED OR EXPECTED FROM ANYSOURCE (TIME PERIOD 1998, 1999 & SECOND QUARTER OF 2003);VIOLATED NASD CONDUCT RULE 2110 BY VIRTUE OF VIOLATING SECTION17(A)(2) OF THE EXCHANGE ACT OF 1933 BY FAILING TO DISCLOSE THAT ITRECEIVED PAYMENTS FROM CERTAIN MUTUAL FUNDS IN EXCHANGE FORHEIGHTENED VISIBILITY WITHIN PIPER'S DISTRIBUTION NETWORK, AND BYFAILING TO DISCLOSE THAT IT RECEIVED DIRECTED BROKERAGE FROMCERTAIN MUTUAL FUNDS FOR SUCH HEIGHTENED VISIBILITY; VIOLATEDSECTION 10(B) OF THE EXCHANGE ACT OF 1934, RULE 10B-10PROMULGATED THEREUNDER, AND NASD CONDUCT RULE 2230 IS BASEDUPON PIPER'S FAILURE TO DISCLOSE TO CUSTOMERS IN TRANSACTIONCONFIRMATIONS THAT IT WAS RECEIVING PAYMENTS FROM CERTAINMUTUAL FUNDS IN EXCHANGE FOR HEIGHTENED VISIBILITY WITHINPIPER'S DISTRIBUTION NETWORK AND ITS FAILURE TO DISCLOSE THAT ITRECEIVED DIRECTED BROKERAGE FROM CERTAIN MUTUAL FUNDS FORSUCH HEIGHTENED VISIBILITY (TIME PERIOD 1/1/98-12/31/03); VIOLATEDNASD CONDUCT RULES 3010(A)&(B) BY FAILING TO ESTABLISH, MAINTAINAND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORYPROCEDURES THAT WERE REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH NASD CONDUCT RULE 283(K).Resolution Date: 01/27/2005Resolution:Other Sanctions Ordered:Sanction Details: CHECK IN THE AMOUNT OF $275,000 WAS SENT ON 2/7/05.Sanctions Ordered: CensureMonetary/Fine $275,000.00Acceptance, Waiver & Consent(AWC)Disclosure 37 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED LOUISIANASECURITIES LAW BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATEDOR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENTBANKING DEPARTMENT OVER RESEARCH ANALYSTS THEREFOREIMPOSING CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS &FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTION WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final982018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF LOUISIANAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 05/20/2004Docket/Case Number: UNKNOWNPrincipal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED LOUISIANASECURITIES LAW BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATEDOR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENTBANKING DEPARTMENT OVER RESEARCH ANALYSTS THEREFOREIMPOSING CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS &FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTION WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 05/26/2004Resolution:Other Sanctions Ordered: $172,170 TO THE STATE OF LOUISIANASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $172,170 PAID TO THE STATE OFLOUISIANA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $172,170 TO THE STATE OFLOUISIANA WAS MADE ON MAY 20, 2004. THE $12,500,000 DISGORGEMENTAMOUNT DESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATESDISTRICT COURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder992018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $172,170 PAID TO THE STATE OFLOUISIANA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $172,170 TO THE STATE OFLOUISIANA WAS MADE ON MAY 20, 2004. THE $12,500,000 DISGORGEMENTAMOUNT DESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATESDISTRICT COURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Disclosure 38 of 134iReporting Source: RegulatorAllegations: **10/15/04**STIPULATION AND CONSENT TO PENALTY FILED BY NYSEDIVISION OF ENFORCEMENT AND PENDING.STIPULATEDFINDINGS:CONSENTED TO FINDINGS THAT IT VIOLATED:1)VIOLATEDEXCHANGE RULE 342(A) AND (B) BY FAILING TO EXERCISE REASONABLESUPERVISION AND CONTROL,INCLUDING A SEPARATE SYSTEM OFFOLLOW-UP AND REVIEW, WITH RESPECT TO: I)SUPERVISION OFPRODUCING BRANCH OFFICE MANAGERS WHEN ACTING IN THE CAPACITYOF REGISTERED REPRESENTATIVES; II)MONITORING RECORDS OFCUSTOMER ADDRESSES;III)TRADE CORRECTIONS;IV)MONITORING THEUSE OF PERSONAL COMPUTERS THAT WERE SEPARATE FROM THE FIRMSCOMPANY-WIDE COMPUTER SYSTEM;V)REVIEW OF COMMUNICATIONSWITH THE PUBLIC;VI)SUPERVISORY REVIEW OF DISCRETIONARY ACCOUNTS; AND,VII)SPECIAL SUPERVISION OF A REGISTERED REPRESENTATIVE.2)VIOLATED EXCHANGE RULE 410 BY FAILING TO:I)MAKE AND PRESERVECERTAIN REQUIRED RECORDS RELATING TO CUSTOMER ORDERSEXECUTED ON THE FLOOR OF THE EXCHANGE; AND,II)FAILING TO OBTAIN APPROPRIATE WRITTEN SUPERVISORY APPROVALFOR ACCOUNT DESIGNATION CHANGES PRIOR TO EFFECTING SUCHCHANGES.3) VIOLATED EXCHANGE RULE 472 BY ISSUINGCOMMUNICATIONS TO THE PUBLIC THAT WERE:I)NOT APPROVED INADVANCE BY AN APPROPRIATE SUPERVISOR; AND/OR;II)FAILED TO MAKETHE REQUIRED DISCLOSURES.4)VIOLATED EXCHANGE RULE 351(D) BY,ON NUMEROUS OCCASIONS, FAILING TO ACCURATELY AND PROMPTLYREPORT TO THE EXCHANGE INFORMATION REGARDING CUSTOMERCOMPLAINTS.5) VIOLATED EXCHANGE RULE 408(B) BY FAILING TOGIVE DISCRETIONARY ACCOUNTS FREQUENT APPROPRIATESUPERVISORY REVIEW.**CONTINUED AT #13C**Current Status: Final1002018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENTPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 10/15/2004Docket/Case Number: HPD#: 04-180Principal Product Type: OtherOther Product Type(s):**10/15/04**STIPULATION AND CONSENT TO PENALTY FILED BY NYSEDIVISION OF ENFORCEMENT AND PENDING.STIPULATEDFINDINGS:CONSENTED TO FINDINGS THAT IT VIOLATED:1)VIOLATEDEXCHANGE RULE 342(A) AND (B) BY FAILING TO EXERCISE REASONABLESUPERVISION AND CONTROL,INCLUDING A SEPARATE SYSTEM OFFOLLOW-UP AND REVIEW, WITH RESPECT TO: I)SUPERVISION OFPRODUCING BRANCH OFFICE MANAGERS WHEN ACTING IN THE CAPACITYOF REGISTERED REPRESENTATIVES; II)MONITORING RECORDS OFCUSTOMER ADDRESSES;III)TRADE CORRECTIONS;IV)MONITORING THEUSE OF PERSONAL COMPUTERS THAT WERE SEPARATE FROM THE FIRMSCOMPANY-WIDE COMPUTER SYSTEM;V)REVIEW OF COMMUNICATIONSWITH THE PUBLIC;VI)SUPERVISORY REVIEW OF DISCRETIONARY ACCOUNTS; AND,VII)SPECIAL SUPERVISION OF A REGISTERED REPRESENTATIVE.2)VIOLATED EXCHANGE RULE 410 BY FAILING TO:I)MAKE AND PRESERVECERTAIN REQUIRED RECORDS RELATING TO CUSTOMER ORDERSEXECUTED ON THE FLOOR OF THE EXCHANGE; AND,II)FAILING TO OBTAIN APPROPRIATE WRITTEN SUPERVISORY APPROVALFOR ACCOUNT DESIGNATION CHANGES PRIOR TO EFFECTING SUCHCHANGES.3) VIOLATED EXCHANGE RULE 472 BY ISSUINGCOMMUNICATIONS TO THE PUBLIC THAT WERE:I)NOT APPROVED INADVANCE BY AN APPROPRIATE SUPERVISOR; AND/OR;II)FAILED TO MAKETHE REQUIRED DISCLOSURES.4)VIOLATED EXCHANGE RULE 351(D) BY,ON NUMEROUS OCCASIONS, FAILING TO ACCURATELY AND PROMPTLYREPORT TO THE EXCHANGE INFORMATION REGARDING CUSTOMERCOMPLAINTS.5) VIOLATED EXCHANGE RULE 408(B) BY FAILING TOGIVE DISCRETIONARY ACCOUNTS FREQUENT APPROPRIATESUPERVISORY REVIEW.**CONTINUED AT #13C**Resolution Date: 12/23/2004Resolution:Other Sanctions Ordered:Sanction Details: **11/24/04**DECISON 04-180 ISSUED BY NYSE HEARING PANELDECISION:VIOLATED EXCHANGE RULE 342BY FAILING TO REASONABLYSUPERVISE WITH RESPECT TO CERTAIN BUSINESS ACTIVITIES; VIOLATEDEXCHANGE RULE 410 BY FAILING TO MAKE AND PRESERVE CERTAINREQUIRED RECORDS RELATING TO CUSTOMER ORDERS EXECUTED ONTHE EXCHANGE FLOOR AND FAILING TO OBTAIN APPROPRIATE WRITTENSUPERVISORY APPROVAL FOR ACCOUNT DESIGNATION CHANGES;VIOLATED EXCHANGE RULE 472 BY ISSUING UNAPPROVEDCOMMUNICATIONS TO THE PUBLIC AND FAILING TO MAKE REQUIREDDISCLOSURES; VIOLATED EXCHANGE RULE 351(D) BY FAILING TOACCURATELY AND PROMPTLY REPORT INFORMATION REGARDINGCUSTOMER COMPLAINTS; VIOLATED EXCHANGE RULE 408(B) BY FAILINGTO GIVE DISCRETIONARY ACCOUNTS FREQUENT APPROPRIATESUPERVISORY REVIEW; VIOLATED SEA REGULATIONS 240.17A-3 AND240.17A-4 AND EXCHANGE RULE 440 BY FAILING TO MAKE AND MAINTAINREQUIRED AND TIMELY RECORDS RELATING TO THE DESIGNATION ANDEXECUTION OF CUSTOMER ORDERS, AND CANCEL AND REBILL FORMSUSED TO ACCOMPLISH POST-EXECUTION ACCOUNT DESIGNATIONCHANGES.CONSENT TO CENSURE, $250,000 FINE, AND AN UNDERTAKING.Sanctions Ordered: CensureMonetary/Fine $250,000.00Decision1012018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User Guidance**11/24/04**DECISON 04-180 ISSUED BY NYSE HEARING PANELDECISION:VIOLATED EXCHANGE RULE 342BY FAILING TO REASONABLYSUPERVISE WITH RESPECT TO CERTAIN BUSINESS ACTIVITIES; VIOLATEDEXCHANGE RULE 410 BY FAILING TO MAKE AND PRESERVE CERTAINREQUIRED RECORDS RELATING TO CUSTOMER ORDERS EXECUTED ONTHE EXCHANGE FLOOR AND FAILING TO OBTAIN APPROPRIATE WRITTENSUPERVISORY APPROVAL FOR ACCOUNT DESIGNATION CHANGES;VIOLATED EXCHANGE RULE 472 BY ISSUING UNAPPROVEDCOMMUNICATIONS TO THE PUBLIC AND FAILING TO MAKE REQUIREDDISCLOSURES; VIOLATED EXCHANGE RULE 351(D) BY FAILING TOACCURATELY AND PROMPTLY REPORT INFORMATION REGARDINGCUSTOMER COMPLAINTS; VIOLATED EXCHANGE RULE 408(B) BY FAILINGTO GIVE DISCRETIONARY ACCOUNTS FREQUENT APPROPRIATESUPERVISORY REVIEW; VIOLATED SEA REGULATIONS 240.17A-3 AND240.17A-4 AND EXCHANGE RULE 440 BY FAILING TO MAKE AND MAINTAINREQUIRED AND TIMELY RECORDS RELATING TO THE DESIGNATION ANDEXECUTION OF CUSTOMER ORDERS, AND CANCEL AND REBILL FORMSUSED TO ACCOMPLISH POST-EXECUTION ACCOUNT DESIGNATIONCHANGES.CONSENT TO CENSURE, $250,000 FINE, AND AN UNDERTAKING.Regulator Statement **THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY.CONTACT:MICHELE VAN TASSEL 212-656-5340iReporting Source: FirmInitiated By: NEW YORK STOCK EXCHANGE, INC.Date Initiated: 04/29/2004Docket/Case Number: DECISION 04-180Principal Product Type: No ProductAllegations: THE EXCHANGE ALLEGES THAT DURING 2001, 2002 AND 2003 PIPERJAFFRAY (1) VIOLATED EXCHANGE RULE 342(A) AND (B) BY FAILING TOEXERCISE REASONABLE SUPERVISION AND CONTROL, INCLUDING ASEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, WITH RESPECT TOSUPERVISION OF PRODUCING BRANCH OFFICE MANAGERS WHEN ACTINGIN THE CAPACITY OF REGISTERED REPRESENTATIVES; MONITORINGRECORDS OF CUSTOMER ADDRESSES; TRADE CORRECTIONS;MONITORING THE USE OF PERSONAL COMPUTERS THAT WERE SEPARATEFROM THE FIRM'S COMPANY-WIDE COMPUTER SYSTEM; REVIEW OFCOMMUNICATIONS WITH THE PUBLIC; SUPERVISORY REVIEW OFDISCRETIONARY ACCOUNTS; AND SPECIAL SUPERVISION OF AREGISTERED REPRESENTATIVE; (2)VIOLATED EXCHANGE RULE 410 BYFAILING TO MAKE AND PRESERVE REQUIRED RECORDS RELATING TOCUSTOMER ORDERS EXECUTED ON THE FLOOR OF THE EXCHANGE; ANDFAILING TO OBTAIN APPROPRIATE WRITTEN SUPERVISORY APPROVALFOR ACCOUNT DESIGNATION CHANGES PRIOR TO EFFECTING SUCHCHANGES; (3)VIOLATED EXCHANGE RULE 472 BY ISSUINGCOMMUNICATIONS THAT WERE NOT APPROVED BY AN APPROPRIATESUPERVISOR; AND ISSUING COMMUNICATIONS THAT FAILED TO MAKE THEREQUIRED DISCLOSURES; (4)VIOLATED EXCHANGE RULE 351(D) BYFAILING TO ACCURATELY AND PROMPTLY REPORT TO THE EXCHANGEINFORMATION REGARDING CUSTOMER COMPLAINTS; (5)VIOLATEDEXCHANGE RULE 408(B)BY FAILING TO GIVE DISCRETIONARY ACCOUNTSFREQUENT APPROPRIATE SUPERVISORY REVIEW; (6)VIOLATEDREGULATIONS 240.17A-3 AND 240.17A-4, PROMULGATED PURSUANT TOSECTION 17 OF THE SECURITIES EXCHANGE ACT AND EXCHANGE RULE440 BY FAILING TO MAKE AND MAINTAIN REQUIRED AND TIMELY RECORDSRELATING TO THE DESIGNATION AND EXECUTION OF CUSTOMERORDERS; AND CANCEL AND REBILL FORMS USED TO ACCOMPLISH POST-EXECUTION ACCOUNT DESIGNATION CHANGES.Current Status: Final1022018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CENSURE; UNDERTAKINGPrincipal Product Type: No ProductOther Product Type(s):Resolution Date: 11/23/2004Resolution:Other Sanctions Ordered: UNDERTAKINGSanction Details: WITHIN 30 DAYS FROM THE DATE THE DECISION BECOMES FINAL, THEFIRM SHALL RETAIN AN OUTSIDE CONSULTANT TO CONDUCT A REVIEW OFTHE FIRM'S POLICIES, PROCEDURES AND SUPERVISORY SYSTEMSRELATING TO THE VIOLATIONS DESCRIBED ABOVE AND PREPARE AREPORT OF ITS REVIEW INCLUDING RECOMMENDATIONS FORADDITIONAL PROCEDURES AND SYSTEMS REASONABLY DESIGNED TOENSURE COMPLIANCE WITH EXCHANGE RULES AND FEDERALSECURITIES LAWS TO PREVENT A RECURRENCE. WITHIN 120 DAYS, THEREVIEW SHALL BE COMPLETED AND THE REPORT WILL BE DELIVERED TOTHE EXCHANGE. WITHIN 120 DAYS OF DELIVERY OF THE REPORT TO THEEXCHANGE, THE FIRM MUST SUBMIT TO THE EXCHANGE A LETTERSIGNED BY THE FIRM'S CEO DESCRIBING THE FIRM'S IMPLEMENTATIONOF ANY RECOMMENDATIONS CONTAINED IN THE REPORT OR OF ANYALTERNATIVE ACTIONS. THE $250,000 FINE WAS PAID ON 1/5/05.Sanctions Ordered: CensureMonetary/Fine $250,000.00Stipulation and ConsentDisclosure 39 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED RSA 421-BBY: A)ENGAGING IN ACTS & PRACTICES THAT CREATED OR MAINTAINEDINAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENTOVER RESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OFINTEREST ON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESECONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER; B)THREATENINGTO DROP RESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS ALEAD MANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REAONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1032018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF NEW HAMPSHIREPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 04/05/2004Docket/Case Number: UNKNOWNPrincipal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED RSA 421-BBY: A)ENGAGING IN ACTS & PRACTICES THAT CREATED OR MAINTAINEDINAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENTOVER RESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OFINTEREST ON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESECONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER; B)THREATENINGTO DROP RESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS ALEAD MANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REAONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 04/08/2004Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF NEW HAMPSHIRESanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OF NEWHAMPSHIRE PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE STATE OF NEWHAMPSHIRE WAS MADE ON APRIL 5, 2004. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1042018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OF NEWHAMPSHIRE PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE STATE OF NEWHAMPSHIRE WAS MADE ON APRIL 5, 2004. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Disclosure 40 of 134iReporting Source: RegulatorInitiated By: UTAH DIVISION OF SECURITIESPrincipal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:MONETARY PENALTYDate Initiated: 11/13/2003Docket/Case Number: SD-03-0029URL for Regulatory Action:Principal Product Type: OtherOther Product Type(s):Allegations: RESEARCH ANALYST CONFLICTS OF INTERESTCurrent Status: FinalResolution Date: 11/13/2003Resolution:Other Sanctions Ordered:Sanction Details: CEASE & DESIST AND ORDERED TO PAY $125,000 TO THE DIVISION'SSECURITIES INVESTOR EDUCATION AND TRAINING FUNDSanctions Ordered: Monetary/Fine $125,000.00Cease and Desist/InjunctionConsent1052018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceRegulator Statement FOR MORE INFORMATION, PLEASE VISIT THE DIVISION'S WEB SITE AT:HTTP://WWW.SECURITIES.STATE.UT.US/ACTIONSEVENTS.ASP?DOCKET+NUMBER=SD%2D03%2D0029iReporting Source: FirmInitiated By: STATE OF UTAHPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 11/05/2003Docket/Case Number: SD-03-0029Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED UTAHUNIFORM SECURITIES ACT BY: A)ENGAGING IN ACTS & PRACTICES THATCREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: FinalResolution Date: 02/02/2004Resolution: Order1062018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceResolution Date: 02/02/2004Other Sanctions Ordered: $125,000 TO THE STATE OF UTAHSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OF UTAHPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $125,000 TO THE STATE OF UTAH WAS MADE ON NOVEMBER5, 2003. THE $12,500,000 DISGORGEMENT AMOUNT DESCRIBED ABOVE ISTO BE PAID TO THE UNITED STATES DISTRICT COURT WITHIN TEN (10)DAYS OF COURT APPROVAL OF THE SEC SETTLEMENT AND ENTRY OFFINAL JUDGMENT IN THAT MATTER. THE $7,500,000 TO PROCUREINDEPENDENT RESEARCH SHALL BE DEPOSITED INTO ESCROW WITHINTHIRTY (30) DAYS OF ENTRY OF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionDisclosure 41 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SECTIONS30-10-201(13)(G), (K) OF THE SECURITIES ACT OF MONTANA BY:A)ENGAGING IN ACTS & PRACTICES THAT CREATED OR MAINTAINEDINAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENTOVER RESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OFINTEREST ON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESECONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER; B)THREATENINGTO DROP RESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS ALEAD MANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILIING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1072018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF MONTANAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 01/06/2004Docket/Case Number: I 05-01-03-116Principal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SECTIONS30-10-201(13)(G), (K) OF THE SECURITIES ACT OF MONTANA BY:A)ENGAGING IN ACTS & PRACTICES THAT CREATED OR MAINTAINEDINAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENTOVER RESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OFINTEREST ON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESECONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER; B)THREATENINGTO DROP RESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS ALEAD MANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILIING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 02/06/2004Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF MONTANASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 TO THE STATE OF MONTANAPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $125,000 TO THE STATE OF MONTANA WAS MADE ONJANUARY 6, 2004. THE $12,500,000 DISGORGEMENT AMOUNT DESCRIBEDABOVE IS TO BE PAID TO THE UNITED STATES DISTRICT COURT WITHINTEN (10) DAYS OF COURT APPROVAL OF THE SEC SETTLEMENT ANDENTRY OF FINAL JUDGMENT IN THAT MATTER. THE $7,500,000 TOPROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITED INTOESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1082018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 TO THE STATE OF MONTANAPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $125,000 TO THE STATE OF MONTANA WAS MADE ONJANUARY 6, 2004. THE $12,500,000 DISGORGEMENT AMOUNT DESCRIBEDABOVE IS TO BE PAID TO THE UNITED STATES DISTRICT COURT WITHINTEN (10) DAYS OF COURT APPROVAL OF THE SEC SETTLEMENT ANDENTRY OF FINAL JUDGMENT IN THAT MATTER. THE $7,500,000 TOPROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITED INTOESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINAL JUDGMENT.Disclosure 42 of 134iReporting Source: FirmInitiated By: STATE OF NEW MEXICOAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SECTIONS58-13B-16.A(2)(H), (K) OF THE ACT AND THE RULES BY: A)ENGAGING INACTS & PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATEINFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVERRESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OF INTERESTON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESE CONFLICTS INAN ADEQUATE OR APPROPRIATE MANNER; B)THREATENING TO DROPRESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS A LEADMANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1092018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF NEW MEXICOPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 01/06/2004Docket/Case Number: 04-03-026-002Principal Product Type: OtherOther Product Type(s): RESEARCHResolution Date: 01/07/2004Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF NEW MEXICOSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OF NEWMEXICO PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO ANDREDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBEDABOVE. THE PAYMENT OF $125,000 TO THE STATE OF NEW MEXICO WASMADE ON JANUARY 6, 2004. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1102018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OF NEWMEXICO PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO ANDREDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBEDABOVE. THE PAYMENT OF $125,000 TO THE STATE OF NEW MEXICO WASMADE ON JANUARY 6, 2004. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Disclosure 43 of 134iReporting Source: RegulatorInitiated By: IOWAPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:N/ADate Initiated: 04/15/2002Docket/Case Number: C03-11-176 (161 SEE BELOW)URL for Regulatory Action:Principal Product Type: Equity Listed (Common & Preferred Stock)Other Product Type(s): N/AAllegations: ENGAGED IN ACTS AND PRACTICES THA CREATED AND /OR MAINTAINEDINAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCHANALYSTS. RESPONDENT FAILED TO MANAGE THESE CONFLICTS IN ANADEQUATE AND APPROPRIATE MANNER. RESPONDENT FAILED TOESTABLISH AND ENFORCE WRITTEN SUPERVISORY PROCEDURES TOPREVENT UNDUE INFLUENCE.Current Status: FinalAppealed To and Date AppealFiled:N/AResolution Date: 02/16/2004Resolution:Other Sanctions Ordered: RESPONDENT CONSENTED TO THE FINE AND CEASE AND DESIST ORDERWITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS OF FACT ORCONCLUSIONS OF LAW.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: Monetary/Fine $125,000.00Cease and Desist/InjunctionConsent1112018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceSanction Details: ONE OF SEVERAL SETTLEMENTS WITH ANDALYST TASK FORCE. SEVERALUNDERTAKINGS AS WELL.Regulator Statement CORRECT IOWA FILE NUMBER IS C03-11-176. ORDER TO US BANCORPPIPER ISSUED IN THIS MATTER ERRONEOUSLY REFERRED TO C03-10-161.THAT IS THE NUMBER US BANCORP PIPER USED TO REFER TO THISINCIDENT.iReporting Source: FirmInitiated By: STATE OF IOWAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 04/15/2002Docket/Case Number: C03-10-161Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED IOWACODE SECTIONS 502.304(1)(G) AND (J)(2003) BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1122018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanction(s)/ReliefSought:CEASE AND DESISTResolution Date: 02/16/2004Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF IOWASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OF IOWAPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $125,000 TO THE STATE OF IOWA WAS MADE ON FEBRUARY12, 2004. THE $12,500,000 DISGORGEMENT AMOUNT DESCRIBED ABOVE ISTO BE PAID TO THE UNITED STATES DISTRICT COURT WITHIN TEN (10)DAYS OF COURT APPROVAL OF THE SEC SETTLEMENT AND ENTRY OFFINAL JUDGMENT IN THAT MATTER. THE $7,500,000 TO PROCUREINDEPENDENT RESEARCH SHALL BE DEPOSITED INTO ESCROW WITHINTHIRTY (30) DAYS OF ENTRY OF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrderDisclosure 44 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED N.C.G.S.78A-39(A)(2)(G) BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATED ORMAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKINGDEPARTMENT OVER RESEARCH ANALYSTS THEREFORE IMPOSINGCONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS & FAILING TOMANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER;B)THREATENING TO DROP RESEARCH COVERAGE IF THE FIRM WAS NOTSELECTED AS A LEAD MANAGER IN AN INVESTMENT BANKINGTRANSACTION; C)ISSUING RESEARCH REPORTS ON ESPERIONTHERAPEUTICS INC. & TRITON NETWORK SYSTEMS THAT DID NOTPROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDING THOSECOMPANIES & THEIR BUSINESS PROSPECTS; CONTAINED EXAGGERATEDOR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; D)MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1132018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF NORTH CAROLINAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 01/06/2004Docket/Case Number: 03-012-IGPrincipal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED N.C.G.S.78A-39(A)(2)(G) BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATED ORMAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKINGDEPARTMENT OVER RESEARCH ANALYSTS THEREFORE IMPOSINGCONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS & FAILING TOMANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER;B)THREATENING TO DROP RESEARCH COVERAGE IF THE FIRM WAS NOTSELECTED AS A LEAD MANAGER IN AN INVESTMENT BANKINGTRANSACTION; C)ISSUING RESEARCH REPORTS ON ESPERIONTHERAPEUTICS INC. & TRITON NETWORK SYSTEMS THAT DID NOTPROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDING THOSECOMPANIES & THEIR BUSINESS PROSPECTS; CONTAINED EXAGGERATEDOR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; D)MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 01/22/2004Resolution:Other Sanctions Ordered: $310,104 TO THE STATE OF NORTH CAROLINASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $310,104 PAID TO THE STATE OF NORTHCAROLINA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $310,104 TO THE STATE OF NORTHCAROLINA WAS MADE ON JANUARY 6, 2004. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1142018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $310,104 PAID TO THE STATE OF NORTHCAROLINA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $310,104 TO THE STATE OF NORTHCAROLINA WAS MADE ON JANUARY 6, 2004. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Disclosure 45 of 134iReporting Source: RegulatorInitiated By: PA SECURITIES COMMISSIONCONTACT: G. PHILIP RUTLEDGE (717) 787-8059Principal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:RESPONDENT U.S. BANCORP PIPER JAFFRAY, INC. PAID A $473,135.00ADMINISTRATIVE ASSESSMENT.Date Initiated: 01/07/2004Docket/Case Number: 2003-04-42URL for Regulatory Action:Principal Product Type: OtherOther Product Type(s): SECURITIESAllegations: THIS ACTION IS IN CONNECTION WITH THE GLOBAL ANALYST SETTLEMENTWHICH INCORPORATED THE FINAL JUDGMENT OF THE U.S. DISTRICTCOURT FOR THE SOUTHERN DISTRICT OF NEW YORK, CIVIL ACTION NO.03 CIV. 2942 (WHP) ENTERED OCTOBER 31, 2003.Current Status: Final1152018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceResolution Date: 01/07/2004Resolution:Other Sanctions Ordered:Sanction Details: RESPONDENT U.S. BANCORP PIPER JAFFRAY, INC. PAID A $473,135.00ADMINISTRATIVE ASSESSMENT.Sanctions Ordered: Monetary/Fine $473,135.00SettlediReporting Source: FirmInitiated By: COMMONWEALTH OF PENNSYLVANIAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Date Initiated: 01/06/2004Docket/Case Number: 2003-04-42Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED THE 1972ACT BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATED ORMAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKINGDEPARTMENT OVER RESEARCH ANALYSTS THEREFORE IMPOSINGCONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS & FAILING TOMANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER;B)THREATENING TO DROP RESEARCH COVERAGE IF THE FIRM WAS NOTSELECTED AS A LEAD MANAGER IN AN INVESTMENT BANKINGTRANSACTION; C)ISSUING RESEARCH REPORTS ON ESPERIONTHERAPEUTICS INC. & TRITON NETWORK SYSTEMS THAT DID NOTPROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDING THOSECOMPANIES & THEIR BUSINESS PROSPECTS; CONTAINED EXAGGERATEDOR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; D)MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1162018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTResolution Date: 01/07/2004Resolution:Other Sanctions Ordered: $473,135 TO THE COMMONWEALTH OF PENNSYLVANIASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $473,135 PAID TO THE COMMONWEALTHOF PENNSYLVANIA PURSUANT TO THE CONSENT ORDER, SHALL BEAPPLIED TO AND REDUCE THE AMOUNT OF THE $12,500,000 CIVILPENALTY DESCRIBED ABOVE. THE PAYMENT OF $473,135 TO THECOMMONWEALTH OF PENNSYLVANIA WAS MADE ON JANUARY 6, 2004. THE$12,500,000 DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAIDTO THE UNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OFCOURT APPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINALJUDGMENT IN THAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENTRESEARCH SHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30)DAYS OF ENTRY OF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrderDisclosure 46 of 134iReporting Source: RegulatorAllegations: NASD RULE 2110 - PIPER JAFFRAY & CO. ENGAGED IN SPINNING BYALLOCATING AND SELLING NUMEROUS PROFITABLE HOT INITIAL PUBLICOFFERING (IPO) SHARES TO CERTAIN CORPORATE EXECUTIVES FROMWHICH PIPER JAFFRAY HAD OBTAINED OR SOUGHT INVESTMENTBANKING BUSINESS.Current Status: Final1172018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NASDPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 07/12/2004Docket/Case Number: CAF040049Principal Product Type: OtherOther Product Type(s): INITIAL PUBLIC OFFERINGSAllegations: NASD RULE 2110 - PIPER JAFFRAY & CO. ENGAGED IN SPINNING BYALLOCATING AND SELLING NUMEROUS PROFITABLE HOT INITIAL PUBLICOFFERING (IPO) SHARES TO CERTAIN CORPORATE EXECUTIVES FROMWHICH PIPER JAFFRAY HAD OBTAINED OR SOUGHT INVESTMENTBANKING BUSINESS.Resolution Date: 07/12/2004Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, PIPER JAFFRAY &CO. CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $2.4 MILLION.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: CensureMonetary/Fine $2,400,000.00Acceptance, Waiver & Consent(AWC)iReporting Source: FirmAllegations: WE WERE ADVISED OF NASDR'S INTENTION TO COMMENCE ANADMINISTRATIVE PROCEEDING AGAINST THE FIRM ALLEGING VIOLATIONSOF NASD RULE 2110 - JUST AND EQUITABLE PRINCIPLES; VIOLATION OFNASD RULE 3010 - SUPERVISION; VIOLATION OF NASD RULE 3060 - GIFTSAND VIOLATION OF NASD RULE 3110 AND SEC RULE 17A-3 - BOOKS ANDRECORDS BASED UPON ITS PRACTICES CONCERNING ALLOCATION OFIPO SHARES TO OFFICERS AND DIRECTORS OF EXISTING OR POTENTIALINVESTMENT BANKING CLIENTS.Current Status: Final1182018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 09/10/2003Docket/Case Number: AWAC CAF040049Principal Product Type: Equity - OTCOther Product Type(s):WE WERE ADVISED OF NASDR'S INTENTION TO COMMENCE ANADMINISTRATIVE PROCEEDING AGAINST THE FIRM ALLEGING VIOLATIONSOF NASD RULE 2110 - JUST AND EQUITABLE PRINCIPLES; VIOLATION OFNASD RULE 3010 - SUPERVISION; VIOLATION OF NASD RULE 3060 - GIFTSAND VIOLATION OF NASD RULE 3110 AND SEC RULE 17A-3 - BOOKS ANDRECORDS BASED UPON ITS PRACTICES CONCERNING ALLOCATION OFIPO SHARES TO OFFICERS AND DIRECTORS OF EXISTING OR POTENTIALINVESTMENT BANKING CLIENTS.Resolution Date: 07/12/2004Resolution:Other Sanctions Ordered:Sanction Details: THE FINE OF 2.4 MILLION WAS SENT ON 7/16/04Firm Statement THE FIRM FILED ITS WELLS SUBMISSION WITH NASDR ON OCTOBER 17,2003, CONTESTING NASD STAFF'S PRELIMINARY DETERMINATION TORECOMMEND INITIATION OF AN ENFORCEMENT PROCEEDING. NASDRHAS NOT COMMENCED AN ADMINISTRATIVE PROCEEDING OR ADVISEDTHE FIRM THAT IT INTENDS TO COMMENCE SUCH PROCEEDINGS.Sanctions Ordered: CensureMonetary/Fine $2,400,000.00Acceptance, Waiver & Consent(AWC)Disclosure 47 of 134iReporting Source: RegulatorInitiated By: VIRGINIA - DIVISION OF SECURITIESDate Initiated: 12/10/2003Docket/Case Number: SEC-2003-00022URL for Regulatory Action:Allegations: COMMISSION RULES 21 VAC 5-20-260 B AND 21 VAC 5-20-280 E 12 WEREVIOLATED. CONTACT THE UNDERSIGNED FOR FURTHER INFORMATIONABOUT THE CONCLUSIONS OF LAW.Current Status: Final1192018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:URL for Regulatory Action:Principal Product Type: No ProductOther Product Type(s): CONTACT UNDERSIGNED FOR FURTHER INFORMATIONResolution Date: 12/10/2003Resolution:Other Sanctions Ordered: CONTACT THE UNDERSIGNED FOR FURTHER INFORMATION.Sanction Details: CONTACT THE UNDERSIGNED FOR FURTHER INFORMATION.Regulator Statement $272,704.00 WAS RECEIVED AS PART OF THE SETTLEMENT AGREEMENTU.S. BANCORP PIPER JAFFRAY, INC. ENTERED INTO WITH ALL FIFTYSTATES, THE DISTRICT OF COLUMBIA AND THE COMMONWEALTH OFPUERTO RICO, THROUGH A COMMITTEE OF THE NORTH AMERICANSECURITIES ADMINISTRATORS ASSOCIATION ("NASAA"). JURISDICTIONREPORTING INCIDENT: VIRGINIA, STATE CORPORATION COMMISSION,DIVISION OF SECURITIES & RETAIL FRANCHISING. CONTACT KEVIN M.FURR AT 804-371-9081.