OSCAR GRUSS & SON INCORPORATED · OSCAR GRUSS & SON INCORPORATED CRD# 2091 SEC# 8-22371 Main Office Location 430 PARK AVENUE 6TH FLOOR NEW YORK, NY 10022 Regulated by FINRA New York

BrokerCheck Report

OSCAR GRUSS & SON INCORPORATED

Section Title

Report Summary

Firm History

CRD# 2091

1

8

Firm Profile 2 - 7

Page(s)

Firm Operations 9 - 15

Disclosure Events 16

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OSCAR GRUSS & SONINCORPORATED

CRD# 2091

SEC# 8-22371

Main Office Location

430 PARK AVENUE6TH FLOORNEW YORK, NY 10022Regulated by FINRA New York Office

Mailing Address

430 PARK AVENUE6TH FLOORNEW YORK, NY 10022

Business Telephone Number

212-419-4000

Report Summary for this Firm

This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.

Disclosure Events

Brokerage 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? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 24

Arbitration 5

Judgment/Lien 10

Firm Profile

This firm is classified as a corporation.

This firm was formed in New York on 10/03/1977.

Its fiscal year ends in December.

Firm History

Information relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.

Firm Operations

Is this brokerage firm currently suspended with anyregulator? No

This firm conducts 7 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• 6 Self-Regulatory Organizations• 52 U.S. states and territories

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1©2020 FINRA. All rights reserved. Report about OSCAR GRUSS & SON INCORPORATED


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This firm is classified as a corporation.

This firm was formed in New York on 10/03/1977.

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 Profile

Firm Names and Locations

Its fiscal year ends in December.

OSCAR GRUSS & SON INCORPORATED

SEC#

2091

8-22371

Main Office Location

Mailing Address

Business Telephone Number

Doing business as OSCAR GRUSS & SON INCORPORATED

212-419-4000

Regulated by FINRA New York Office








This section provides information relating to all direct owners and executive officers of the brokerage firm.

Direct Owners and Executive Officers

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

MAKOR PARTNERS LIMITED

SHAREHOLDER

75% or more

No

Foreign Entity

08/2014

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


ANREDER, LAURA ELLEN

CHIEF EXECUTIVE OFFICER

Less than 5%

No

Individual

12/2018

Yes

1325698



Position


Position Start Date

LANDAU, DANIELLE

CHIEF COMPLIANCE OFFICER / CHIEF FINANCIAL OFFICER / FINOP

Less than 5%

Individual

08/2014

4671417








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes






This section provides information relating to any indirect owners of the brokerage firm.

Indirect Owners

Firm Profile

MAKOR HOLDINGS PTE LTD.

SOLE SHAREHOLDER


75% or more

No

Foreign Entity

07/2013

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established




BOUHADANA, AVI

SHAREHOLDER


50% but less than 75%

No

Individual

07/2013

Yes

6382537









HALIMI, MICHAEL ELIE

Individual

2354986








Indirect Owners (continued)

Firm Profile

SHAREHOLDER


50% but less than 75%

No

Individual

11/2010

Yes








BOUHADANA, AVI

DIRECTOR


Other General Partners

No

Individual

06/2010

Yes

6382537









HASSAN, YANKEL BENJAMIN ANDREW


Individual

6611030









Indirect Owners (continued)

Firm Profile

SHAREHOLDER


Other General Partners

No

10/2015

No












Firm History

This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

No information reported.






Firm Operations

RegistrationsThis 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, 6 SROs and 52 U.S. states and territories.