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: Monetary/Fine $272,704.00SettlediReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED 21 VAC 5-20-280(E)(12) AND 21 VAC 5-20-260 BY: A)ENGAGING IN ACTS & PRACTICESTHAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSING RESEARCH REPORTS ONESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THAT DIDNOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1202018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: COMMONWEALTH OF VIRGINIAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 11/05/2003Docket/Case Number: SEC-2003-00022Principal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED 21 VAC 5-20-280(E)(12) AND 21 VAC 5-20-260 BY: A)ENGAGING IN ACTS & PRACTICESTHAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSING RESEARCH REPORTS ONESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THAT DIDNOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 12/10/2003Resolution:Other Sanctions Ordered: $272,704 TO THE COMMONWEALTH OF VIRGINIASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $272,704 PAID TO THE COMMONWEALTHOF VIRGINIA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $272,704 TO THE COMMONWEALTHOF VIRGINIA WAS MADE ON DECMEBER 5, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1212018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $272,704 PAID TO THE COMMONWEALTHOF VIRGINIA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $272,704 TO THE COMMONWEALTHOF VIRGINIA WAS MADE ON DECMEBER 5, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Disclosure 48 of 134iReporting Source: FirmInitiated By: STATE OF WEST VIRGINIAAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED WESTVIRGINIA CODE 2-204(A)(2)(G) AND (J) BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1222018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF WEST VIRGINIAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 12/19/2003Docket/Case Number: E03-1350Principal Product Type: OtherOther Product Type(s): RESEARCHResolution Date: 12/29/2003Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF WEST VIRGINIASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING $125,000 PAID TO THE STATE OF WESTVIRGINIA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE STATE OF WESTVIRGINIA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE STATE OF WESTVIRGINIA WAS MADE ON DECEMBER 23, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1232018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING $125,000 PAID TO THE STATE OF WESTVIRGINIA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE STATE OF WESTVIRGINIA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE STATE OF WESTVIRGINIA WAS MADE ON DECEMBER 23, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Disclosure 49 of 134iReporting Source: FirmInitiated By: GOVERNMENT OF THE DISTRICT OF COLUMBIAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 12/05/2003Docket/Case Number: CO 03-06Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED D.C.OFFICIAL CODE 31-5602.07(A)(9),(12) BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES &/OR CONTAINED EXAGGERATED OR UNWARRANTEDCLAIMS ABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FORWHICH THERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1242018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceResolution Date: 12/11/2003Resolution:Other Sanctions Ordered: $125,000 TO THE DISTRICT OF COLUMBIASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE DISTRICT OFCOLUMBIA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE DISTRICT OFCOLUMBIA WAS MADE ON DECEMBER 5, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrderDisclosure 50 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SEE, 11-51-410(1)(G) AND (I), C.R.S. AND RULE 51-4.7 AND 11-51-501(1) BY: A)ENGAGINGIN ACTS & PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATEINFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVERRESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OF INTERESTON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESE CONFLICTS INAN ADEQUATE OR APPROPRIATE MANNER; B)THREATENING TO DROPRESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS A LEADMANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1252018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF COLORADOPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 12/12/2003Docket/Case Number: 04-L-26Principal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SEE, 11-51-410(1)(G) AND (I), C.R.S. AND RULE 51-4.7 AND 11-51-501(1) BY: A)ENGAGINGIN ACTS & PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATEINFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVERRESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OF INTERESTON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESE CONFLICTS INAN ADEQUATE OR APPROPRIATE MANNER; B)THREATENING TO DROPRESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS A LEADMANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 12/16/2003Resolution:Other Sanctions Ordered: $165,708 TO THE STATE OF COLORADOSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $165,708 PAID TO THE STATE OFCOLORADO PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $165,708 TO THE STATE OFCOLORADO WAS MADE ON DECEMBER 12, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1262018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $165,708 PAID TO THE STATE OFCOLORADO PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $165,708 TO THE STATE OFCOLORADO WAS MADE ON DECEMBER 12, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Disclosure 51 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATEDCORPORATE SECURITIES LAW OF 1968 BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1272018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF CALIFORNIAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 12/05/2003Docket/Case Number: UNKNOWNPrincipal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATEDCORPORATE SECURITIES LAW OF 1968 BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 12/15/2003Resolution:Other Sanctions Ordered: $1,304,926 TO THE STATE OF CALIFORNIASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $1,304,926 PAID TO THE STATE OFCALIFORNIA PURSUANT TO THE ADMINISTRATIVE ORDER, SHALL BEAPPLIED TO AND REDUCE THE AMOUNT OF THE $12,500,000 CIVILPENALTY DESCRIBED ABOVE. THE PAYMENT OF $1,304,926 TO THE STATEOF CALIFORNIA WAS MADE ON DECEMBER 5, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS T BE PAID TO THE UNITEDSTATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURT APPROVAL OFTHE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER.THE $7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BEDEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THEFINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1282018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $1,304,926 PAID TO THE STATE OFCALIFORNIA PURSUANT TO THE ADMINISTRATIVE ORDER, SHALL BEAPPLIED TO AND REDUCE THE AMOUNT OF THE $12,500,000 CIVILPENALTY DESCRIBED ABOVE. THE PAYMENT OF $1,304,926 TO THE STATEOF CALIFORNIA WAS MADE ON DECEMBER 5, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS T BE PAID TO THE UNITEDSTATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURT APPROVAL OFTHE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER.THE $7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BEDEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THEFINAL JUDGMENT.Disclosure 52 of 134iReporting Source: FirmInitiated By: STATE OF INDIANAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 12/05/2003Docket/Case Number: CAUSE NO. 03-0067 COPrincipal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED IND. CODE23-2-1-11(A)(6); 710 IND. ADMIN. CODE 1-17-1(V); 710 IND. ADMIN. CODE 1-17-1(W) AND IND. CODE 23-2-1-11(A)(14) BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THSE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1292018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanction(s)/ReliefSought:CEASE AND DESISTResolution Date: 12/09/2003Resolution:Other Sanctions Ordered: $234,354 TO THE STATE OF INDIANASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $234,354 PAID TO THE STATE OFINDIANA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO ANDREDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBEDABOVE. THE PAYMENT OF $234,354 TO THE STATE OF INDIANA WAS MADEON DECEMBER 5, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrderDisclosure 53 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED CHAPTER47-31A BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATED ORMAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKINGDEPARTMENT OVER RESEARCH ANALYSTS THEREFORE IMPOSINGCONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS & FAILING TOMANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER;B)THREATENING TO DROP RESEARCH COVERAGE IF THE FIRM WAS NOTSELECTED AS A LEAD MANAGER IN AN INVESTMENT BANKINGTRANSACTION; C)ISSUING RESEARCH REPORTS ON ESPERIONTHERAPEUTICS INC. & TRITON NETWORK SYSTEMS THAT DID NOTPROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDING THOSECOMPANIES & THEIR BUSINESS PROSPECTS; CONTAINED EXAGGERATEDOR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; D)MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1302018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF SOUTH DAKOTAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 12/05/2003Docket/Case Number: CASE NO. 652Principal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED CHAPTER47-31A BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATED ORMAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKINGDEPARTMENT OVER RESEARCH ANALYSTS THEREFORE IMPOSINGCONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS & FAILING TOMANAGE THESE CONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER;B)THREATENING TO DROP RESEARCH COVERAGE IF THE FIRM WAS NOTSELECTED AS A LEAD MANAGER IN AN INVESTMENT BANKINGTRANSACTION; C)ISSUING RESEARCH REPORTS ON ESPERIONTHERAPEUTICS INC. & TRITON NETWORK SYSTEMS THAT DID NOTPROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDING THOSECOMPANIES & THEIR BUSINESS PROSPECTS; CONTAINED EXAGGERATEDOR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; D)MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 12/08/2003Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF SOUTH DAKOTASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OF SOUTHDAKOTA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO ANDREDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBEDABOVE. THE PAYMENT OF $125,000 TO THE STATE OF SOUTH DAKOTA WASMADE ON DECEMBER 5, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1312018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OF SOUTHDAKOTA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO ANDREDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBEDABOVE. THE PAYMENT OF $125,000 TO THE STATE OF SOUTH DAKOTA WASMADE ON DECEMBER 5, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Disclosure 54 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED MARYLANDSECURITIES ACT, SECTION 11-412(A)(7) AND SECTION 11-412(A)(10) BY:A)ENGAGING IN ACTS & PRACTICES THAT CREATED OR MAINTAINEDINAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENTOVER RESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OFINTEREST ON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESECONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER; B)THREATENINGTO DROP RESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS ALEAD MANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPUETICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1322018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF MARYLANDPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 10/07/2003Docket/Case Number: 2002-0885Principal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED MARYLANDSECURITIES ACT, SECTION 11-412(A)(7) AND SECTION 11-412(A)(10) BY:A)ENGAGING IN ACTS & PRACTICES THAT CREATED OR MAINTAINEDINAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENTOVER RESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OFINTEREST ON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESECONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER; B)THREATENINGTO DROP RESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS ALEAD MANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPUETICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 11/21/2003Resolution:Other Sanctions Ordered: $204,050 TO THE STATE OF MARYLANDSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND TASKFORCE, THE FIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 INSETTLEMENT OF THESE MATTERS AND HAS AGREED TO CEASE ANDDESIST IN THE FUTURE FROM THE ALLEGED IMPROPER CONDUCT.PURSUANT TO THE SETTLEMENT DOCUMENTS, $12,500,000 OF THISAMOUNT SHALL BE DESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THISAMOUNT SHALL BE DESIGNATED AS DISGORGEMENT OF COMMISSIONSAND FEES, AND $7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $204,050 PAID TO THE STATE OFMARYLAND PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $204,050 WAS MADE ON OCTOBER7, 2003. THE $12,500,000 DISGORGEMENT AMOUNT DESCRIBED ABOVE ISTO BE PAID TO THE UNITED STATES DISTRICT COURT WITHIN TEN (10)DAYS OF COURT APPROVAL OF THE SEC SETTLEMENT AND ENTRY OFFINAL JUDGMENT IN THAT MATTER. THE $7,500,000 TO PROCUREINDEPENDENT RESEARCH SHALL BE DEPOSITED INTO ESCROW WITHINTHIRTY (30) DAYS OF ENTRY OF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1332018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND TASKFORCE, THE FIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 INSETTLEMENT OF THESE MATTERS AND HAS AGREED TO CEASE ANDDESIST IN THE FUTURE FROM THE ALLEGED IMPROPER CONDUCT.PURSUANT TO THE SETTLEMENT DOCUMENTS, $12,500,000 OF THISAMOUNT SHALL BE DESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THISAMOUNT SHALL BE DESIGNATED AS DISGORGEMENT OF COMMISSIONSAND FEES, AND $7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $204,050 PAID TO THE STATE OFMARYLAND PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $204,050 WAS MADE ON OCTOBER7, 2003. THE $12,500,000 DISGORGEMENT AMOUNT DESCRIBED ABOVE ISTO BE PAID TO THE UNITED STATES DISTRICT COURT WITHIN TEN (10)DAYS OF COURT APPROVAL OF THE SEC SETTLEMENT AND ENTRY OFFINAL JUDGMENT IN THAT MATTER. THE $7,500,000 TO PROCUREINDEPENDENT RESEARCH SHALL BE DEPOSITED INTO ESCROW WITHINTHIRTY (30) DAYS OF ENTRY OF THE FINAL JUDGMENT.Disclosure 55 of 134iReporting Source: RegulatorInitiated By: VERMONTPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:N/ADate Initiated: 07/01/2002Docket/Case Number: 03-069-SURL for Regulatory Action:Principal Product Type: Equity Listed (Common & Preferred Stock)Other Product Type(s):Allegations: VIOLATIONS OF THE VT SECURITIES ACT IN THAT: (A) THE FIRM FAILED TOINSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELYINSULATED FROM PRESSURES AND INFLUENCES FROM COVEREDCOMPANIES AND INVESTMENT BANKING WHICH CONDUCT IS ADISHONEST AND UNETHICAL PRACTICE UNDER SECTION 4221A(A)(8) OFTHE ACT; AND (B) THE FIRM FAILED TO REASONABLY SUPERVISE ITSEMPLOYEES TO INSURE THAT ITS ANALYSTS WERE ADEQUATELYINSULATED FROM PRESSURES AND INFLUENCES FROM COVEREDCOMPANIES AND INVESTMENT BANKING AS REQUIRED BY SECTION4221A(A)(11) OF THE ACT.Current Status: FinalAppealed To and Date AppealFiled:N/AResolution Date: 11/06/2003Resolution:Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?YesOrder1342018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions Ordered: FIRM ADMITS THE JURISDICTION OF THE COMMISSIONER, NEITHERADMITS NOR DENIES THE FINDINGS OF FACT AND CONCLUSIONS OF LAWCONTAINED IN THIS ORDER AND CONSENTS TO THE ENTRY OF THISORDER BY THE COMMISSIONER.Sanction Details: GLOBAL SETTLEMENT RESULTING FROM INVESTIGATION OF ANALYSTTASK FORCESanctions Ordered: Monetary/Fine $125,000.00Cease and Desist/InjunctioniReporting Source: FirmInitiated By: STATE OF VERMONTPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Date Initiated: 11/05/2003Docket/Case Number: 03-069-SPrincipal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED 4221A(A)(8)AND 4221A(A)(11) OF THE SECURITIES ACT BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1352018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTResolution Date: 11/06/2003Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF VERMONTSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OFVERMONT PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE STATE OFVERMONT WAS MADE ON NOVEMBER 5, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrderDisclosure 56 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED NEB. REV.STAT. 8-1103(9)(A)(VII) BY: A)ENGAGING IN ACTS & PRACTICES THATCREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1362018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF NEBRASKAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 10/07/2003Docket/Case Number: UNKNOWNPrincipal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED NEB. REV.STAT. 8-1103(9)(A)(VII) BY: A)ENGAGING IN ACTS & PRACTICES THATCREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 11/04/2003Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF NEBRASKASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OFNEBRASKA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE STATE OFNEBRASKA WAS MADE ON 11/3/03. THE $12,500,000 DISGORGEMENTAMOUNT DESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATESDISTRICT COURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1372018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OFNEBRASKA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE STATE OFNEBRASKA WAS MADE ON 11/3/03. THE $12,500,000 DISGORGEMENTAMOUNT DESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATESDISTRICT COURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Disclosure 57 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED CHAPTER1707 OF THE OHIO REVISED CODE BY: A)ENGAGING IN ACTS & PRACTICESTHAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1382018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF OHIOPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 11/05/2003Docket/Case Number: UNKNOWNPrincipal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED CHAPTER1707 OF THE OHIO REVISED CODE BY: A)ENGAGING IN ACTS & PRACTICESTHAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 11/06/2003Resolution:Other Sanctions Ordered: $437,386 TO THE STATE OF OHIOSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $437,386 PAID TO THE STATE OF OHIOPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $437,386 TO THE STATE OF OHIO WAS MADE ON OCTOBER 5,2003. THE $12,500,000 DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TOBE PAID TO THE UNITED STATES DISTRICT COURT WITHIN TEN (10) DAYSOF COURT APPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINALJUDGMENT IN THAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENTRESEARCH SHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30)DAYS OF ENTRY OF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1392018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $437,386 PAID TO THE STATE OF OHIOPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $437,386 TO THE STATE OF OHIO WAS MADE ON OCTOBER 5,2003. THE $12,500,000 DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TOBE PAID TO THE UNITED STATES DISTRICT COURT WITHIN TEN (10) DAYSOF COURT APPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINALJUDGMENT IN THAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENTRESEARCH SHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30)DAYS OF ENTRY OF THE FINAL JUDGMENT.Disclosure 58 of 134iReporting Source: FirmInitiated By: STATE OF TENNESSEEPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Date Initiated: 09/17/2003Docket/Case Number: 03-008Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED T.C.A. 48-2-112(A)(2)(G) AND (J) BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATEDOR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENTBANKING DEPARTMENT OVER RESEARCH ANALYSTS THEREFOREIMPOSING CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS &FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1402018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTResolution Date: 11/06/2003Resolution:Other Sanctions Ordered: $219,183 TO THE STATE OF TENNESSEESanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $219,183 PAID TO THE STATE OFTENNESSEE PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $219,183 TO THE STATE OFTENNESSEE WAS MADE ON NOVEMBER 3, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrderDisclosure 59 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED ARK. CODEANN. 23-42-308(A)(2)(G) AND 23-42-308(A)(2)(J) BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1412018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF ARKANSASPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 10/07/2003Docket/Case Number: S-03-016-03-C006Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED ARK. CODEANN. 23-42-308(A)(2)(G) AND 23-42-308(A)(2)(J) BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 11/05/2003Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF ARKANSASSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OFARKANSAS PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE STATE OFARKANSAS WAS MADE ON OCTOBER 7, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1422018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OFARKANSAS PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE STATE OFARKANSAS WAS MADE ON OCTOBER 7, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Disclosure 60 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED MISSOURISECURITIES ACT 409.204(A)(2)(G) AND (J) RSMO BY: A)ENGAGING IN ACTS& PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATEINFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVERRESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OF INTERESTON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESE CONFLICTS INADEQUATE OR APPROPRIATE MANNER; B)THREATENING TO DROPRESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS A LEADMANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1432018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF MISSOURIPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 10/08/2003Docket/Case Number: AO-03-21Principal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED MISSOURISECURITIES ACT 409.204(A)(2)(G) AND (J) RSMO BY: A)ENGAGING IN ACTS& PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATEINFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVERRESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OF INTERESTON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESE CONFLICTS INADEQUATE OR APPROPRIATE MANNER; B)THREATENING TO DROPRESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS A LEADMANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 10/23/2003Resolution:Other Sanctions Ordered: $215,558 TO THE STATE OF MISSOURISanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $215,558 PAID TO THE STATE OFMISSOURI PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $215,558 TO THE STATE OFMISSOURI WAS MADE ON OCTOBER 10, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1442018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $215,558 PAID TO THE STATE OFMISSOURI PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $215,558 TO THE STATE OFMISSOURI WAS MADE ON OCTOBER 10, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Disclosure 61 of 134iReporting Source: FirmInitiated By: STATE OF MINNESOTADate Initiated: 09/17/2003Docket/Case Number: UNKNOWNPrincipal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED MINN.STATE 80A.07, SUBD. 1(7)(2002) AND MINN. R. CH. 2875.0910, SUBP. 3(2001)BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATED OR MAINTAINEDINAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENTOVER RESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OFINTEREST ON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESECONFLICTS IN ADEQUATE OR APPROPRIATE MANNER; B)THREATENING TODROP RESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS A LEADMANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1452018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTOther Product Type(s): RESEARCHResolution Date: 10/13/2003Resolution:Other Sanctions Ordered: $189,526 TO THE STATE OF MINNESOTASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $189,526 PAID TO THE STATE OFMINNESOTA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $189,526 TO THE STATE OFMINNESOTA WAS MADE ON SEPTEMBER 17, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrderDisclosure 62 of 134iReporting Source: Regulator1462018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NORTH DAKOTAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 10/20/2003Docket/Case Number:URL for Regulatory Action:Principal Product Type: OtherOther Product Type(s): ANALYST CONFLICT OF INTERESTAllegations: SEE GLOBAL SETTLEMENTCurrent Status: FinalResolution Date: 10/20/2003Resolution:Other Sanctions Ordered:Sanction Details: $120,000 ASSESSED IN CIVIL PENALTY. $5,000 PAID TO THE INVESTOREDUCATION AND TECHNOLOGY FUND ADMINISTERED BY THE SECURITIESDEPARTMENT. OTHER PENALTIES AS SET FORTH IN GLOBAL SETTLEMENTDOCUMENTS.Sanctions Ordered: Monetary/Fine $125,000.00ConsentiReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SECTION10-04-11(1)(C) N.D.C.C. AND SECTION 10-04-11(1)(M)N.D.C.C. BY:A)ENGAGING IN ACTS & PRACTICES THAT CREATED OR MAINTAINEDINAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENTOVER RESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OFINTEREST ON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESECONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER; B)THREATENINGTO DROP RESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS ALEAD MANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1472018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF NORTH DAKOTAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 09/17/2003Docket/Case Number: NONEPrincipal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SECTION10-04-11(1)(C) N.D.C.C. AND SECTION 10-04-11(1)(M)N.D.C.C. BY:A)ENGAGING IN ACTS & PRACTICES THAT CREATED OR MAINTAINEDINAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENTOVER RESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OFINTEREST ON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESECONFLICTS IN AN ADEQUATE OR APPROPRIATE MANNER; B)THREATENINGTO DROP RESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS ALEAD MANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 10/20/2003Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF NORTH DAKOTASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OF NORTHDAKOTA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO ANDREDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBEDABOVE. THE PAYMENT OF $125,000 TO THE STATE OF NORTH DAKOTA WASMADE ON OCTOBER 7, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1482018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OF NORTHDAKOTA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO ANDREDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBEDABOVE. THE PAYMENT OF $125,000 TO THE STATE OF NORTH DAKOTA WASMADE ON OCTOBER 7, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Disclosure 63 of 134iReporting Source: FirmInitiated By: STATE OF WISCONSINDate Initiated: 10/07/2003Docket/Case Number: S-03099(EX)Allegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED CH. 551,WIS. STATS. BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATED ORMAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKINGDEPARTMENT OVER RESEARCH ANALYSTS THEREFORE IMPOSINGCONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS & FAILING TOMANAGE THESE CONFLICTS IN ADEQUATE OR APPROPRIATE MANNER;B)THREATENING TO DROP RESEARCH COVERAGE IF THE FIRM WAS NOTSELECTED AS A LEAD MANAGER IN AN INVESTMENT BANKINGTRANSACTION; C)ISSUING RESEARCH REPORTS ON ESPERIONTHERAPEUTICS INC. & TRITON NETWORK SYSTEMS THAT DID NOTPROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDING THOSECOMPANIES & THEIR BUSINESS PROSPECTS; CONTAINED EXAGGERATEDOR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; D)MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1492018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDocket/Case Number: S-03099(EX)Principal Product Type: OtherOther Product Type(s): RESEARCHResolution Date: 10/09/2003Resolution:Other Sanctions Ordered: $206,638 TO THE STATE OF WISCONSINSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $206,638 PAID TO THE STATE OFWISCONSIN PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $206,638 TO THE STATE OFWISCONSIN WAS MADE ON OCTOBER 7, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrderDisclosure 64 of 134i1502018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceDisclosure 64 of 134Reporting Source: RegulatorInitiated By: KANSAS SECURITIES COMMISSIONERPrincipal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:WITH FINEDate Initiated: 05/05/2003Docket/Case Number: 2003E049/KSC 2003-4742URL for Regulatory Action:Principal Product Type: OtherOther Product Type(s): GENERAL SECURITIES/ BDAllegations: US BANCORP PIPER JAFFREY, INC.'S ACTIVITIES IN CONNECTION WITHCERTAIN CONFLICTS OF INTEREST THAT RESEARCH ANALYSTS WERESUBJECT TO DURING THE PERIOD OF JULY 1, 1999, THROUGH JUNE 30,2001.Current Status: FinalResolution Date: 10/14/2003Resolution:Other Sanctions Ordered:Sanction Details: US BANCORP PIPER JAFFREY, INC.'S WILL CEASE AND DESIST FROMVIOLATING KSA 17-1254(M)(7) & (12) IN CONNECTION WITH THE RESEARCHPRACTICES REFERENCED IN THE ORDER, WILL COMPLY WITH KSA 17-1254(M) (7)&(12) IN CONNECTION WITH THE RESEARCH PRACTICESREFERENCED IN THE ORDER, AND WILL COMPLY WITH THEUNDERTAKINGS.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?YesSanctions Ordered: Monetary/Fine $125,000.00ConsentiReporting Source: Firm1512018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF KANSASPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 10/08/2003Docket/Case Number: DOCKET NO. 2003E049Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED K.S.A. 17-1254(M)(7) & (12) BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATEDOR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENTBANKING DEPARTMENT OVER RESEARCH ANALYSTS THEREFOREIMPOSING CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS &FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE OR APPROPRIATEMANNER; B)THREATENING TO DROP RESEARCH IF THE FIRM WAS NOTSELECTED AS A LEAD MANAGER IN AN INVESTMENT BANKINGTRANSACTION; C)ISSUING RESEARCH REPORTS ON ESPERIONTHERAPEUTICS INC. & TRITON NETWORK SYSTEMS THAT DID NOTPROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDING THOSECOMPANIES & THEIR BUSINESS PROSPECTS; CONTAINED EXAGGERATEDOR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; D)MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: FinalResolution Date: 10/14/2003Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF KANSASSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OFKANSAS PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO ANDREDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBEDABOVE. THE PAYMENT OF $125,000 TO THE STATE OF KANSAS WAS MADEON OCTOBER 10, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1522018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OFKANSAS PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO ANDREDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBEDABOVE. THE PAYMENT OF $125,000 TO THE STATE OF KANSAS WAS MADEON OCTOBER 10, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Disclosure 65 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SECTION204(A)(J) OF ACT NO. 60 AND SECTIONS 25 4.4 AND 28.2 OF REGULATION6078, SECTION 204(A)(G) OF ACT NO. 60 AND SECTION 26.1 OFREGULATION 6078, SECTION 204(A)(J) OF ACT NO. 60 AND SECTIONS 25.4.4AND 28.2 OF REGULATION 6078 BY: A)ENGAGING IN ACTS & PRACTICESTHAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1532018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: COMMONWEALTH OF PUERTO RICOPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 08/29/2003Docket/Case Number: C 03-V-007Principal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SECTION204(A)(J) OF ACT NO. 60 AND SECTIONS 25 4.4 AND 28.2 OF REGULATION6078, SECTION 204(A)(G) OF ACT NO. 60 AND SECTION 26.1 OFREGULATION 6078, SECTION 204(A)(J) OF ACT NO. 60 AND SECTIONS 25.4.4AND 28.2 OF REGULATION 6078 BY: A)ENGAGING IN ACTS & PRACTICESTHAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 09/30/2003Resolution:Other Sanctions Ordered: $146,729 TO THE COMMONWEALTH OF PUERTO RICOSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $146,729 PAID TO THE COMMONWEALTHOF PUERTO RICO PURSUANT TO THE CONSENT ORDER, SHALL BEAPPLIED TO AND REDUCE THE AMOUNT OF THE $12,500,000 CIVILPENALTY DESCRIBED ABOVE. THE PAYMENT OF $146,729 TO THECOMMONWEALTH OF PUERTO RICO WAS MADE ON SEPTEMBER 2, 2003.THE $12,500,000 DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BEPAID TO THE UNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OFCOURT APPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINALJUDGMENT IN THAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENTRESEARCH SHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30)DAYS OF ENTRY OF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1542018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $146,729 PAID TO THE COMMONWEALTHOF PUERTO RICO PURSUANT TO THE CONSENT ORDER, SHALL BEAPPLIED TO AND REDUCE THE AMOUNT OF THE $12,500,000 CIVILPENALTY DESCRIBED ABOVE. THE PAYMENT OF $146,729 TO THECOMMONWEALTH OF PUERTO RICO WAS MADE ON SEPTEMBER 2, 2003.THE $12,500,000 DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BEPAID TO THE UNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OFCOURT APPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINALJUDGMENT IN THAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENTRESEARCH SHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30)DAYS OF ENTRY OF THE FINAL JUDGMENT.Disclosure 66 of 134iReporting Source: FirmInitiated By: STATE OF NEW JERSEYDate Initiated: 08/20/2003Docket/Case Number: UNKNOWNAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED N.J.S.A.49:3-58(A)(2)(VII) & N.J.S.A. 49:3-58(2)(XI) BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1552018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDocket/Case Number: UNKNOWNPrincipal Product Type: OtherOther Product Type(s): RESEARCHResolution Date: 09/09/2003Resolution:Other Sanctions Ordered: $324,168 TO THE STATE OF NEW JERSEYSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THECIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BE DESIGNATED AS ACIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BE DESIGNATED ASDISGORGEMENT OF COMMISSIONS AND FEES, AND $7,500,000 OF THISAMOUNT SHALL BE USED TO FUND THE PROCUREMENT OF INDEPENDENTRESEARCH. AMOUNTS PAID TO THE VARIOUS STATES, INCLUDING THE$324,168 PAID TO THE STATE OF NEW JERSEY PURSUANT TO THECONSENT ORDER, SHALL BE APPLIED TO AND REDUCE THE AMOUNT OFTHE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THE PAYMENT OF$324,168 TO THE STATE OF NEW JERSEY WAS MADE ON AUGUST 25, 2003.THE $12,500,000 DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BEPAID TO THE UNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OFCOURT APPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINALJUDGMENT IN THAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENTRESEARCH SHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30)DAYS OF ENTRY OF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrderDisclosure 67 of 134i1562018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceReporting Source: FirmInitiated By: STATE OF NEVADAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 10/07/2003Docket/Case Number: I03-187Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED NRS 90.420(1)(H) & NRS 90.420(1)(K) BY: ENGAGING IN ACTS & PRACTICES THATCREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: FinalResolution Date: 10/08/2003Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF NEVADASanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1572018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OFNEVADA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO ANDREDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBEDABOVE. THE PAYMENT OF $125,000 TO THE STATE OF NEVADA WAS MADEON OCTOBER 7, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Disclosure 68 of 134iReporting Source: RegulatorInitiated By: OREGON DIVISION OF FINANCE AND CORPORATE SECURITIESDate Initiated: 07/24/2003Docket/Case Number: S-03-0033URL for Regulatory Action:Principal Product Type: OtherOther Product Type(s): STOCKAllegations: RESPONDENT ENGAGED IN UNETHICAL AND DISHONEST PRACTICES INCONNECTION WITH THE OFFER OR SALE OF SECURITIES. RESPONDENTALSO FAILED REASONABLY TO SUPERVISE THEIR EMPLOYEES. ALLALLEGATIONS RELATED TO PRACTICES OF THE RESEARCH ANDINVESTMENT BANKING SECTIONS OF THE RESPONDENT'S FIRM.Current Status: Final1582018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTOther Product Type(s): STOCKResolution Date: 09/29/2003Resolution:Other Sanctions Ordered:Sanction Details: NO PORTION OF PENALTY SUSPENDEDRegulator Statement RESEARCH ANALYSTS AT THE FIRM WERE SUBJECTED TO PRESSURESFROM THE INVESTMENT BANKING SECTION OF THE FIRM TO RATESTOCKS FAVORABLY SO AS TO GAIN THE INVESTMENT BANKINGBUSINESS OF THE FIRMS ISSUING THE STOCKS.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?YesSanctions Ordered: Monetary/Fine $131,811.00Cease and Desist/InjunctionConsentiReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED ORS 59.205(13) AND ORS 59.205(2) BY: A)ENGAGING IN ACTS & PRACTICES THATCREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1592018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF OREGONPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 09/17/2003Docket/Case Number: S-03-0033Principal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED ORS 59.205(13) AND ORS 59.205(2) BY: A)ENGAGING IN ACTS & PRACTICES THATCREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 09/29/2003Resolution:Other Sanctions Ordered: $131,811 TO THE STATE OF OREGONSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $131,811 PAID TO THE STATE OFOREGON PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $131,811 TO THE STATE OF OREGONWAS MADE ON SEPTEMBER 17, 2003. THE $12,500,000 DISGORGEMENTAMOUNT DESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATESDISTRICT COURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1602018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $131,811 PAID TO THE STATE OFOREGON PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $131,811 TO THE STATE OF OREGONWAS MADE ON SEPTEMBER 17, 2003. THE $12,500,000 DISGORGEMENTAMOUNT DESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATESDISTRICT COURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Disclosure 69 of 134iReporting Source: FirmInitiated By: STATE OF ALABAMAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Date Initiated: 09/17/2003Docket/Case Number: CO-2003-0029Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED 8-6-3(J)(7)CODE OF ALABAMA 1975 AND 830-X-3-.13(1) & (3) BY: A)ENGAGING INACTS & PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATEINFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVERRESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OF INTERESTON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESE CONFLICTS INADEQUATE OR APPROPRIATE MANNER; B)THREATENING TO DROPRESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS A LEADMANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; D)MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1612018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTResolution Date: 09/23/2003Resolution:Other Sanctions Ordered: $171,327 TO THE STATE OF ALABAMASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PACTICES BY THE SEC, NYSE, NASD AND A MULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTS REACHEDJOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THE FIRM ISREQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OF THESEMATTERS AND HAS AGREED TO CEASE AND DESIST IN THE FUTURE FROMTHE ALLEGED IMPROPER CONDUCT. PURSUANT TO THE SETTLEMENTDOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BE DESIGNATED AS ACIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BE DESIGNATED ASDISGORGEMENT OF COMMISSIONS AND FEES, AND $7,500,000 OF THISAMOUNT SHALL BE USED TO FUND THE PROCUREMENT OF INDEPENDENTRESEARCH. AMOUNTS PAID TO THE VARIOUS STATES, INCLUDING$171,327 PAID TO THE STATE OF ALABAMA PURSUANT TO THE CONSENTORDER, SHALL BE APPLIED TO AND REDUCE THE AMOUNT OF THE$12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THE PAYMENT OF $171,327TO THE STATE OF ALABAMA WAS MADE ON SEPTEMBER 17, 2003. THE$12,500,000 DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAIDTO THE UNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OFCOURT APPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINALJUDGMENT IN THAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENTRESEARCH SHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30)DAYS OF ENTRY OF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrderDisclosure 70 of 134iReporting Source: RegulatorAllegations: CONFLICTS OF INTEREST OF RESEARCH ANALYSTS DURING THE TIMEPERIOD BEGINNING JULY 1, 1999, TO JUNE 30, 2001, TO WIT, USBPJ FAILEDTO ENSURE THAT RESEARCH ANALYSTS WERE ADEQUATELY INSULATEDFROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES ANDINVESTMENT BANKING, AND USBPJ FAILED TO REASONABLY SUPERVISEITS EMPLOYEES TO ENSURE THAT ITS RESEARCH ANALYSTS WEREADEQUATELY INSULATED FROM SUCH PRESSURES AND INFLUENCES.Current Status: Final1622018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: OKLAHOMAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 05/02/2003Docket/Case Number: ODS 03-128URL for Regulatory Action:Principal Product Type: OtherOther Product Type(s): ANALYST INDEPENDENCE (IPO)Allegations: CONFLICTS OF INTEREST OF RESEARCH ANALYSTS DURING THE TIMEPERIOD BEGINNING JULY 1, 1999, TO JUNE 30, 2001, TO WIT, USBPJ FAILEDTO ENSURE THAT RESEARCH ANALYSTS WERE ADEQUATELY INSULATEDFROM PRESSURES AND INFLUENCES FROM COVERED COMPANIES ANDINVESTMENT BANKING, AND USBPJ FAILED TO REASONABLY SUPERVISEITS EMPLOYEES TO ENSURE THAT ITS RESEARCH ANALYSTS WEREADEQUATELY INSULATED FROM SUCH PRESSURES AND INFLUENCES.Resolution Date: 09/23/2003Resolution:Other Sanctions Ordered:Sanction Details: USBPJ ALSO AGREED TO COMPLY WITH ALL UNDERTAKINGS ESTABLISHEDAS PART OF THE GLOBAL ANALYST SETTLEMENT IN CONNECTION WITHTHE FIRM'S RESEARCH PRACTICES.Sanctions Ordered: Monetary/Fine $132,938.00Cease and Desist/InjunctionConsentiReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATEDSUBSECTION (B) OF 660:10-5-42 OF THE RULES BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1632018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF OKLAHOMAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 09/17/2003Docket/Case Number: ODS 03-128Principal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATEDSUBSECTION (B) OF 660:10-5-42 OF THE RULES BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 09/23/2003Resolution:Other Sanctions Ordered: $132,938 TO THE STATE OF OKLAHOMASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $132,938 TO THE STATE OF OKLAHOMAPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $132,938 TO THE STATE OF OKLAHOMA WAS MADE ONSEPTEMBER 17, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1642018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $132,938 TO THE STATE OF OKLAHOMAPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $132,938 TO THE STATE OF OKLAHOMA WAS MADE ONSEPTEMBER 17, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Disclosure 71 of 134iReporting Source: RegulatorInitiated By: FLORIDADate Initiated: 09/19/2003Docket/Case Number: 0040-S-6/03URL for Regulatory Action:Principal Product Type: OtherAllegations: RESPONDENT ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/ORMAINTAINED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVERRESEARCH ANALYSTS AND THEREFORE IMPOSED CONFLICTS OFINTEREST ON RESEARCH ANALYSTS. THE FIRM FAILED TO MANAGE THECONFLICTS IN AN ADEQUATE MANNER. FIRM ENGAGED IN DISHONESTAND UNETHICAL PRACTICES BY ISSUING RESEARCH THAT CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS AND/OREXAGGERATED OR UNWARRANTED CLAIMS. THE FIRM RECEIVEDCOMPENSATION FROM AN ISSUER, UNDERWRITER, OR DEALER, IN PARTFOR ISSUING RESEARCH REPORTS WITHOUT FULLY DISCLOSING THERECEIPT OR THE AMOUNT OF THE COMPENSATION. FIRM MADEPAYMENTS FOR RESEARCH TO OTHER BROKER DELAERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION AND FAILED TO DISCLOSE THIS INTHE OFFERING DOCUMENTS. FIRM FAILED TO ESTABLISH AND ENFORCESUPERVISORY PROCEDURES REASOBLY DESIGNED TO ENSURE THATANALYSTS WERE NOT UNDULY INFLUENCED BY INVESTMENT BANKINGCONCERNS.Current Status: Final1652018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:Principal Product Type: OtherOther Product Type(s): RESEARCH.Resolution Date: 09/19/2003Resolution:Other Sanctions Ordered:Sanction Details: NARegulator Statement RESPONDENT ENGAGED IN ACTS AND PRACTICES THAT CREATED AND/ORMAINTAINED INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVERRESEARCH ANALYSTS AND THEREFORE IMPOSED CONFLICTS OFINTEREST ON RESEARCH ANALYSTS. THE FIRM FAILED TO MANAGE THECONFLICTS IN AN ADEQUATE MANNER. FIRM ENGAGED IN DISHONESTAND UNETHICAL PRACTICES BY ISSUING RESEARCH THAT CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS AND/OREXAGGERATED OR UNWARRANTED CLAIMS. THE FIRM RECEIVEDCOMPENSATION FROM AN ISSUER, UNDERWRITER, OR DEALER, IN PARTFOR ISSUING RESEARCH REPORTS WITHOUT FULLY DISCLOSING THERECEIPT OR THE AMOUNT OF THE COMPENSATION. FIRM MADEPAYMENTS FOR RESEARCH TO OTHER BROKER DELAERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION AND FAILED TO DISCLOSE THIS INTHE OFFERING DOCUMENTS. FIRM FAILED TO ESTABLISH AND ENFORCESUPERVISORY PROCEDURES REASOBLY DESIGNED TO ENSURE THATANALYSTS WERE NOT UNDULY INFLUENCED BY INVESTMENT BANKINGCONCERNS.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: Monetary/Fine $615,731.00Cease and Desist/InjunctionOrderiReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SECTION517.161(1)(A) FLA. STAT. AND RULE 3E-600.013(1)(P), FLA. ADMIN. CODE BY:A)ENGAGING IN ACTS & PRACTICES THAT CREATED OR MAINTAINEDINAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENTOVER RESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OFINTEREST ON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESECONFLICTS IN ADEQUATE OR APPROPRIATE MANNER; B)THREATENING TODROP RESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS A LEADMANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1662018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF FLORIDAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 09/17/2003Docket/Case Number: OFR NO. 0040-S-6/03Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SECTION517.161(1)(A) FLA. STAT. AND RULE 3E-600.013(1)(P), FLA. ADMIN. CODE BY:A)ENGAGING IN ACTS & PRACTICES THAT CREATED OR MAINTAINEDINAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENTOVER RESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OFINTEREST ON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESECONFLICTS IN ADEQUATE OR APPROPRIATE MANNER; B)THREATENING TODROP RESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS A LEADMANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 09/19/2003Resolution:Other Sanctions Ordered: $615,731 TO THE STATE OF FLORIDASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $615,731 TO THE STATE OF FLORIDAPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENTS OF $615,731 TO THE STATE OF FLORIDA WAS MADE ONSEPTEMBER 17, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1672018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $615,731 TO THE STATE OF FLORIDAPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENTS OF $615,731 TO THE STATE OF FLORIDA WAS MADE ONSEPTEMBER 17, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Disclosure 72 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED AS45.55.025 AND AS 845.55.060 BY: A)ENGAGING IN ACTS & PRACTICES THATCREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1682018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF ALASKAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 08/20/2003Docket/Case Number: 04-06 SPrincipal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED AS45.55.025 AND AS 845.55.060 BY: A)ENGAGING IN ACTS & PRACTICES THATCREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 08/29/2003Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF ALASKASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OFALASKA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO ANDREDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBEDABOVE. THE PAYMENT OF $125,000 TO THE STATE OF ALASKA WAS MADEON AUGUST 25, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1692018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OFALASKA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO ANDREDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBEDABOVE. THE PAYMENT OF $125,000 TO THE STATE OF ALASKA WAS MADEON AUGUST 25, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF FINAL JUDGMENT.Disclosure 73 of 134iReporting Source: RegulatorInitiated By: GEORGIA SECRETARY OF STATE - SECURITIES DIVISION.Principal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:THE RESPONDENT SHALL PAY $315,388.00 IN CIVIL PENALTIES TO GA.Date Initiated: 09/08/2003Docket/Case Number: EN-19521URL for Regulatory Action:Principal Product Type: OtherOther Product Type(s): SEE #7.Allegations: THE RESPONDENT SETTLED ALLEGATIONS THAT UNDUE INFLUENCE BYTHE INVESTMENT BANKING DIVISION ON SECURITIES RESEARCH AT THEFIRM RESULTED IN TAINTED RESEARCH.Current Status: FinalResolution Date: 09/25/2003Resolution:Other Sanctions Ordered: SEE #2Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?YesSanctions Ordered: Monetary/Fine $315,388.00Cease and Desist/InjunctionConsent1702018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions Ordered: SEE #2Sanction Details: FIRM AGREED TO PAY MONETEARY PENALTIES. FIRM ALSO AGREED TOREFORM PRACTICES TO MINIMIZE THE POSSIBILITY OF FUTURECONFLICTS OF INTEREST.iReporting Source: FirmInitiated By: STATE OF GEORGIAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 08/29/2003Docket/Case Number: EN-19521Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED O.C.G.A.10-5-4(A)(8)AND 10-5-12(A)(1) AND RULE 590-4-2-.14(1) BY: A)ENGAGING INACTS & PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATEINFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVERRESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OF INTERESTON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESE CONFLICTS INADEQUATE OR APPROPRIATE MANNER; B)THREATENING TO DROPRESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS A LEADMANAGER IN AN INVESTMENT BANKING TRANSACITON; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1712018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanction(s)/ReliefSought:CEASE AND DESISTResolution Date: 09/25/2003Resolution:Other Sanctions Ordered: $315,388 TO THE STATE OF GEORGIASanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $315,388 PAID TO THE STATE OFGEORGIA PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $315,388 TO THE STATE OFGEORGIA WAS MADE ON SEPTEMBER 2, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrderDisclosure 74 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED WYOMINGSECURITIES ACT BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATEDOR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENTBANKING DEPARTMENT OVER RESEARCH ANALYSTS THEREFOREIMPOSING CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS &FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE OR APPROPRIATEMANNER; B)THREATENING TO DROP RESEARCH COVERAGE IF THE FIRMWAS NOT SELECTED AS A LEAD MANAGER IN AN INVESTMENT BANKINGTRANSACTION; C)ISSUING RESEARCH REPORTS ON ESPERIONTHERAPEUTICS INC. & TRITON NETWORK SYSTEMS THAT DID NOTPROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDING THOSECOMPANIES & THEIR BUSINESS PROSPECTS; CONTAINED EXAGGERATEDOR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; D)MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1722018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF WYOMINGPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 08/29/2003Docket/Case Number: 02-13Principal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED WYOMINGSECURITIES ACT BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATEDOR MAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENTBANKING DEPARTMENT OVER RESEARCH ANALYSTS THEREFOREIMPOSING CONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS &FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE OR APPROPRIATEMANNER; B)THREATENING TO DROP RESEARCH COVERAGE IF THE FIRMWAS NOT SELECTED AS A LEAD MANAGER IN AN INVESTMENT BANKINGTRANSACTION; C)ISSUING RESEARCH REPORTS ON ESPERIONTHERAPEUTICS INC. & TRITON NETWORK SYSTEMS THAT DID NOTPROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDING THOSECOMPANIES & THEIR BUSINESS PROSPECTS; CONTAINED EXAGGERATEDOR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; D)MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 09/03/2003Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF WYOMINGSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 TO THE STATE OF WYOMINGPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $125,000 TO THE STATE OF WYOMING WAS MADE ONSEPTEMBER 2, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1732018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 TO THE STATE OF WYOMINGPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $125,000 TO THE STATE OF WYOMING WAS MADE ONSEPTEMBER 2, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Disclosure 75 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED RHODEISLAND UNIFORM SECURITIES ACT OF 1990 ("RIUSA") 7-11-101 ET SEQ. OFTHE RHODE ISLAND GENERAL LAWS BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NOT REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1742018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF RHODE ISLANDPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 09/17/2003Docket/Case Number: 09-29-2003 INPrincipal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED RHODEISLAND UNIFORM SECURITIES ACT OF 1990 ("RIUSA") 7-11-101 ET SEQ. OFTHE RHODE ISLAND GENERAL LAWS BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NOT REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 09/24/2003Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF RHODE ISLANDSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OF RHODEISLAND PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO ANDREDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBEDABOVE. THE PAYMENT OF $125,000 TO THE STATE OF RHODE ISLAND WASMADE ON SEPTEMBER 17, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1752018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OF RHODEISLAND PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO ANDREDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBEDABOVE. THE PAYMENT OF $125,000 TO THE STATE OF RHODE ISLAND WASMADE ON SEPTEMBER 17, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Disclosure 76 of 134iReporting Source: FirmInitiated By: ARIZONA CORPORATION COMMISSIONPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Date Initiated: 08/29/2003Docket/Case Number: S-03537A-03-0000 DECISION 66295Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED A.R.S. 44-1961(A)(13) BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATED ORMAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKINGDEPARTMENT OVER RESEARCH ANALYSTS THEREFORE IMPOSINGCONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS & FAILING TOMANAGE THESE CONFLICTS IN ADEQUATE OR APPROPRIATE MANNER;B)THREATENING TO DROP RESEARCH COVERAGE IF THE FIRM WAS NOTSELECTED AS A LEAD MANAGER IN AN INVESTMENT BANKINGTRANSACTION; C)ISSUING RESEARCH REPORTS ON ESPERIONTHERAPEUTICS INC. & TRITON NETWORK SYSTEMS THAT DID NOTPROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDING THOSECOMPANIES & THEIR BUSINESS PROSPECTS; CONTAINED EXAGGERATEDOR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; D)MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRTING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1762018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanction(s)/ReliefSought:CEASE AND DESISTResolution Date: 09/24/2003Resolution:Other Sanctions Ordered: $197,660 TO THE ARIZONA CORPORATION COMMISSIONSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $197,660 TO THE ARIZONACORPORATION COMMISSION PURSUANT TO THE CONSENT ORDER, SHALLBE APPLIED TO AND REDUCE THE AMOUNT OF THE $12,500,000 CIVILPENALTY DESCRIBED ABOVE. THE PAYMENT OF $197,660 TO THE ARIZONACORPORATION COMMISSION WAS MADE ON SEPTEMBER 2, 2003. THE$12,500,000 DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAIDTO THE UNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OFCOURT APPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINALJUDGMENT IN THAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENTRESEARCH SHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30)DAYS OF ENTRY OF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrderDisclosure 77 of 134iReporting Source: RegulatorAllegations: THE SECURITIES COMMISSIONER FINDS THAT US BANCORP PIPERJAFFRAY INC (USBPJ) ENGAGED IN ACTS AND PRACTICES THAT CREATEDAND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY INVESTMENTBANKING OVER RESEARCH ANALYSTS AND THEREFORE IMPOSEDCONFLICTS OF INTEREST ON RESEARCH ANALYSTS AND FAILED TOMANAGE THESE CONFLICTS IN AN ADEQUATE AND APPROPRIATE MANNERIN VIOLATION OF THE TEXAS SECURITIES ACT RELATING TO INEQUITABLEPRACTICES IN THE SALE OF SECURITIES AND THAT USBPJ HASCOMMITTED INEQUITABLE PRACTICES IN THE SALE OF SECURITIESUNDER SECTION 14.A(3) OF THE TEXAS SECURITIES ACT, BY ISSUINGRESEARCH THAT CONTAINED OPINIONS FOR WHICH THERE WAS NOREASONABLE BASIS AND/OR EXAGGERATED OR UNWARRENTED CLAIMS.THE SECURITIES COMMISSIONER ALSO FINDS THAT USBPJINAPPROPRIATELY THREATENED EXECUTIVES OF A POTENTIALINVESTMENT-BANKING CLIENT BY STATING THAT THEY WOULD DROPRESEARCH COVERAGE OF THE COMPANY IF THE FIRM WAS NOTSELECTED AS THE LEAD MANAGER IN AN INVESTMENT BANKINGTRANSACTION, WHICH CONSTITUTES INEQUITABLE PRACTICES IN THESALE OF SECURITIES UNDER THE TEXAS SECURITIES ACT AND THATUSBPJ RECEIVED COMPENSATION DIRECTLY OR INDIRECTLY, FROM ANISSUER, UNDERWRITER OR DEALER, IN PART, FOR ISSUING RESEARCHREPORTS, WITHOUT FULLY DISCLOSING THE RECEIPT OR THE AMOUNTOF THE COMPENSATION. THE SECURITIES COMMISSIONER FINDS THATUSBPJ MADE PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERSNOT INVOLVED IN AN UNDERWRITING TRANSACTION, WHEN THE FIRMKNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FORRESERACH COVERAGE, AND FAILED TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS AND THAT USBPJ FAILED TO ESTABLISH AND ENFORCEWRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TOENSURE THAT ANALYSTS WERE NOT UNDULY INFLUENCED BYINVESTMENT BANKING CONCERNS.Current Status: Final1772018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: TEXASPrincipal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:CEASE & DESIST FROM VIOLATING THE TEXAS SECURITIES ACT & ANADMINISTRATIVE FINE AND UNDERTAKING.Date Initiated: 09/23/2003Docket/Case Number: SSB DKT NO 03-042;ORDER NO CDO/FIN-1539URL for Regulatory Action:Principal Product Type: No ProductOther Product Type(s):THE SECURITIES COMMISSIONER FINDS THAT US BANCORP PIPERJAFFRAY INC (USBPJ) ENGAGED IN ACTS AND PRACTICES THAT CREATEDAND/OR MAINTAINED INAPPROPRIATE INFLUENCE BY INVESTMENTBANKING OVER RESEARCH ANALYSTS AND THEREFORE IMPOSEDCONFLICTS OF INTEREST ON RESEARCH ANALYSTS AND FAILED TOMANAGE THESE CONFLICTS IN AN ADEQUATE AND APPROPRIATE MANNERIN VIOLATION OF THE TEXAS SECURITIES ACT RELATING TO INEQUITABLEPRACTICES IN THE SALE OF SECURITIES AND THAT USBPJ HASCOMMITTED INEQUITABLE PRACTICES IN THE SALE OF SECURITIESUNDER SECTION 14.A(3) OF THE TEXAS SECURITIES ACT, BY ISSUINGRESEARCH THAT CONTAINED OPINIONS FOR WHICH THERE WAS NOREASONABLE BASIS AND/OR EXAGGERATED OR UNWARRENTED CLAIMS.THE SECURITIES COMMISSIONER ALSO FINDS THAT USBPJINAPPROPRIATELY THREATENED EXECUTIVES OF A POTENTIALINVESTMENT-BANKING CLIENT BY STATING THAT THEY WOULD DROPRESEARCH COVERAGE OF THE COMPANY IF THE FIRM WAS NOTSELECTED AS THE LEAD MANAGER IN AN INVESTMENT BANKINGTRANSACTION, WHICH CONSTITUTES INEQUITABLE PRACTICES IN THESALE OF SECURITIES UNDER THE TEXAS SECURITIES ACT AND THATUSBPJ RECEIVED COMPENSATION DIRECTLY OR INDIRECTLY, FROM ANISSUER, UNDERWRITER OR DEALER, IN PART, FOR ISSUING RESEARCHREPORTS, WITHOUT FULLY DISCLOSING THE RECEIPT OR THE AMOUNTOF THE COMPENSATION. THE SECURITIES COMMISSIONER FINDS THATUSBPJ MADE PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERSNOT INVOLVED IN AN UNDERWRITING TRANSACTION, WHEN THE FIRMKNEW THAT THESE PAYMENTS WERE MADE, AT LEAST IN PART, FORRESERACH COVERAGE, AND FAILED TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS AND THAT USBPJ FAILED TO ESTABLISH AND ENFORCEWRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TOENSURE THAT ANALYSTS WERE NOT UNDULY INFLUENCED BYINVESTMENT BANKING CONCERNS.Resolution Date: 09/23/2003Resolution: Order1782018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceResolution Date: 09/23/2003Other Sanctions Ordered: CEASE AND DESIST FROM VIOLATING THE TEXAS SECURITIES ACT ANDCOMPLY WITH THE TERMS OF THE UNDERTAKING.Sanction Details: ADMINISTRATIVE FINE WAS PAID CONTEMPORANEOUSLY WITH THEDELIVERY OF THE ORDER.Sanctions Ordered: Monetary/Fine $803,329.00Cease and Desist/InjunctioniReporting Source: FirmInitiated By: TEXAS STATE SECURITIES BOARDDate Initiated: 09/17/2003Docket/Case Number: CDO/FIN-1539; SSB DOCKET NO. 03-042Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SECTION14.A(3) OF THE TEXAS SECURITIES ACT, AND SECTION 115.10 OF THERULES & REGULATIONS OF THE TEXAS SECURITIES BOARD BY:A)ENGAGING IN ACTS & PRACTICES THAT CREATED OR MAINTAINEDINAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENTOVER RESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OFINTEREST ON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESECONFLICTS IN ADEQUATE OR APPROPRIATE MANNER; B)THREATENING TODROP RESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS A LEADMANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS WHICH THEREWAS NO REASONABLE BASIS; D)MAKING PAYMENTS FOR RESEARCH TOOTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITINGTRANSACTION WHEN THE FIRM KNEW THAT THESE PAYMENTS WEREMADE AT LEAST IN PART FOR RESEARCH COVERAGE & BY FAILING TODISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERING DOCUMENTS ORELSEWHERE THE FACT OF SUCH PAYMENTS; AND E)RECEIVINGPAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS INCONJUNCTION WITH UNDERWRITING TRANSACTIONS WITHOUTDISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1792018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTOther Product Type(s): RESEARCHResolution Date: 09/30/2003Resolution:Other Sanctions Ordered: $803,329 TO THE STATE OF TEXASSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE STATE TASK FORCE. UNDER THE TERMS OF THESETTLEMENTS REACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASKFORCE, THE FIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 INSETTLEMENT OF THESE MATTERS AND HAS AGREED TO CEASE ANDDESIST IN THE FUTURE FROM THE ALLEGED IMPROPER CONDUCT.PURSUANT TO THE SETTLEMENT DOCUMENTS, $12,500,000 OF THISAMOUNT SHALL BE DESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THISAMOUNT SHALL BE DESIGNATED AS DISGORGEMENT OF COMMISSIONSAND FEES, AND $7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $803,329 TO THE STATE OF TEXASPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $803,329 TO THE STATE OF TEXAS WAS MADE ONSEPTEMBER 17, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrderDisclosure 78 of 134iReporting Source: Firm1802018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF IDAHOPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 08/20/2003Docket/Case Number: 2003-7-24Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED IDAHOCODE 30-1413(7), IDAPA 12.01.08.110 AND IDAPA 12.01.08.119 BY:A)ENGAGING IN ACTS & PRACTICES THAT CREATED OR MAINTAINEDINAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENTOVER RESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OFINTEREST ON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESECONFLICTS IN ADEQUATE OR APPROPRIATE MANNER; B)THREATENING TODROP RESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS A LEADMANAGER IN AN INVESTMENT BANKING TRANSACTION; C)ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D)MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: FinalResolution Date: 09/18/2003Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF IDAHOSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OF IDAHOPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $125,000 TO THE STATE OF IDAHO WAS MADE ONSEPTEMBER 17, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1812018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OF IDAHOPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $125,000 TO THE STATE OF IDAHO WAS MADE ONSEPTEMBER 17, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Disclosure 79 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED 6 DEL.C.73116(A)(7) AND DEL.C. 7316(A)(10) BY A) ENGAGING IN ACTS & PRACTICESTHAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANLAYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1822018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF DELAWAREPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 08/29/2003Docket/Case Number: C.A. NO. 03-6-4Principal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED 6 DEL.C.73116(A)(7) AND DEL.C. 7316(A)(10) BY A) ENGAGING IN ACTS & PRACTICESTHAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANLAYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 09/11/2003Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF DELAWARESanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OFDELAWARE PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE STATE OFDELAWARE WAS MADE ON SEPTEMBER 15, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1832018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OFDELAWARE PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE STATE OFDELAWARE WAS MADE ON SEPTEMBER 15, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Disclosure 80 of 134iReporting Source: RegulatorInitiated By: MICHIGANPrincipal Sanction(s)/ReliefSought:InjunctionOther Sanction(s)/ReliefSought:Date Initiated: 09/05/2003Docket/Case Number: 03-043-MURL for Regulatory Action:Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: THE SEC SETTLED THEIR ACTION AGAINST THE FIRM IN WHICH IT WASALLEGED THAT THERE WAS A CONFLICT OF INTEREST INVOLVING THERESEARCH ANALYSTS AND INVESTMENT BANKING DIVISIONS OF THEFIRM. THE RESEARCH ANALYSTS WERE SUBJECT TO INAPPROPRIATEINFLUENCE BY INVESTMENT BANKING AT THE FIRM. THE FIRM PAIDOTHER FIRMS FOR THOSE FIRMS TO PUBLISH RESEARCH ON ITSUNDERWRITING CLIENTS WITHOUT ENSURING THAT SUCH PAYMENTSWERE DISCLOSED, AND FAILED TO MAINTAIN APPROPRIATE SUPERVISIONOVER ITS RESEARCH AND INVESTMENT BANKING OPERATIONS.Current Status: FinalResolution Date: 09/05/2003Resolution:Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoOrder1842018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions Ordered: THE FIRM SHALL COMPLY WITH THE ORDER OF JUDGMENT OF THECOURT IN THE CASE BROUGHT BY THE SEC INCLUDING PAYMENT OF THEFINE ORDERED, PART OF WHICH IS TO BE ALLOCATED FOR SETTING UPINDEPENDENT RESEARCH ANALYSTS.Sanction Details: THE FIRM SHALL COMPLY WITH THE NASD AND NYSE RULES FOR ETHICALBUSINESS CONDUCTDoes the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: Cease and Desist/InjunctioniReporting Source: FirmInitiated By: STATE OF MICHIGANDate Initiated: 08/29/2003Docket/Case Number: 03-043-MAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED MCL451.604(A)(1)(G) AND MCL 451.604(A)(2) BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NOT REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRTINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1852018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDocket/Case Number: 03-043-MPrincipal Product Type: OtherOther Product Type(s): RESEARCHResolution Date: 09/05/2003Resolution:Other Sanctions Ordered: $382,884 TO THE STATE OF MICHIGANSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURES FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING $382,884 PAID TO THE STATE OF MICHIGANPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $382,884 TO THE STATE OF MICHIGAN WAS MADE ONSEPTEMBER 15, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Sanctions Ordered: Monetary/Fine $1,250,000.00Cease and Desist/InjunctionOrderDisclosure 81 of 134i1862018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceDisclosure 81 of 134Reporting Source: FirmInitiated By: STATE OF HAWAII, DEPARTMENT OF COMMERCE & CONSUMER AFFAIRSPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 08/29/2003Docket/Case Number: SEU2002-043Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED H.R.S. 485-15(7) & H.R.S. 485-15(10) BY: A)ENGAGING IN ACTS & PRACTICES THATCREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: FinalResolution Date: 09/04/2003Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF HAWAIISanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1872018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions Ordered: $125,000 TO THE STATE OF HAWAIISanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OF HAWAIIPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $125,000 TO THE STATE OF HAWAII WAS MADE ONSEPTEMBER 9, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Disclosure 82 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SECTION36B-4(B) & SECTION 36B-31-6F(B) BY: A)ENGAGING IN ACTS & PRACTICESTHAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER;C)ISSUING RESEARCH REPORTS ON ESPERION THERAPEUTICS INC. &TRITON NETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; D)MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1882018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF CONNECTICUT, SECURITIES & BUSINESS INVESTMENTSDIVISION OF THE DEPARTMENT OF BANKINGPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 08/20/2003Docket/Case Number: CO-2003-6801-SPrincipal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED SECTION36B-4(B) & SECTION 36B-31-6F(B) BY: A)ENGAGING IN ACTS & PRACTICESTHAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER;C)ISSUING RESEARCH REPORTS ON ESPERION THERAPEUTICS INC. &TRITON NETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS; D)MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 08/28/2003Resolution:Other Sanctions Ordered: $131,201 TO STATE OF CONNECTICUTSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $131,201 PAID TO THE STATE OFCONNECTICUT PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIEDTO AND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $131,201 TO THE STATE OFCONNECTICUT WAS MADE ON SEPTEMBER 3, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1892018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $131,201 PAID TO THE STATE OFCONNECTICUT PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIEDTO AND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $131,201 TO THE STATE OFCONNECTICUT WAS MADE ON SEPTEMBER 3, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Disclosure 83 of 134iReporting Source: FirmInitiated By: COMMONWEALTH OF KENTUCKYDate Initiated: 08/20/2003Docket/Case Number: UNKNOWNPrincipal Product Type: OtherAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED KRS292.330(13)(A)7 & KRS 202.330(13)(A)9A BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1902018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTPrincipal Product Type: OtherOther Product Type(s): RESEARCHResolution Date: 08/27/2003Resolution:Other Sanctions Ordered: $155,711 TO COMMONWEALTH OF KENTUCKYSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 FOR THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $155,711 PAID TO THE COMMONWEALTHOF KENTUCKY PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIEDTO AND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $155,711 TO THE COMMONWEALTHOF KENTUCKY WAS MADE ON SEPTEMBER 2, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrderDisclosure 84 of 134iReporting Source: Regulator1912018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: MAINE OFFICE OF SECURITIESPrincipal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:Date Initiated: 05/30/2002Docket/Case Number: 03-107URL for Regulatory Action:Principal Product Type: Equity Listed (Common & Preferred Stock)Other Product Type(s):Allegations: THE FIRM ENGAGED IN UNETHICAL AND DISHONEST CONDUCT BY FAILINGTO ENSURE THAT ANALYSTS WHO ISSUED RESEARCH WERE ADEQUATELYINSULATED FROM PRESSURES AND INFLUENCES OF COVEREDCOMPANIES AND INVESTMENT BANKING. THE FIRM ALSO FAILED TOREASONABLY SUPERVISE ITS EMPLOYEES IN CONNECTION WITH THEISSUANCE OF RESEARCH.Current Status: FinalResolution Date: 08/28/2003Resolution:Other Sanctions Ordered:Sanction Details: PENALTY WAS PAID ON 8/28/2003.Regulator Statement THE FIRM WAS ORDERED TO CEASE AND DESIST FROM VIOLATING THERMSA IN CONNECTION WITH CERTAIN CONFLICTS OF INTEREST TO WHICHITS RESEARCH ANALYSTS WERE SUBJECT AND TO IMPLEMENT CERTAINCHANGES WITH RESPECT TO ITS RESEARCH AND BANKING PRACTICES.THE CONSENT ORDER WAS EXECUTED AS PART OF A GLOBALSETTLEMENT OF COORDINATED INVESTIGATIONS ENTERED INTO BYFEDERAL AND STATE REGULATORS, AND SEVERAL LARGE BROKER-DEALERS WHO ENGAGED IN THE RESEARCH PRACTICES AT ISSUE.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: Monetary/Fine $125,000.00Cease and Desist/InjunctionOrder1922018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceTHE FIRM WAS ORDERED TO CEASE AND DESIST FROM VIOLATING THERMSA IN CONNECTION WITH CERTAIN CONFLICTS OF INTEREST TO WHICHITS RESEARCH ANALYSTS WERE SUBJECT AND TO IMPLEMENT CERTAINCHANGES WITH RESPECT TO ITS RESEARCH AND BANKING PRACTICES.THE CONSENT ORDER WAS EXECUTED AS PART OF A GLOBALSETTLEMENT OF COORDINATED INVESTIGATIONS ENTERED INTO BYFEDERAL AND STATE REGULATORS, AND SEVERAL LARGE BROKER-DEALERS WHO ENGAGED IN THE RESEARCH PRACTICES AT ISSUE.iReporting Source: FirmInitiated By: STATE OF MAINE, OFFICE OF SECURITIESPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 08/20/2003Docket/Case Number: 03-107Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED 32 M.R.S.A.10313(G) & 32 M.R.S.A. 10313(J) BY: A)ENGAGING IN ACTS & PRACTICESTHAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS &FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE OR APPROPRIATEMANNER; B)THREATENING TO DROP RESEARCH COVERAGE IF THE FIRMWAS NOT SELECTED AS A LEAD MANAGER IN AN INVESTMENT BANKINGTRANSACTION; C)ISSUING RESEARCH REPORTS ON ESPERIONTHERAPEUTICS INC. & TRITON NETWORK SYSTEMS THAT DID NOTPROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDING THOSECOMPANIES & THEIR BUSINESS PROSPECTS; CONTAINED EXAGGERATEDOR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NOT REASONABLE BASIS; D)MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; ANDE)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: FinalResolution Date: 08/28/2003Resolution:Other Sanctions Ordered: $125,000 TO STATE OF MAINE OFFICE OF SECURITIESSanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1932018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions Ordered: $125,000 TO STATE OF MAINE OFFICE OF SECURITIESSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING $125,000 PAID TO THE STATE OF MAINEPURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TO AND REDUCETHE AMOUNT OF THE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. THEPAYMENT OF $125,000 TO THE STATE OF MAINE WAS MADE ONSEPTEMBER 2, 2003. THE $12,500,000 DISGORGEMENT AMOUNTDESCRIBED ABOVE IS TO BE PAID TO THE UNITED STATES DISTRICTCOURT WITHIN TEN (10) DAYS OF COURT APPROVAL OF THE SECSETTLEMENT AND ENTRY OF FINAL JUDGMENT IN THAT MATTER. THE$7,500,000 TO PROCURE INDEPENDENT RESEARCH SHALL BE DEPOSITEDINTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRY OF THE FINALJUDGMENT.Disclosure 85 of 134iReporting Source: FirmAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED MISS.CODE ANN. 75-71-321(A)(F) & 75-71-321(B)(A) BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1942018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: STATE OF MISSISSIPPIPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 08/29/2003Docket/Case Number: 02-11-06-SPrincipal Product Type: OtherOther Product Type(s): RESEARCHU.