SEC Registration Questions

This 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:

Yes

Yes

No

No

Federal Regulator Status Date Effective

SEC Approved 01/26/1978

Self-Regulatory Organization Status Date Effective

FINRA Approved 07/08/1949

Cboe BZX Exchange, Inc. Approved 08/07/2017

NYSE American LLC Approved 02/25/1988

NYSE Arca, Inc. Approved 10/10/2003

Nasdaq Stock Market Approved 07/12/2006

New York Stock Exchange Approved 11/17/1982






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 09/12/1988

Alaska Approved 06/09/1988

Arizona Approved 07/27/1988

Arkansas Approved 05/10/1988

California Approved 06/01/1987

Colorado Approved 06/03/1987

Connecticut Approved 03/28/1988

Delaware Approved 06/20/1988

District of Columbia Approved 06/21/1987

Florida Approved 04/07/1988

Georgia Approved 02/19/1988

Hawaii Approved 08/22/1988

Idaho Approved 04/27/1988

Illinois Approved 02/05/1988

Indiana Approved 02/26/1988

Iowa Approved 09/15/1988

Kansas Approved 02/18/1988

Kentucky Approved 06/02/1987

Louisiana Approved 03/02/1988

Maine Approved 03/23/1990

Maryland Approved 04/17/1989

Massachusetts Approved 04/11/1988

Michigan Approved 03/15/1988

Minnesota Approved 04/11/1988

Mississippi Approved 04/12/1988

Missouri Approved 04/08/1988

Montana Approved 02/23/1988

Nebraska Approved 02/04/1997

Nevada Approved 06/01/1987

New Hampshire Approved 04/19/1988

New Jersey Approved 07/13/1988

New Mexico Approved 02/26/1988

New York Approved 01/02/1985

U.S. States &Territories

Status Date Effective

North Carolina Approved 04/08/1988

North Dakota Approved 04/11/1988

Ohio Approved 01/24/1997

Oklahoma Approved 06/15/1988

Oregon Approved 05/05/1988

Pennsylvania Approved 03/18/1988

Puerto Rico Approved 01/29/1990

Rhode Island Approved 03/08/1988

South Carolina Approved 04/18/1988

South Dakota Approved 06/19/1989

Tennessee Approved 05/19/1988

Texas Approved 07/21/1988

Utah Approved 09/17/1987

Vermont Approved 08/22/1988

Virginia Approved 04/01/1988

Washington Approved 05/06/1988

West Virginia Approved 06/14/1989

Wisconsin Approved 04/15/1988

Wyoming Approved 03/11/1988






Firm Operations

Types 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 Business

This firm does not effect transactions in commodities, commodity futures, or commodity options.This firm does not engage in other non-securities business.

Non-Securities Business Description:

This firm currently conducts 7 types of businesses.

Types of Business

Exchange member engaged in exchange commission business other than floor activities

Broker or dealer retailing corporate equity securities over-the-counter

Broker or dealer selling corporate debt securities

U S. government securities dealer

U S. government securities broker

Put and call broker or dealer or option writer

Other - -CREATION AND DISTRIBUTION OF RESEARCH WITHIN THE MEANING OF NASD RULE 271A(A)(9)-COMMISSION SHARING FROM CUSTOMER REFERRALS TO OTHER BROKER-DEALERS.






Firm Operations

Clearing Arrangements

This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does refer or introduce customers to other brokers and dealers.

Name: BOFA SECURITIES, INC.

Business Address: ONE BRYANT PARKNEW YORK, NY 10036

CRD #: 283942

Effective Date: 12/07/2010

Description: THE FIRM HAS AN ARRANGEMENT WITH BOFA SECURITIES, INC TOINTRODUCE CUSTOMERS ON A FULLY DISCLOSED BASIS. (THISARRANGEMENT WAS TRANSFERRED FROM MERRILL LYNCH,PIERCE,FENNER & SMITH INCORPROATED CRD # 7691)






Firm Operations

Industry Arrangements

This 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.

This firm does not have individuals who control its management or policies through agreement.

Control Persons/Financing



CRD #: 283942





CRD #: 283942





CRD #: 283942








Firm Operations

Industry Arrangements (continued)

This firm does not have individuals who wholly or partly finance the firm's business.






Firm Operations

Organization 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.