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED MISS.CODE ANN. 75-71-321(A)(F) & 75-71-321(B)(A) BY: A)ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B)THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C)ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 09/04/2003Resolution:Other Sanctions Ordered: $125,000 TO THE STATE OF MISSISSIPPISanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OFMISSISSIPPI PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE STATE OFMISSISSIPPI WAS MADE ON SEPTEMBER 8, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1952018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceWITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $125,000 PAID TO THE STATE OFMISSISSIPPI PURSUANT TO THE CONSENT ORDER, SHALL BE APPLIED TOAND REDUCE THE AMOUNT OF THE $12,500,000 CIVIL PENALTYDESCRIBED ABOVE. THE PAYMENT OF $125,000 TO THE STATE OFMISSISSIPPI WAS MADE ON SEPTEMBER 8, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEARCHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Disclosure 86 of 134iReporting Source: FirmInitiated By: ATTORNEY GENERAL, STATE OF NEW YORKDate Initiated: 08/20/2003Docket/Case Number: UNKNOWNAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED THEMARTIN ACT BY: A)ENGAGING IN ACTS & PRACTICES THAT CREATED ORMAINTAINED INAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKINGDEPARTMENT OVER RESEARCH ANALYSTS THEREFORE IMPOSINGCONFLICTS OF INTEREST ON ITS RESEARCH ANALYSTS & FAILING TOMANAGE THESE CONFLICTS IN ADEQUATE OR APPROPRIATE MANNER;B)THREATENING TO DROP RESEARCH COVERAGE IF THE FIRM WAS NOTSELECTED AS A LEAD MANAGER IN AN INVESTMENT BANKINGTRANSACTION; C)ISSUING RESEARCH REPORTS ON ESPERIONTHERAPEUTICS INC. & TRITON NETWORK SYSTEMS THAT DID NOTPROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDING THOSECOMPANIES AND THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS; D)MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final1962018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDocket/Case Number: UNKNOWNPrincipal Product Type: OtherOther Product Type(s): RESEARCHResolution Date: 09/02/2003Resolution:Other Sanctions Ordered: $731,079 TO THE NEW YORK STATE DEPARTMENT OF LAWSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES, INCLUDING THE $731,079 PAID TO THE STATE OF NEWYORK PURSUANT TO THE ASSURANCE OF DISCONTINUANCE, SHALL BEAPPLIED TO AND REDUCE THE AMOUNT OF THE $12,500,000 CIVILPENALTY DESCRIBED ABOVE. THE PAYMENT OF $731,079 TO THE STATEOF NEW YORK WAS MADE ON SEPTEMBER 3, 2003. THE $12,500,000DISGORGEMENT AMOUNT DESCRIBED ABOVE IS TO BE PAID TO THEUNITED STATES DISTRICT COURT WITHIN TEN (10) DAYS OF COURTAPPROVAL OF THE SEC SETTLEMENT AND ENTRY OF FINAL JUDGMENT INTHAT MATTER. THE $7,500,000 TO PROCURE INDEPENDENT RESEACHSHALL BE DEPOSITED INTO ESCROW WITHIN THIRTY (30) DAYS OF ENTRYOF THE FINAL JUDGMENT.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOtherDisclosure 87 of 134i1972018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceDisclosure 87 of 134Reporting Source: FirmInitiated By: STATE OF WASHINGTON, SECURITIES DIVISIONPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CEASE AND DESISTDate Initiated: 04/21/2003Docket/Case Number: UNKNOWNPrincipal Product Type: OtherOther Product Type(s): RESEARCHAllegations: U.S. BANCORP PIPER JAFFRAY IS ALLEGED TO HAVE VIOLATED RCW21.20.110 BY ENGAGING IN CONDUCT INCONSISTENT WITH JUST &EQUITABLE PRINCIPLES OF TRADE BY: A) ENGAGING IN ACTS &PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCEBY THE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B) THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C) ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASES; D) MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E) RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: FinalResolution Date: 04/23/2003Resolution:Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionOrder1982018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions Ordered: $227,074 TO THE WASHINGTON STATE SECURITIES DIVISION; $200,000ADMINISTRATIVE FINE; $27,074 FOR REIMBURSEMENT OF WASHINGTONSTATE SECURITIES DIVISION'S LEGAL AND INVESTIGATIVE COSTS.Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE DESCRIBED SANCTIONS AND TOTHE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS ORDERED TO CEASEAND DESIST/INJUNCTION, REQUIRED TO PAY $32,500,000 AS SPECIFIED INTHE FINAL JUDGMENT ORDERED IN A RELATED ACTION FILED BY THE SECWHICH INCLUDES A FINE OF $12,500,000, DISGORGEMENT OF $12,500,000IN COMMISSIONS, FEES AND OTHER MONIES, AND PAYMENT OF $7,500,000FOR THE PROCUREMENT OF INDEPENDENT RESEARCH. THE MONETARYSANCTIONS IMPOSED BY NASD SHALL BE REDUCED BY THE AMOUNTSPAID BY RESPONDENT PURSUANT TO THE FINAL JUDGMENT. UPONEXECUTION OF THE STATE OF WASHINGTON DEPARTMENT OF FINANCIALINSTITUTION SECURITIES DIVISION'S CONSENT ORDER, PAYMENT OF$227,074 WAS PAID ON 4/23/03 TO THE WASHINGTON STATE SECURITIESDIVISION. 10 BUSINESS DAYS FROM ENTRY OF THE FINAL JUDGMENT, AWIRE TRANSFER OF $12,500,000 WILL BE SENT TO THE UNITED STATESDISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK.Sanctions Ordered: Monetary/Fine $12,500,000.00Cease and Desist/InjunctionDisclosure 88 of 134iReporting Source: RegulatorAllegations: **11/12/02**CONSENTED FINDINGS: (1)VIOLATED EXCHANGE RULE 440 ANDSECTION 17(A) OF THE SECURITIES AND EXCHANGE ACT OF 1934 AND SECREGULATION 17A-4 BY FAILING TO PRESERVE FOR A PERIOD OF THREEYEARS, AND/OR PRESERVE IN AN ACCESSIBLE PLACE FOR TWO YEARS,ELECTRONIC COMMUNICATIONS RELATING TO THE BUSINESS OF THEFIRM.(2)VIOLATED EXCHANGE RULES 342 IN THAT IT FAILED TOREASONABLY SUPERVISE AND CONTROL THE ACTIVITIES OF ITSEMPLOYEES, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP ANDREVIEW TO ASSURE COMPLIANCE WITH EXCHANGE RULES AND FEDERALSECURITIES LAWS RELATING TO RETENTION OF ELECTRONICCOMMUNICATIONS. STIPULATED SANCTION: THE IMPOSITION BY THEEXCHANGE OF A CENSURE AND A FINE IN THE AMOUNT OF $1,650,000, FORTOTAL FINES OF $8,250,000 FROM ALL RESPONDENTS. THE AMOUNT TOBE PAID TO THE NYSE BY EACH RESPONDENT SHALL BE REDUCED BYAMOUNTS PAID BY EACH RESPONDENT PURSUANT TO AGREEMENTS TOPAY A CIVIL MONETARY PENALTY OF $550,000 TO THE U.S. TREASURY ANDA FINE OF $550,000 TO NASD IN RELATED PROCEEDINGS. IN ADDITION TOTHE MONETARY FINE, RESPONDENTS SHALL COMPLETE AN APPROPRIATEUNDERTAKING TO REVIEW ITS PROCEDURES REGARDING THEPRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FORCOMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND REGULATIONSAND THE RULES OF THE EXCHANGE AND NASD. WITHIN 90 DAYS OF THEEXECUTION OF THE STIPULATION AND CONSENT EACH RESPONDENTUNDERTAKES AND AGREES TO INFORM THE EXCHANGE IN WRITING THATIT HAS COMPLETED ITS REVIEW AND THAT IT HAS SYSTEMS ANDPROCEDURES IN PLACE REASONABLY DESIGNED TO ENSURECOMPLIANCE WITH THOSE LAWS AND RULES CONCERNING THEPRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS.ENFORCEMENT SHALL HAVE THE DISCRETION, UPON A SHOWING OFGOOD CAUSE, TO EXTEND THE DEADLINE FOR COMPLIANCE WITH THEUNDERTAKING SET FORTH IN THIS PARAGRAPH.Current Status: Final1992018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENTPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 11/12/2002Docket/Case Number: HPD#: 02-227Principal Product Type: OtherOther Product Type(s):**11/12/02**CONSENTED FINDINGS: (1)VIOLATED EXCHANGE RULE 440 ANDSECTION 17(A) OF THE SECURITIES AND EXCHANGE ACT OF 1934 AND SECREGULATION 17A-4 BY FAILING TO PRESERVE FOR A PERIOD OF THREEYEARS, AND/OR PRESERVE IN AN ACCESSIBLE PLACE FOR TWO YEARS,ELECTRONIC COMMUNICATIONS RELATING TO THE BUSINESS OF THEFIRM.(2)VIOLATED EXCHANGE RULES 342 IN THAT IT FAILED TOREASONABLY SUPERVISE AND CONTROL THE ACTIVITIES OF ITSEMPLOYEES, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP ANDREVIEW TO ASSURE COMPLIANCE WITH EXCHANGE RULES AND FEDERALSECURITIES LAWS RELATING TO RETENTION OF ELECTRONICCOMMUNICATIONS. STIPULATED SANCTION: THE IMPOSITION BY THEEXCHANGE OF A CENSURE AND A FINE IN THE AMOUNT OF $1,650,000, FORTOTAL FINES OF $8,250,000 FROM ALL RESPONDENTS. THE AMOUNT TOBE PAID TO THE NYSE BY EACH RESPONDENT SHALL BE REDUCED BYAMOUNTS PAID BY EACH RESPONDENT PURSUANT TO AGREEMENTS TOPAY A CIVIL MONETARY PENALTY OF $550,000 TO THE U.S. TREASURY ANDA FINE OF $550,000 TO NASD IN RELATED PROCEEDINGS. IN ADDITION TOTHE MONETARY FINE, RESPONDENTS SHALL COMPLETE AN APPROPRIATEUNDERTAKING TO REVIEW ITS PROCEDURES REGARDING THEPRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FORCOMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND REGULATIONSAND THE RULES OF THE EXCHANGE AND NASD. WITHIN 90 DAYS OF THEEXECUTION OF THE STIPULATION AND CONSENT EACH RESPONDENTUNDERTAKES AND AGREES TO INFORM THE EXCHANGE IN WRITING THATIT HAS COMPLETED ITS REVIEW AND THAT IT HAS SYSTEMS ANDPROCEDURES IN PLACE REASONABLY DESIGNED TO ENSURECOMPLIANCE WITH THOSE LAWS AND RULES CONCERNING THEPRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS.ENFORCEMENT SHALL HAVE THE DISCRETION, UPON A SHOWING OFGOOD CAUSE, TO EXTEND THE DEADLINE FOR COMPLIANCE WITH THEUNDERTAKING SET FORTH IN THIS PARAGRAPH.Resolution Date: 12/13/2002Resolution:Other Sanctions Ordered: CONSENT TO CENSURE,$1,650,000 FINE (REDUCED BY AMOUNTS PAIDPURSUANT TO AGREEMENTS TO PAY A CIVIL PENALTY OF $550,000 TO THEU.S. TREASURY AND A FINE OF $550,000 TO THE NASD) AND ANUNDERTAKING.Sanction Details: **11/15/02**DECISION: HPD#02-227 VIOLATED RULE 440 AND SEA 17(A) ANDSEC REG. 17A-4 BY FAILING TO PRESERVE FOR A PERIOD OF THREEYEARS, AND/OR PRESERVE IN AN ACCESSIBLE PLACE FOR TWO YEARS,ELECTRONIC COMMUNICATIONS RELATING TO THE BUSINESS OF THEFIRM AND VIOLATED EXCHANGE RULES 342 BY FAILING TO REASONABLYSUPERVISE AND CONTROL THE ACTIVITIES OF ITS EMPLOYEES TOASSURE COMPLIANCE WITH EXCHANGE RULES AND FEDERALSECURITIES LAWS RELATING TO RETENTION OF ELECTRONICCOMMUNICATIONS. - CONSENT TO CENSURE, $1,650,000 FINE (REDUCEDBY AMOUNTS PAID PURSUANT TO AGREEMENTS TO PAY A CIVIL PENALTYOF $550,000 TO THE U.S. TREASURY AND A FINE OF $550,000 TO THENASD) AND AN UNDERTAKING TO REVIEW ITS PROCEDURES REGARDINGTHE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FORCOMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND REGULATIONS,AND THE RULES OF THE EXCHANGE AND NASD. WITHIN 90 DAYS OF THEEXECUTION OF THE STIPULATION AND CONSENT EACH RESPONDENTUNDERTAKES AND AGREES TO INFORM THE EXCHANGE IN WRITING THATIT HAS COMPLETED ITS REVIEW AND THAT IT HAS SYSTEMS ANDPROCEDURES IN PLACE REASONABLY DESIGNED TO ENSURECOMPLIANCE WITH THOSE LAWS AND RULES CONCERNING THEPRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS.ENFORCEMENT SHALL HAVE THE DISCRETION, UPON A SHOWING OFGOOD CAUSE, TO EXTEND THE DEADLINE FOR COMPLIANCE WITH THEUNDERTAKING SET FORTH IN THIS PARAGRAPH.Sanctions Ordered: CensureMonetary/Fine $1,650,000.00Decision2002018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User Guidance**11/15/02**DECISION: HPD#02-227 VIOLATED RULE 440 AND SEA 17(A) ANDSEC REG. 17A-4 BY FAILING TO PRESERVE FOR A PERIOD OF THREEYEARS, AND/OR PRESERVE IN AN ACCESSIBLE PLACE FOR TWO YEARS,ELECTRONIC COMMUNICATIONS RELATING TO THE BUSINESS OF THEFIRM AND VIOLATED EXCHANGE RULES 342 BY FAILING TO REASONABLYSUPERVISE AND CONTROL THE ACTIVITIES OF ITS EMPLOYEES TOASSURE COMPLIANCE WITH EXCHANGE RULES AND FEDERALSECURITIES LAWS RELATING TO RETENTION OF ELECTRONICCOMMUNICATIONS. - CONSENT TO CENSURE, $1,650,000 FINE (REDUCEDBY AMOUNTS PAID PURSUANT TO AGREEMENTS TO PAY A CIVIL PENALTYOF $550,000 TO THE U.S. TREASURY AND A FINE OF $550,000 TO THENASD) AND AN UNDERTAKING TO REVIEW ITS PROCEDURES REGARDINGTHE PRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FORCOMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND REGULATIONS,AND THE RULES OF THE EXCHANGE AND NASD. WITHIN 90 DAYS OF THEEXECUTION OF THE STIPULATION AND CONSENT EACH RESPONDENTUNDERTAKES AND AGREES TO INFORM THE EXCHANGE IN WRITING THATIT HAS COMPLETED ITS REVIEW AND THAT IT HAS SYSTEMS ANDPROCEDURES IN PLACE REASONABLY DESIGNED TO ENSURECOMPLIANCE WITH THOSE LAWS AND RULES CONCERNING THEPRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS.ENFORCEMENT SHALL HAVE THE DISCRETION, UPON A SHOWING OFGOOD CAUSE, TO EXTEND THE DEADLINE FOR COMPLIANCE WITH THEUNDERTAKING SET FORTH IN THIS PARAGRAPH.Regulator Statement **12/13/02**THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY.CONTACT: EVELYN PENA 212-656-5211.iReporting Source: FirmInitiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENTPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CENSUREDate Initiated: 05/02/2002Docket/Case Number: HPD #02-227Principal Product Type: No ProductOther Product Type(s):Allegations: IT WAS ALLEGED THAT U.S. BANCORP PIPER JAFFRAY VIOLATED NYSERULES 440 & 342 AND SECTION 17(A) OF THE SECURITES AND EXCHANGEACT OF 1934 CONCERNING THE FAILURE TO RETAIN E-MAILCORRESPONDENCE.Current Status: FinalResolution Date: 11/22/2002Resolution:Sanctions Ordered: CensureMonetary/Fine $1,650,000.00Decision2012018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions Ordered: UNDERTAKINGSanction Details: CENSURED, FINED $1,650,000 WHICH SHALL BE REDUCED BY AMOUNTSPAID PURSUANT TO AGREEMENTS TO PAY A CIVIL MONETARY PENALTY OF$550,000 TO THE U.S. TREASURY AND A FINE OF $550,000 TO THE NYSE INRELATED PROCEEDINGS AND $550,000 TO THE NASD AND ANUNDERTAKING TO REVIEW ITS PROCEDURES REGARDING THEPRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FORCOMPLIANCE WITH FEDERAL SECURITIES LAWS AND THE RULES OF NASDAND THE EXCHANGE. PAYMENT OF $550,000 WAS PAID TO THE NYSE ON12/6/02, $550,000 TO THE NASD ON 12/6/02 AND $550,000 TO THE SEC ON12/11/02. WITHIN 90 DAYS OF ISSUANCE OF THIS ORDER, UNLESSOTHERWISE EXTENDED BY NASD FOR GOOD CUASE SHOWN,RESPONDENT UNDERTAKES AND AGREES TO INFORM THE EXCHANGE INWRITING THAT IT HAS COMPLETED ITS REVEW AND THAT IT HASESTABLISHED SYSTEMS AND PROCEDURES REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH THOSE LAWS, REGULATIONS AND RULESCONCERNING THE PREVSERVATION OF ELECTRONIC MAILCOMMUNICATIONS.Disclosure 89 of 134iReporting Source: RegulatorAllegations: **4/21/03**STIP.& CONSENT TO PENALTY FILED BY NYSE DIV. OFENFORCE.CONSENTED TO FINDINGS:WITHOUT ADMITTING OR DENYINGGUILT U.S. BANCORP PIPER JAFFRAY INC. CONSENTED TO FINDINGS BYTHE HEARING PANEL THAT THE FIRM:1.)VIOLATED NYSE RULE 476(A)(6) BYENGAGING IN CONDUCT INCONSISTENT WITH JUST & EQUITABLEPRINCIPLES OF TRADE BY:A. ENGAGING IN ACTS & PRACTICES THATCREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B. THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER ININVESTMENT BANKING TRANSACTION;C.ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES BUSINESS PROSPECTS CONTAINED EXAGGERATEDOR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS;D.MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS;E.RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS IN VIOLATION OFSECTION 17(B) OF THE SECURITIES ACT OF 1933.2.VIOLATED NYSE RULE401 BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESSPRACTICE IN THE CONDUCT OF ITS BUSINESS AFFAIRS BY:A.ENGAGING INACTS AND PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATEINFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVERRESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OF INTERESTON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESE CONFLICTS INAN ADEQUATE OR APPROPRIATE MANNER;*CONT.ON HISTORICAL FILE*Current Status: Final2022018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENTPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 04/21/2003Docket/Case Number: HPD#: 03-71Principal Product Type: OtherOther Product Type(s):**4/21/03**STIP.& CONSENT TO PENALTY FILED BY NYSE DIV. OFENFORCE.CONSENTED TO FINDINGS:WITHOUT ADMITTING OR DENYINGGUILT U.S. BANCORP PIPER JAFFRAY INC. CONSENTED TO FINDINGS BYTHE HEARING PANEL THAT THE FIRM:1.)VIOLATED NYSE RULE 476(A)(6) BYENGAGING IN CONDUCT INCONSISTENT WITH JUST & EQUITABLEPRINCIPLES OF TRADE BY:A. ENGAGING IN ACTS & PRACTICES THATCREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B. THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER ININVESTMENT BANKING TRANSACTION;C.ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES BUSINESS PROSPECTS CONTAINED EXAGGERATEDOR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES &/OR CONTAINEDOPINIONS FOR WHICH THERE WAS NO REASONABLE BASIS;D.MAKINGPAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVEDIN AN UNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS;E.RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITING TRANSACTIONSWITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS IN VIOLATION OFSECTION 17(B) OF THE SECURITIES ACT OF 1933.2.VIOLATED NYSE RULE401 BY FAILING TO ADHERE TO THE PRINCIPLES OF GOOD BUSINESSPRACTICE IN THE CONDUCT OF ITS BUSINESS AFFAIRS BY:A.ENGAGING INACTS AND PRACTICES THAT CREATED OR MAINTAINED INAPPROPRIATEINFLUENCE BY THE INVESTMENT BANKING DEPARTMENT OVERRESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OF INTERESTON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESE CONFLICTS INAN ADEQUATE OR APPROPRIATE MANNER;*CONT.ON HISTORICAL FILE*Resolution Date: 05/23/2003Resolution:Other Sanctions Ordered: CONSENT TO CENSURE, A TOTAL PAYMENT OF $32,500,000 AND ANUNDERTAKINGSanction Details: **4/22/03**DECISION 03-71 ISSUED BY NYSE HEARING PANELDECISION:VIOLATED EXCHANGE RULES 476(A)(6) AND 401 BY ENGAGINGIN ACTS THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BYTHE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS,THEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS, BY FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATEOR APPROPRIATE MANNER, BY THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION, BY ISSUING CERTAIN RESEARCHREPORTS THAT DID NOT PROVIDE A SOUND BASIS FOR EVALUATINGCOMPANIES, BY MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS FOR RESEARCH COVERAGE AND BY FAILING TO DISCLOSE ORCAUSE TO BE DISCLOSED SUCH PAYMENTS IN OFFERING DOCUMENTSOR ELSEWHERE, BY RECEIVING PAYMENTS FOR RESEARCH WITHOUTDISCLOSURE; VIOLATED EXCHANGE RULE 472 BY ISSUING CERTAINRESEARCH REPORTS THAT CONTAINED OPINIONS FOR WHICH THEREWAS NO REASONABLE BASIS AND BY MAKING PAYMENTS TO OTHERBROKER-DEALERS FOR RESEARCH, BY FAILING TO DISCLOSE OR CAUSETO BE DISCLOSED SUCH PAYMENTS IN OFFERING DOCUMENTS ORELSEWHERE, AND BY RECEIVING PAYMENTS FOR RESEARCH INCONJUNCTION WITH UNDERWRITING TRANSACTIONS WITHOUTDISCLOSING RECEIPT OF SUCH PAYMENTS; AND VIOLATED EXCHANGERULE 342 BY FAILING TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES,SYSTEMS, AND PROCEDURES FOR SUPERVISION AND CONTROL OF ITSRESEARCH AND INVESTMENT BANKING DEPARTMENTS CONSENT TOCENSURE, A TOTAL PAYMENT OF $32,500,000 AND AN UNDERTAKING.Sanctions Ordered: CensureMonetary/Fine $32,500,000.00Decision2032018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User Guidance**4/22/03**DECISION 03-71 ISSUED BY NYSE HEARING PANELDECISION:VIOLATED EXCHANGE RULES 476(A)(6) AND 401 BY ENGAGINGIN ACTS THAT CREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BYTHE INVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTS,THEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS, BY FAILING TO MANAGE THESE CONFLICTS IN AN ADEQUATEOR APPROPRIATE MANNER, BY THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION, BY ISSUING CERTAIN RESEARCHREPORTS THAT DID NOT PROVIDE A SOUND BASIS FOR EVALUATINGCOMPANIES, BY MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS FOR RESEARCH COVERAGE AND BY FAILING TO DISCLOSE ORCAUSE TO BE DISCLOSED SUCH PAYMENTS IN OFFERING DOCUMENTSOR ELSEWHERE, BY RECEIVING PAYMENTS FOR RESEARCH WITHOUTDISCLOSURE; VIOLATED EXCHANGE RULE 472 BY ISSUING CERTAINRESEARCH REPORTS THAT CONTAINED OPINIONS FOR WHICH THEREWAS NO REASONABLE BASIS AND BY MAKING PAYMENTS TO OTHERBROKER-DEALERS FOR RESEARCH, BY FAILING TO DISCLOSE OR CAUSETO BE DISCLOSED SUCH PAYMENTS IN OFFERING DOCUMENTS ORELSEWHERE, AND BY RECEIVING PAYMENTS FOR RESEARCH INCONJUNCTION WITH UNDERWRITING TRANSACTIONS WITHOUTDISCLOSING RECEIPT OF SUCH PAYMENTS; AND VIOLATED EXCHANGERULE 342 BY FAILING TO ESTABLISH AND MAINTAIN ADEQUATE POLICIES,SYSTEMS, AND PROCEDURES FOR SUPERVISION AND CONTROL OF ITSRESEARCH AND INVESTMENT BANKING DEPARTMENTS CONSENT TOCENSURE, A TOTAL PAYMENT OF $32,500,000 AND AN UNDERTAKING.Regulator Statement **5/23/03**THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY.CONTACT:EVELYN PENA 212-656-5211iReporting Source: FirmAllegations: IT WAS ALLEGED THAT U.S. BANCORP PIPER JAFFRAY VIOLATED NYSERULE 476(A)(6), NYSE RULE 401 AND NYSE RULE 472 AND NYSE RULE 342BY ENGAGING IN CONDUCT INCONSISTENT WITH JUST & EQUITABLEPRINCIPLES OF TRADE BY: A) ENGAGING IN ACTS & PRACTICES THATCREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B) THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C) ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS D) MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E) RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: Final2042018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENTPrincipal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:Date Initiated: 04/21/2003Docket/Case Number: NYSE DECISION 03-71Principal Product Type: OtherOther Product Type(s): RESEARCHIT WAS ALLEGED THAT U.S. BANCORP PIPER JAFFRAY VIOLATED NYSERULE 476(A)(6), NYSE RULE 401 AND NYSE RULE 472 AND NYSE RULE 342BY ENGAGING IN CONDUCT INCONSISTENT WITH JUST & EQUITABLEPRINCIPLES OF TRADE BY: A) ENGAGING IN ACTS & PRACTICES THATCREATED OR MAINTAINED INAPPROPRIATE INFLUENCE BY THEINVESTMENT BANKING DEPARTMENT OVER RESEARCH ANALYSTSTHEREFORE IMPOSING CONFLICTS OF INTEREST ON ITS RESEARCHANALYSTS & FAILING TO MANAGE THESE CONFLICTS IN ADEQUATE ORAPPROPRIATE MANNER; B) THREATENING TO DROP RESEARCHCOVERAGE IF THE FIRM WAS NOT SELECTED AS A LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; C) ISSUING RESEARCH REPORTSON ESPERION THERAPEUTICS INC. & TRITON NETWORK SYSTEMS THATDID NOT PROVIDE A SOUND BASIS FOR EVALUATING FACTS REGARDINGTHOSE COMPANIES & THEIR BUSINESS PROSPECTS; CONTAINEDEXAGGERATED OR UNWARRANTED CLAIMS ABOUT THOSE COMPANIES&/OR CONTAINED OPINIONS FOR WHICH THERE WAS NO REASONABLEBASIS D) MAKING PAYMENTS FOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN AN UNDERWRITING TRANSACTION WHEN THEFIRM KNEW THAT THESE PAYMENTS WERE MADE AT LEAST IN PART FORRESEARCH COVERAGE & BY FAILING TO DISCLOSE OR CAUSE TO BEDISCLOSED IN OFFERING DOCUMENTS OR ELSEWHERE THE FACT OFSUCH PAYMENTS; AND E) RECEIVING PAYMENTS FOR RESEARCH FROMOTHER BROKER-DEALERS IN CONJUNCTION WITH UNDERWRITINGTRANSACTIONS WITHOUT DISCLOSING RECEIPT OF SUCH PAYMENTS.Resolution Date: 05/23/2003Resolution:Other Sanctions Ordered: UNDERTAKINGSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED, REQUIRED TOPAY $32,500,000 AS SPECIFIED IN THE FINAL JUDGMENT ORDERED IN ARELATED ACTION FILED BY THE SEC WHICH INCLUDES A FINE OF$12,500,000, DISGORGEMENT OF $12,500,000 IN COMMISSIONS, FEES ANDOTHER MONIES AND PAYMENT OF $7,500,000 FOR THE PROCUREMENT OFINDEPENDENT RESEARCH. UPON EXECUTION OF THE STATE OFWASHINGTON DEPARTMENT OF FINANCIAL INSTITUTION SECURITIESDIVISION'S CONSENT ORDER PAYMENT OF $227,074 WAS PAID ON 4/23/03TO THE WASHINGTON STATE SECURITIES DIVISION. 10 BUSINESS DAYSFROM ENTRY OF THE FINAL JUDGMENT, A WIRE TRANSFER OF $12,500,000WILL BE SENT TO THE UNITED STATE DISTRICT COURT FOR THESOUTHERN DISTRICT OF NEW YORK.Sanctions Ordered: CensureMonetary/Fine $32,500,000.00Stipulation and ConsentDisclosure 90 of 134iReporting Source: RegulatorCurrent Status: Final2052018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 04/24/2003Docket/Case Number: CAF030020Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: SECTION 17(B) OF THE SECURITIES ACT, NASD RULES 2110, 2210(D)(1),2210(D)(1)(A), 2210(D)(2), AND 3010(A) RESPONDENT MEMBER ENGAGEDIN ACTS AND PRACTICES THAT CREATED AND/OR MAINTAINEDINAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCHANALYSTS AND THEREFORE IMPOSED CONFLICTS OF INTEREST ONRESEARCH ANALYSTS AND FAILED TO MANAGE THESE CONFLICTS IN ANADEQUATE AND APPROPRIATE MANNER; ISSUED RESEARCH REPORTS ONIPOS THAT WERE NOT BASED ON PRINCIPLES OF FAIR DEALING ANDGOOD FAITH AND DID NOT PROVIDE A SOUND BASIS FOR EVALUATINGFACTS, CONTAINED EXAGGERATED OR UNWARRANTED CLAIMS ABOUTTHESE COMPANIES, AND/OR CONTAINED OPINIONS FOR WHICH THEREWAS NO REASONABLE BASIS; INAPPROPRIATELY THREATENEDEXECUTIVES OF A POTENTIAL INVESTMENT BANKING CLIENT BY STATINGTHAT THE FIRM WOULD DROP RESEARCH COVERAGE OF THE COMPANYIF THE FIRM WAS NOT SELECTED AS THE LEAD MANAGER IN ANINVESTMENT BANKING TRANSACTION; RECEIVED COMPENSATION,DIRECTLY OR INDIRECTLY, FROM AN ISSUER, UNDERWRITER, OR DEALER,IN PART, FOR ISSUING RESEARCH REPORTS WITHOUT FULLY DISCLOSINGTHE RECEIPT OR THE AMOUNT OF THE COMPENSATION; MADE PAYMENTSFOR RESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE, AT LEAST IN PART, FOR RESEARCH COVERAGEAND FAILED TO DISCLOSE, OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; AND FAILEDTO ESTABLISH AND MAINTAIN ADEQUATE PROCEDURES TO PROTECTRESEARCH ANALYSTS FROM CONFLICTS OF INTEREST, FAILED TOIMPLEMENT A SYSTEM TO DETECT AND INSULATE ITS RESEARCHANALYSTS FROM IMPROPER INFLUENCE AND PRESSURE BY INVESTMENTBANKING PERSONNEL AND, INSTEAD, MOTIVATED RESEARCH ANALYSTSTO ISSUE RESEARCH THAT WOULD ATTRACT AND RETAIN INVESTMENTBANKING BUSINESS.Current Status: FinalResolution: Acceptance, Waiver & Consent(AWC)2062018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceResolution Date: 04/24/2003Resolution:Other Sanctions Ordered: PAYMENT OF $7,500,000 FOR THE PROCUREMENT OF INDEPENDENTRESEARCHSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFREY INC. CONSENTED TO THE DESCRIBED SANCTIONS AND TOTHE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED,REQUIRED TO PAY $32,500,000 AS SPECIFIED IN THE FINAL JUDGMENTORDERED IN A RELATED ACTION FILED BY THE SEC WHICH INCLUDES AFINE OF $12,500,000, DISGORGEMENT OF $12,500,000 IN COMMISSIONS,FEES AND OTHER MONIES, AND PAYMENT OF $7,500,000 FOR THEPROCUREMENT OF INDEPENDENT RESEARCH. THE MONETARYSANCTIONS IMPOSED BY NASD SHALL BE REDUCED BY THE AMOUNTSPAID BY RESPONDENT PURSUANT TO THE FINAL JUDGMENT.Regulator Statement RESPONDENT AGREES THAT IT SHALL NOT SEEK OR ACCEPT, DIRECTLYOR INDIRECTLY, REIMBURSEMENT OR INDEMNIFICATION, INCLUDING BUTNOT LIMITED TO PAYMENT MADE PURSUANT TO ANY INSURANCE POLICY,WITH REGARD TO ANY FINE/PENALTY AMOUNTS THAT RESPONDENTSHALL PAY PURSUANT TO SECTION II OF THE FINAL JUDGMENT,REGARDLESS OF WHETHER SUCH FINE/PENALTY AMOUNTS OR ANY PARTTHEREOF ARE ADDED TO THE DISTRIBUTION FUND ACCOUNT OROTHERWISE USED FOR THE BENEFIT OF INVESTORS. RESPONDENTFURTHER AGREES THAT IT SHALL NOT CLAIM, ASSET, OR APPLY FOR A TAXDEDUCTION OR TAX CREDIT WITH REGARD TO ANY FEDERAL, STATE, ORLOCAL TAX FOR ANY FINE/PENALTY AMOUNTS THAT RESPONDENT SHALLPAY PURSUANT TO SECTION II OF THE FINAL JUDGMENT, REGARDLESS OFWHETHER SUCH FINE/PENALTY AMOUNTS OR ANY PART THEREOF AREADDED TO THE DISTRIBUTION FUND ACCOUNT OR OTHERWISE USED FORTHE BENEFIT OF INVESTORS. RESPONDENT UNDERSTANDS ANDACKNOWLEDGES THAT THESE PROVISIONS ARE NOT INTENDED TO IMPLYTHAT NASD WOULD AGREE THAT ANY OTHER AMOUNTS RESPONDENTSHALL PAY PURSUANT TO THE FINAL JUDGMENT MAY BE REIMBURSED ORINDEMNIFIED (WHETHER PURSUANT TO AN INSURANCE POLICY OROTHERWISE) UNDER APPLICABLE LAW OR MAY BE THE BASIS FOR ANYTAX DEDUCTION OR TAX CREDIT WITH REGARD TO ANY FEDERAL, STATE,OR LOCAL TAX.Sanctions Ordered: CensureMonetary/Fine $12,500,000.00Disgorgement/RestitutionAcceptance, Waiver & Consent(AWC)iReporting Source: Firm2072018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:Date Initiated: 04/24/2003Docket/Case Number: CAF030020Principal Product Type: OtherOther Product Type(s): RESEARCHAllegations: IT WAS ALLEGED THAT U.S. BANCORP PIPER JAFFRAY VIOLATED SECTION17(B) OF THE SECURITIES EXCHANGE ACT, NASD RULES 2110, 2210(D)(1),2210(D)(1)(A), 2210(D)(2) AND 3010(A) BY ENGAGING IN CONDUCTINCONSISTENT WITH JUST & EQUITABLE PRINCIPLES OF TRADE BY:A.)ENGAGING IN ACTS & PRACTICES THAT CREATED OR MAINTAINEDINAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENTOVER RESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OFINTEREST ON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESECONFLICTS IN ADEQUATE OR APPROPRIATE MANNER; B) THREATENINGTO DROP RESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS ALEAD MANAGER IN AN INVESTMENT BANKING TRANSACTION; C) ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS D) MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERSIN CONJUNCTION WITH UNDERWRITING TRANSACTIONS WITHOUTDISCLOSING RECEIPT OF SUCH PAYMENTS.Current Status: FinalResolution Date: 04/24/2003Resolution:Sanctions Ordered: CensureMonetary/Fine $12,500,000.00Disgorgement/RestitutionAcceptance, Waiver & Consent(AWC)2082018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions Ordered: PAYMENT OF $7,500,000 FOR THE PROCUREMENT OF INDEPENDENTRESEARCHSanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED, REQUIRED TOPAY $32,500,000 AS SPECIFIED IN THE FINAL JUDGMENT ORDERED IN ARELATED ACTION FILED BY THE SEC WHICH INCLUDES A FINE OF$12,500,000, DISGORGEMENT OF $12,500,000 IN COMMISSIONS, FEES ANDOTHER MONIES, AND PAYMENT OF $7,500,000 FOR THE PROCUREMENT OFINDEPENDENT RESEARCH. THE MONETARY SANCTIONS IMPOSED BYNASD SHALL BE REDUCED BY THE AMOUNTS PAID BY PIPER PURSUANTTO FINAL JUDGMENT. UPON EXECUTION OF THE STATE OF WASHINGTONDEPARTMENT OF FINANCIAL INSTITUTION SECURITIES DIVISION'SCONSENT ORDER, PAYMENT OF $227,074 WAS PAID ON 4/23/03 TOWASHINGTON STATE SECURITIES DIVISION. 10 BUSINESS DAYS FROMENTRY OF THE FINAL JUDGMENT, A WIRE TRANSFER OF $12,500,000 WILLBE SENT TO THE UNITED STATES DISTRICT COURT FOR THE SOUTHERNDISTRICT OF NEW YORK.CensureMonetary/Fine $12,500,000.00Disgorgement/RestitutionDisclosure 91 of 134iReporting Source: RegulatorAllegations: NASD CONDUCT RULE 3320, NASD MARKETPLACE RULE 4613(B), 4613(E),4613(E)(1)(C), AND SEC RULE 11AC1-1 - RESPONDENT MEMBER ("FIRM"), AMARKET MAKER IN SECURITIES, WITHOUT MAKING REASONABLEEFFORTS TO AVOID A LOCKED OR CROSSED MARKET BY EXECUTINGTRANSACTIONS WITH ALL MARKET MAKERS WHOSE QUOTATIONS WOULDBE LOCKED OR CROSSED, ENTERED BID OR ASKED QUOTATIONS IN THENASDAQ STOCK MARKET, WHICH CAUSED A LOCKED OR CROSSEDMARKET CONDITION TO OCCUR IN EACH INSTANCE. IN ADDITION, THEFIRM AS A MARKET MAKER IN SECURITIES, WAS A PARTY TO A LOCKED ORCROSSED MARKET CONDITION PRIOR TO THE MARKET OPENING ANDRECEIVED A TRADE-OR-MOVE MESSAGE IN EACH INSTANCE THROUGHSELECTNET AND WITHIN 30 SECONDS OF RECEIVING SUCH MESSAGES,FAILED TO FILL THE INCOMING TRADE-OR-MOVE MESSAGE FOR THE FULLSIZE OF THE MESSAGE OR MOVE ITS BID DOWN (OFFER UP) BY AQUOTATION INCREMENT THAT WOULD HAVE UNLOCKED/UNCROSSED THEMARKET. FURTHERMORE, THE FIRM WAS A MARKET MAKER INSECURITIES, AND AN ORDER WAS PRESENTED TO THE FIRM AT THEFIRM'S PUBLISHED BID OR PUBLISHED OFFER IN AN AMOUNT UP TO ITSPUBLISHED QUOTATION SIZE. THE FIRM FAILED TO EXECUTE THE ORDERSUPON PRESENTMENT AND THEREBY FAILED TO HONOR ITS PUBLISHEDQUOTATION.Current Status: Final2092018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 03/27/2003Docket/Case Number: CMS030070Principal Product Type: OtherOther Product Type(s): UNKOWN TYPE OF SECURITIESNASD CONDUCT RULE 3320, NASD MARKETPLACE RULE 4613(B), 4613(E),4613(E)(1)(C), AND SEC RULE 11AC1-1 - RESPONDENT MEMBER ("FIRM"), AMARKET MAKER IN SECURITIES, WITHOUT MAKING REASONABLEEFFORTS TO AVOID A LOCKED OR CROSSED MARKET BY EXECUTINGTRANSACTIONS WITH ALL MARKET MAKERS WHOSE QUOTATIONS WOULDBE LOCKED OR CROSSED, ENTERED BID OR ASKED QUOTATIONS IN THENASDAQ STOCK MARKET, WHICH CAUSED A LOCKED OR CROSSEDMARKET CONDITION TO OCCUR IN EACH INSTANCE. IN ADDITION, THEFIRM AS A MARKET MAKER IN SECURITIES, WAS A PARTY TO A LOCKED ORCROSSED MARKET CONDITION PRIOR TO THE MARKET OPENING ANDRECEIVED A TRADE-OR-MOVE MESSAGE IN EACH INSTANCE THROUGHSELECTNET AND WITHIN 30 SECONDS OF RECEIVING SUCH MESSAGES,FAILED TO FILL THE INCOMING TRADE-OR-MOVE MESSAGE FOR THE FULLSIZE OF THE MESSAGE OR MOVE ITS BID DOWN (OFFER UP) BY AQUOTATION INCREMENT THAT WOULD HAVE UNLOCKED/UNCROSSED THEMARKET. FURTHERMORE, THE FIRM WAS A MARKET MAKER INSECURITIES, AND AN ORDER WAS PRESENTED TO THE FIRM AT THEFIRM'S PUBLISHED BID OR PUBLISHED OFFER IN AN AMOUNT UP TO ITSPUBLISHED QUOTATION SIZE. THE FIRM FAILED TO EXECUTE THE ORDERSUPON PRESENTMENT AND THEREBY FAILED TO HONOR ITS PUBLISHEDQUOTATION.Resolution Date: 03/27/2003Resolution:Other Sanctions Ordered:Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENT FIRMCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $40,000.Sanctions Ordered: CensureMonetary/Fine $40,000.00Acceptance, Waiver & Consent(AWC)iReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC., DEPARTMENT OFMARKET REGULATIONPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Date Initiated: 12/23/2002Docket/Case Number: CMS030070Principal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGED VIOLATIONS OF NASD MARKETPLACE RULE 4613(E), NASDMARKETPLACE RULE 4613(E)(1)(C), SEC RULE 11AC1-1, NASD CONDUCTRULE 3320 AND NASD MARKETPLACE RULE 4613(B).Current Status: Final2102018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanction(s)/ReliefSought:Resolution Date: 03/27/2003Resolution:Other Sanctions Ordered:Sanction Details: $40,000 FINE ($15,000 FOR LOCKED-CROSSED MARKET VIOLATIONS,$20,000 FOR TRADE-OR-MOVE VIOLATIONS, AND $5,000 FOR FIRM QUOTEVIOLATIONS. CHECK FOR $40,000 WAS SENT TO THE NASD ON FEBRUARY28, 2003.Sanctions Ordered: CensureMonetary/Fine $40,000.00Acceptance, Waiver & Consent(AWC)Disclosure 92 of 134iReporting Source: RegulatorInitiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSIONPrincipal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:CIVIL PENALTIES, CENSURE, UNDERTAKINGDate Initiated: 12/03/2002Docket/Case Number: FILE NO. 3-10957Principal Product Type: No ProductOther Product Type(s):Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE 34-46937, DECEMBER 3,2002; THIS ACTION CONCERNS RESPONDENTS' VIOLATIONS OF THERECORD-KEEPING REQUIREMENTS OF SECTION 17(A) OF THE EXCHANGEACT AND RULE 17A-4 THEREUNDER DURING THE PERIOD FROM 1999 TOAT LEAST 2001 (THE "RELEVANT PERIOD"). DURING ALL OR PART OF THERELEVANT PERIOD, RESPONDENT FAILED TO PRESERVE FOR THREEYEARS, AND/OR TO PRESERVE IN AN ACCESSIBLE PLACE FOR TWOYEARS, ELECTRONIC MAIL COMMUNICATIONS (INCLUDING INTER-OFFICEMEMORANDA AND COMMUNICATIONS) RECEIVED AND SENT BY ITSAGENTS AND EMPLOYEES THAT RELATED TO ITS BUSINESS AS A MEMBEROF AN EXCHANGE, BROKER OR DEALER. RESPONDENT LACKEDADEQUATE SYSTEMS OR PROCEDURES FOR THE PRESERVATION OFELECTRONIC MAIL COMMUNICATIONS.Current Status: Final2112018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanction(s)/ReliefSought:CIVIL PENALTIES, CENSURE, UNDERTAKINGResolution Date: 12/03/2002Resolution:Other Sanctions Ordered: UNDERTAKING: TO REVIEW ITS PROCEDURES REGARDING THEPRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FORCOMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND REGULATION,AND THE RULES OF NASD AND NEW YORK STOCK EXCHANGE.Sanction Details: RESPONDENT PURSUANT TO SECTION 21C OF THE EXCHANGE ACT,CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONSAND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACTAND RULE 17A-4 PROMULGATED THEREUNDER, CENSURED PURSUANT TOSECTION 15(B)(4) OF THE EXCHANGE ACT, AND SHALL, WITHIN TEN DAYSOF THE ENTRY OF THIS ORDER, PAY THE AMOUNT OF $1,650,000.Sanctions Ordered: CensureMonetary/Fine $1,650,000.00Cease and Desist/InjunctionOrderiReporting Source: FirmInitiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSIONPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CENSURE, UNDERTAKING & CEASE AND DESISTDate Initiated: 05/02/2002Docket/Case Number: FILE NO. 3-10957Principal Product Type: No ProductOther Product Type(s):Allegations: ALLEGES USBPJI FOR VIOLATIONS OF SEC RULE 17A-4 AND NASDCONDUCT RULES 2110 AND 3110 CONCERNING THE FAILURE TO RETAIN E-MAIL CORRESPONDENCE.Current Status: FinalResolution Date: 12/03/2002Resolution:Sanctions Ordered: CensureMonetary/Fine $1,650,000.00Cease and Desist/InjunctionOrder2122018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions Ordered: UNDERTAKING: TO REVIEW ITS PROCEDURES REGARDING THEPRESERVATION OF ELECTRONIC MAIL COMMUNICATIONS FORCOMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND REGULATIONAND THE RULES OF NASD AND NEW YORK STOCK EXCHANGE.Sanction Details: PIPER JAFFRAY PURSUANT TO SECTION 21C OF THE EXCHANGE ACT,CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONSAND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE EXCHANGE ACTAND RULE 17A-4 PROMULGATED THEREUNDER, CENSURED PURSUANT TOSECTION 15(B)(4) OF THE EXCHANGE ACT, AND SHALL, WITHIN TEN DAYSOF THE ENTRY OF THIS ORDER, PAY THE AMOUNT OF $1,650,000.PAYMENT OF $550,000 WAS PAID TO THE NYSE ON 12/6/02, $550,000 WASPAID TO THE NASD ON 12/6/02 AND $550,000 WAS PAID TO THE SEC ON12/11/02.Sanctions Ordered: CensureMonetary/Fine $1,650,000.00Cease and Desist/InjunctionDisclosure 93 of 134iReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 11/22/2002Docket/Case Number: CAF020064Principal Product Type: No ProductOther Product Type(s):Allegations: SECTION 17(A) OF THE EXCHANGE ACT, RULE 17A-4 THEREUNDER, NASDRULES 3010 AND 3110 ? WITHOUT ADMITTING OR DENYING THEALLEGATIONS, RESPONDENT MEMBER CONSENTED TO THE ENTRY OFFINDINGS THAT IT FAILED TO KEEP ELECTRONIC MAIL COMMUNICATIONSFOR THREE YEARS AND/OR FAILED TO PRESERVE ELECTRONIC MAILCOMMUNICATIONS FOR THE FIRST TWO YEARS IN AN ACCESSIBLE PLACE;AND, HAD INADEQUATE SUPERVISORY SYSTEMS AND PROCEDURES THATWERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHSECTION 17(A) OF THE EXCHANGE ACT, RULE 17A-4 THEREUNDER ANDNASD RULE 3110 REGARDING PRESERVATION OF BOOKS AND RECORDS.Current Status: Final2132018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanction(s)/ReliefSought:Resolution Date: 11/22/2002Resolution:Other Sanctions Ordered: UNDERTAKINGSanction Details: CENSURED, FINED $1,650,000 WHICH SHALL BE REDUCED BY AMOUNTSPAID PURSUANT TO AGREEMENTS TO PAY A CIVIL MONETARY PENALTY OF$550,000 TO THE U.S. TREASURY AND A FINE OF $550,000 TO THE NYSE INRELATED PROCEEDINGS. PAYMENTS TO NASD SHALL BE MADE WITHIN 10DAYS OF NOTICE OF ACCEPTANCE OF THIS AWC AND AN UNDERTAKINGTO REVIEW ITS PROCEDURES REGARDING THE PRESERVATION OFELECTRONIC MAIL COMMUNICATIONS FOR COMPLIANCE WITH FEDERALSECURITIES LAWS AND THE RULES OF NASD AND THE EXCHANGE. WITHIN90 DAYS OF ISSUANCE OF THIS ORDER, UNLESS OTHERWISE EXTENDEDBY NASD FOR GOOD CAUSE SHOWN, RESPONDENT UNDERTAKES ANDAGREES TO INFORM NASD IN WRITING THAT IT HAS COMPLETED ITSREVIEW AND THAT IT HAS ESTABLISHED SYSTEMS AND PROCEDURESREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THOSE LAWS,REGULATIONS, AND RULES CONCERNING THE PRESERVATION OFELECTRONIC MAIL COMMUNICATIONS.Sanctions Ordered: CensureMonetary/Fine $1,650,000.00Acceptance, Waiver & Consent(AWC)iReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CENSUREDate Initiated: 05/02/2002Docket/Case Number: CAF020064Principal Product Type: No ProductOther Product Type(s):Allegations: ALLEGES USBPJI FOR VIOLATIONS OF SEC RULE 17A-4 AND NASDCONDUCT RULES 2110 AND 3110 CONCERNING THE FAILURE TO RETAIN E-MAIL CORRESPONDENCE.Current Status: Final2142018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanction(s)/ReliefSought:CENSUREResolution Date: 11/22/2002Resolution:Other Sanctions Ordered: UNDERTAKINGSanction Details: CENSURED, FINED $1,650,000 WHICH SHALL BE REDUCED BY AMOUNTSPAID PURSUANT TO AGREEMENTS TO PAY A CIVIL MONETARY PENALTY OF$550,000 TO THE U.S. TREASURY AND A FINE OF $550,000 TO THE NYSE INRELATED PROCEEDINGS. PAYMENTS TO NASD SHALL BE MADE WITHIN 10DAYS OF NOTICE OF ACCEPTANCE OF THIS AWC AND AN UNDERTAKINGTO REVIEW ITS PROCEDURES REGARDING THE PRESERVATION OFELECTRONIC MAIL COMMUNICATIONS FOR COMPLIANCE WITH FEDERALSECURITIES LAWS AND THE RULES OF NASD AND THE EXCHANGE.PAYMENT OF $550,000 WAS PAID TO THE NYSE ON 12/6/02, $550,000 TOTHE NASD ON 12/6/02 AND $550,000 TO THE SEC ON 12/11/02. WITHIN 90DAYS OF ISSUANCE OF THIS ORDER, UNLESS OTHERWISE EXTENDED BYNASD FOR GOOD CAUSE SHOWN, RESPONDENT UNDERTAKES ANDAGREES TO INFORM NASD IN WRITING THAT IT HAS COMPLETED ITSREVIEW AND THAT IT HAS ESTABLISHED SYSTEMS AND PROCEDURESREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THOSE LAWS,REGULATIONS, AND RULES CONCERNING THE PRESERVATION OFELECTRONIC MAIL COMMUNICATIONS.Sanctions Ordered: CensureMonetary/Fine $1,650,000.00Acceptance, Waiver & Consent(AWC)Disclosure 94 of 134iReporting Source: FirmInitiated By: NASD REGULATION, INC.Principal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 05/30/2001Docket/Case Number: AWAC CMS020154 MRVPrincipal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGES VIOLATIONS OF NASD RULE 4632(A)(9)Current Status: Final2152018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanction(s)/ReliefSought:Resolution Date: 09/04/2002Resolution:Other Sanctions Ordered:Sanction Details: CHECK IN THE AMOUNT OF $2500 WAS MAILED TO THE NASD ON 9/25/02.Sanctions Ordered: Monetary/Fine $2,500.00Acceptance, Waiver & Consent(AWC)Disclosure 95 of 134iReporting Source: RegulatorInitiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSIONPrincipal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:Date Initiated: 11/05/2002Docket/Case Number: FILE NO. 3-10926Principal Product Type: No ProductOther Product Type(s):Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE NO. 34-46770, DATEDNOVEMBER 5, 2002: THE SECURITIES AND EXCHANGE COMMISSION("COMMISSION" OR "SEC") DEEMS IT APPROPRIATE AND IN THE PUBLICINTEREST THAT PUBLIC ADMINISTRATIVE PROCEEDINGS BE, AND HEREBYARE, INSTITUTED PURSUANT TO SECTION 15(B) OF THE SECURITIESEXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST U.S. BANCORPPIPER JAFFRAY INC. ("PIPER JAFFRAY").Current Status: FinalResolution Date: 11/05/2002Resolution:Other Sanctions Ordered: UNDERTAKINGS.Sanction Details: IT IS ORDERED THAT: A. PIPER JAFFRAY BE, AND HEREBY IS, CENSUREDPURSUANT TO SECTION 15(B)(4) OF THE EXCHANGE ACT.B. PIPER JAFFRAY SHALL, WITHIN 30 DAYS OF THE ENTRY OF THE ORDER,PAY A CIVIL MONEY PENALTY OF $100,000 TO THE UNITED STATESTREASURY. C. PIPER JAFFRAY SHALL COMPLY WITH ITS UNDERTAKINGSTO: 1. MAINTAIN THE REVISED PROCEDURES, AS DESCRIBED ABOVE, THATIT IMPLEMENTED TO MONITOR END OF THE DAY TRADES THROUGHREVIEW OF THE MARKING THE CLOSE EXCEPTION REPORT. 2. MAINTAINTHE DISTRICT SALES SUPERVISOR POSITION. THE DISTRICT SALESSUPERVISORS WILL REPLACE THE BOMAS FOR SUPERVISING "PRODUCING" BRANCH MANAGERS. PIPER JAFFRAY WILL EMPLOY ATLEAST EIGHT INDIVIDUALS AS DISTRICT SALES SUPERVISORS. THEDISTRICT SALES SUPERVISORS WILL BE RESPONSIBLE FOR "PRODUCING"BRANCH MANAGER SUPERVISION IN DEFINED GEOGRAPHIC AREAS. D.WITH RESPECT TO THE UNDERTAKINGS REFERRED TO IN SECTION IV.C.,NOTHING HEREIN WILL PREVENT RESPONDENT FROM ADOPTINGADDITIONAL POLICIES AND PROCEDURES OR IMPROVING UPON THEPOLICIES AND PROCEDURES ADOPTED PURSUANT TO THEUNDERTAKINGS.Sanctions Ordered: CensureMonetary/Fine $100,000.00Order2162018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceSanction Details: IT IS ORDERED THAT: A. PIPER JAFFRAY BE, AND HEREBY IS, CENSUREDPURSUANT TO SECTION 15(B)(4) OF THE EXCHANGE ACT.B. PIPER JAFFRAY SHALL, WITHIN 30 DAYS OF THE ENTRY OF THE ORDER,PAY A CIVIL MONEY PENALTY OF $100,000 TO THE UNITED STATESTREASURY. C. PIPER JAFFRAY SHALL COMPLY WITH ITS UNDERTAKINGSTO: 1. MAINTAIN THE REVISED PROCEDURES, AS DESCRIBED ABOVE, THATIT IMPLEMENTED TO MONITOR END OF THE DAY TRADES THROUGHREVIEW OF THE MARKING THE CLOSE EXCEPTION REPORT. 2. MAINTAINTHE DISTRICT SALES SUPERVISOR POSITION. THE DISTRICT SALESSUPERVISORS WILL REPLACE THE BOMAS FOR SUPERVISING "PRODUCING" BRANCH MANAGERS. PIPER JAFFRAY WILL EMPLOY ATLEAST EIGHT INDIVIDUALS AS DISTRICT SALES SUPERVISORS. THEDISTRICT SALES SUPERVISORS WILL BE RESPONSIBLE FOR "PRODUCING"BRANCH MANAGER SUPERVISION IN DEFINED GEOGRAPHIC AREAS. D.WITH RESPECT TO THE UNDERTAKINGS REFERRED TO IN SECTION IV.C.,NOTHING HEREIN WILL PREVENT RESPONDENT FROM ADOPTINGADDITIONAL POLICIES AND PROCEDURES OR IMPROVING UPON THEPOLICIES AND PROCEDURES ADOPTED PURSUANT TO THEUNDERTAKINGS.Regulator Statement PIPER JAFFRAY HAS SUBMITTED AN OFFER OF SETTLEMENT WITHOUTADMITTING OR DENYING THE SEC'S FINDINGS, EXCEPT AS TO THE SEC'SJURISDICTION, AND CONSENTED TO THE ENTRY OF THIS ORDER. THE SECFINDS THAT: FROM JANUARY 1998 THROUGH SEPTEMBER 2001, AREGISTERED REPRESENTATIVE ("REGISTERED REPRESENTATIVE") OFPIPER JAFFRAY'S BRANCH OFFICE AND HIS CUSTOMER ("CUSTOMER")ENGAGED IN A "MARKING THE CLOSE" SCHEME TO AFFECT THE CLOSINGPRICE OF THE COMMON STOCK OF A PUBLICLY-TRADED COMPANY.THROUGHOUT MOST OF THE RELEVANT PERIOD, THE REGISTEREDREPRESENTATIVE ALSO ACTED AS BRANCH MANAGER OF THE PIPERJAFFRAY'S OFFICE. THE REGISTERED REPRESENTATIVE AND THECUSTOMER SUCCEEDED IN THIS SCHEME BY PLACING THE DAY-ENDTRADES AT ARTIFICIALLY HIGHER PRICES IN THIS STOCK THEREBYINCREASING IMPROPERLY THE STOCK'S CLOSING PRICE. THE PURPOSEBEHIND THIS SCHEME WAS SO THE CUSTOMER WOULD SATISFY ORREDUCE THE AMOUNT OF NUMEROUS MARGIN CALLS ON HISBROKERAGE ACCOUNTS AT PIPER JAFFRAY. THE REGISTEREDREPRESENTATIVE MATERIALLY PARTICIPATED IN THIS SCHEME BYPLACING THE TRADES AND CALCULATING WITH THE CUSTOMER THEAMOUNT OF APPRECIATION NECESSARY IN THE SECURITY TO AVOIDMARGIN CALLS WITH FULL KNOWLEDGE THAT THESE TRADES WEREINTENDED TO ARTIFICIALLY INCREASE THE CLOSING PRICE OF THESTOCK. THE REGISTERED REPRESENTATIVE ALSO MARKED THE CLOSE INHIS PERSONAL BROKERAGE ACCOUNT TO FURTHER THIS SCHEME.BASED ON THE FOREGOING, PIPER JAFFRAY FAILED REASONABLY TOSUPERVISE ITS REGISTERED REPRESENTATIVE IN THIS REGARD ANDFAILED TO HAVE ADEQUATE SYSTEMS IN PLACE TO DETECT OR PREVENTTHIS MARKING THE CLOSE SCHEME. PIPER JAFFRAY FAILED REASONABLYTO SUPERVISE A REGISTERED REPRESENTATIVE SUBJECT TO ITSSUPERVISION, WITH A VIEW TO PREVENTING VIOLATIONS OF SECTION10(B) OF THE EXCHANGE ACT AND RULES 10B-5 THEREUNDER, WITHINTHE MEANING OF SECTION 15(B) OF THE EXCHANGE ACT.2172018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePIPER JAFFRAY HAS SUBMITTED AN OFFER OF SETTLEMENT WITHOUTADMITTING OR DENYING THE SEC'S FINDINGS, EXCEPT AS TO THE SEC'SJURISDICTION, AND CONSENTED TO THE ENTRY OF THIS ORDER. THE SECFINDS THAT: FROM JANUARY 1998 THROUGH SEPTEMBER 2001, AREGISTERED REPRESENTATIVE ("REGISTERED REPRESENTATIVE") OFPIPER JAFFRAY'S BRANCH OFFICE AND HIS CUSTOMER ("CUSTOMER")ENGAGED IN A "MARKING THE CLOSE" SCHEME TO AFFECT THE CLOSINGPRICE OF THE COMMON STOCK OF A PUBLICLY-TRADED COMPANY.THROUGHOUT MOST OF THE RELEVANT PERIOD, THE REGISTEREDREPRESENTATIVE ALSO ACTED AS BRANCH MANAGER OF THE PIPERJAFFRAY'S OFFICE. THE REGISTERED REPRESENTATIVE AND THECUSTOMER SUCCEEDED IN THIS SCHEME BY PLACING THE DAY-ENDTRADES AT ARTIFICIALLY HIGHER PRICES IN THIS STOCK THEREBYINCREASING IMPROPERLY THE STOCK'S CLOSING PRICE. THE PURPOSEBEHIND THIS SCHEME WAS SO THE CUSTOMER WOULD SATISFY ORREDUCE THE AMOUNT OF NUMEROUS MARGIN CALLS ON HISBROKERAGE ACCOUNTS AT PIPER JAFFRAY. THE REGISTEREDREPRESENTATIVE MATERIALLY PARTICIPATED IN THIS SCHEME BYPLACING THE TRADES AND CALCULATING WITH THE CUSTOMER THEAMOUNT OF APPRECIATION NECESSARY IN THE SECURITY TO AVOIDMARGIN CALLS WITH FULL KNOWLEDGE THAT THESE TRADES WEREINTENDED TO ARTIFICIALLY INCREASE THE CLOSING PRICE OF THESTOCK. THE REGISTERED REPRESENTATIVE ALSO MARKED THE CLOSE INHIS PERSONAL BROKERAGE ACCOUNT TO FURTHER THIS SCHEME.BASED ON THE FOREGOING, PIPER JAFFRAY FAILED REASONABLY TOSUPERVISE ITS REGISTERED REPRESENTATIVE IN THIS REGARD ANDFAILED TO HAVE ADEQUATE SYSTEMS IN PLACE TO DETECT OR PREVENTTHIS MARKING THE CLOSE SCHEME. PIPER JAFFRAY FAILED REASONABLYTO SUPERVISE A REGISTERED REPRESENTATIVE SUBJECT TO ITSSUPERVISION, WITH A VIEW TO PREVENTING VIOLATIONS OF SECTION10(B) OF THE EXCHANGE ACT AND RULES 10B-5 THEREUNDER, WITHINTHE MEANING OF SECTION 15(B) OF THE EXCHANGE ACT.iReporting Source: FirmInitiated By: SECURITIES & EXCHANGE COMMISSIONPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CENSURE, UNDERTAKINGSDate Initiated: 04/30/2002Docket/Case Number: FILE NO. 3-10926Principal Product Type: No ProductOther Product Type(s):Allegations: ALLEGES USBPJI FAILED TO REASONABLY SUPERVISE THOMAS HALLWITHIN THE MEAING OF SECTION 15(B) OF THE SECURITIES EXCHANGEACT OF 1934.Current Status: FinalResolution Date: 11/05/2002Resolution:Other Sanctions Ordered: UNDERTAKINGSSanction Details: A. PIPER JAFFRAY IS CENSURED PURSUANT TO SECTION 15(B)(4) OF THEEXCHANGE ACT. B. PIPER JAFFRAY PAID A CIVIL MONEY PENALTY OF$100,000 ON DECEMBER 2, 2002. PIPER JAFFRAY SHALL COMPLY WITH ITSUNDERTAKINGS TO: 1. MAINTAIN THE REVISED PROCEDURES, THAT ITIMPLEMENTED TO MONITOR END OF THE DAY TRADES THROUGH REVIEWOF THE MARKING THE CLOSE EXCEPTION REPORT. 2. MAINTAIN THEDISTRICT SALES SUPERVISOR POSITION. THE DISTRICT SALESSUPERVISORS WILL REPLACE THE BOMAS FOR SUPERVISING "PRODUCING" BRANCH MANAGERS. PIPER JAFFRAY WILL EMPLOY ATLEAST EIGHT INDIVIDUALS AS DISTRICT SALES SUPERVISORS. THEDISTRICT SALES SUPERVISORS WILL BE RESPONSIBLE FOR "PRODUCING"BRANCH MANAGER SUPERVISION IN DEFINED GEOGRAPHIC AREAS. D.WITH RESPECT TO THE UNDERTAKINGS REFERRED TO IN SECTION IV.C.,NOTHING HEREIN WILL PREVENT PIPER JAFFRAY FROM ADOPTINGADDITIONAL POLICIES AND PROCEDURES OR IMPROVING UPON POLICIESAND PROCEDURES ADOPTED PURSUANT TO THE UNDERTAKINGS.Sanctions Ordered: CensureMonetary/Fine $100,000.00Order2182018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceA. PIPER JAFFRAY IS CENSURED PURSUANT TO SECTION 15(B)(4) OF THEEXCHANGE ACT. B. PIPER JAFFRAY PAID A CIVIL MONEY PENALTY OF$100,000 ON DECEMBER 2, 2002. PIPER JAFFRAY SHALL COMPLY WITH ITSUNDERTAKINGS TO: 1. MAINTAIN THE REVISED PROCEDURES, THAT ITIMPLEMENTED TO MONITOR END OF THE DAY TRADES THROUGH REVIEWOF THE MARKING THE CLOSE EXCEPTION REPORT. 2. MAINTAIN THEDISTRICT SALES SUPERVISOR POSITION. THE DISTRICT SALESSUPERVISORS WILL REPLACE THE BOMAS FOR SUPERVISING "PRODUCING" BRANCH MANAGERS. PIPER JAFFRAY WILL EMPLOY ATLEAST EIGHT INDIVIDUALS AS DISTRICT SALES SUPERVISORS. THEDISTRICT SALES SUPERVISORS WILL BE RESPONSIBLE FOR "PRODUCING"BRANCH MANAGER SUPERVISION IN DEFINED GEOGRAPHIC AREAS. D.WITH RESPECT TO THE UNDERTAKINGS REFERRED TO IN SECTION IV.C.,NOTHING HEREIN WILL PREVENT PIPER JAFFRAY FROM ADOPTINGADDITIONAL POLICIES AND PROCEDURES OR IMPROVING UPON POLICIESAND PROCEDURES ADOPTED PURSUANT TO THE UNDERTAKINGS.Firm Statement PIPER JAFFRAY HAS SUBMITTED AN OFFER OF SETTLEMENT WITHOUTADMITTING OR DENYING THE SEC'S FINDINGS, EXCEPT AS TO THE SEC'SJURISDICTION, AND CONSENTED TO THE ENTRY OF THIS ORDER.Disclosure 96 of 134iReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 06/25/2002Docket/Case Number: CAF020020Principal Product Type: OtherOther Product Type(s): COMMON STOCKAllegations: NASD RULE 2110 - WITHOUT ADMITTING OR DENYING THE ALLEGATIONS,THE RESPONDENT MEMBER CONSENTED TO THE ENTRY OF FINDINGSTHAT IT INAPPROPRIATELY THREATENED TO DROP RESEARCH COVERAGEAND TO STOP MAKING A MARKET IN A STOCK IF THE FIRM WAS NOTSELECTED AS LEAD UNDERWRITER FOR A SECONDARY OFFERING. THESETHREATS WERE MADE IN AN ATTEMPT TO FORCE THE ISSUER TO ENGAGEIN BUSINESS ON TERMS FAVORABLE TO THE FIRM BUT WERE NOTWANTED BY THE ISSUER.Current Status: FinalResolution Date: 06/25/2002Resolution:Other Sanctions Ordered:Sanction Details: CENSURED AND FINED $250,000Sanctions Ordered: CensureMonetary/Fine $250,000.00Acceptance, Waiver & Consent(AWC)2192018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceSanction Details: CENSURED AND FINED $250,000iReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:FINEDate Initiated: 05/01/2002Docket/Case Number: CAF020020Principal Product Type: OtherOther Product Type(s): COMMON STOCKAllegations: ALLEGES VIOLATION OF NASD CONDUCT RULE 2110.Current Status: FinalResolution Date: 06/25/2002Resolution:Other Sanctions Ordered:Sanction Details: A CHECK IN THE AMOUNT OF $250,000 WAS SENT TO THE NASD ON 7/9/02.Firm Statement SEE ABOVESanctions Ordered: CensureMonetary/Fine $250,000.00Acceptance, Waiver & Consent(AWC)Disclosure 97 of 134iReporting Source: FirmInitiated By: STATE OF NEBRASKADate Initiated: 03/14/2002Docket/Case Number: UNKNOWNAllegations: STATE OF NEBRASKA ALLEGES THAT U.S. BANCORP PIPER JAFFRAY(USBPJI) FAILED TO REASONABLY SUPERVISE EMPLOYEES TO PREVENTTHE INADVERTANT TRANSFER OF SECURITIES IN 1991 WITHOUT ACLIENT'S AUTHORIZATION.Current Status: Final2202018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Principal Product Type: Equity - OTCOther Product Type(s):Resolution Date: 05/20/2002Resolution:Other Sanctions Ordered:Sanction Details: THE FINE OF $5,000 WAS PAID ON 5/30/02.Sanctions Ordered: Monetary/Fine $5,000.00ConsentDisclosure 98 of 134iReporting Source: RegulatorInitiated By: MONTANA STATE AUDITOR, COMMISSIONER OF SECURITIESPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:SUSPENSION AND/OR REVOCATION, RESTITUTION, REASONABLEATTORNEYS FEES AND COSTS, REIMBURSEMENT FOR COST OFEXAMINATIONDate Initiated: 02/06/2002Docket/Case Number: I 02-05-01-075URL for Regulatory Action:Principal Product Type: Equity Listed (Common & Preferred Stock)Other Product Type(s): MUTUAL FUNDSAllegations: UNETHICAL BUSINESS PRACTICES; FAILURE TO REASONABLY SUPERVISE;FRAUDULENT SECURITIES TRANSACTIONSCurrent Status: FinalResolution Date: 10/27/2003Resolution:Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?YesSettled2212018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions Ordered: TO CREATE A RESTITUTION AND INVESTOR PROTECTION FUND IN THEAMOUNT OF $1,500,000.00. TO PAY $125,000.00 FOR REIMBURSEMENT OFINVESTIGATION AND LITIGATION COSTS OF THE ACTION. TO IMPLEMENTPROCEDURES THAT MODIFY THE PAYMENT OF PRODUCTION AWARDS TOREGISTERED REPRESENTATIVES WHO ARE THE SUBJECT OF ANAGREEMENT FOR SPECIAL SUPERVISION BY ANY REGULATOR OR PIPER;TO EXCLUDE FROM CALCULATION OF PRODUCTION AWARDS ANYPRODUCTION BY A REGISTERED REPRESENTATIVE FROM ANY PERIOD OFSPECIAL SUPERVISION; TO EXCLUDE FROM PRODUCTION AWARDS ANYREGISTERED REPRESENTATIVE WHO IS SUBJECT OF ANY SUSPENSION,CENSURE OR FINE RESULTING FROM A FINAL ORDER OF A STATESECURITIES COMMISSIONER OR SRO CONSENTED TO BY THEREGISTERED REPRESENTATIVE FOR A PERIOD OF TWO YEARS FROM THEDATE OF SUCH ADMINISTRATIVE SANCTION. TO REQUIRE ANY PERSONWHO SUPERVISES SALESPERSONS IN MONTANA TO BE APPROPRIATELYREGISTERED WITH THE MONTANA SECURITIES DEPARTMENT.Sanction Details: SEE ABOVE.Regulator Statement DURING THE PERIOD JANUARY 1, 1997 THROUGH MARCH 23, 2001,APPROXIMATELY 38 INVESTORS WERE VICTIMIZED BY US BANCORP/PIPERJAFFRAY, ITS AGENTS, OFFICERS AND EMPLOYEES, THROUGH OVER 5,000UNAUTHORIZED, UNSUITABLE AND EXCESSIVE TRADES IN THEIRINVESTMENT ACCOUNTS.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?YesSanctions Ordered: Monetary/Fine $1,000,000.00Disgorgement/RestitutioniReporting Source: FirmInitiated By: THE OFFICE OF THE AUDITOR FOR THE STATE OF MONTANADate Initiated: 03/05/2002Docket/Case Number: CASE NO. I 02-02-01-075Principal Product Type: Equity - OTCAllegations: THE COMPLAINT BY THE STATE OF MONTANA ALLEGES FAILURE TOSUPERVISE AND UNETHICAL BUSINESS PRACTICES.Current Status: Final2222018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:THE PRINCIPAL SANCTION BEING SOUGHT IS REGISTRATION REVOCATIONOR SUSPENSION; FINES AND RESTITUTIONPrincipal Product Type: Equity - OTCOther Product Type(s): MUTUAL FUNDSResolution Date: 10/27/2003Resolution:Other Sanctions Ordered: $1,500,000 INTO AN ESCROW ACCOUNT FOR RESTITUTION AND INVESTORPROTECTION FUND; $125,000 FOR REIMBURSEMENT OF GRANTS TO ANDEXPENSES TO THE STATE AUDITOR, DEPARTMENT OF SECURITIES,INCURRED IN CONNECTION WITH THE INVESTIGATION AND LITIGATION OFTHE ACTION.Sanction Details: U.S. BANCORP PIPER JAFFRAY INC. ENTERED INTO A SETTLEMENTAGREEMENT WITH THE STATE OF MONTANA. THE $1,000,000 FINE WASMAILED ON 11/18/03; THE $1,500,000 WAS WIRED ON 11/12/03; THE $125,000WAS ISSUED ON 11/19/03.Sanctions Ordered: Monetary/Fine $1,000,000.00SettledDisclosure 99 of 134iReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Date Initiated: 12/18/2001Docket/Case Number: CMS010196Allegations: NASD MARKETPLACE RULES 4632(A)(9), 6130, 6420(B), 6440(F)(2) -WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENTMEMBER CONSENTED TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT THE CORRECT PRIOR REFERENCE TIME THROUGH ACT INREPORTS OF TRANSACTIONS IN NASDAQ NATIONAL MARKET SECURITIESFOR WHICH THE EXECUTION PRICE WAS BASED ON A PRIOR REFERENCEPOINT IN TIME; FAILED TO REPORT THROUGH ACT LAST SALE REPORTSOF TRANSACTIONS IN ELIGIBLE SECURITIES; FAILED TOCONTEMPORANEOUSLY OR PARTIALLY EXECUTE CUSTOMER LIMITORDERS IN ELIGIBLE SECURITIES AFTER TRADING EACH SUCH SUBJECTSECURITY FOR ITS OWN MARKET-MAKING ACCOUNT AT A PRICE THATWOULD HAVE SATISFIED THE CUSTOMER'S LIMIT ORDER.Current Status: Final2232018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Principal Product Type: OtherOther Product Type(s): VARIOUS SECURITIESResolution Date: 12/18/2001Resolution:Other Sanctions Ordered:Sanction Details: CENSURED AND FINED $7,500Sanctions Ordered: CensureMonetary/Fine $7,500.00Acceptance, Waiver & Consent(AWC)iReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:CENSUREDate Initiated: 09/25/2001Docket/Case Number: CMS010196Principal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGES VIOLATIONS OF NASD MARKETPLACE 4632(A)(9) AND 6130;VIOLATIONS OF NASD MARKETPLACE RULE 6420(B); VIOLATIONS OF NASDMARKETPLACE RULE 6440(F)(2).Current Status: FinalResolution Date: 12/18/2001Resolution:Other Sanctions Ordered:Sanctions Ordered: CensureMonetary/Fine $7,500.00Acceptance, Waiver & Consent(AWC)2242018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceSanction Details: FINE OF $7500 WAS PAID 10/9/01Disclosure 100 of 134iReporting Source: RegulatorInitiated By: NYSE DIVISION OF ENFORCEMENTPrincipal Sanction(s)/ReliefSought:Date Initiated: 10/04/2001Docket/Case Number: HPD# 01-205Principal Product Type: OtherOther Product Type(s):Allegations: **10/04/2001**STIPULATION AND CONSENT TO PENALTY FILED BY DIVISIONOF ENFORCEMENT AND PENDING.CONSENTED TO FINDINGS:FINDINGS THAT U.S. BANCORP PIPER JAFFRAY INC. (1) VIOLATEDEXCHANGE RULE 410 BY FAILING TO MAKE AND PRESERVE REQUIREDRECORDS RELATING TO CUSTOMER ORDERS EXECUTED ON THE FLOOROF THE EXCHANGE; (2) VIOLATED EXCHANGE RULE 440 AND SEC RULES17A-3 AND 17A-4 BY FAILING TO MAKE AND PRESERVE REQUIRED ANDTIMELY RECORDS RELATING TO RECEIPT AND EXECUTION OF CUSTOMERORDERS; AND (3) VIOLATED EXCHANGE RULE 342 IN THAT THE FIRMFAILED TO REASONABLY SUPERVISE AND CONTROL THE ACTIONS OF ITSEMPLOYEES, AND FAILED TO ESTABLISH ADEQUATE CONTROLS,INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, TOASSURE COMPLIANCE WITH EXCHANGE RULES AND THE FEDERALSECURITIES LAWS WITH RESPECT TO (1) THE PROPER EXECUTION OFCUSTOMER ORDERS WITH THE ACCOUNT DESIGNATION INFORMATIONREQUIRED BY EXCHANGE RULES AND THE FEDERAL SECURITIES LAWS,AND (2) MAKING AND PRESERVING REQUIRED AND TIMELY RECORDSRELATING TO DESIGNATION AND EXECUTION OF CUSTOMERORDERS.STIPULATED SANCTION:THE IMPOSITION BY THE EXCHANGE OFTHE PENALTY OF A CENSURE, A FINE OF $200,000, AND A REQUIREMENTTO COMPLY WITH AN UNDERTAKING TO RETAIN AN OUTSIDE CONSULTANT,NOT UNACCEPTABLE TO THE EXCHANGE, TO COMPLETE A REVIEW ANDPREPARE A REPORT OF THE PROCEDURES AND SYSTEMS OF FOLLOW-UPAND REVIEW ADOPTED BY THE FIRM TO PREVENT RECURRENCE OF THEFOREGOING VIOLATIONS, INCLUDING THE TIMELY ALLOCATION OF BLOCKOR BUNCHED ORDERS; MAKE RECOMMENDATIONS FOR ADDITIONALPROCEDURES, IF NECESSARY; AND SUBMIT SUCH REPORT ANDRECOMMENDATIONS TO THE EXCHANGE WITHIN NINETY (90) DAYS FROMTHE DATE THIS DECISION BECOMES FINAL.Current Status: Final2252018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Resolution Date: 12/20/2001Resolution:Other Sanctions Ordered: CONSENT TO CENSURE, $200,000 FINE, AND AN UNDERTAKING.Sanction Details: **11/20/2001**DECISION 01-205 ISSUED BY NYSE HEARING PANELDECISION:VIOLATED EXCHANGE RULE 410 BY FAILING TO MAKE ANDPRESERVE REQUIRED RECORDS; VIOLATED RULE 440 AND SEC RULES17A-3 AND 17A-4 BY FAILING TO MAKE AND PRESERVE REQUIREDRECORDS RELATING TO CUSTOMER ORDERS; AND VIOLATED RULE 342 BYFAILING TO REASONABLY SUPERVISE AND CONTROL ITS EMPLOYEES ?CONSENT TO CENSURE, $200,000 FINE, AND AN UNDERTAKING.Regulator Statement **12/20/2001** THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY.CONTACT: PEGGY GERMINO 212-656-8450Sanctions Ordered: CensureMonetary/Fine $200,000.00DecisioniReporting Source: FirmInitiated By: NYSE DIVISION OF ENFORCEMENTDate Initiated: 10/04/2001Allegations: ALLEGES USBPJI (1) VIOLATED EXCHANGE RULE 410 BY FAILING TO MAKEAND PRESERVE REQUIRED RECORDS RELATING TO CUSTOMER ORDERSEXECUTED ON THE FLOOR OF THE EXCHANGE; (2) VIOLATED EXCHANGERULE 440 AND SEC RULES 17A-3 AND 17A-4 BY FAILING TO MAKE ANDPRESERVE REQUIRED AND TIMELY RECORDS RELATING TO RECEIPT ANDEXECUTION OF CUSTOMER ORDERS; AND (3) VIOLATED EXCHANGE RULE342 IN THAT THE FIRM FAILED TO REASONABLY SUPERVISE AND CONTROLTHE ACTIONS OF ITS EMPLOYEES AND FAILED TO ESTABLISH ADEQUATECONTROLS, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP ANDREVIEW, TO ASSURE COMPLIANCE WITH EXCHANGE RULES AND THEFEDERAL SECURITIES LAWS WITH RESPECT TO (1) THE PROPEREXECUTION OF CUSTOMER ORDERS WITH THE ACCOUNT DESIGNATIONINFORMATION REQUIRED BY EXCHANGE RULES AND THE FEDERALSECURITIES LAWS, AND (2) MAKING AND PRESERVING REQUIRED ANDTIMELY RECORDS RELATING TO DESIGNATION AND EXECUTION OFCUSTOMER ORDERS.Current Status: Final2262018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 10/04/2001Docket/Case Number:Principal Product Type: Equity - OTCOther Product Type(s):Resolution Date: 12/17/2001Resolution:Other Sanctions Ordered: RETAIN AN OUTSIDE CONSULTANT TO COMPLETE A REVIEW AND PREPAREA REPORT OF THE PROCEDURES AND SYSTEMS OF FOLLOW-UP ANDREVIEW ADOPTED BY THE FIRM TO PREVENT RECURRENCE OF THEFOREGOING VIOLATIONS, INCLUDING THE TIMELY ALLOCATION OF BLOCKOR BUNCHED ORDERS; MAKE RECOMMENDATIONS FOR ADDITIONALPROCEDURES; AND SUBMIT SUCH REPORT AND RECOMMENDATIONS TOTHE EXCHANGE WITHIN 90 DAYS FROM THE DATE THIS DECISIONBECOMES FINAL.Sanction Details: $200,000 FINE WAS PAID 12/27/01. OUTSIDE CONSULTANT'S REPORT DUE2/28/02.Sanctions Ordered: CensureMonetary/Fine $200,000.00Stipulation and ConsentDisclosure 101 of 134iReporting Source: RegulatorInitiated By: NORTH DAKOTA OFFICE OF THE SECURITIES COMMISSIONERDate Initiated: 11/09/2000Docket/Case Number: 11092000URL for Regulatory Action:Principal Product Type: Annuity(ies) - VariableAllegations: OMMISSION OF MATERIAL FACTS IN RECOMMENDING THE SALE OF THEANNUITY AND SUBSEQUENT TRANSACTIONS AND NEGLECTED TODISCUSS TAX CONSEQUENCES OR CONTINGENT-DEFERRED SALESCHARGESCurrent Status: Final2272018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:$20,000 CIVIL PENALTY; $3700 INVESTIGATIVE COSTSPrincipal Product Type: Annuity(ies) - VariableOther Product Type(s):Resolution Date: 05/08/2001Resolution:Other Sanctions Ordered:Sanction Details: $13,250 RESTITUTION TO CLIENT.Regulator Statement SOLD A VARIABLE ANNUITY PRODUCT AS A LONG-TERM INVESTMENT TOAN ELDERLY INDIVIDUAL WHO LACKED INVESTMENT EXPERIENCE THENRECOMMENDED THE SALE OF THE ANNUNITY FOLLOWED BYSUBSEQUENT HIGH-RISK TRANSACTIONSDoes the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered: Monetary/Fine $10,000.00Disgorgement/RestitutionConsentiReporting Source: FirmInitiated By: NORTH DAKOTA OFFICE OF THE SECURITIES COMMISSIONERPrincipal Sanction(s)/ReliefSought:Date Initiated: 11/09/2000Docket/Case Number: 11092000Principal Product Type: Annuity(ies) - VariableOther Product Type(s):Allegations: ALLEGED OMISSION OF MATERIAL FACTS IN RECOMMENDING THE SALEOF THE ANNUITY AND SUBSEQUENT TRANSACTIONS AND NEGLECTED TODISCUSS TAX CONSEQUENCES OR CONTINGENT-DEFERRED SALESCHARGES.Current Status: Final2282018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:$20,000 CIVIL PENALTY; $3700 INVESTIGATIVE COSTSResolution Date: 05/08/2001Resolution:Other Sanctions Ordered: PAYMENT OF $13,250 TO MAGDALINE STRICKER TO RESOLVE CUSTOMERCOMPLAINT.Sanction Details: PAYMENT OF $10,000 TO THE SECURITIES PROTECTION FUND WAS PAIDON 5/8/01.PAYMENT OF $13,250 TO MAGDALINE STRICKER WAS PAID ON 04/26/01Firm Statement REGULATOR FILED U6 08/25/2015. BD AMENDMENT FILED PER FINRAREQUEST.Sanctions Ordered: Monetary/Fine $10,000.00Disgorgement/RestitutionConsentDisclosure 102 of 134iReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERSPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 03/31/2000Docket/Case Number: CMS000059Principal Product Type: Equity - OTCOther Product Type(s):Allegations: 05/08/00GS: NASD RULE 4613(E) - RESPONDENT MEMBER, A MARKETMAKER IN SECURITIES, WITHOUT MAKING REASONABLE EFFORTS TOAVOID A LOCKED MARKET BY EXECUTING TRANSACTIONS WITH ALLMARKET MAKERS WHOSE QUOTATIONS WOULD BE LOCKED, ENTERED ABID OR ASK QUOTATION IN THE NASDAQ STOCK MARKET WHICH CAUSEDA LOCKED MARKET CONDITION TO OCCUR IN EACH INSTANCE.Current Status: Final2292018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceResolution Date: 03/31/2000Resolution:Other Sanctions Ordered:Sanction Details: 09-21-00, $3,000 PAID 4/28/00, INVOICE 00-12-283Sanctions Ordered: Monetary/Fine $3,000.00Acceptance, Waiver & Consent(AWC)iReporting Source: FirmInitiated By: NASD REGULATION INC.Principal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 01/13/2000Docket/Case Number: AWC CMS000059Principal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGES VIOLATION OF NASD MARKETPLACE RULE 4613(E).Current Status: FinalResolution Date: 03/02/2000Resolution:Other Sanctions Ordered:Sanction Details: FINE OF $3,000 WAS PAID ON 03/02/2000.Sanctions Ordered: Monetary/Fine $3,000.00Acceptance, Waiver & Consent(AWC)Disclosure 103 of 134iReporting Source: RegulatorAllegations: ARTICLE III, SECTIONS 1, 2, 27, AND 35 OF THE RULES OF FAIR PRACTICE -RESPONDENT MEMBER RECOMMENDED AND SOLD SHARES OF PIPERJAFFRAY WITHOUT ADEQUATELY DISCLOSING MATERIAL FACTSCONCERNING THE CHARACTERISTICS AND SAFETY OF THE FUND; FAILEDTO ENSURE THAT SALES LITERATURE WAS APPROVED BY A REGISTEREDPRINCIPAL; FAILED TO MAINTAIN SEPARATE FILES OF THAT REVIEW;FAILED TO PROVIDE ADEQUATE DISCLOSURE OF THE FUND'S CHANGINGNATURE AND RISK. AS A RESULT, RESPONDENT MEMBER ALLOWEDCUSTOMERS TO BELIEVE THE FUND WAS A SAFE INVESTMENT;RECOMMENDED AND SOLD THE FUNDS TO CUSTOMERS FOR WHOM ITWAS AN UNSUITABLE INVESTMENT; AND, FAILED TO ESTABLISH, MAINTAINAND ENFORCE REASONABLE SUPERVISORY PROCEDURES TO ENSUREADHERENCE TO NASD RULES).Current Status: Final2302018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 03/04/1996Docket/Case Number: C04960008Principal Product Type: No ProductOther Product Type(s):ARTICLE III, SECTIONS 1, 2, 27, AND 35 OF THE RULES OF FAIR PRACTICE -RESPONDENT MEMBER RECOMMENDED AND SOLD SHARES OF PIPERJAFFRAY WITHOUT ADEQUATELY DISCLOSING MATERIAL FACTSCONCERNING THE CHARACTERISTICS AND SAFETY OF THE FUND; FAILEDTO ENSURE THAT SALES LITERATURE WAS APPROVED BY A REGISTEREDPRINCIPAL; FAILED TO MAINTAIN SEPARATE FILES OF THAT REVIEW;FAILED TO PROVIDE ADEQUATE DISCLOSURE OF THE FUND'S CHANGINGNATURE AND RISK. AS A RESULT, RESPONDENT MEMBER ALLOWEDCUSTOMERS TO BELIEVE THE FUND WAS A SAFE INVESTMENT;RECOMMENDED AND SOLD THE FUNDS TO CUSTOMERS FOR WHOM ITWAS AN UNSUITABLE INVESTMENT; AND, FAILED TO ESTABLISH, MAINTAINAND ENFORCE REASONABLE SUPERVISORY PROCEDURES TO ENSUREADHERENCE TO NASD RULES).Resolution Date: 03/04/1996Resolution:Other Sanctions Ordered:Sanction Details: LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. C04960008 WASACCEPTED; THUS, THE FIRM IS CENSURED, FINED $1,250,000, AND SHALLCOMPLY WITH THE FOLLOWING: (1) THE FIRM SHALL RETAIN ANINDEPENDENT CONSULTANT NOT UNACCEPTABLE TO THE NASD("CONSULTANT") WITHIN 45 DAYS OF EFFECTIVE DATE; (2) CONSULTANTSHALL, WITHIN 180 DAYS OF EFFECTIVE DATE, COMPLETE A REVIEW OFTHE FIRM'S PRACTICES AND PROCEDURES, MAKE WRITTENRECOMMENDATIONS ("CONSULTANT'S REPORT"); (3) ALL POLICIES,PRODECURES SHALL BE IMPLEMENTED BY THE FIRM THROUGH REVISIONTO ITS MANUALS . SUCH REPORTS SHALL BE SUBMITTED TO THE DBCCAS PART OF THE NON-PUBLIC FILES. IF THE FIRM FINDS A SPECIFICRECOMMENDATION UNDULY BURDENSOME: (A) THE FIRM SHALL SUBMITSUCH RECOMMENDATION, AND ITS REASONS FOR FAILURE TOIMPLEMENT, AND ANY ALTERNATIVE RECOMMENDATION TO ITS AUDITCOMMITTEE; (B) AUDIT COMMITTEE SHALL REVIEW AND DETERMINEWHETHER THE FAILURE TO IMPLEMENT IS APPROPRIATE, AND WHETHERTHE ALTERNATIVE ACHIEVES THE SAME OBJECTIVES ("AUDIT COMMITTEEREPORT"); (C) AUDIT COMMITTEE REPORT AND CONSULTANT'S REPORTSHALL BE PRESENTED TO THE DBCC -Sanctions Ordered: CensureMonetary/Fine $1,250,000.00Acceptance, Waiver & Consent(AWC)2312018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceLETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. C04960008 WASACCEPTED; THUS, THE FIRM IS CENSURED, FINED $1,250,000, AND SHALLCOMPLY WITH THE FOLLOWING: (1) THE FIRM SHALL RETAIN ANINDEPENDENT CONSULTANT NOT UNACCEPTABLE TO THE NASD("CONSULTANT") WITHIN 45 DAYS OF EFFECTIVE DATE; (2) CONSULTANTSHALL, WITHIN 180 DAYS OF EFFECTIVE DATE, COMPLETE A REVIEW OFTHE FIRM'S PRACTICES AND PROCEDURES, MAKE WRITTENRECOMMENDATIONS ("CONSULTANT'S REPORT"); (3) ALL POLICIES,PRODECURES SHALL BE IMPLEMENTED BY THE FIRM THROUGH REVISIONTO ITS MANUALS . SUCH REPORTS SHALL BE SUBMITTED TO THE DBCCAS PART OF THE NON-PUBLIC FILES. IF THE FIRM FINDS A SPECIFICRECOMMENDATION UNDULY BURDENSOME: (A) THE FIRM SHALL SUBMITSUCH RECOMMENDATION, AND ITS REASONS FOR FAILURE TOIMPLEMENT, AND ANY ALTERNATIVE RECOMMENDATION TO ITS AUDITCOMMITTEE; (B) AUDIT COMMITTEE SHALL REVIEW AND DETERMINEWHETHER THE FAILURE TO IMPLEMENT IS APPROPRIATE, AND WHETHERTHE ALTERNATIVE ACHIEVES THE SAME OBJECTIVES ("AUDIT COMMITTEEREPORT"); (C) AUDIT COMMITTEE REPORT AND CONSULTANT'S REPORTSHALL BE PRESENTED TO THE DBCC -Regulator Statement [TOP]ON 3/4/96, DISTRICT NO. 4 NOTIFIED RESPONDENT PIPERJAFFRAY INC. THAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENTNO. C04960008 WAS ACCEPTED; THUS, THE FIRM IS CENSURED, FINED$1,250,000, AND SHALL COMPLY WITH THE FOLLOWING: (1) THE FIRMSHALL RETAIN AN INDEPENDENT CONSULTANT NOT UNACCEPTABLE TOTHE NASD ("CONSULTANT") WITHIN45 DAYS OF EFFECTIVE DATE; (2)CONSULTANT SHALL, WITHIN 180 DAYS OF EFFECTIVE DATE, COMPLETE AREVIEW OF THE FIRM'S PRACTICES AND PROCEDURES, MAKE WRITTENRECOMMENDATIONS ("CONSULTANT'S REPORT"); (3) ALL POLICIES,PRODECURES SHALL BE IMPLEMENTED BY THE FIRM THROUGH REVISIONTO ITS MANUALS . SUCH REPORTS SHALL BE SUBMITTED TO THE DBCCAS PART OF THE NON-PUBLIC FILES. IF THE FIRM FINDS A SPECIFICRECOMMENDATION UNDULY BURDENSOME: (A) THE FIRM SHALL SUBMITSUCH RECOMMENDATION, AND ITS REASONS FOR FAILURE TOIMPLEMENT, AND ANY ALTERNATIVE RECOMMENDATION TO ITS AUDITCOMMITTEE; (B) AUDIT COMMITTEE SHALL REVIEW AND DETERMINEWHETHER THE FAILURE TO IMPLEMENT IS APPROPRIATE, AND WHETHERTHE ALTERNATIVE ACHIEVES THE SAME OBJECTIVES ("AUDIT COMMITTEEREPORT"); (C) AUDIT COMMITTEE REPORT AND CONSULTANT'S REPORTSHALL BE PRESENTED TO THE DBCC - (ARTICLE III, SECTIONS 1, 2, 27, AND35 OF THE RULES OF FAIR PRACTICE - RESPONDENT MEMBERRECOMMENDED AND SOLD SHARES OF PIPER JAFFRAY WITHOUTADEQUATELY DISCLOSING MATERIAL FACTS CONCERNING THECHARACTERISTICS AND SAFETY OF THE FUND; FAILED TO ENSURE THATSALES LITERATURE WAS APPROVED BY A REGISTERED PRINCIPAL; FAILEDTO MAINTAIN SEPARATE FILES OF THAT REVIEW; FAILED TO PROVIDEADEQUATE DISCLOSURE OF THE FUND'S CHANGING NATURE AND RISK.AS A RESULT, RESPONDENT MEMBER ALLOWED CUSTOMERS TO BELIEVETHE FUND WAS A SAFE INVESTMENT; RECOMMENDED AND SOLD THEFUNDS TO CUSTOMERS FOR WHOM IT WAS AN UNSUITABLE INVESTMENT;AND, FAILED TO ESTABLISH, MAINTAIN AND ENFORCE REASONABLESUPERVISORY PROCEDURES TO ENSURE ADHERENCE TO NASD RULES).iReporting Source: FirmAllegations: THE JOINT INVESTIGATION BY THE NASD AND THE STATE OF MINNESOTAPRIMARILY RELATED TO DISCLOSURES AND SALES PRACTICESPERTAINING TO THE SALE OF PIPER FUNDS INC. INSTITUTIONALGOVERNMENT PORTFOLIO.Current Status: Final2322018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERSPrincipal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:Date Initiated: 08/14/1994Docket/Case Number: C04960008Principal Product Type: Mutual Fund(s)Other Product Type(s):THE JOINT INVESTIGATION BY THE NASD AND THE STATE OF MINNESOTAPRIMARILY RELATED TO DISCLOSURES AND SALES PRACTICESPERTAINING TO THE SALE OF PIPER FUNDS INC. INSTITUTIONALGOVERNMENT PORTFOLIO.Resolution Date: 03/06/1996Resolution:Other Sanctions Ordered: AN AGREEMENT TO HIRE AN INDEPENDENT CONSULTANT TO REVIEW ANDMAKE RECOMMENDATIONS PRIMARILY RELATING TO THE MARKETING ANDSALE OF PIPER CAPITAL MANAGEMENT'S MUTUAL FUNDS.Sanction Details: THE CONSENT AGREEMENT PROVIDES THAT PIPER JAFFRAY PAY $65,000TO THE SECURITIES TRADING INVESTOR EDUCATION AND INVESTIGATIONFUND.Sanctions Ordered: CensureMonetary/Fine $1,250,000.00SettledDisclosure 104 of 134iReporting Source: RegulatorAllegations: 04-10-00, SEC RULES 17(A)(2),(3), NASD RULE 2110 - RESPONDENTMEMBER EFFECTED DEFEASANCE ESCROW TRANSACTIONS WITHMUNICIPALITIES AT PRICES NOT REASONABLY RELATED TO THE CURRENTWHOLESALE MARKET PRICES FOR THE SECURITIES UNDER THEPARTICULAR FACTS AND CIRCUMSTANCES, INCLUDING THE PERTINENTTAX REGULATIONS. THE FIRM KNEW, OR SHOULD HAVE KNOWN, THAT THEPRICES IT CHARGED WERE NOT REASONABLY RELATED TO THEPREVAILING WHOLESALE MARKET PRICES OF THE SECURITIES. THEEXCESSIVE MARKUPS ALSO JEOPARDIZED THE TAX-EXEMPT STATUS OFTHOSE MUNICIPALITIES REFUNDING BONDS AND DIVERTED MONEY FROMTHE U.S. TREASURY TO THE FIRM WHEN THE TRANSACTION WAS INPOSITIVE ARBITRAGE OR REDUCED THE SAVINGS AVAILABLE TO THEMUNICIPALITIES FROM THE REFUNDINGS WHEN THE TRANSACTION WASIN NEGATIVE ARBITRAGE.Current Status: Final2332018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 04/05/2000Docket/Case Number: C05000015Principal Product Type: OtherOther Product Type(s):04-10-00, SEC RULES 17(A)(2),(3), NASD RULE 2110 - RESPONDENTMEMBER EFFECTED DEFEASANCE ESCROW TRANSACTIONS WITHMUNICIPALITIES AT PRICES NOT REASONABLY RELATED TO THE CURRENTWHOLESALE MARKET PRICES FOR THE SECURITIES UNDER THEPARTICULAR FACTS AND CIRCUMSTANCES, INCLUDING THE PERTINENTTAX REGULATIONS. THE FIRM KNEW, OR SHOULD HAVE KNOWN, THAT THEPRICES IT CHARGED WERE NOT REASONABLY RELATED TO THEPREVAILING WHOLESALE MARKET PRICES OF THE SECURITIES. THEEXCESSIVE MARKUPS ALSO JEOPARDIZED THE TAX-EXEMPT STATUS OFTHOSE MUNICIPALITIES REFUNDING BONDS AND DIVERTED MONEY FROMTHE U.S. TREASURY TO THE FIRM WHEN THE TRANSACTION WAS INPOSITIVE ARBITRAGE OR REDUCED THE SAVINGS AVAILABLE TO THEMUNICIPALITIES FROM THE REFUNDINGS WHEN THE TRANSACTION WASIN NEGATIVE ARBITRAGE.Resolution Date: 04/05/2000Resolution:Other Sanctions Ordered: PAY $988,042.98 TO THE U.S. TREASURY UNDER AN AGREEMENTSIMULTANEOUSLY ENTERED INTO AMONG THE FIRM, THE IRS, AND THEU.S. ATTORNEY FOR THE SOUTHERN DISTRICT OF NEW YORK.AT THE TIMETHE PAYMENTS ARE MADE TO THE MUNICIPALITIES AND THE U.S.TREASURY, COPIES OF THE PAYMENTS AND ANY COVER LETTERS SHALLBE SENT TO DISTRICT NO. 5.Sanction Details: 11-01-00, $55,000 PAID 4/17/00Sanctions Ordered: CensureAcceptance, Waiver & Consent(AWC)iReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERSDate Initiated: 05/03/1999Docket/Case Number: ETR04-9800089/AWC C05000015Principal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGES TRADE REPORT PRICE NOT ON CONFIRMS FOR PRINCIPALTRADES, LIMIT ORDER DISPLAY VIOLATIONS AND FAILURE TO ESTABLISH,MAINTAIN AND ENFORCE ADEQUATE WRITTEN SUPERVISORYPROCEDURES FOR LIMIT ORDER DISPLAY, LIMIT ORDER PROTECTION,BEST EXECUTION, TRADE UP & SOES.Current Status: Final2342018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:CIVIL AND ADMINISTRATIVE PENALTIES/FINESOther Product Type(s):Resolution Date: 04/05/2000Resolution:Other Sanctions Ordered:Sanction Details: DISGORGEMENT OF $988,042.98 WAS PAID ON 4/10/00.Sanctions Ordered: CensureDisgorgement/RestitutionAcceptance, Waiver & Consent(AWC)Disclosure 105 of 134iReporting Source: RegulatorInitiated By: THE NATIONAL ASSOCITION OF SECURITIES DEALERSPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 02/08/2000Docket/Case Number: C04000010Principal Product Type: Debt - MunicipalOther Product Type(s):Allegations: 02/25/00GS: MSRB RULES G-37 AND G-38 - RESPONDENT MEMBER FAILEDTO REFLECT NEGOTIATED UNDERWRITINGS, A NEGOTIATED FINANCIALADVISORY RELATIONSHIP AND NEGOTIATED FINANCIAL ADVISORYRELATIONSHIPS ON ITS FORM G-37/G-38.Current Status: FinalResolution Date: 02/08/2000Resolution:Other Sanctions Ordered: NONESanction Details: 09-07-00,$2,000 PAID 3/09/00, INVOICE 00-04-089Sanctions Ordered: Monetary/Fine $2,000.00Acceptance, Waiver & Consent(AWC)2352018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceSanction Details: 09-07-00,$2,000 PAID 3/09/00, INVOICE 00-04-089iReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 12/14/1999Docket/Case Number: C04000010Principal Product Type: No ProductOther Product Type(s):Allegations: ALLEGED FAILURE TO REFLECT 13 NEGOTIATED UNDERWRITINGS ON ITS12/31/98 FORM G-37/G-38; 3 NEGOTIATED UNDERWRITINGS ON ITS 3/31/99FORM G-37/G-38, AS SET FORTH ON SCHEDULE A. ALLEGED FAILURE TOREFLECT ONE NEGOTIATED FINANCIAL ADVISORY RELATIONSHIP ON ITS12/31/98 FORM G-37/G-38 & 6 NEGOTIATED FINANCIAL ADVISORYRELATIONSHIPS ON ITS 3/31/99 FORM G-37/G-38, AS SET FORTH ONSCHEDULE B.Current Status: FinalResolution Date: 02/08/2000Resolution:Other Sanctions Ordered:Sanction Details: FINE OF $2,000 WAS PAID ON 2/8/00.Sanctions Ordered: Monetary/Fine $2,000.00Acceptance, Waiver & Consent(AWC)Disclosure 106 of 134iReporting Source: RegulatorAllegations: 12/28/99GS: NASD RULES 2110, 3010, AND SEC RULES 10B-10, AND 11AC1-4- PIPER JAFFRAY, INC. FAILED TO PROVIDE ITS CUSTOMERS WITHWRITTEN NOTIFICATION OF THE REPORTED TRADE PRICE INTRANSACTIONS AND, IN ONE CASE, FAILED TO PROVIDE THE CUSTOMERWITH WRITTEN NOTIFICATION THAT THE PRICE HE RECEIVED WAS ANAVERAGE PRICE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TODISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS EITHER WHEN THEORDERS WERE AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM?S BIDOR OFFER IN EACH SECURITY RELATED TO THOSE ORDERS OR WHENTHE ORDERS WERE PRICED EQUAL TO THE FIRM?S BID OR OFFER ANDTHE NATIONAL BEST BID OR OFFER AND THE OFFERS REPRESENTEDMORE THAN A DE MINIMUS CHANGE IN RELATION TO THE SIZEASSOCIATED WITH THE FIRM?S BID OR OFFER IN EACH SECURITY. INADDITION, THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCEWRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH APPLICABLE RULES REGARDING LIMITORDER DISPLAY AND PROTECTION, BEST EXECUTION, TRADEREPORTING, AND THE USE OF SOES.Current Status: Final2362018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 11/24/1999Docket/Case Number: CMS990145Principal Product Type: OtherOther Product Type(s):12/28/99GS: NASD RULES 2110, 3010, AND SEC RULES 10B-10, AND 11AC1-4- PIPER JAFFRAY, INC. FAILED TO PROVIDE ITS CUSTOMERS WITHWRITTEN NOTIFICATION OF THE REPORTED TRADE PRICE INTRANSACTIONS AND, IN ONE CASE, FAILED TO PROVIDE THE CUSTOMERWITH WRITTEN NOTIFICATION THAT THE PRICE HE RECEIVED WAS ANAVERAGE PRICE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TODISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS EITHER WHEN THEORDERS WERE AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM?S BIDOR OFFER IN EACH SECURITY RELATED TO THOSE ORDERS OR WHENTHE ORDERS WERE PRICED EQUAL TO THE FIRM?S BID OR OFFER ANDTHE NATIONAL BEST BID OR OFFER AND THE OFFERS REPRESENTEDMORE THAN A DE MINIMUS CHANGE IN RELATION TO THE SIZEASSOCIATED WITH THE FIRM?S BID OR OFFER IN EACH SECURITY. INADDITION, THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCEWRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH APPLICABLE RULES REGARDING LIMITORDER DISPLAY AND PROTECTION, BEST EXECUTION, TRADEREPORTING, AND THE USE OF SOES.Resolution Date: 11/24/1999Resolution:Other Sanctions Ordered:Sanction Details: FIRM SUBMITTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENTPURSUANT TO WHICH THE FIRM WAS CENSURED AND FINED $12,500.09-07-00, $12,500 PAID 12/31/99, INVOICE #99-MS-1032Regulator Statement N/ASanctions Ordered: Monetary/Fine $12,500.00Acceptance, Waiver & Consent(AWC)iReporting Source: FirmAllegations: ALLEGED VIOLATIONS OF SEC RULE 10B-10, SEC RULE 11AC1-4 ANDCONDUCT RULES 2110 AND 3010.Current Status: Final2372018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NASD REGULATION INC.Principal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:FINE OF $12,500Date Initiated: 05/03/1999Docket/Case Number: CMS990145 AWCPrincipal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGED VIOLATIONS OF SEC RULE 10B-10, SEC RULE 11AC1-4 ANDCONDUCT RULES 2110 AND 3010.Resolution Date: 11/23/1999Resolution:Other Sanctions Ordered:Sanction Details: THE FINE OF $12,500 WAS PAID ON 5/3/99.Sanctions Ordered: CensureMonetary/Fine $12,500.00Acceptance, Waiver & Consent(AWC)Disclosure 107 of 134iReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERSPrincipal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:FINE OF $1,000Date Initiated: 11/14/1995Docket/Case Number: CM950193Principal Product Type: Equity - OTCOther Product Type(s):Allegations: NASD ALLEGED VIOLATION OF PART V, SECTION 2(D) OF SCHEDULE D TOTHE ASSOCIATION'S BY-LAWS (IN CONNECTION WITH ITS EXCESSIVESPREAD POLICY)Current Status: Final2382018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanction(s)/ReliefSought:FINE OF $1,000Resolution Date: 04/10/1996Resolution:Other Sanctions Ordered:Sanction Details: FINE OF $1,000 WAS PAID ON 4/10/96Sanctions Ordered: CensureMonetary/Fine $1,000.00Acceptance, Waiver & Consent(AWC)Disclosure 108 of 134iReporting Source: FirmInitiated By: NEW YORK MERCANTILE EXCHANGEPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:FINE OF $1500.00Date Initiated: 07/01/1977Docket/Case Number: NOT AVAILABLEPrincipal Product Type: Futures - CommodityOther Product Type(s):Allegations: ALLEGED THAT PIPER, JAFFRAY & HOPWOOD INCORPORATED (NKA PIPERJAFFRAY) ACCEPTED A DAY TRADE IN THE LAST 15 MINUTES IN A VOLATILEMARKET FOR A COMMODITIES CUSTOMER THAT PJH ALLEGEDLY KNEWWAS IN NO POSITION TO DELIVER HIS CONTRACTS. THE ALLEGEDCONDUCT WAS DEEMED DETRIMENTAL TO THE BEST INTERESTS OF THENEW YORK MERCANTILE EXCHANGE.Current Status: FinalResolution Date: 07/13/1977Resolution:Other Sanctions Ordered:Sanction Details: FINE OF $1500.00 WAS PAID ON 7/13/77.Sanctions Ordered: Monetary/Fine $1,500.00Settled2392018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceDisclosure 109 of 134iReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERSPrincipal Sanction(s)/ReliefSought:DisgorgementOther Sanction(s)/ReliefSought:Date Initiated: 12/02/1998Docket/Case Number: E05970495Principal Product Type: OtherOther Product Type(s): U.S. TREASURY DEBT OBLIGATIONSAllegations: THE DEPARTMENT OF JUSTICE (CASE #DOJ 95 CIV 1363) AND NASDR SEEKDISGORGEMENT OF PROFITS MADE FOR MARK-UPS ON THE PURCHASEAND SUBSEQUENT SALE OF U.S. TREASURY OBLIGATIONS INTOESCROWS BUILT FOR THE PURPOSE OF PERFORMING ADVANCEDREFUNDING OF MUNICIPAL BONDS. THE ALLEGATIONS ARE GENERALLYREFERRED TO AS "YIELD BURNING".Current Status: FinalResolution Date: 04/06/2000Resolution:Other Sanctions Ordered:Sanction Details: DISGORGEMENT OF $988,042.98 WAS PAID ON 4/10/00.Sanctions Ordered: Disgorgement/RestitutionSettledDisclosure 110 of 134iReporting Source: FirmAllegations: THE DOJ AND NASDR (CASE#E05970495) SEEK DISGORGEMENT OFPROFITS MADE FOR MARK-UPS ON THE PURCHASE AND SUBSEQUENTSALE OF U.S. TREASURY OBLIGATIONS INTO ESCROWS BUILT FOR THEPURPOSE OF PERFORMING ADVANCED REFUNDING OF MUNICIPALBONDS. THE ALLEGATIONS ARE GENERALLY REFERRED TO AS "YIELDBURNING".Current Status: Final2402018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: DEPARTMENT OF JUSTICEPrincipal Sanction(s)/ReliefSought:DisgorgementOther Sanction(s)/ReliefSought:Date Initiated: 12/03/1998Docket/Case Number: DOJ 95 CIV 1363Principal Product Type: OtherOther Product Type(s): U.S. TREASURY DEBT OBLIGATIONSResolution Date: 04/06/2000Resolution:Other Sanctions Ordered:Sanction Details: DISGORGEMENT OF $988,042.98 WAS PAID ON 4/10/00.Sanctions Ordered: Disgorgement/RestitutionSettledDisclosure 111 of 134iReporting Source: FirmInitiated By: MONTANA SECURITIES COMMISSIONERPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:CIVIL AND ADMINISTRATIVE PENALTIES/FINESDate Initiated: 11/16/1995Docket/Case Number: CO1-13-95-04Principal Product Type: Mutual Fund(s)Other Product Type(s):Allegations: THE COMMISSIONER ALLEGED THAT PIPER JAFFRAY INC AND PIPERCAPITAL MANAGEMENT INCORPORATED FAILED TO REASONABLYSUPERVISE AGENTS, EMPLOYEES OR REPRESENTATIVES IN MARKETINGCERTAIN PROPRIETARY FUNDS.Current Status: FinalResolution: Settled2412018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceResolution Date: 10/29/1996Resolution:Other Sanctions Ordered: PAY $10,000 TO THE INVESTOR PROTECTION TRUST; PAY $35,000 TO THEMONTANA STATE AUDITOR'S OFFICE; SUBMIT TO THE COMMISSIONER ANYCUSTOMER COMPLAINTS INVOLVING A MT RESIDENT; ALLOW PERSONNELFROM THE COMMISSIONER'S OFFICE TO PARTICIPATE IN ANY MT PJBRANCH OFFICE REVIEW OCCURRING WITHIN 1 YEAR OF THEAGREEMENT.Sanction Details: FINE OF $25,000, $10,000 TO THE INVESTOR PROTECTION TRUST, $35,000TO THE MONTANA STATE AUDITOR'S OFFICE WAS PAID ON 10/29/96.Sanctions Ordered: Monetary/Fine $25,000.00SettledDisclosure 112 of 134iReporting Source: FirmInitiated By: NORTH DAKOTA SECURITIES COMMISSIONERPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:CIVIL AND ADMINISTRATIVE PENALTIES/FINESDate Initiated: 02/25/1997Docket/Case Number: UNKNOWNPrincipal Product Type: Mutual Fund(s)Other Product Type(s):Allegations: THE COMMISSIONER ALLEGED THAT PIPER JAFFRAY INC. AND PIPERCAPITAL MANAGEMENT INCORPORATED FAILED TO REASONABLYSUPERVISE AGENTS, EMPLOYEES AND/OR INVESTMENT ADVISORREPRESENTATIVES.Current Status: FinalResolution Date: 02/25/1997Resolution:Other Sanctions Ordered: THE CONSENT AGREEMENT PROVIDES THAT RESPONDENTS SHALL (1)PAY $120,000 TO THE SECURITIES PROTECTION FUND OF THECOMMISSIONER'S OFFICE; (2) SUBMIT TO THE COMMISSIONER EVIDENCETHAT THEY HAVE FULLY COMPLIED WITH THE UNDERTAKINGS SET FORTHIN THE 2/7/96 STATE OF MINNESOTA CONSENT ORDER; (3) SUBMIT TO THECOMMISSIONER ANY ND CUSTOMER COMPLAINT ALLEGING DAMAGES OF$10,000 OR MORE, FRAUD OR WRONGFUL TAKING OF PROPERTY; (4)NOTIFY THE COMMISSIONER AND ALLOW PERSONNEL FROM THECOMMISSIONER'S OFFICE TO PARTICIPATE IN ANY ND PJ BRANCH OFFICEREVIEW OCCURRING WITHIN 1 YEAR OF THE AGREEMENT.Sanctions Ordered: Monetary/Fine $120,000.00Settled2422018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceTHE CONSENT AGREEMENT PROVIDES THAT RESPONDENTS SHALL (1)PAY $120,000 TO THE SECURITIES PROTECTION FUND OF THECOMMISSIONER'S OFFICE; (2) SUBMIT TO THE COMMISSIONER EVIDENCETHAT THEY HAVE FULLY COMPLIED WITH THE UNDERTAKINGS SET FORTHIN THE 2/7/96 STATE OF MINNESOTA CONSENT ORDER; (3) SUBMIT TO THECOMMISSIONER ANY ND CUSTOMER COMPLAINT ALLEGING DAMAGES OF$10,000 OR MORE, FRAUD OR WRONGFUL TAKING OF PROPERTY; (4)NOTIFY THE COMMISSIONER AND ALLOW PERSONNEL FROM THECOMMISSIONER'S OFFICE TO PARTICIPATE IN ANY ND PJ BRANCH OFFICEREVIEW OCCURRING WITHIN 1 YEAR OF THE AGREEMENT.Sanction Details: FINE OF $120,000 TO THE SECURITIES PROTECTION FUND AND EVIDENCEOF COMPLIANCE WITH THE 2/7/96 MN CONSENT ORDER WAS COMPLETEDON 2/25/97.Disclosure 113 of 134iReporting Source: FirmInitiated By: SOUTH DAKOTA DIVISION OF SECURITIESPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:CIVIL AND ADMINISTRATIVE PENALTIES/FINESDate Initiated: 11/15/1995Docket/Case Number: UNKNOWNPrincipal Product Type: Mutual Fund(s)Other Product Type(s):Allegations: THE DIVISION ALLEGED THAT PIPER JAFFRAY INC. AND PIPER CAPITALMANAGEMENT INCORPORATED FAILED TO REASONABLY SUPERVISEAGENTS, EMPLOYEES OR REPRESENTATIVES IN MARKETING CERTAINPROPRIETARY FUNDS.Current Status: FinalResolution Date: 07/11/1996Resolution:Other Sanctions Ordered: THE CONSENT AGREEMENT PROVIDES THAT $10,000 BE PAID TO THEINVESTOR PROTECTION TRUST; REIMBURSE THE DIVISION IN THEAMOUNT OF $25,000; SUBMIT TO THE DIVISION EVIDENCE OF COMPLIANCEWITH THE 2/7/96 MN CONSENT ORDER; SUBMIT TO THE DIVISION ANYCUSTOMER COMPLAINTS MADE WITHIN 1 YEAR OF THE AGREEMENTINVOLVING A SD RESIDENT THAT ALLEGED DAMAGES OF $10,000 ORMORE, FRAUD OR WRONGFUL TAKING OF PROPERTY AND ALLOWPERSONNEL FROM THE DIVISION TO PARTICIPATE IN ANY SD PJ BRANCHOFFICE REVIEW OCCURING WITHIN 1 YEAR OF THE AGREEMENT.Sanctions Ordered: Monetary/Fine $40,000.00Settled2432018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceTHE CONSENT AGREEMENT PROVIDES THAT $10,000 BE PAID TO THEINVESTOR PROTECTION TRUST; REIMBURSE THE DIVISION IN THEAMOUNT OF $25,000; SUBMIT TO THE DIVISION EVIDENCE OF COMPLIANCEWITH THE 2/7/96 MN CONSENT ORDER; SUBMIT TO THE DIVISION ANYCUSTOMER COMPLAINTS MADE WITHIN 1 YEAR OF THE AGREEMENTINVOLVING A SD RESIDENT THAT ALLEGED DAMAGES OF $10,000 ORMORE, FRAUD OR WRONGFUL TAKING OF PROPERTY AND ALLOWPERSONNEL FROM THE DIVISION TO PARTICIPATE IN ANY SD PJ BRANCHOFFICE REVIEW OCCURING WITHIN 1 YEAR OF THE AGREEMENT.Sanction Details: FINE OF $40,000, $10,000 TO THE INVESTOR PROTECTION TRUST, $25,000TO THE DIVISION AND EVIDENCE OF COMPLIANCE WITH THE 2/7/96 MNCONSENT ORDER WAS COMPLETED ON 7/11/96.Disclosure 114 of 134iReporting Source: FirmInitiated By: PUERTO RICO COMMISSIONER OF FINANCIAL INSTITUTIONSPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:CIVIL AND ADMINISTRATIVE PENALTIES/FINESDate Initiated: 05/26/1998Docket/Case Number: UNKNOWNPrincipal Product Type: No ProductOther Product Type(s):Allegations: PIPER JAFFRAY INC. CONDUCTED TRANSACTIONS FOR CLIENTS RESIDINGIN PUERTO RICO WITHOUT BEING REGISTERED AS A BROKER-DEALER INPUERTO RICO.Current Status: FinalResolution Date: 06/02/1998Resolution:Other Sanctions Ordered: THE CONSENT AGREEMENT PROVIDES THAT PIPER JAFFRAY INC. PAY$65,000.00 TO THE SECURITIES TRADING INVESTOR EDUCATION ANDINVESTIGATION FUND.Sanction Details: $65,000 WAS PAID TO THE SECURITIES TRADING INVESTOR EDUCATIONAND INVESTIGATION FUND ON 05/26/1998.Firm Statement PIPER JAFFRAY INC. WAS APPROVED IN PUERTO RICO AS A BROKER-DEALER EFFECTIVE JUNE 4, 1998.Sanctions Ordered: Monetary/Fine $65,000.00OtherDisclosure 115 of 134i2442018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 01/27/1999Docket/Case Number: CMS980113 AWCPrincipal Product Type:Other Product Type(s):Allegations:Current Status: FinalResolution Date: 01/27/1999Resolution:Other Sanctions Ordered:Sanction Details:Regulator Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS980113 AWC.ON JANUARY 27, 1999, PIPER JAFFRAY INC. (PIPR) WAS NOTIFIEDTHAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) ITSUBMITTED WAS ACCEPTED BY NASD REGULATION, INC.'S OFFICE OFDISCIPLINARY AFFAIRS AND THE NATIONAL ADJUDICATORY COUNCIL. THEAWC ALLEGES THAT THE FOLLOWING VIOLATIONS OCCURRED:IN 45 INSTANCES, WHERE THE FIRM ACTED AS PRINCIPAL FOR ITS OWNACCOUNT, PIPR FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSINGTO EACH OF ITS CUSTOMERS THE REPORTED TRADE PRICE, THE PRICETOTHE CUSTOMER IN THE TRANSACTION, AND THE DIFFERENCE, IF ANY,BETWEEN THE REPORTED TRADE PRICE AND THE PRICE TO THECUSTOMER. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OFSEC RULE 10b-10.IN SIX INSTANCES INVOLVING NASDAQ SECURITIES, PIPR ENTERED ATOTAL OF 12 ORDERS INTO SOES ON THE SAME SIDE OF THE MARKETWITHIN A FIVE MINUTE TIME PERIOD ON BEHALF OF ELEVEN ACCOUNTSCONTROLLED BY THE SAME ASSOCIATED PERSON OR CUSTOMER. INEACHSUCH INSTANCE, THESE ORDERS, WHEN AGGREGATED, EXCEEDED THESOESMAXIMUM ORDER SIZE FOR THAT SECURITY; AND PIPR ENTERED NINEORDERS INTO SOES ON BEHALF OF PROPRIETARY ACCOUNTS. THISCONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASDMARKETPLACE RULE 4730(c)(3).PIPR FAILED TO ESTABLISH AND MAINTAIN WRITTEN SUPERVISORYPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHTHEAPPLICABLE RULES WITH REGARD TO SEC RULE 10b-10 AND RECORDKEEPING. THIS CONDUCT CONSTITUTES A VIOLATION OF NASD CONDUCTRULE 3010.PIPR WAS CENSURED AND FINED $4,000.******$4,000.00 PAID ON 3/19/99 - INVOICE NO. 99-MS-199*****Sanctions Ordered: CensureMonetary/Fine $4,000.00Acceptance, Waiver & Consent(AWC)2452018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceLETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS980113 AWC.ON JANUARY 27, 1999, PIPER JAFFRAY INC. (PIPR) WAS NOTIFIEDTHAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) ITSUBMITTED WAS ACCEPTED BY NASD REGULATION, INC.'S OFFICE OFDISCIPLINARY AFFAIRS AND THE NATIONAL ADJUDICATORY COUNCIL. THEAWC ALLEGES THAT THE FOLLOWING VIOLATIONS OCCURRED:IN 45 INSTANCES, WHERE THE FIRM ACTED AS PRINCIPAL FOR ITS OWNACCOUNT, PIPR FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSINGTO EACH OF ITS CUSTOMERS THE REPORTED TRADE PRICE, THE PRICETOTHE CUSTOMER IN THE TRANSACTION, AND THE DIFFERENCE, IF ANY,BETWEEN THE REPORTED TRADE PRICE AND THE PRICE TO THECUSTOMER. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OFSEC RULE 10b-10.IN SIX INSTANCES INVOLVING NASDAQ SECURITIES, PIPR ENTERED ATOTAL OF 12 ORDERS INTO SOES ON THE SAME SIDE OF THE MARKETWITHIN A FIVE MINUTE TIME PERIOD ON BEHALF OF ELEVEN ACCOUNTSCONTROLLED BY THE SAME ASSOCIATED PERSON OR CUSTOMER. INEACHSUCH INSTANCE, THESE ORDERS, WHEN AGGREGATED, EXCEEDED THESOESMAXIMUM ORDER SIZE FOR THAT SECURITY; AND PIPR ENTERED NINEORDERS INTO SOES ON BEHALF OF PROPRIETARY ACCOUNTS. THISCONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASDMARKETPLACE RULE 4730(c)(3).PIPR FAILED TO ESTABLISH AND MAINTAIN WRITTEN SUPERVISORYPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHTHEAPPLICABLE RULES WITH REGARD TO SEC RULE 10b-10 AND RECORDKEEPING. THIS CONDUCT CONSTITUTES A VIOLATION OF NASD CONDUCTRULE 3010.PIPR WAS CENSURED AND FINED $4,000.******$4,000.00 PAID ON 3/19/99 - INVOICE NO. 99-MS-199*****iReporting Source: FirmInitiated By: NASD REGULATION INC.Principal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:FINE OF $4000.00Date Initiated: 02/01/1997Docket/Case Number: CMS980113Principal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGED PIPER JAFFRAY INC. VIOLATED SEC RULE 10B 10, NASDMARKETPLACE RULE 4730 (E)(3) AND NASD CONDUCT RULES 2110 AND3010.Current Status: FinalResolution Date: 01/27/1999Resolution: Acceptance, Waiver & Consent(AWC)2462018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceResolution Date: 01/27/1999Other Sanctions Ordered:Sanction Details: FINE OF $4,000 WAS PAID ON 1/27/99.Sanctions Ordered: CensureMonetary/Fine $4,000.00Disclosure 116 of 134iReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 04/02/1970Docket/Case Number: 389Principal Product Type:Other Product Type(s):Allegations:Current Status: FinalResolution Date: 10/18/1972Resolution:Other Sanctions Ordered:Sanction Details:Regulator Statement COMPLAINT: #389 FILED 04/02/70.05/19/71: DBCC CALLED FOR REVIEW.06/19/71: TO BE FINAL.06/17/71: B/G CALLED FOR REVIEW.10/18/72: CENSURED, FINED $400010/18/72: TO BE FINAL10/18/72: FINAL10/25/72: PAIDSanctions Ordered: CensureMonetary/Fine $4,000.00Decision2472018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceiReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERSPrincipal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:Date Initiated: 05/01/1971Docket/Case Number: CHI-389Principal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGED PIPER, JAFFRAY & HOPWOOD INCORPORATED (NKA PIPERJAFFRAY INC.) VIOLATED SECTION 1, ARTICLE III OF THE RULES OF FAIRPRACTICE AND THE INTERPRETATION OF THE BOARD OF GOVERNORS INREGARD TO FREE-RIDING & WITHHOLDING.Current Status: FinalResolution Date: 09/01/1972Resolution:Other Sanctions Ordered: IN 9/72, THE BOARD OF GOVERNORS OF THE NASD REVERSED THEDISTRICT COMMITTEE AND INCREASED THE PENALTIES TO A CENSUREAND FINE OF $4000.00.Sanction Details: FINE OF $4,000 WAS PAID IN SEPTEMBER 1972.Sanctions Ordered: CensureMonetary/Fine $2,750.00DecisionDisclosure 117 of 134iReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Date Initiated: 11/21/1997Docket/Case Number:Principal Product Type:Allegations:Current Status: Final2482018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Principal Product Type:Other Product Type(s):Resolution Date: 11/21/1997Resolution:Other Sanctions Ordered:Sanction Details:Sanctions Ordered: CensureMonetary/FineDecisioniReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERSPrincipal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:Date Initiated: 10/30/1997Docket/Case Number: CMS970007Principal Product Type: Debt - GovernmentOther Product Type(s): DEBT-MUNICIPALAllegations: ALLEGES PIPER JAFFRAY, FROM 7/1/95 THROUGH 6/30/96, VIOLATED MSRBRULES G-36 BY FAILING TO TIMELY SUBMIT OFFICIAL STATEMENTS AND/OROTHER DOCUMENTS TO THE MSRB AND MSRB RULE G-8 BY FAILING ONOCCASSION TO MAINTAIN RECORDS.Current Status: FinalResolution Date: 12/12/1997Resolution:Other Sanctions Ordered:Sanctions Ordered: CensureMonetary/Fine $10,000.00Acceptance, Waiver & Consent(AWC)2492018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions Ordered:Sanction Details: FINE OF $10,000 WAS PAID ON 12/12/97.Disclosure 118 of 134iReporting Source: RegulatorInitiated By: SECURITIES AND EXCHANGE COMMISSIONPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 01/11/1999Docket/Case Number:Principal Product Type: Equity Listed (Common & Preferred Stock)Other Product Type(s):Allegations: RESPONDENTS HAD ENGAGED IN ONE OR MORE OF THE FOLLOWINGTYPES OF VIOLATIONS: THE COORDINATION OF QUOTATIONS ANDTRANSACTIONS BY TRADERS MAKING MARKETS IN NASDAQ STOCKS INVIOLATION OF ANTIFRAUD AND FICTITIOUS QUOTATION RULES,THE INTENTIONAL DELAY OF TRADE REPORTS, OTHER MANIPULATIVEACTIVITY, AND FAILURE TO HONOR QUOTED PRICES.Current Status: FinalResolution Date: 01/11/1999Resolution:Other Sanctions Ordered: WITHIN 90 DAYS OF THE DATE OF THE ENTRY OF THIS ORDER, PROVIDETO THE INDEPENDED CONSULTANT APPOINTED BY THE COMMISSION INCONNECTION WITH THESE PROCEEDINGS (THE "INDEPENDENTCONSULTANT") A DESCRIPTION OF ITS POLICIES, PROCEDURES ANDPRACTICES RELATING TO PREVENTION OR DETECTION OF THE TYPES OFIMPROPER CONDUCT.Sanction Details: CIVIL PENALTY IN THE AMOUNT OF $350,000.00; DISGORGEMENT IN THEAMOUNT OF $864.00Regulator Statement [TOP]02/11/99 SEC NEWS DIGEST, ISSUE NO. 99-6, 1/11/99;SEC TODAY ANNOUNCED THE INSTITUTION OF ADMINISTRATIVEPROCEEDINGS AGAINST 28 NASDAQ MARKET MAKING FIRMS AND 51INDIVIDUALS PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIESEXCHANGE ACT OF 1934. THE ORDERS FOUND THAT THE RESPONDENTSHAD ENGAGED IN ONE OR MORE OF THE FOLLOWING TYPES OFVIOLATIONS: THE COORDINATION OF QUOTATIONS AND TRANSACTIONSBY TRADERS MAKING MARKETS IN NASDAQ STOCKS IN VIOLATION OFANTIFRAUD AND FICTITIOUS QUOTATION RULES,THE INTENTIONAL DELAY OF TRADE REPORTS, OTHER MANIPULATIVEACTIVITY, AND FAILURE TO HONOR QUOTED PRICES. (RELS. 34-40900THROUGH 34-40930, INCLUSIVE; IA-1781; FILE NO. 3-9803); (PRESS REL. 99-2) ***2/11/99 SEC ADMINISTRATIVE PROCEEDING FILE NO. 3-9803 1/11/99SEC HAS DECIDED TO ACCEPT THE RESPONDENTS' OFFERS ANDACCORDINGLY IS ISSUING THIS ORDER. SEC FINDS THE FOLLOWING:PIPER TRADED NASDAQ STOCKS FOR ITS OWN ACCOUNTS AND FOR THEACCOUNTS OF INSTITUTIONAL AND RETAIL INVESTORS. IT IS HEREBYORDERED, PURSUANT TO SECTIONS 15(B) AND 21C OF THE EXCHANGEACT, THAT: (1) PIPER SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATION OF, AND COMMITTING OR CAUSING ANYFUTURE VIOLATION OF, SECTIONS 15(C)(1) AND (2), AND 17(A) OF THEEXCHANGE ACT, AND RULES 15C1-2, 15C2-7, AND 17A-3 THEREUNDER; (2)SHALL, PAY A CIVIL PENALTY IN THE AMOUNT OF $350,000.00 WITHIN 10BUSINESS DAYS; (3) SHALL, PAY DISGORGEMENT IN THE AMOUNT OF$864.00 WITHIN 10 BUSINESS DAYS PURSUANT TO SECTION 21C(E) OF THEEXCHANGE ACT. (4) PIPER SHALL, WITHIN 90 DAYS OF THE DATE OF THEENTRY OF THIS ORDER, PROVIDE TO THE INDEPENDED CONSULTANTAPPOINTED BY THE COMMISSION IN CONNECTION WITH THESEPROCEEDINGS (THE "INDEPENDENT CONSULTANT") A DESCRIPTION OFITS POLICIES, PROCEDURES AND PRACTICES RELATING TO PREVENTIONOR DETECTION OF THE TYPES OF IMPROPER CONDUCT. (REL. NO. 34-40920, FILE NO. 3-9803)Sanctions Ordered: Disgorgement/RestitutionCease and Desist/InjunctionDecision & Order of Offer of Settlement2502018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User Guidance[TOP]02/11/99 SEC NEWS DIGEST, ISSUE NO. 99-6, 1/11/99;SEC TODAY ANNOUNCED THE INSTITUTION OF ADMINISTRATIVEPROCEEDINGS AGAINST 28 NASDAQ MARKET MAKING FIRMS AND 51INDIVIDUALS PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIESEXCHANGE ACT OF 1934. THE ORDERS FOUND THAT THE RESPONDENTSHAD ENGAGED IN ONE OR MORE OF THE FOLLOWING TYPES OFVIOLATIONS: THE COORDINATION OF QUOTATIONS AND TRANSACTIONSBY TRADERS MAKING MARKETS IN NASDAQ STOCKS IN VIOLATION OFANTIFRAUD AND FICTITIOUS QUOTATION RULES,THE INTENTIONAL DELAY OF TRADE REPORTS, OTHER MANIPULATIVEACTIVITY, AND FAILURE TO HONOR QUOTED PRICES. (RELS. 34-40900THROUGH 34-40930, INCLUSIVE; IA-1781; FILE NO. 3-9803); (PRESS REL. 99-2) ***2/11/99 SEC ADMINISTRATIVE PROCEEDING FILE NO. 3-9803 1/11/99SEC HAS DECIDED TO ACCEPT THE RESPONDENTS' OFFERS ANDACCORDINGLY IS ISSUING THIS ORDER. SEC FINDS THE FOLLOWING:PIPER TRADED NASDAQ STOCKS FOR ITS OWN ACCOUNTS AND FOR THEACCOUNTS OF INSTITUTIONAL AND RETAIL INVESTORS. IT IS HEREBYORDERED, PURSUANT TO SECTIONS 15(B) AND 21C OF THE EXCHANGEACT, THAT: (1) PIPER SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATION OF, AND COMMITTING OR CAUSING ANYFUTURE VIOLATION OF, SECTIONS 15(C)(1) AND (2), AND 17(A) OF THEEXCHANGE ACT, AND RULES 15C1-2, 15C2-7, AND 17A-3 THEREUNDER; (2)SHALL, PAY A CIVIL PENALTY IN THE AMOUNT OF $350,000.00 WITHIN 10BUSINESS DAYS; (3) SHALL, PAY DISGORGEMENT IN THE AMOUNT OF$864.00 WITHIN 10 BUSINESS DAYS PURSUANT TO SECTION 21C(E) OF THEEXCHANGE ACT. (4) PIPER SHALL, WITHIN 90 DAYS OF THE DATE OF THEENTRY OF THIS ORDER, PROVIDE TO THE INDEPENDED CONSULTANTAPPOINTED BY THE COMMISSION IN CONNECTION WITH THESEPROCEEDINGS (THE "INDEPENDENT CONSULTANT") A DESCRIPTION OFITS POLICIES, PROCEDURES AND PRACTICES RELATING TO PREVENTIONOR DETECTION OF THE TYPES OF IMPROPER CONDUCT. (REL. NO. 34-40920, FILE NO. 3-9803)iReporting Source: FirmInitiated By: SECURITIES & EXCHANGE COMMISSIONDate Initiated: 01/11/1999Docket/Case Number: 3-9803Allegations: IN AN ACTION BROUGHT AGAINST ALMOST ALL THE MAJOR NASDAQMARKET MAKERS, THE SEC FOUND THAT IN 1994, MARKET MAKERS,INCLUDING PIPER JAFFRAY INC., VIOLATED PROVISIONS OF THE FEDERALSECURITIES LAWS IN CONNECTION WITH THEIR MARKET MAKINGACTIVITIES IN NASDAQ SECURITIES.Current Status: Final2512018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:DisgorgementOther Sanction(s)/ReliefSought:Principal Product Type: Equity - OTCOther Product Type(s):Resolution Date: 01/11/1999Resolution:Other Sanctions Ordered: CIVIL PENALTY OF $350000.00 AND PIPER JAFFRAY INC. AGREED TO ADESIST AND DESIST ORDER AND TO SUBMIT CERTAIN OF ITS POLICIES TOAN INDEPENDENT CONSULTANT.Sanction Details: CIVIL PENALTY OF $350,000 WAS PAID ON 1/11/99.Sanctions Ordered: Monetary/Fine $350,000.00Acceptance, Waiver & Consent(AWC)Disclosure 119 of 134iReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 07/20/1998Docket/Case Number: CMS980068 AWCPrincipal Product Type:Other Product Type(s):Allegations:Current Status: FinalResolution Date: 07/20/1998Resolution:Other Sanctions Ordered:Sanction Details:Sanctions Ordered: CensureMonetary/Fine $12,500.00Acceptance, Waiver & Consent(AWC)2522018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceSanction Details:Regulator Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS980068 AWC.ON JULY 20, 1998, PIPER JAFFRAY, INC. (PIPR) WAS NOTIFIED THATTHE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) ITSUBMITTEDWAS ACCEPTED BY NASD REGULATION, INC.'S DEPARTMENT OFENFORCEMENT AND THE NATIONAL ADJUDICATORY COUNCIL. THE AWCALLEGES THAT THE FOLLOWING VIOLATIONS OCCURRED:PIPR FAILED TO EXECUTE 15 PREFERENCED SELECTNET ORDERS WHICHWERE PRESENTED TO PIPR AT PIPR'S PUBLISHED BID OR PUBLISHEDOFFER IN AN AMOUNT EQUAL TO OR LESS THAN ITS PUBLISHEDQUOTATION SIZE AND, THEREFORE, FAILED TO HONOR ITS PUBLISHEDQUOTATION. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCTVIOLATIONS OF SEC RULE 11Ac1-1 ("SEC FIRM QUOTE RULE"), NASDCONDUCT RULE 3320 AND NASD MARKETPLACE RULE 4613(b) ("NASD FIRMQUOTE RULES").PIPR FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTENSUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH THE APPLICABLE SECURITIES LAWS ANDREGULATIONSCONCERNING THE SEC'S FIRM QUOTE RULE AND NASD FIRM QUOTERULES.PIPR WAS CENSURED AND FINED $12,500.******* $12,500 PAID ON 8/27/98, INVOICE NO. 98-MS-675 ****iReporting Source: FirmAllegations: ALLEGED PIPER FAILED TO EXECUTE 15 PREFERENCED SELECTNETORDERS WHICH WERE PRESENTED TO PIPER AT PIPER'S PUBLISHED BIDOR PUBLISHED OFFER IN AN AMOUNT EQUAL TO OR LESS THAN ITSPUBLISHED QUOTATION SIZE AND THEREFORE FAILED TO HONOR ITSPUBLISHED QUOTATION. THIS CONDUCT VIOLATED SEC RULE 11AC1-1("SEC FIRM QUOTE RULE"), NASD CONDUCT RULE 3320 & NASDMARKETPLACE RULE 4613(B) ("NASD FIRM QUOTE RULES"). PIPER FAILEDTO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORYPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHTHE APPLICABLE SECURITIES LAWS AND REGULATIONS CONCERNINGTHE SEC'S FIRM QUOTE RULE AND NASD FIRM QUOTE RULES.Current Status: Final2532018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:FINED $12,500Date Initiated: 07/20/1998Docket/Case Number: CMS980068Principal Product Type: Equity - OTCOther Product Type(s):ALLEGED PIPER FAILED TO EXECUTE 15 PREFERENCED SELECTNETORDERS WHICH WERE PRESENTED TO PIPER AT PIPER'S PUBLISHED BIDOR PUBLISHED OFFER IN AN AMOUNT EQUAL TO OR LESS THAN ITSPUBLISHED QUOTATION SIZE AND THEREFORE FAILED TO HONOR ITSPUBLISHED QUOTATION. THIS CONDUCT VIOLATED SEC RULE 11AC1-1("SEC FIRM QUOTE RULE"), NASD CONDUCT RULE 3320 & NASDMARKETPLACE RULE 4613(B) ("NASD FIRM QUOTE RULES"). PIPER FAILEDTO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORYPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHTHE APPLICABLE SECURITIES LAWS AND REGULATIONS CONCERNINGTHE SEC'S FIRM QUOTE RULE AND NASD FIRM QUOTE RULES.Resolution Date: 08/27/1998Resolution:Other Sanctions Ordered:Sanction Details: $12,500 WAS PAID ON 8/27/98, INVOICE NO. 98-MS-675.Sanctions Ordered: CensureMonetary/Fine $12,500.00Acceptance, Waiver & Consent(AWC)Disclosure 120 of 134iReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 01/08/1998Docket/Case Number: CMS970067 AWCPrincipal Product Type:Other Product Type(s):Allegations:Current Status: FinalResolution: Acceptance, Waiver & Consent(AWC)2542018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceResolution Date: 01/08/1998Resolution:Other Sanctions Ordered:Sanction Details:Regulator Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS970067 AWC.ON JANUARY 8, 1998, PIPER JAFFRAY, INC. (PIPR) WAS NOTIFIEDTHAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) ITSUBMITTED WAS ACCEPTED BY THE NASD REGULATION, INC.'SDEPARTMENT OF ENFORCEMENT AND THE NATIONAL BUSINESSCONDUCTCOMMITTEE. THE AWC ALLEGES THAT THE FOLLOWING VIOLATIONSOCCURRED: PIPR FAILED TO REPORT TO ACT THREE TRANSACTIONS INNASDAQ NATIONAL MARKET SYSTEM SECURITIES THAT IT WAS REQUIREDTO REPORT IN VIOLATION OF NASD MARKETPLACE RULE 4632(a);INCORRECTLY IDENTIFIED AS AGGREGATED ONE TRANSACTION REPORTINA NASDAQ NATIONAL MARKET SECURITY IN VIOLATION OF NASDCONDUCT4632(f); AND FAILED TO DESIGNATE AS LATE TO ACT ONE TRANSACTIONIN A NASDAQ NATIONAL MARKET SYSTEM SECURITY IN VIOLATION OFNASD CONDUCT RULE 4632(a).PIPR FAILED TO CONTEMPORANEOUSLY EXECUTE A CUSTOMERLIMIT ORDER AFTER IT EXECUTED TRANSACTIONS FOR ITS OWN MARKETMAKING ACCOUNT AT PRICES BETTER THAN THE CUSTOMER LIMIT ORDERIN VIOLATION OF NASD CONDUCT RULE 2110 AND IM-2110-2. FINALLY,PIPR FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTENSUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH THE APPLICABLE SECURITIES LAWS ANDREGULATIONSREGARDING TRADE REPORTING AND THE LIMIT ORDER PROTECTIONINTERPRETATION IN VIOLATION OF NASD CONDUCT RULES 2110 AND3010.PIPR WAS CENSURED AND FINED $8,500.****** $8,500 PAID ON 2/25/98, INVOICE NO. 98-MS-163 *******Sanctions Ordered: CensureMonetary/Fine $8,500.00Acceptance, Waiver & Consent(AWC)i2552018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceiReporting Source: FirmInitiated By: NASD REGULATION INC.Principal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:Date Initiated: 08/27/1997Docket/Case Number: CMS970067Principal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGED PIPER JAFFRAY INC. VIOLATED NASD MARKETPLACE RULE4632(A), NASD CONDUCT RULE 2632(F), NASD CONDUCT RULE 4632(A),NASD CONDUCT RULE 2110 AND IM-2110-2 AND NASD CONDUCT RULES2110 AND 3010.Current Status: FinalResolution Date: 01/08/1998Resolution:Other Sanctions Ordered:Sanction Details: FINE OF $8,500 WAS PAID ON 1/8/98.Sanctions Ordered: CensureMonetary/Fine $8,500.00Acceptance, Waiver & Consent(AWC)Disclosure 121 of 134iReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Date Initiated: 02/17/1998Docket/Case Number: CMS970078 AWCPrincipal Product Type:Other Product Type(s):Allegations:Current Status: Final2562018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Resolution Date: 02/17/1998Resolution:Other Sanctions Ordered:Sanction Details:Regulator Statement LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS970078 AWC.ON FEBRUARY 17, 1998, PIPER JAFFRAY, INC. (PIPR) WAS NOTIFIEDTHAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) ITSUBMITTED WAS ACCEPTED BY THE NASD REGULATION, INC.'SDEPARTMENT OF ENFORCEMENT AND THE NATIONAL ADJUDICATORYCOUNCIL. THE AWC ALLEGES THAT THE FOLLOWING VIOLATIONSOCCURRED:PIPR EXECUTED 23 SHORT SALE TRANSACTIONS WITHOUT IDENTIFYINGTHE TRADES AS SHORT SALES IN ITS AUTOMATED CONFIRMATIONTRANSACTION SYSTEM (ACT) REPORTING. THIS CONDUCT CONSTITUTESSEPARATE AND DISTINCT VIOLATIONS OF NASD MARKETPLACE RULE6130(d)(6).PIPR EXECUTED SIX SHORT SALE TRANSACTIONS IN NASDAQ NATIONALMARKET SYSTEM SECURITIES AT OR BELOW THE INSIDE BID WHEN THECURRENT INSIDE BID WAS BELOW THE PRECEDING INSIDE BID IN EACHOF THE SECURITIES. THIS CONDUCT CONSTITUTES SEPARATE ANDDISTINCT VIOLATIONS OF NASD CONDUCT RULE 3350.PIPR FAILED TO ESTABLISH, MAINTAIN AND ENFORCE ADEQUATE WRITTENSUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVECOMPLIANCE FOR NASD CONDUCT RULE 3350 AND NASD MARKETPLACERULES 6130 AND 4700. THIS CONDUCT CONSTITUTES VIOLATIONS OFNASD CONDUCT RULE 3010.PIPR WAS FINED $13,300 AND HAS AGREED TO A REMITTAL OF $7,579IN PROFITS RELATING TO THESE TRANSACTIONS, AND AN UNDERTAKINGTO IMMEDIATELY REVISE ITS WRITTEN SUPERVISORY PROCEDURESRELATING TO THE SHORT SALE AND SOES RULES.**$20,897.00 PAID ON 5/6/98, INVOICE # 98-MS-357**Sanctions Ordered: Monetary/Fine $13,300.00Disgorgement/RestitutionAcceptance, Waiver & Consent(AWC)2572018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceLETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. CMS970078 AWC.ON FEBRUARY 17, 1998, PIPER JAFFRAY, INC. (PIPR) WAS NOTIFIEDTHAT THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) ITSUBMITTED WAS ACCEPTED BY THE NASD REGULATION, INC.'SDEPARTMENT OF ENFORCEMENT AND THE NATIONAL ADJUDICATORYCOUNCIL. THE AWC ALLEGES THAT THE FOLLOWING VIOLATIONSOCCURRED:PIPR EXECUTED 23 SHORT SALE TRANSACTIONS WITHOUT IDENTIFYINGTHE TRADES AS SHORT SALES IN ITS AUTOMATED CONFIRMATIONTRANSACTION SYSTEM (ACT) REPORTING. THIS CONDUCT CONSTITUTESSEPARATE AND DISTINCT VIOLATIONS OF NASD MARKETPLACE RULE6130(d)(6).PIPR EXECUTED SIX SHORT SALE TRANSACTIONS IN NASDAQ NATIONALMARKET SYSTEM SECURITIES AT OR BELOW THE INSIDE BID WHEN THECURRENT INSIDE BID WAS BELOW THE PRECEDING INSIDE BID IN EACHOF THE SECURITIES. THIS CONDUCT CONSTITUTES SEPARATE ANDDISTINCT VIOLATIONS OF NASD CONDUCT RULE 3350.PIPR FAILED TO ESTABLISH, MAINTAIN AND ENFORCE ADEQUATE WRITTENSUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVECOMPLIANCE FOR NASD CONDUCT RULE 3350 AND NASD MARKETPLACERULES 6130 AND 4700. THIS CONDUCT CONSTITUTES VIOLATIONS OFNASD CONDUCT RULE 3010.PIPR WAS FINED $13,300 AND HAS AGREED TO A REMITTAL OF $7,579IN PROFITS RELATING TO THESE TRANSACTIONS, AND AN UNDERTAKINGTO IMMEDIATELY REVISE ITS WRITTEN SUPERVISORY PROCEDURESRELATING TO THE SHORT SALE AND SOES RULES.**$20,897.00 PAID ON 5/6/98, INVOICE # 98-MS-357**iReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERSPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:CIVIL AND ADMINISTRATIVE PENALTIES/FINESDate Initiated: 05/23/1996Docket/Case Number: CMS970078Principal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGES PIPER JAFFRAY, DURING APRIL 1996, VIOLATED CONDUCT RULE3350 AND RULE 3010 AND FAILED TO ESTABLISH, MAINTAIN AND ENFORCEADEQUATE WRITTEN SUPERVISORY PROCEDURES REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH CONDUCT RULE 3350 ANDMARKETPLACE RULES 6130 & 4700.Current Status: FinalResolution Date: 02/17/1998Resolution:Other Sanctions Ordered: A REMITTAL OF $7,597 IN PROFITS RELATING TO THE TRANSACTIONSLISTED IN THE AWAC AND AN UNDERTAKING TO IMMEDIATELY REVISE ITSWRITTEN SUPERVISORY PROCEDURES RELATING TO SHORT SALES &SOES RULES.Sanction Details: FINE OF $13,300, REMITTAL OF $7,597 IN PROFITS AND WRITTENSUPERVISORY PROCEDURES TO SHORT SALES & SOES RULES WERECOMPLETED.Sanctions Ordered: Monetary/Fine $13,300.00Acceptance, Waiver & Consent(AWC)Disclosure 122 of 134iReporting Source: RegulatorAllegations:Current Status: Final2582018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 12/15/1997Docket/Case Number: CAF970007Principal Product Type:Other Product Type(s):Allegations:Resolution Date: 12/15/1997Resolution:Other Sanctions Ordered:Sanction Details:Regulator Statement ON DECEMBER 15, 1997, THE DEPARTMENT OF ENFORCEMENT NOTIFIEDRESPONDENT PIPER JAFFREY INC. THAT THE LETTER OF ACCEPTANCE,WAIVER AND CONSENT NO. CAF970007 WAS ACCEPTED; THEREFORE THEFIRM IS CENSURED AND FINED $10,000 - (MSRB RULES G-8(a)(xv) ANDG-36 - RESPONDENT MEMBER SERVED AS SOLE OR MANAGINGUNDERWRITERIN PRIMARY OFFERINGS OF MUNICIPAL SECURITIES AND FAILED TOTIMELY SUBMIT OFFICIAL STATEMENTS AND/OR OTHER DOCUMENTS TOTHEMSRB; AND FAILED TO MAINTAIN RECORDS).Sanctions Ordered: CensureMonetary/Fine $10,000.00Acceptance, Waiver & Consent(AWC)iReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERSDate Initiated: 10/30/1997Docket/Case Number: CAF970007Principal Product Type: Debt - GovernmentAllegations: ALLEGED VIOLATION OF MSRB RULES G-36 AND G8(A)(XV).Current Status: Final2592018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:Principal Product Type: Debt - GovernmentOther Product Type(s): DEBT - MUNICIPALResolution Date: 12/12/1997Resolution:Other Sanctions Ordered:Sanction Details: FINE OF $10,000 WAS PAID ON 12/12/97.Sanctions Ordered: CensureMonetary/Fine $10,000.00Acceptance, Waiver & Consent(AWC)Disclosure 123 of 134iReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 04/23/1997Docket/Case Number: CMS960211 AWCPrincipal Product Type:Other Product Type(s):Allegations:Current Status: FinalResolution Date: 04/23/1997Resolution:Other Sanctions Ordered:Sanction Details:Regulator Statement LETTER OF ACCEPTANCE, WAIVER & CONSENT NO. CMS960211 AWC.ON APRIL 23, 1997, PIPER JAFFRAY INC. (PIPR) WAS NOTIFIED THATTHE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) ITSUBMITTEDWAS ACCEPTED BY THE MARKET REGULATION AND THE NATIONALBUSINESSCONDUCT COMMITTEES. THE AWC ALLEGES THAT PIPR VIOLATEDMARKETPLACE RULE 4613(e) FOR ENTERING OR MAINTAININGQUOTATIONSTHE NASDAQ STOCK MARKET, DURING NORMAL BUSINESS HOURS,WHICHCAUSED A LOCKED AND/OR CROSSED MARKET CONDITION TO OCCUR INTHREE SECURITIES.PIPR WAS FINED $3,000.***$3,000.00 PAID ON 5/13/97, INVOICE #97-MS-464***Sanctions Ordered: Monetary/Fine $3,000.00Acceptance, Waiver & Consent(AWC)2602018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceRegulator Statement LETTER OF ACCEPTANCE, WAIVER & CONSENT NO. CMS960211 AWC.ON APRIL 23, 1997, PIPER JAFFRAY INC. (PIPR) WAS NOTIFIED THATTHE LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) ITSUBMITTEDWAS ACCEPTED BY THE MARKET REGULATION AND THE NATIONALBUSINESSCONDUCT COMMITTEES. THE AWC ALLEGES THAT PIPR VIOLATEDMARKETPLACE RULE 4613(e) FOR ENTERING OR MAINTAININGQUOTATIONSTHE NASDAQ STOCK MARKET, DURING NORMAL BUSINESS HOURS,WHICHCAUSED A LOCKED AND/OR CROSSED MARKET CONDITION TO OCCUR INTHREE SECURITIES.PIPR WAS FINED $3,000.***$3,000.00 PAID ON 5/13/97, INVOICE #97-MS-464***iReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERSPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:CIVIL AND ADMINISTRATIVE PENALTIES/FINESDate Initiated: 12/20/1996Docket/Case Number: CMS96022Principal Product Type: Equity - OTCOther Product Type(s):Allegations: THE COMMITTEE ALLEGED PIPER JAFFRAY INC. VIOLATED MARKETPLACERULE 4613(E) BY ENTERING OR MAINTAINING QUOTATIONS IN THENASDAQ STOCK MARKET DURING NORMAL BUSINESS HOURS WHICHCAUSED A LOCKED AND/OR CROSSED MARKET CONDITION TO OCCUR INTHEIR SECURITIES.Current Status: FinalResolution Date: 05/08/1997Resolution:Sanctions Ordered: Monetary/Fine $3,000.00Acceptance, Waiver & Consent(AWC)2612018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions Ordered: TO CONDUCT A RULE EDUCATION CLASS FOR ITS TRADERS.Sanction Details: FINE OF $3,000 WAS PAID AND A RULE EDUCATION CLASS WASCOMPLETED FOR THE TRADERS.Sanctions Ordered: Monetary/Fine $3,000.00Disclosure 124 of 134iReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 11/18/1996Docket/Case Number: CMS960244Principal Product Type:Other Product Type(s):Allegations:Current Status: FinalResolution Date: 04/29/1997Resolution:Other Sanctions Ordered:Sanction Details:Regulator Statement COMPLAINT NO. CMS960244 WAS FILED BY THE MARKET SURVEILLANCECOMMITTEE ON NOVEMBER 18, 1996 ALLEGING VIOLATIONS OFMARKETPLACE RULE 4513(D).THE MARKET REGULATION COMMITTEE ISSUED A DECISION AND ORDEROFACCEPTANCE OF RESPONDENT PIPER JAFFREY, INC.'S OFFER OFSETTLEMENT IN COMPLAINT NO. CMS960244 ON APRIL 29, 1997. THECOMMITTEE FOUND THAT PIPR VIOLATED MARKETPLACE RULE 4613(D),ASALLEGED IN THE COMPLAINT. PIPR IS FINED $1,000.***$1,000.00 PAID ON 6/9/97, INVOICE #97-MS-369***Sanctions Ordered: Monetary/Fine $1,000.00Decision & Order of Offer of Settlement2622018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceCOMPLAINT NO. CMS960244 WAS FILED BY THE MARKET SURVEILLANCECOMMITTEE ON NOVEMBER 18, 1996 ALLEGING VIOLATIONS OFMARKETPLACE RULE 4513(D).THE MARKET REGULATION COMMITTEE ISSUED A DECISION AND ORDEROFACCEPTANCE OF RESPONDENT PIPER JAFFREY, INC.'S OFFER OFSETTLEMENT IN COMPLAINT NO. CMS960244 ON APRIL 29, 1997. THECOMMITTEE FOUND THAT PIPR VIOLATED MARKETPLACE RULE 4613(D),ASALLEGED IN THE COMPLAINT. PIPR IS FINED $1,000.***$1,000.00 PAID ON 6/9/97, INVOICE #97-MS-369***iReporting Source: FirmInitiated By: NASD REGULATION, INC. - MARKET SURVEILLANCE COMMITTEEPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:FINE OF $1,000Date Initiated: 11/18/1996Docket/Case Number: CMS960244Principal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGED PJI VIOLATED MARKETPLACE RULE 4613(D) BY ENTERINGQUOTATIONS INTO THE NASDAQ STOCK MARKET WHICH EXCEEDED THEPARAMETERS FOR MAXIMUM ALLOWABLE SPREADS.Current Status: FinalResolution Date: 04/29/1997Resolution:Other Sanctions Ordered:Sanction Details: FINE OF $1,000 WAS PAID ON 4/29/97Sanctions Ordered: Monetary/Fine $1,000.00SettledDisclosure 125 of 134iReporting Source: RegulatorInitiated By: MN DEPT OF COMMERCEDate Initiated: 03/06/1996Docket/Case Number: SE9404156/TMEURL for Regulatory Action:Allegations: FAILURE TO REASONABLY SUPERVISE IN CONNECTIONWITH THE MARKETING OF THE PIPER FUNDS INC INSTITUTIONALGOVERNMENT INCOME PORTFOLIOCurrent Status: Final2632018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:URL for Regulatory Action:Principal Product Type:Other Product Type(s):Resolution Date: 03/06/1996Resolution:Other Sanctions Ordered:Sanction Details: CONSENT TO CENSURE BY PIPER JAFFRAY AND PIPERCAPITAL, CONSENT TO PAY COSTS AND OTHER AMOUNTS, CONSENT TOOTHER PROVISIONSRegulator Statement THE DEPARTMENT ALLEGES THAT PIPER JAFFRAY INCAND PIPER CAPITAL MANAGEMENT INCORPORATED FAILED REASONABLYTOSUPERVISE THEIR RESPECTIVE AGENTS, EMPLOYEES, AND/ORINVESTMENTADVISER REPS IN CONNECTION WITH THE MARKETING OF THE PIPERFUNDS INC INSTITUTIONAL GOVERNMENT INCOME PORTFOLIO AND SUCHFAILURE TO SUPERVISE IS A VIOLATION OF MINN STAT 80A.07, SUBD.1(10). RESPONDENTS WILL, UPON EXECUTION OF THIS ORDER DONATE$200,000 TO THE MN FOOD BANK NETWORK AND $50,000 FOR INVESTOREDUCATION. IT IS ORDERED THAT PIPER JAFFRAY IS CENSURED ANDPIPER CAPITAL MANAGEMENT IS CENSURED. EACH OF THE FIRMS SHALLPAY CIVIL PENALTY OF $150,000, JOINTLY PAY INVESTIGATIVE COSTSOF $100,000,AND EACH FIRM SHALL HIRE A CONSULTANT TO REVIEWPROCEDURES CONCERNING THE MARKETING OF FUNDS MANAGED BYPIPERCAPITAL. PIPER JAFFRAY WAS ORDERED TO DESIGNATE AN EMPLOYEEOFTHE COMPLIANCE DEPT. TO BE RESPONSIBLE FOR STATE COMPLIANCEANDNOTIFY ALL STATES OF THE IDENTITY OF THAT EMPLOYEE. THE FIRMSWERE PROHIBITED FROM ENTERING INTO ANY CIVIL OR OTHERSETTLEMENT WITH CLIENTS OR EMPLOYEES WHICH WOULD LIMIT ORPROHIBIT DISCLOSURE TO REGULATORY AUTHORITIES. PIPER JAFFRAYWAS ORDERED TO UPDATE U-4 FORMS WITHIN 30 DAYS AND TO UPDATE,IF NOT ALREADY DISCLOSED THE U-4 FOR AGENTS OF PIPER JAFFRAYEMPLOYED BY PIPER CAPITAL TO REFLECT SUCH EMPLOYMENT.CONTACT:TERESA FISCHER (612) 296-2594.Sanctions Ordered: CensureConsent2642018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceTHE DEPARTMENT ALLEGES THAT PIPER JAFFRAY INCAND PIPER CAPITAL MANAGEMENT INCORPORATED FAILED REASONABLYTOSUPERVISE THEIR RESPECTIVE AGENTS, EMPLOYEES, AND/ORINVESTMENTADVISER REPS IN CONNECTION WITH THE MARKETING OF THE PIPERFUNDS INC INSTITUTIONAL GOVERNMENT INCOME PORTFOLIO AND SUCHFAILURE TO SUPERVISE IS A VIOLATION OF MINN STAT 80A.07, SUBD.1(10). RESPONDENTS WILL, UPON EXECUTION OF THIS ORDER DONATE$200,000 TO THE MN FOOD BANK NETWORK AND $50,000 FOR INVESTOREDUCATION. IT IS ORDERED THAT PIPER JAFFRAY IS CENSURED ANDPIPER CAPITAL MANAGEMENT IS CENSURED. EACH OF THE FIRMS SHALLPAY CIVIL PENALTY OF $150,000, JOINTLY PAY INVESTIGATIVE COSTSOF $100,000,AND EACH FIRM SHALL HIRE A CONSULTANT TO REVIEWPROCEDURES CONCERNING THE MARKETING OF FUNDS MANAGED BYPIPERCAPITAL. PIPER JAFFRAY WAS ORDERED TO DESIGNATE AN EMPLOYEEOFTHE COMPLIANCE DEPT. TO BE RESPONSIBLE FOR STATE COMPLIANCEANDNOTIFY ALL STATES OF THE IDENTITY OF THAT EMPLOYEE. THE FIRMSWERE PROHIBITED FROM ENTERING INTO ANY CIVIL OR OTHERSETTLEMENT WITH CLIENTS OR EMPLOYEES WHICH WOULD LIMIT ORPROHIBIT DISCLOSURE TO REGULATORY AUTHORITIES. PIPER JAFFRAYWAS ORDERED TO UPDATE U-4 FORMS WITHIN 30 DAYS AND TO UPDATE,IF NOT ALREADY DISCLOSED THE U-4 FOR AGENTS OF PIPER JAFFRAYEMPLOYED BY PIPER CAPITAL TO REFLECT SUCH EMPLOYMENT.CONTACT:TERESA FISCHER (612) 296-2594.iReporting Source: FirmInitiated By: MINNESOTA DEPARTMENT OF COMMERCE (DOC)Principal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:Date Initiated: 06/09/1994Docket/Case Number: UNKNOWNPrincipal Product Type: Mutual Fund(s)Other Product Type(s):Allegations: THE JOINT INVESTIGATION BY THE NASD & DOC PRIMARILY RELATED TODISCLOSURES AND SALES PRACTICES PERTAINING TO THE SALE OFPIPER FUNDS INC. INSTITUTIONAL GOVERNMENT PORTFOLIO.Current Status: FinalResolution Date: 03/06/1996Resolution:Other Sanctions Ordered: JOINT PAYMENT OF $100,000 WITH PIPER CAPITAL MANAGEMENT FORINVESTIGATIVE COSTS, $200,000 TO BE DONATED TO THE MINNESOTAFOOD BANK NETWORK AND $50,000 TO BE PAID TO THE BUSINESSEDUCATION FUND.Sanction Details: FINE OF $150,000, JOINT PAYMENT OF $100,000 WITH PIPER CAPITALMANAGEMENT, $200,000 TO THE MINNESOTA FOOD BANK NETWORK ND$50,000 TO THE BUSINESS EDUCATION FUND WAS PAID ON 3/6/96.Sanctions Ordered: CensureMonetary/Fine $150,000.00OrderDisclosure 126 of 134iReporting Source: RegulatorAllegations:Current Status: Final2652018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 02/02/1996Docket/Case Number: CMS950076 AWCPrincipal Product Type:Other Product Type(s):Resolution Date: 02/02/1996Resolution:Other Sanctions Ordered:Sanction Details:Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT NO. CMS950076 AWCLETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED BY THE MARKETSURVEILLANCE COMMITTEE (MSC) AGAINST PIPER, JAFFRAY, INC.(PIPR) ALLEGING A VIOLATION OF SEC RULE 10b-6A IN THAT PIPR, APASSIVE MARKET MAKER IN A COMMON STOCK, EXCEEDED ITS 30% ADTVLIMIT AND DID NOT IMMEDIATELY REMOVE ITS QUOTES FROM THENASDAQWORKSTATION. PIPR IS ALSO ALLEGEDLY IN VIOLATION OF ARTICLEIII, SECTIONS 1 AND 27 OF THE NASD'S RULES OF FAIR PRACTICE FORFAILING TO ENFORCE SUPERVISORY PROCEDURES TO PREVENT THEVIOLATION DESCRIBED ABOVE.AS SANCTIONS, THE MSC CENSURED AND FINED PIPR $1,000. THE AWCBECAME FINAL ON FEBRUARY 2, 1996.**$1,000.00 PAID ON 02/29/96, INVOICE #96-MS-124**Sanctions Ordered: CensureMonetary/Fine $1,000.00ConsentiReporting Source: FirmAllegations: NASD ALLEGED VIOLATION OF SEC RULE 10B-6A (IN CONNECTION WITHITS PASSIVE MARKET MAKING POLICY)Current Status: Final2662018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERSPrincipal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:FINE OF $1,000Date Initiated: 10/06/1994Docket/Case Number: CM950076 AWCPrincipal Product Type: Equity - OTCOther Product Type(s):Allegations: NASD ALLEGED VIOLATION OF SEC RULE 10B-6A (IN CONNECTION WITHITS PASSIVE MARKET MAKING POLICY)Resolution Date: 02/02/1996Resolution:Other Sanctions Ordered:Sanction Details: FINE OF $1,000 WAS PAID ON 2/2/96Sanctions Ordered: CensureMonetary/Fine $1,000.00Acceptance, Waiver & Consent(AWC)Disclosure 127 of 134iReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Date Initiated: 07/13/1992Docket/Case Number: C3B920023Principal Product Type: No ProductAllegations: ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 2, 15(B) AND 27 OF THERULES OF FAIR PRACTICE IN THAT STOVER RECOMMENDED SECURITIESTRANSACTIONS IN CUSTOMER ACCOUNTS WITHOUT REASONABLYBELIEVING THEY WERE SUITABLE IN VIEW OF THEIR NATURE AND THECUSTOMER'S FINANCIAL SITUATION AND NEEDS; EXERCISED DISCRETIONIN CUSTOMER ACCOUNTS WITHOUT OBTAINING PRIOR WRITTENAUTHORITY FROM THE CUSTOMER AND BY HIS MEMBER FIRM; AND,RESPONDENT MEMBER FAILED TO CREATE ADEQUATE SUPERVISORYPROCEDURES, AND FAILED TOENSURE THAT BROTHERTON WASPERFORMING HIS SUPERVISORY RESPONSIBILITIES OVER STOVER.Current Status: Final2672018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Principal Product Type: No ProductOther Product Type(s):Resolution Date: 01/04/1993Resolution:Other Sanctions Ordered:Sanction Details: OFFER OF SETTLEMENT SUBMITTED BY PIPER AND BROTHERTON WASACCEPTED; THEREFORE, PIPER IS CENSURED AND FINED $35,000.Regulator Statement [TOP]COMPLAINT NO. C3B920023 (DISTRICT NO. 3) FILED 7/13/92 AGAINST RESPONDENTS PIPER JAFFRAY, INC., DANIEL FRANCIS BROTHERTON, AND DAVID THOMAS STOVER ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 2, 15(B) AND 27 OF THE RULES OF FAIRPRACTICE IN THAT STOVER RECOMMENDED SECURITIES TRANSACTIONS IN CUSTOMER ACCOUNTS WITHOUT REASONABLYBELIEVING THEY WERE SUITABLE IN VIEW OF THEIR NATURE AND THECUSTOMER'S FINANCIAL SITUATION AND NEEDS; EXERCISED DISCRETIONIN CUSTOMER ACCOUNTS WITHOUT OBTAINING PRIOR WRITTENAUTHORITY FROM THE CUSTOMER AND BY HIS MEMBER FIRM; AND,RESPONDENT MEMBER FAILED TO CREATE ADEQUATE SUPERVISORYPROCEDURES, AND FAILED TOENSURE THAT BROTHERTON WASPERFORMING HIS SUPERVISORY RESPONSIBILITIES OVER STOVER.DECISION RENDERED 1/14/93, WHEREIN THE OFFER OF SETTLEMENTSUBMITTED BY PIPER AND BROTHERTON WAS ACCEPTED; THEREFORE,PIPER IS CENSURED AND FINED $35,000 AND BROTHERTON IS CENSUREDAND FINED $25,000. DECISION RENDERED 5/21/92, OFFER OF SETTLEMENTSUBMITTED BY STOVER WAS ACCEPTED; STOVER CENSURED AND FINED $20,000. STOVER WILL PROVIDE $55,000 INRESTITUTION TO A PUBLIC CUSTOMER AND MUST SUBMIT TO THEDISTRICT NO. 3 STAFF WITHIN 40 DAYS OF THE OFFER. SHOULD THERESTITUTION NOT BE SUBMITTED WITHIN THE REQUIRED TIME PERIOD,RESPONDENT STOVER WILL BE SUSPENDED FROM ASSOCIATION WITHANY MEMBER OF THE NASD UNTIL SUCH TIME AS HE HAS PROVIDEDRESTITUTION SATISFACTORY TO DISTRICT NO. 3 STAFF. IN ADDITION,RESPONDENT STOVER IS SUSPENDED FROM ASSOCIATION WITH ANY NASD MEMBER IN ANY CAPACITY FOR A 30 DAYPERIOD. STOVER MUST REQUALIFY BY EXAMINATION FOR ANYREGISTERED CAPACITY WITHIN 90 DAYS FROM THE DATE OF THISOFFER'S ACCEPTANCE..RECEIVED NOTIFICATION ON JULY 1, 1993, THATRESPONDENT STOVER HAS PAID $55,000 IN RESTITUTION TO THECUSTOMER.Sanctions Ordered: CensureMonetary/Fine $35,000.00Consent2682018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User Guidance[TOP]COMPLAINT NO. C3B920023 (DISTRICT NO. 3) FILED 7/13/92 AGAINST RESPONDENTS PIPER JAFFRAY, INC., DANIEL FRANCIS BROTHERTON, AND DAVID THOMAS STOVER ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 2, 15(B) AND 27 OF THE RULES OF FAIRPRACTICE IN THAT STOVER RECOMMENDED SECURITIES TRANSACTIONS IN CUSTOMER ACCOUNTS WITHOUT REASONABLYBELIEVING THEY WERE SUITABLE IN VIEW OF THEIR NATURE AND THECUSTOMER'S FINANCIAL SITUATION AND NEEDS; EXERCISED DISCRETIONIN CUSTOMER ACCOUNTS WITHOUT OBTAINING PRIOR WRITTENAUTHORITY FROM THE CUSTOMER AND BY HIS MEMBER FIRM; AND,RESPONDENT MEMBER FAILED TO CREATE ADEQUATE SUPERVISORYPROCEDURES, AND FAILED TOENSURE THAT BROTHERTON WASPERFORMING HIS SUPERVISORY RESPONSIBILITIES OVER STOVER.DECISION RENDERED 1/14/93, WHEREIN THE OFFER OF SETTLEMENTSUBMITTED BY PIPER AND BROTHERTON WAS ACCEPTED; THEREFORE,PIPER IS CENSURED AND FINED $35,000 AND BROTHERTON IS CENSUREDAND FINED $25,000. DECISION RENDERED 5/21/92, OFFER OF SETTLEMENTSUBMITTED BY STOVER WAS ACCEPTED; STOVER CENSURED AND FINED $20,000. STOVER WILL PROVIDE $55,000 INRESTITUTION TO A PUBLIC CUSTOMER AND MUST SUBMIT TO THEDISTRICT NO. 3 STAFF WITHIN 40 DAYS OF THE OFFER. SHOULD THERESTITUTION NOT BE SUBMITTED WITHIN THE REQUIRED TIME PERIOD,RESPONDENT STOVER WILL BE SUSPENDED FROM ASSOCIATION WITHANY MEMBER OF THE NASD UNTIL SUCH TIME AS HE HAS PROVIDEDRESTITUTION SATISFACTORY TO DISTRICT NO. 3 STAFF. IN ADDITION,RESPONDENT STOVER IS SUSPENDED FROM ASSOCIATION WITH ANY NASD MEMBER IN ANY CAPACITY FOR A 30 DAYPERIOD. STOVER MUST REQUALIFY BY EXAMINATION FOR ANYREGISTERED CAPACITY WITHIN 90 DAYS FROM THE DATE OF THISOFFER'S ACCEPTANCE..RECEIVED NOTIFICATION ON JULY 1, 1993, THATRESPONDENT STOVER HAS PAID $55,000 IN RESTITUTION TO THECUSTOMER.iReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS INC.Principal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:Date Initiated: 07/13/1992Docket/Case Number: C-3B920021Principal Product Type: No ProductOther Product Type(s):Allegations: DBCC ALLEGED PIPER JAFFRAY INC. FAILED TO SUPERVISE.Current Status: FinalResolution Date: 01/01/1993Resolution:Other Sanctions Ordered:Sanction Details: FINE OF $35,000 WAS PAID IN JANUARY 1993.Sanctions Ordered: Monetary/Fine $35,000.00SettledDisclosure 128 of 134iReporting Source: RegulatorInitiated By: NYSEDate Initiated: 09/06/1991Docket/Case Number: 91-105Principal Product Type:Allegations: SEE SUMMARYCurrent Status: Final2692018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Principal Product Type:Other Product Type(s):Resolution Date: 09/06/1991Resolution:Other Sanctions Ordered:Sanction Details: SEE SUMMARYRegulator Statement PIPER, JAFFRAY & HOPWOOD INCORPORATED, A MEMBERORGANIZATION, VIOLATED EXCHANGE RULE 342(a) IN THAT THE FIRM:1) FAILED TO ESTABLISH AND IMPLEMENT AN APPROPRIATE SYSTEM FORSUPERVISING PRODUCING BRANCH OFFICE MANAGERS, AND 2) FAILEDTOREASONABLY SUPERVISE AND EMPLOYEE UNDER ITS SUPERVISION --CONSENT TO CENSURE, $25,000 FINE, AND A REQUIREMENT THAT THEFIRM ADOPT AND IMPLEMENT PROCEDURES PERTAINING TO THESUPERVISION OF THE ACCOUNTS OF PRODUCING BRANCH OFFICEMANAGERS.Sanctions Ordered: CensureMonetary/Fine $25,000.00ConsentiReporting Source: FirmInitiated By: NEW YORK STOCK EXCHANGE, INC.Principal Sanction(s)/ReliefSought:OtherDate Initiated: 08/01/1988Docket/Case Number: 91-105Principal Product Type: No ProductOther Product Type(s):Allegations: ALLEGED VIOLATION OF EXCHANGE RULE 342(A) IN THAT PIPER, JAFFRAY& HOPWOOD (NKA PIPER JAFFRAY INC.) FAILED TO ESTABLISH ANDIMPLEMENT AN APPROPRIATE SYSTEM FOR SUPERVISING PRODUCINGBRANCH OFFICE MANAGERS AND FAILED TO REASONABLY SUPERVISE ANEMPLOYEE UNDER ITS SUPERVISION.Current Status: Final2702018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:FINE OF $25,000Resolution Date: 07/01/1991Resolution:Other Sanctions Ordered:Sanction Details: FINE OF $25,000 WAS PAID ON 7/1/91.Sanctions Ordered: Monetary/Fine $25,000.00SettledDisclosure 129 of 134iReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 11/13/1989Docket/Case Number: SEA-521Principal Product Type: No ProductOther Product Type(s):Allegations: ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1, 2 AND 27 OF THERULES OF FAIR PRACTICE IN THAT VAN MARLE RECOMMENDED THEPURCHASE AND SALE OF COMMON STOCK, WARRANTS OR RIGHTSWITHOUT REASONABLY BELIEVING THAT SUCH RECOMMENDATIONSWERE SUITABLE FOR CUSTOMERS'; MADE EXAGGERATED ANDMISLEADING STATEMENTS; AND, PIPER FAILED TO ESTABLISH A WRITTENPROCEDURE TO SUPERVISE VAN MARLE'S SALES ACTIVITIES, AND PIPERAND DUNLEAVY FAILED TO REVIEW OR MONITOR THE SALES ACTIVITY BYVAN MARLE TO DETECT THE UNSUITABLE PURCHASES AND SALES MADEIN THE CUSTOMERS' ACCOUNTS.Current Status: FinalResolution Date: 12/27/1990Resolution: Consent2712018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions Ordered:Sanction Details: PIPER'S OFFER OF SETTLEMENT WAS ACCEPTED; THEREFORE, PIPER ISCENSURED AND FINED $10,000. A PORTION OF THE THIRD CAUSE OFCOMPLAINT WAS DISMISSED AS TO PIPER IN THAT IT WAS DETERMINEDTHAT IT DID NOT FAIL TO ESTABLISH A WRITTEN PROCEDURE TOSUPERVISE VAN MARLE.***$10,000.00 PAID ON 1/22/91 INVOICE #91-38-12***Regulator Statement [TOP]COMPLAINT NUMBER SEA-521 (DISTRICT NO. 1) 11/13/89 AGAINSTPIPER, JAFFRAY & HOPWOOD, INC., (PIPER) ANDREW WILLIAM DUNLEAVYAND ANTHONY VAN MARLE ALLEGING VIOLATIONS OF ARTICLE III,SECTIONS 1, 2 AND 27 OF THE RULES OF FAIR PRACTICE IN THAT VANMARLE RECOMMENDED THE PURCHASE AND SALE OF COMMON STOCK,WARRANTS OR RIGHTS WITHOUT REASONABLY BELIEVING THAT SUCHRECOMMENDATIONS WERE SUITABLE FOR CUSTOMERS'; MADEEXAGGERATED AND MISLEADING STATEMENTS; AND, PIPER FAILED TOESTABLISH A WRITTEN PROCEDURE TO SUPERVISE VAN MARLE'S SALESACTIVITIES, AND PIPER AND DUNLEAVY FAILED TO REVIEW OR MONITORTHE SALES ACTIVITY BY VAN MARLE TO DETECT THE UNSUITABLEPURCHASES AND SALES MADE IN THE CUSTOMERS' ACCOUNTS.DECISION RENDERED 9/28/90, WHEREIN VAN MARLE IS CENSURED, FINED$25,000, BARRED FROM ASSOCIATION WITH ANY MEMBER OF THE NASD INANY CAPACITY AND ASSESSED COSTS OF $1,426.74. PIPER ANDDUNLEAVY HAVE SUBMITTED OFFERS OF SETTLEMENT, THEREFORE, ASEPARATE DECISION WILL BE RENDERED. DECISION IS FINAL 11/11/90.DECISION RENDERED 12/27/90, WHEREIN THE OFFER OF SETTLEMENTSUBMITTED BY PIPER AND DUNLEAVY WAS ACCEPTED; THEREFORE,PIPER IS CENSURED AND FINED $10,000. A PORTION OF THE THIRD CAUSEOF COMPLAINT WAS DISMISSED AS TO PIPER IN THAT IT WAS DETERMINED THAT IT DID NOT FAIL TO ESTABLISH A WRITTEN PROCEDURE TO SUPERVISE VAN MARLE. DUNLEAVY WAS DISMISSED INTHAT THE COMMITTEE DETERMINED THAT DURING HIS TENURE AS THEREGIONAL MANAGER RESPONSIBLE FOR RESPONDENT VAN MARLE,THERE WERE NO WRITTEN SUPERVISORY PROCEDURES IN PLACE ANDNO CUSTOMER COMPLAINTS TO ALERT HIM TO ANY POTENTIALPROBLEMS. ***$10,000.00 PAID ON 1/22/91 INVOICE #91-38-12***Sanctions Ordered: CensureMonetary/Fine $10,000.00iReporting Source: FirmAllegations: ALLEGED VIOLATIONS OF ARTICLE III, SECTIONS 1 & 27 OF THEIR RULES(DBCC ALLEGED UNSUITABLE RECOMMENDATIONS, UNFAIR SALESPRACTICES AND LACK OF SUPERVISION).Current Status: Final2722018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SCURITIES DEALERSPrincipal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:Date Initiated: 11/13/1989Docket/Case Number: SEA-521Principal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGED VIOLATIONS OF ARTICLE III, SECTIONS 1 & 27 OF THEIR RULES(DBCC ALLEGED UNSUITABLE RECOMMENDATIONS, UNFAIR SALESPRACTICES AND LACK OF SUPERVISION).Resolution Date: 12/27/1990Resolution:Other Sanctions Ordered:Sanction Details: FINE OF $10,000 WAS PAID ON 12/27/90.Sanctions Ordered: Monetary/Fine $10,000.00SettledDisclosure 130 of 134iReporting Source: RegulatorInitiated By: MINNESOTAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 07/14/1989Docket/Case Number: SE8900799URL for Regulatory Action:Principal Product Type:Other Product Type(s):Allegations:Current Status: FinalResolution: Decision2732018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceResolution Date: 07/14/1989Resolution:Other Sanctions Ordered:Sanction Details:Regulator Statement 8/12/89: FORM U6 (8054-21489) DISCLOSES: RESPONDENT PIPERJAFFRAY & HOPWOOD, INC. WAS CENSURED AND FINED $40,000 FORFAILURE TO PROPERLY SUPERVISE A BRANCH MANAGER, W. MICHAELADAMS, AND FAILED TO PREVENT ABUSES IN CLIENTS ACCOUNTS OFADAMS. DOCKET/CASE #SE8900799, DATED JULY 14, 1989Sanctions Ordered: CensureMonetary/Fine $40,000.00DecisioniReporting Source: FirmInitiated By: STATE OF MINNESOTAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated: 04/01/1988Docket/Case Number: SE8900799Principal Product Type: No ProductOther Product Type(s):Allegations: ALLEGED VIOLATION OF MINNESOTA STAT. 80A.07 SUBD. 1(10)(1988) ANDMINNESOTA RULE PART 2875.0910 SUBP. 3 & 4 (1987)Current Status: FinalResolution Date: 07/10/1989Resolution:Other Sanctions Ordered: $20,000 TO COVER INVESTIGATIVE COSTSSanction Details: $20,000 AND $20,000 INVESTIGATIVE COSTS WERE PAID ON 7/10/89Sanctions Ordered: Monetary/Fine $20,000.00OrderDisclosure 131 of 134i2742018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 04/09/1985Docket/Case Number: MS-121Principal Product Type:Other Product Type(s):Allegations:Current Status: FinalResolution Date: 04/24/1985Resolution:Other Sanctions Ordered:Sanction Details:Regulator Statement 1/13/86: MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-121 SCFILED 4/9/85, ALLEGING VIOLATIONS OF "NO VOLUME". DECISIONRENDERED 4/24/85 WHEREIN THE FIRM WAS FINED $250.00.Sanctions Ordered: Monetary/Fine $250.00DecisioniReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:OtherDate Initiated: 04/01/1985Docket/Case Number: MS-121Principal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGED VIOLATIONS OF "NO VOLUME"Current Status: Final2752018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:FINE OF $250Resolution Date: 04/25/1985Resolution:Other Sanctions Ordered:Sanction Details: FINE OF $250 WAS PAID ON 4/25/85Sanctions Ordered: Monetary/Fine $250.00SettledDisclosure 132 of 134iReporting Source: RegulatorInitiated By: CHICAGO BOARD OF OPTION EXCHANGEPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 01/10/1979Docket/Case Number: 78-0180Principal Product Type:Other Product Type(s):Allegations:Current Status: FinalResolution Date: 04/23/1979Resolution:Other Sanctions Ordered:Sanction Details:Regulator Statement CBOE FILE NO. 78-0180,04/23/79,CONSENTS TO BEING CENSURED AND FINED$1,500.Sanctions Ordered: CensureMonetary/Fine $1,500.00Consent2762018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceCBOE FILE NO. 78-0180,04/23/79,CONSENTS TO BEING CENSURED AND FINED$1,500.iReporting Source: FirmInitiated By: CHICAGO BOARD OPTIONS EXCHANGEPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:FINE OF $1500.00Date Initiated: 01/01/1979Docket/Case Number: 78-0180Principal Product Type: OptionsOther Product Type(s):Allegations: ALLEGED PIPER, JAFFRAY & HOPWOOD INCORPORATED (NKA PIPERJAFFRAY) ACCEPTED ORDERS FROM CLIENTS PRIOR TO A BOM OR ROPAPPROVING THE ACCOUNTS FOR OPTIONS, PJH'S ROP FAILED TOCONFIRM INITIAL BOM APPROVAL OF CLIENT ACCOUNTS FOR OPTIONSWITHIN A REASONABLE TIME, PJH FAILED TO OBTAIN AN OPTIONAGREEMENT WITHIN 15 DAYS AFTER ACCOUNTS WERE APPROVED FOROPTIONS, PJH FAILED TO GIVE CLIENT A CURRENT PROSPECTUS AT ORPRIOR TO TIME ACCOUNT WAS APPROVED.Current Status: FinalResolution Date: 01/01/1979Resolution:Other Sanctions Ordered:Sanction Details: FINE OF $1500.00 WAS PAID.Sanctions Ordered: Monetary/Fine $1,500.00SettledDisclosure 133 of 134iReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Date Initiated: 10/05/1973Allegations:Current Status: Final2772018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 10/05/1973Docket/Case Number: SC-62Principal Product Type:Other Product Type(s):Resolution Date: 12/07/1973Resolution:Other Sanctions Ordered:Sanction Details:Regulator Statement COMPLAINT: #SC-62 FILED 10/05/73.DECISION: 12/07/73: FINAL.FINES & COSTS: 10/26/73: PAIDSanctions Ordered: Monetary/Fine $300.00DecisioniReporting Source: FirmInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:FINE OF $300Date Initiated: 12/01/1973Docket/Case Number: COMPLAINT NO. SC-62Principal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGED PIPER, JAFFRAY & HOPWOOD INCORPORATED (NKA PIPERJAFFRAY) VIOLATED ARTICLE III, SECTION 1 OF THE RULES OF FAIRPRACTICE IN THAT THEY FAILED TO TIMELY FILE THE NECESSARYDOCUMENTS IN CONNECTION WITH AN UNDERWRITING.Current Status: FinalResolution: Settled 2782018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceResolution Date: 12/07/1973Resolution:Other Sanctions Ordered:Sanction Details: FINE OF $300 WAS PAID ON 12/7/73Sanctions Ordered: CensureMonetary/Fine $300.00SettledDisclosure 134 of 134iReporting Source: RegulatorInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated: 03/20/1973Docket/Case Number: AWC-1Principal Product Type:Other Product Type(s):Allegations:Current Status: FinalResolution Date: 09/20/1973Resolution:Other Sanctions Ordered:Sanction Details:Regulator Statement COMPLAINT: #AWC-1 FILED 09/20/73.DECISION: 09/20/73: FINAL.Sanctions Ordered: CensureMonetary/Fine $2,000.00ConsentiReporting Source: FirmAllegations: ALLEGED PIPER, JAFFRAY & HOPWOOD INCORPORATED (NKA PIPERJAFFRAY) VIOLATED ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OFFAIR PRACTICE IN THAT THEY FAILED TO MAKE BONA FIDE PUBLICOFFERINGS IN THE DISTRIBUTION OF NEW ISSUES.Current Status: Final2792018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceInitiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, DISTRICT 1Principal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:FINE OF $2,000Date Initiated: 03/02/1973Docket/Case Number: COMPLAINT NO. AWC-1Principal Product Type: Equity - OTCOther Product Type(s):Allegations: ALLEGED PIPER, JAFFRAY & HOPWOOD INCORPORATED (NKA PIPERJAFFRAY) VIOLATED ARTICLE III, SECTIONS 1 AND 27 OF THE RULES OFFAIR PRACTICE IN THAT THEY FAILED TO MAKE BONA FIDE PUBLICOFFERINGS IN THE DISTRIBUTION OF NEW ISSUES.Resolution Date: 03/02/1973Resolution:Other Sanctions Ordered:Sanction Details: FINE OF $2,000 WAS PAID ON 3/2/73.Sanctions Ordered: CensureMonetary/Fine $2,000.00Settled2802018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceCivil - FinalThis type of disclosure event involves (1) an injunction issued by a foreign or domestic court within the last 10 years inconnection with investment-related activity, (2) a finding by a court of a violation of any investment-related statute orregulation, or (3) an action dismissed by a court pursuant to a settlement agreement.Disclosure 1 of 1Reporting Source: RegulatorInitiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSIONRelief Sought: InjunctionDate Court Action Filed: 04/28/2003Principal Product Type: OtherOther Product Types: EQUITY SECURITIESCourt Details: UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEWYORK, CIVIL ACTION NO. 03 CV 2942 (WHP) (S.D.N.Y.)SEC LITIGATION RELEASE 18118, APRIL 28, 2003: THE SECURITIES ANDEXCHANGE COMMISSION ANNOUNCED THAT IT HAS SETTLED CHARGESAGAINST U.S. BANCORP PIPER JAFFRAY INC., A MINNEAPOLIS,MINNESOTA-BASED BROKERAGE FIRM AND INVESTMENT BANK, ARISINGFROM AN INVESTIGATION OF RESEARCH ANALYST CONFLICTS OFINTEREST. THIS SETTLEMENT, AND SETTLEMENTS WITH NINE OTHERBROKERAGE FIRMS, ARE PART OF THE GLOBAL SETTLEMENT THE FIRMSHAVE REACHED WITH THE COMMISSION, NASD, INC., THE NEW YORKSTOCK EXCHANGE, INC. ("NYSE"), THE NEW YORK ATTORNEY GENERAL,AND OTHER STATE REGULATORS.IN CONNECTION WITH THIS MATTER,THE COMMISSION FILED A COMPLAINT AGAINST PIPER JAFFRAY IN THEU.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK,ALLEGING VIOLATIONS OF THE FEDERAL SECURITIES LAWS AND NASDAND NYSE RULES. ACCORDING TO THE COMMISSION'S COMPLAINT, FROMJUNE 1999 THROUGH 2001, RESEARCH ANALYSTS AT THE FIRM WERESUBJECT TO INAPPROPRIATE INFLUENCE BY INVESTMENT BANKING ATTHE FIRM. THE COMPLAINT ALSO ALLEGES THAT IT MADE PAYMENTS TOOTHER FIRMS FOR THOSE FIRMS TO PUBLISH RESEARCH ON ITSUNDERWRITING CLIENTS WITHOUT ENSURING THAT SUCH PAYMENTSWERE DISCLOSED, AND FAILED TO MAINTAIN APPROPRIATE SUPERVISIONOVER ITS RESEARCH AND INVESTMENT BANKING OPERATIONS.SPECIFICALLY, THE COMMISSION'S COMPLAINT ALLEGES THAT: THE FIRMENGAGED IN ACTS AND PRACTICES THAT CREATED AND MAINTAINEDINAPPROPRIATE INFLUENCE BY INVESTMENT BANKING OVER RESEARCHANALYSTS. MANAGEMENT FAILED TO ADEQUATELY MONITOR ACTIVITIESOF THE FIRM'S RESEARCH AND INVESTMENT BANKING.Allegations:Current Status: Final2812018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceRelief Sought: InjunctionOther Relief Sought: CIVIL PENALTY; DISGORGEMENTResolution: Judgment RenderedResolution Date: 10/31/2003Other Sanctions: $7,500,000 INDEPENDENT RESEARCH,UNDERTAKINGSSanction Details: SEC LITIGATION RELEASE 18438, OCTOBER 31, 2003: THE SECURITIES ANDEXCHANGE COMMISSION ANNOUNCED THAT THE UNITED STATESDISTRICT JUDGE FOR THE SOUTHERN DISTRICT OF NEW YORK, ISSUEDAN ORDER WHEREBY PIPER JAFFRAY IS PERMANENTLY ENJOINED FROMVIOLATIONS OF SECTION 17(B) OF THE SECURITIES ACT OF 1933, NASDRULES 2110, 2210,3010, NYSE RULES 342,401,472,476; WILL PAY $12,500,000AS A PENALTY; $12,500,000 AS DISGORGEMENT OF COMMISSIONS ANDOTHER MONIES; $7,500,000 FOR PROCUREMENT OF INDEPENDENTRESEARCH; AND REQUIRED TO UNDERTAKE REFORMS REGARDINGSEPARATION OF RESEARCH AND INVESTMENT BANKING,DISCLOSURE/TRANSPARENCY AND OTHER ISSUES, AND INDEPENDENT,THIRD-PARTY RESEARCH.Regulator Statement AS PART OF THE SETTLEMENT, THE FIRM HAS AGREED TO PAY $12.5MILLION AS DISGORGEMENT AND AN ADDITIONAL $12.5 MILLION INPENALTIES. ONE-HALF OF THE TOTAL OF THESE PAYMENTS - $12.5MILLION - WILL BE PAID IN CONNECTION WITH THE SEC ACTION ANDRELATED PROCEEDINGS BY NASD AND NYSE AND WILL BE PLACED INTO ADISTRIBUTION FUND FOR THE BENEFIT OF CUSTOMERS OF THE FIRM.THE REMAINDER WILL BE PAID TO RESOLVE RELATED PROCEEDINGS BYSTATE REGULATORS. THE FIRM WILL PAY, OVER FIVE YEARS, $7.5 MILLIONTO PROVIDE THE FIRM'S CLIENTS WITH INDEPENDENT RESEARCH ANDHAS AGREED TO SETTLE THE COMMISSION'S ACTION AND HASCONSENTED, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OFTHE COMPLAINT, TO THE ENTRY OF A FINAL JUDGMENT. THE FIRM HASAGREED TO SETTLE THE COMMISSION'S ACTION AND HAS CONSENTED,WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT,TO THE ENTRY OF A FINAL JUDGMENT THAT, IF APPROVED BY THE COURT,PERMANENTLY ENJOINS THE FIRM FROM VIOLATIONS OF SECTION 17(B)OF THE SECURITIES ACT OF 1933 AND NASD AND NYSE RULESPERTAINING TO JUST AND EQUITABLE PRINCIPLES OF TRADE (NASD RULE2110; NYSE RULES 401 AND 476), ADVERTISING (NASD RULE 2210; NYSERULE 472), AND SUPERVISORY PROCEDURES (NASD RULE 3010; NYSERULE 342). THE FINAL JUDGMENT ALSO ORDERS THE FIRM TO MAKE THEPAYMENTS DESCRIBED ABOVE, AND PROVIDES FOR THE APPOINTMENTOF A FUND ADMINISTRATOR WHO, SUBJECT TO COURT APPROVAL, WILLFORMULATE AND ADMINISTER A PLAN OF DISTRIBUTION FOR THOSEMONIES PLACED INTO A DISTRIBUTION FUND.SEC LITIGATION RELEASE 21457, MARCH 19, 2010: THE HONORABLEJUDGE OF THE UNITED STATES DISTRICT COURT FOR THE SOUTHERNDISTRICT OF NEW YORK ISSUED AN ORDER ON MARCH 15, 2010APPROVING MODIFICATIONS TO THE FINAL JUDGMENTS ENTEREDAGAINST THE DEFENDANT AND OTHERS. THE FINAL JUDGMENTSCONTAINED AN EXTENSIVE ADDENDUM WITH PROVISIONS MANDATINGSTRUCTURAL AND OTHER REFORMS THAT ADDRESSED POTENTIALCONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS ANDINVESTMENT BANKING. THE SETTLEMENT PROVIDED THAT WITHRESPECT TO ANY PROVISION THAT HAD NOT BEEN EXPRESSLYSUPERSEDED BY SUBSEQUENT RULEMAKING WITHIN FIVE YEARS, THESEC WOULD AGREE TO AN AMENDMENT/MODIFICATION OF SUCH TERM,SUBJECT TO COURT APPROVAL, UNLESS THE SEC BELIEVES IT WOULDNOT BE IN THE PUBLIC INTEREST. THE COURT APPROVED REMOVING ANUMBER OF PROVISIONS. THE ADDENDUM NO LONGER INCLUDESPROHIBITIONS AGAINST INVESTMENT BANKING INPUT INTO RESEARCHANALYST COMPENSATION AND THE BAR AGAINST RESEARCH ANALYSTSPARTICIPATING IN EFFORTS TO SOLICIT INVESTMENT BANKING BUSINESS,AMONG OTHER THINGS. THE MODIFIED ADDENDUM AS ORDERED BY THECOURT AND SUPPORTED BY THE SEC MAINTAINED THE REQUIREMENTTHAT A CHAPERONE FROM LEGAL OR COMPLIANCE BE PRESENT WHENINVESTMENT BANKING SEEKS THE VIEWS OF RESEARCH ANALYSTSCONCERNING A PROPOSED TRANSACTION OR A POTENTIAL CANDIDATEFOR A TRANSACTION. ONE PROPOSED MODIFICATION WOULD HAVEALLOWED INVESTMENT BANKING TO SEEK THE VIEWS OF RESEARCHANALYSTS REGARDING MARKET OR INDUSTRY TRENDS, CONDITIONS, ORDEVELOPMENTS WITHOUT THE REQUIREMENT OF A CHAPERONE,SUBJECT TO CERTAIN LIMITATIONS INCLUDING THE IMPLEMENTATION OFCONTROLS AND TRAINING AS DESCRIBED IN THE NOVEMBER 30, 2009LETTER TO THE COURT FROM THE SETTLING FIRMS. IN HIS MARCH 15,2010 ORDER, THE HONORABLE JUDGE DID NOT APPROVE THISPROPOSED MODIFICATION. AS A RESULT OF THE COURT'S ORDER, THEDEFENDANT REMAINS SUBJECT TO A NUMBER OF IMPORTANTRESTRICTIONS THAT APPLY ONLY TO IT AND OTHER FIRMS AFFECTED BYTHE FINAL JUDGMENTS AND SETTLEMENT. TOGETHER WITH THE RESTOF THE INDUSTRY, THEY ALSO REMAIN SUBJECT TO ALL OF THEPROVISIONS OF NASD RULE 2711, NYSE RULE 472, AND THE SEC'SREGULATION AC THAT ADDRESS RESEARCH ANALYST CONFLICTS OFINTEREST.Monetary/Fine $12,500,000.00Disgorgement/RestitutionCease and Desist/InjunctionSanctions Ordered or ReliefGranted:2822018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceAS PART OF THE SETTLEMENT, THE FIRM HAS AGREED TO PAY $12.5MILLION AS DISGORGEMENT AND AN ADDITIONAL $12.5 MILLION INPENALTIES. ONE-HALF OF THE TOTAL OF THESE PAYMENTS - $12.5MILLION - WILL BE PAID IN CONNECTION WITH THE SEC ACTION ANDRELATED PROCEEDINGS BY NASD AND NYSE AND WILL BE PLACED INTO ADISTRIBUTION FUND FOR THE BENEFIT OF CUSTOMERS OF THE FIRM.THE REMAINDER WILL BE PAID TO RESOLVE RELATED PROCEEDINGS BYSTATE REGULATORS. THE FIRM WILL PAY, OVER FIVE YEARS, $7.5 MILLIONTO PROVIDE THE FIRM'S CLIENTS WITH INDEPENDENT RESEARCH ANDHAS AGREED TO SETTLE THE COMMISSION'S ACTION AND HASCONSENTED, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OFTHE COMPLAINT, TO THE ENTRY OF A FINAL JUDGMENT. THE FIRM HASAGREED TO SETTLE THE COMMISSION'S ACTION AND HAS CONSENTED,WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT,TO THE ENTRY OF A FINAL JUDGMENT THAT, IF APPROVED BY THE COURT,PERMANENTLY ENJOINS THE FIRM FROM VIOLATIONS OF SECTION 17(B)OF THE SECURITIES ACT OF 1933 AND NASD AND NYSE RULESPERTAINING TO JUST AND EQUITABLE PRINCIPLES OF TRADE (NASD RULE2110; NYSE RULES 401 AND 476), ADVERTISING (NASD RULE 2210; NYSERULE 472), AND SUPERVISORY PROCEDURES (NASD RULE 3010; NYSERULE 342). THE FINAL JUDGMENT ALSO ORDERS THE FIRM TO MAKE THEPAYMENTS DESCRIBED ABOVE, AND PROVIDES FOR THE APPOINTMENTOF A FUND ADMINISTRATOR WHO, SUBJECT TO COURT APPROVAL, WILLFORMULATE AND ADMINISTER A PLAN OF DISTRIBUTION FOR THOSEMONIES PLACED INTO A DISTRIBUTION FUND.SEC LITIGATION RELEASE 21457, MARCH 19, 2010: THE HONORABLEJUDGE OF THE UNITED STATES DISTRICT COURT FOR THE SOUTHERNDISTRICT OF NEW YORK ISSUED AN ORDER ON MARCH 15, 2010APPROVING MODIFICATIONS TO THE FINAL JUDGMENTS ENTEREDAGAINST THE DEFENDANT AND OTHERS. THE FINAL JUDGMENTSCONTAINED AN EXTENSIVE ADDENDUM WITH PROVISIONS MANDATINGSTRUCTURAL AND OTHER REFORMS THAT ADDRESSED POTENTIALCONFLICTS OF INTEREST BETWEEN EQUITY RESEARCH ANALYSTS ANDINVESTMENT BANKING. THE SETTLEMENT PROVIDED THAT WITHRESPECT TO ANY PROVISION THAT HAD NOT BEEN EXPRESSLYSUPERSEDED BY SUBSEQUENT RULEMAKING WITHIN FIVE YEARS, THESEC WOULD AGREE TO AN AMENDMENT/MODIFICATION OF SUCH TERM,SUBJECT TO COURT APPROVAL, UNLESS THE SEC BELIEVES IT WOULDNOT BE IN THE PUBLIC INTEREST. THE COURT APPROVED REMOVING ANUMBER OF PROVISIONS. THE ADDENDUM NO LONGER INCLUDESPROHIBITIONS AGAINST INVESTMENT BANKING INPUT INTO RESEARCHANALYST COMPENSATION AND THE BAR AGAINST RESEARCH ANALYSTSPARTICIPATING IN EFFORTS TO SOLICIT INVESTMENT BANKING BUSINESS,AMONG OTHER THINGS. THE MODIFIED ADDENDUM AS ORDERED BY THECOURT AND SUPPORTED BY THE SEC MAINTAINED THE REQUIREMENTTHAT A CHAPERONE FROM LEGAL OR COMPLIANCE BE PRESENT WHENINVESTMENT BANKING SEEKS THE VIEWS OF RESEARCH ANALYSTSCONCERNING A PROPOSED TRANSACTION OR A POTENTIAL CANDIDATEFOR A TRANSACTION. ONE PROPOSED MODIFICATION WOULD HAVEALLOWED INVESTMENT BANKING TO SEEK THE VIEWS OF RESEARCHANALYSTS REGARDING MARKET OR INDUSTRY TRENDS, CONDITIONS, ORDEVELOPMENTS WITHOUT THE REQUIREMENT OF A CHAPERONE,SUBJECT TO CERTAIN LIMITATIONS INCLUDING THE IMPLEMENTATION OFCONTROLS AND TRAINING AS DESCRIBED IN THE NOVEMBER 30, 2009LETTER TO THE COURT FROM THE SETTLING FIRMS. IN HIS MARCH 15,2010 ORDER, THE HONORABLE JUDGE DID NOT APPROVE THISPROPOSED MODIFICATION. AS A RESULT OF THE COURT'S ORDER, THEDEFENDANT REMAINS SUBJECT TO A NUMBER OF IMPORTANTRESTRICTIONS THAT APPLY ONLY TO IT AND OTHER FIRMS AFFECTED BYTHE FINAL JUDGMENTS AND SETTLEMENT. TOGETHER WITH THE RESTOF THE INDUSTRY, THEY ALSO REMAIN SUBJECT TO ALL OF THEPROVISIONS OF NASD RULE 2711, NYSE RULE 472, AND THE SEC'SREGULATION AC THAT ADDRESS RESEARCH ANALYST CONFLICTS OFINTEREST.iReporting Source:2832018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceReporting Source: FirmInitiated By: SECURITIES AND EXCHANGE COMMISSIONRelief Sought: Civil Penalty(ies)/Fine(s)Other Relief Sought: DISGORGEMENTDate Court Action Filed: 04/28/2003Principal Product Type: OtherOther Product Types: RESEARCHCourt Details: UNITED STATES DISTRICT COURT, SOUTHERN DISTRICT OF NEW YORK;CASE NO. 03 CV 2942IT WAS ALLEGED THAT U.S. BANCORP PIPER JAFFRAY VIOLATED SECTION17(B) OF THE SECURITIES EXCHANGE ACT OF 1934, NASD CONDUCT RULE2110 AND NYSE RULES 401 AND 476 BY ENGAGING IN CONDUCTINCONSISTENT WITH JUST & EQUITABLE PRINCIPLES OF TRADE BY A)ENGAGING IN ACTS & PRACTICES THAT CREATED OR MAINTAINEDINAPPROPRIATE INFLUENCE BY THE INVESTMENT BANKING DEPARTMENTOVER RESEARCH ANALYSTS THEREFORE IMPOSING CONFLICTS OFINTEREST ON ITS RESEARCH ANALYSTS & FAILING TO MANAGE THESECONFLICTS IN ADEQUATE OR APPROPRIATE MANNER; B)THREATENING TODROP RESEARCH COVERAGE IF THE FIRM WAS NOT SELECTED AS A LEADMANAGER IN AN INVESTMENT BANKING TRANSACTION; C) ISSUINGRESEARCH REPORTS ON ESPERION THERAPEUTICS INC. & TRITONNETWORK SYSTEMS THAT DID NOT PROVIDE A SOUND BASIS FOREVALUATING FACTS REGARDING THOSE COMPANIES & THEIR BUSINESSPROSPECTS; CONTAINED EXAGGERATED OR UNWARRANTED CLAIMSABOUT THOSE COMPANIES &/OR CONTAINED OPINIONS FOR WHICHTHERE WAS NO REASONABLE BASIS; D) MAKING PAYMENTS FORRESEARCH TO OTHER BROKER-DEALERS NOT INVOLVED IN ANUNDERWRITING TRANSACTION WHEN THE FIRM KNEW THAT THESEPAYMENTS WERE MADE AT LEAST IN PART FOR RESEARCH COVERAGE &BY FAILING TO DISCLOSE OR CAUSE TO BE DISCLOSED IN OFFERINGDOCUMENTS OR ELSEWHERE THE FACT OF SUCH PAYMENTS; AND E)RECEIVING PAYMENTS FOR RESEARCH FROM OTHER BROKER-DEALERSIN CONJUNCTION WITH UNDERWRITING TRANSACTIONS WITHOUTDISCLOSING RECEIPT OF SUCH PAYMENTS.Allegations:Current Status: FinalDate Notice/Process Served: 04/28/2003Resolution: ConsentResolution Date: 10/31/2003Monetary/Fine $32,500,000.00Cease and Desist/InjunctionSanctions Ordered or ReliefGranted: 2842018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceOther Sanctions:Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, U.S. BANCORPPIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF FINDINGS ANDIMPOSITION OF SANCTIONS IN CONNECTION WITH THE RESOLUTION OFCOORDINATED INVESTIGATIONS OF CERTAIN EQUITY RESEARCH ANDINVESTMENT BANKING PRACTICES BY THE SEC, NYSE, NASD AND AMULTI-STATE TASK FORCE. UNDER THE TERMS OF THE SETTLEMENTSREACHED JOINTLY WITH THE SEC, NYSE, NASD AND TASK FORCE, THEFIRM IS REQUIRED TO PAY A TOTAL OF $32,500,000 IN SETTLEMENT OFTHESE MATTERS AND HAS AGREED TO CEASE AND DESIST IN THEFUTURE FROM THE ALLEGED IMPROPER CONDUCT. PURSUANT TO THESETTLEMENT DOCUMENTS, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS A CIVIL PENALTY, $12,500,000 OF THIS AMOUNT SHALL BEDESIGNATED AS DISGORGEMENT OF COMMISSIONS AND FEES, AND$7,500,000 OF THIS AMOUNT SHALL BE USED TO FUND THEPROCUREMENT OF INDEPENDENT RESEARCH. AMOUNTS PAID TO THEVARIOUS STATES SHALL BE APPLIED TO AND REDUCE THE AMOUNT OFTHE $12,500,000 CIVIL PENALTY DESCRIBED ABOVE. $12,500,000 WASWIRED ON 11/14/03; THE FIRST INSTALLMENT ($1,500,000)OF THE$7,500,000 WILL BE WIRED ON 12/1/03.Firm Statement U.S. BANCORP PIPER JAFFRAY INC. CONSENTED TO THE ENTRY OF AJUDGMENT IN CONNECTION WITH THE SETTLEMENT OF THE ACTION.Monetary/Fine $32,500,000.00Cease and Desist/InjunctionSanctions Ordered or ReliefGranted:2852018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/brokercheck User GuidanceArbitration Award - Award / JudgmentBrokerage firms are not required to report arbitration claims filed against them by customers; however, BrokerCheckprovides summary information regarding FINRA arbitration awards involving securities and commodities disputesbetween public customers and registered securities firms in this section of the report. The full text of arbitration awards issued by FINRA is available at www.finra.org/awardsonline.Disclosure 1 of 55Reporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD02/28/200000-00387ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-TRANSFER; DO NOT USE-NO OTHERCONTROVERSY INVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS$17,922.84AWARD AGAINST PARTY10/18/2000$10,414.37There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 2 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:NASD10/31/200000-04044ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCECORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUNICIPAL BONDS 2862018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgwww.finra.org/awardsonlinehttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=00-00387https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=00-04044www.finra.org/brokercheck User GuidanceDisputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:CORPORATE BONDS; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUNICIPAL BONDS$320,000.00AWARD AGAINST PARTY11/07/2001$120,000.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 3 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD05/24/200101-01542ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHERCONTROVERSY INVOLVEDCOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$8,854.91AWARD AGAINST PARTY01/24/2002$162.50There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 4 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Allegations:NASDACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; TRADINGDISPUTES-BUY IN2872018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=01-01542www.finra.org/brokercheck User GuidanceArbitration Forum:Case Initiated:Case Number:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD04/04/200101-01633COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$30,236.65AWARD AGAINST PARTY03/04/2002$30,236.65There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 5 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD11/15/200101-06111ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCECOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVEUnspecified DamagesAWARD AGAINST PARTY01/27/2003$0.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 6 of 55iReporting Source: RegulatorType of Event: ARBITRATIONAllegations: ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-MARGIN CALLS; ACCOUNTRELATED-NEGLIGENCE 2882018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=01-01633https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=01-06111www.finra.org/brokercheck User GuidanceArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD01/04/200201-07118ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-MARGIN CALLS; ACCOUNTRELATED-NEGLIGENCECOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$34,437.04AWARD AGAINST PARTY12/18/2003$12,196.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 7 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD07/26/200202-01428ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NOOTHER CONTROVERSY INVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES$10,000,000.00AWARD AGAINST PARTY05/05/2005$2,209,500.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 8 of 55i2892018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=01-07118https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=02-01428www.finra.org/brokercheck User GuidanceReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD05/16/200202-02561ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; ACCOUNT RELATED-TRANSFERDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES$79,075.38AWARD AGAINST PARTY07/07/2003$45,000.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 9 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD09/12/200202-04772ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-ERRORS-CHARGES; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; TRADINGDISPUTES-TRANSFERSANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUALFUNDS$25,250.00AWARD AGAINST PARTY02/28/2003$1,065.932902018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=02-02561https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=02-04772www.finra.org/brokercheck User GuidanceThere may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 10 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD10/08/200202-05268ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURETO SUPERVISECOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$25,425.00AWARD AGAINST PARTY05/01/2003$25,425.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 11 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:NASD12/17/200202-07406ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZEDTRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES$2,570,125.21AWARD AGAINST PARTY01/23/20042912018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=02-05268https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=02-07406www.finra.org/brokercheck User GuidanceDisposition Date:Sum of All Relief Awarded:01/23/2004$60,000.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 12 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD01/09/200302-07812ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADINGCOMMON STOCK; MUTUAL FUNDS; OPTIONS; OTHER TYPES OFSECURITIES$360,000.00AWARD AGAINST PARTY03/17/2005$100,000.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 13 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:NASD05/06/200303-03203DO NOT USE-EXECUTIONS-OTHER; DO NOT USE-NO OTHERCONTROVERSY INVOLVEDCOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$5,392.03 2922018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=02-07812https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=03-03203www.finra.org/brokercheck User GuidanceSum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:$5,392.03AWARD AGAINST PARTY09/10/2003$87.50There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 14 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD05/23/200303-03490ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-EXECUTIONS-OTHERDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; FANNIE MAE; PREFERREDSTOCK$95,000.00AWARD AGAINST PARTY03/09/2004$20,000.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 15 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Allegations:NASD08/26/2004ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISE2932018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=03-03490www.finra.org/brokercheck User GuidanceCase Initiated:Case Number:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:08/26/200404-06006COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$23,450.00AWARD AGAINST PARTY01/20/2005$23,817.01There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 16 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD07/22/200505-03731ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES$500,000.00AWARD AGAINST PARTY05/26/2006$133,405.01There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 17 of 55iReporting Source: RegulatorType of Event: ARBITRATIONAllegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-FAILURE TO SUPERVISE2942018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=04-06006https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=05-03731www.finra.org/brokercheck User GuidanceArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:FINRA10/30/200707-02834ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-FAILURE TO SUPERVISEANNUITIES; COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SECINVOLVE$19,024.15AWARD AGAINST PARTY04/15/2008$212.50There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 18 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD01/01/198888-02970ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHERCONTROVERSY INVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS$7,215.56AWARD AGAINST PARTY02/02/1990$5,772.45There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 19 of 55iReporting Source: Regulator2952018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=07-02834https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=88-02970www.finra.org/brokercheck User GuidanceType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD01/01/198888-03063DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHERCONTROVERSY INVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES$4,000.00AWARD AGAINST PARTY11/17/1989$1,000.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 20 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD05/26/198988-03518DO NOT USE-NO OTHER CONTROVERSY INVOLVEDCOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$100,000.00AWARD AGAINST PARTY08/17/1990$30,000.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 21 of 55i2962018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=88-03063https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=88-03518www.finra.org/brokercheck User GuidanceReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD01/01/198989-01034DO NOT USE-EXECUTIONS-OTHER; DO NOT USE-NO OTHERCONTROVERSY INVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES$13,455.00AWARD AGAINST PARTY02/15/1990$1,393.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 22 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD01/01/198989-02259ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHERCONTROVERSY INVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES$10,000.00AWARD AGAINST PARTY12/05/1989$5,000.00There may be a non-monetary award associated with this arbitration.2972018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=89-01034https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=89-02259www.finra.org/brokercheck User GuidancePlease select the Case Number above to view more detailed information.Disclosure 23 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD01/09/199090-00050DO NOT USE-NO OTHER CONTROVERSY INVOLVEDCOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$2,713,856.00AWARD AGAINST PARTY12/13/1990$125,000.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 24 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD09/05/199090-02220ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER;ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-NO OTHERCONTROVERSY INVOLVEDCOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$26,652.00AWARD AGAINST PARTY11/27/1991$0.002982018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=90-00050https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=90-02220www.finra.org/brokercheck User GuidanceThere may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 25 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD03/14/199190-03301ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; DO NOT USE-NO OTHERCONTROVERSY INVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OPTIONS$67,490.00AWARD AGAINST PARTY03/31/1992$24,470.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 26 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD02/01/199190-03644ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVEDCOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$3,700.00AWARD AGAINST PARTY07/05/1991$750.002992018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=90-03301https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=90-03644www.finra.org/brokercheck User GuidanceSum of All Relief Awarded: $750.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 27 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD03/22/199191-00764ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-NO OTHER CONTROVERSY INVOLVEDCOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$20,309.00AWARD AGAINST PARTY09/23/1991$4,500.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 28 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:NASD07/23/199292-01788ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURETO SUPERVISECOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$5,000,000.00AWARD AGAINST PARTY3002018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=91-00764https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=92-01788www.finra.org/brokercheck User GuidanceDisposition:Disposition Date:Sum of All Relief Awarded:AWARD AGAINST PARTY11/23/1993$170,800.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 29 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD10/16/199292-03244ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNTRELATED-NEGLIGENCECOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$291,958.30AWARD AGAINST PARTY10/15/1993$7,500.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 30 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:NASD11/11/199292-03795ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNT RELATED-NEGLIGENCE; DO NOTUSE-NO OTHER CONTROVERSY INVOLVEDCOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE 3012018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=92-03244https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=92-03795www.finra.org/brokercheck User GuidanceDisputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVEUnspecified DamagesAWARD AGAINST PARTY04/29/1993$36,915.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 31 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD04/02/199393-01030ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADINGCOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;OPTIONS$5,811,542.00AWARD AGAINST PARTY01/20/1994$991,541.55There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 32 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Allegations:NASD01/05/1994ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHER CONTROVERSYINVOLVED3022018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=93-01030www.finra.org/brokercheck User GuidanceCase Initiated:Case Number:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:01/05/199494-00023DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUNICIPAL BONDS$10,000.00AWARD AGAINST PARTY12/19/1994$12,214.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 33 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD04/19/199494-00892ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZEDTRADING; DO NOT USE-NO OTHER CONTROVERSY INVOLVEDCOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$9,166.23AWARD AGAINST PARTY12/15/1995$1,616.23There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 34 of 55iReporting Source: RegulatorType of Event: ARBITRATIONAllegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-FAILURE TO SUPERVISE3032018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=94-00023https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=94-00892www.finra.org/brokercheck User GuidanceArbitration Forum:Case Initiated:Case Number:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD08/10/199494-02226ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-FAILURE TO SUPERVISECOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;MUNICIPAL BOND FUNDS; OPTIONS$170,000.00AWARD AGAINST PARTY10/04/1995$45,000.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 35 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD07/19/199494-02573ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACHOF CONTRACT; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES$8,700.00AWARD AGAINST PARTY05/02/1995$8,700.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 36 of 55iReporting Source: Regulator3042018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=94-02226https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=94-02573www.finra.org/brokercheck User GuidanceType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD11/23/199494-03254ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNTRELATED-FAILURE TO SUPERVISECOMMON STOCK; MUNICIPAL BOND FUNDS; OPTIONS; PREFERRED STOCK$4,800,000.00AWARD AGAINST PARTY06/19/1996$485,457.84There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 37 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD11/23/199494-03285ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT ACTIVITY-SUITABILITYDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES$1,524,189.00AWARD AGAINST PARTY10/09/1997$2,380,888.17There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.3052018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=94-03254https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=94-03285www.finra.org/brokercheck User GuidanceDisclosure 38 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD12/02/199494-03321ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NOOTHER CONTROVERSY INVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; FANNIE MAE; GINNIEMAES; OTHER TYPES OF SECURITIES$4,717.56AWARD AGAINST PARTY06/29/1995$2,710.63There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 39 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:NASD11/08/199494-03973ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACTDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES$5,513,077.00AWARD AGAINST PARTY10/18/19953062018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=94-03321https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=94-03973www.finra.org/brokercheck User GuidanceDisposition Date:Sum of All Relief Awarded:10/18/1995$6,017,865.51There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 40 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD01/10/199594-05467ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-BREACH OF CONTRACT;ACCOUNT RELATED-NEGLIGENCECOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$12,000.00AWARD AGAINST PARTY03/06/1996$4,500.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 41 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:NASD01/12/199595-00090ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE; DO NOT USE-NO OTHER CONTROVERSY INVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES3072018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=94-05467https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=95-00090www.finra.org/brokercheck User GuidanceDisputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES$30,000.00AWARD AGAINST PARTY10/23/1996$11,920.50There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 42 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD01/13/199595-00139ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-NEGLIGENCECOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$4,191,025.30AWARD AGAINST PARTY07/08/1996$105,141.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 43 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Allegations:NASD06/28/1995ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSYINVOLVED3082018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=95-00139www.finra.org/brokercheck User GuidanceCase Number:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:95-01947DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES$9,999.99AWARD AGAINST PARTY04/12/1996$6,286.08There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 44 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD06/29/199595-02094ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-FAILURE TO SUPERVISECOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$9,999.00AWARD AGAINST PARTY12/22/1995$150.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 45 of 55iReporting Source: RegulatorType of Event: ARBITRATIONAllegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-BREACH OF CONTRACT3092018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=95-01947https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=95-02094www.finra.org/brokercheck User GuidanceArbitration Forum:Case Initiated:Case Number:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD07/21/199595-03491ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; ACCOUNTRELATED-BREACH OF CONTRACTDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENTSECURITIES; OTHER TYPES OF SECURITIES$500,001.00AWARD AGAINST PARTY08/15/1996$473,724.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 46 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD05/07/199696-01420ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSY INVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES$2,241.51AWARD AGAINST PARTY09/13/1996$1,822.46There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 47 of 55iReporting Source: Regulator3102018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=95-03491https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=96-01420www.finra.org/brokercheck User GuidanceType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD05/07/199696-01605ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSYINVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS$7,147.87AWARD AGAINST PARTY10/30/1996$5,181.43There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 48 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD07/12/199696-02754ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS;ACCOUNT RELATED-FAILURE TO SUPERVISEDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS$100,001.00AWARD AGAINST PARTY04/25/1997$66,667.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 49 of 55i3112018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=96-01605https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=96-02754www.finra.org/brokercheck User GuidanceDisclosure 49 of 55Reporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD09/09/199696-02923ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHERCONTROVERSY INVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; OTHER TYPES OFSECURITIES$4,702.00AWARD AGAINST PARTY04/16/1997$4,852.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 50 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD11/12/199696-04530ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT RELATED-OTHER; DO NOT USE-NO OTHERCONTROVERSY INVOLVEDDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS$10,000.00AWARD AGAINST PARTY07/30/1997$6,188.003122018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=96-02923https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=96-04530www.finra.org/brokercheck User GuidanceThere may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 51 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD01/24/199797-00222ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNTRELATED-BREACH OF CONTRACTCOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$9,000,000.00AWARD AGAINST PARTY02/17/1998$26,686.23There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 52 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:NASD04/18/199797-01843ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OTHER;ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHERCONTROVERSY INVOLVEDCOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$437,508.00AWARD AGAINST PARTY05/11/1998 3132018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=97-00222https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=97-01843www.finra.org/brokercheck User GuidanceDisposition Date:Sum of All Relief Awarded:05/11/1998$45,693.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 53 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD04/02/199898-00396ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING;ACCOUNT RELATED-FAILURE TO SUPERVISECOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$100,513.00AWARD AGAINST PARTY11/12/1999$25,000.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 54 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:NASD06/10/199898-02010ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURETO SUPERVISEDO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES3142018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=98-00396https://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=98-02010www.finra.org/brokercheck User GuidanceDisputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIESUnspecified DamagesAWARD AGAINST PARTY06/21/1999$17,802.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.Disclosure 55 of 55iReporting Source: RegulatorType of Event: ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:NASD11/24/199999-05125ACCOUNT ACTIVITY-SUITABILITY; DO NOT USE-NO OTHER CONTROVERSYINVOLVEDCOMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE$561,500.00AWARD AGAINST PARTY10/11/2000$139,500.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.3152018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orghttps://www.finra.org/arbitration-and-mediation/arbitration-awards-online?search=99-05125www.finra.org/brokercheck User GuidanceEnd of ReportThis page is intentionally left blank.3162018 FINRA. All rights reserved. Report about PIPER JAFFRAY & CO.http://www.finra.org/brokercheckhttp://www.finra.org/brokercheck_reportshttp://www.finra.orgReport SummaryFirm ProfileFirm HistoryFirm OperationsDisclosure EventsDisclosure InformationRegulatory - FinalDisclosure #1Disclosure #2Disclosure #3Disclosure #4Disclosure #5Disclosure #6Disclosure #7Disclosure #8Disclosure #9Disclosure #10Disclosure #11Disclosure #12Disclosure #13Disclosure #14Disclosure #15Disclosure #16Disclosure #17Disclosure #18Disclosure #19Disclosure #20Disclosure #21Disclosure #22Disclosure #23Disclosure #24Disclosure #25Disclosure #26Disclosure #27Disclosure #28Disclosure #29Disclosure #30Disclosure #31Disclosure #32Disclosure #33Disclosure #34Disclosure #35Disclosure #36Disclosure #37Disclosure #38Disclosure #39Disclosure #40Disclosure #41Disclosure #42Disclosure #43Disclosure #44Disclosure #45Disclosure #46Disclosure #47Disclosure #48Disclosure #49Disclosure #50Disclosure #51Disclosure #52Disclosure #53Disclosure #54Disclosure #55Disclosure #56Disclosure #57Disclosure #58Disclosure #59Disclosure #60Disclosure #61Disclosure #62Disclosure #63Disclosure #64Disclosure #65Disclosure #66Disclosure #67Disclosure #68Disclosure #69Disclosure #70Disclosure #71Disclosure #72Disclosure #73Disclosure #74Disclosure #75Disclosure #76Disclosure #77Disclosure #78Disclosure #79Disclosure #80Disclosure #81Disclosure #82Disclosure #83Disclosure #84Disclosure #85Disclosure #86Disclosure #87Disclosure #88Disclosure #89Disclosure #90Disclosure #91Disclosure #92Disclosure #93Disclosure #94Disclosure #95Disclosure #96Disclosure #97Disclosure #98Disclosure #99Disclosure #100Disclosure #101Disclosure #102Disclosure #103Disclosure #104Disclosure #105Disclosure #106Disclosure #107Disclosure #108Disclosure #109Disclosure #110Disclosure #111Disclosure #112Disclosure #113Disclosure #114Disclosure #115Disclosure #116Disclosure #117Disclosure #118Disclosure #119Disclosure #120Disclosure #121Disclosure #122Disclosure #123Disclosure #124Disclosure #125Disclosure #126Disclosure #127Disclosure #128Disclosure #129Disclosure #130Disclosure #131Disclosure #132Disclosure #133Disclosure #134Civil - FinalDisclosure #1Arbitration Award - Award / JudgmentDisclosure #1Disclosure #2Disclosure #3Disclosure #4Disclosure #5Disclosure #6Disclosure #7Disclosure #8Disclosure #9Disclosure #10Disclosure #11Disclosure #12Disclosure #13Disclosure #14Disclosure #15Disclosure #16Disclosure #17Disclosure #18Disclosure #19Disclosure #20Disclosure #21Disclosure #22Disclosure #23Disclosure #24Disclosure #25Disclosure #26Disclosure #27Disclosure #28Disclosure #29Disclosure #30Disclosure #31Disclosure #32Disclosure #33Disclosure #34Disclosure #35Disclosure #36Disclosure #37Disclosure #38Disclosure #39Disclosure #40Disclosure #41Disclosure #42Disclosure #43Disclosure #44Disclosure #45Disclosure #46Disclosure #47Disclosure #48Disclosure #49Disclosure #50Disclosure #51Disclosure #52Disclosure #53Disclosure #54Disclosure #55