No

Yes

UNITED KINGDOM

Yes

08/07/2014

34 DOVER STREET6TH FLOORLONDON, UNITED KINGDOM W1S 4NG

MAKOR PARTNERS LIMITED controls the firm.

CORPORATION DIRECTLY OWNS 100%, SOLE SHAREHOLDER, OF OSCARGRUSS & SON INCORPORATED

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

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 bank






Disclosure Events

All 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 AppealPending

Regulatory Event 0 24 0

Arbitration N/A 5 N/A

Judgment/Lien 10 N/A N/A






Disclosure Event Details

What 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.

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particular 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 currently

being appealed.§ A "final" event has been concluded and its resolution is not subject to change.

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or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.

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5. You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure events contained in this BrokerCheck report.

Regulatory - Final

This 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 24

Reporting Source: Regulator

Allegations: NASD RULES 2110, 6220(A): THE FIRM FAILED, WITHIN 90 SECONDS AFTEREXECUTION, TO TRANSMIT TO THE OVER THE COUNTER (OTC)REPORTING FACILITY 102 LAST SALE REPORTS OF TRANSACTIONS IN OTCEQUITY SECURITIES. THESE TRANSACTIONS CONSTITUTE 15 PERCENTOF THE TRANSACTIONS REVIEWED THAT THE FIRM REPORTED TO THEOTC REPORTING FACILITY DURING THE REVIEW PERIOD.

Current Status: Final






Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 04/28/2011

Docket/Case Number: 2008015256201

Principal Product Type: Equity - OTC

Other Product Type(s):

Allegations: NASD RULES 2110, 6220(A): THE FIRM FAILED, WITHIN 90 SECONDS AFTEREXECUTION, TO TRANSMIT TO THE OVER THE COUNTER (OTC)REPORTING FACILITY 102 LAST SALE REPORTS OF TRANSACTIONS IN OTCEQUITY SECURITIES. THESE TRANSACTIONS CONSTITUTE 15 PERCENTOF THE TRANSACTIONS REVIEWED THAT THE FIRM REPORTED TO THEOTC REPORTING FACILITY DURING THE REVIEW PERIOD.

Resolution Date: 04/28/2011

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED AND FINED $7,500.

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

No

Sanctions Ordered: CensureMonetary/Fine $7,500.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC.

Allegations: ALLEGED VIOLATIONS OF RULES 2110 AND 6220(A)RELATING TO ALLEGEDFAILURE TO TRANSMIT 102 SALES REPORTS TO OVER-THE-COUNTERREPORTING FACILITY ON TIMELY BASIS.









Censure


FINE






Resolution:


Sanction Details: FINE WAS PAID IN MAY 2011.

Firm Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, REGISTRANTCONSENTED TO THE DESCRIBED SANCTIONS AND ENTRY OF THEFINDINGS.



Disclosure 2 of 24

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Allegations: SEC RULE 605 OF REGULATION NMS, NASD RULES 2110, 4632, 6130(D) AND6620: RESPONDENT OSCAR GRUSS & SON, INCORPORATED FAILED TOREPORT TO THE NASD/NASDAQ TRADE REPORTING FACILITY (NNTRF) THECORRECT SYMBOL INDICATING WHETHER THE TRANSACTION WAS A BUY,SELL, SELL SHORT, OR CROSS FOR TRANSACTIONS IN REPORTABLESECURITIES AND FAILED TO REPORT TO THE OTC REPORTING FACILITY(OTCRF) THE CORRECT SYMBOL INDICATING WHETHER THE FIRMEXECUTED TRANSACTIONS IN REPORTABLE SECURITIES IN A PRINCIPALOR AGENCY CAPACITY. THIS CONDUCT CONSTITUTES SEPARATE ANDDISTINCT VIOLATIONS OF NASD RULE 6130(D). THE FIRM FAILED TOREPORT THE CORRECT TIME OF EXECUTION TO THE OTCRF IN LAST SALEREPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES, AND FAILEDTO SUBMIT TO THE OTCRF, FOR THE OFFSETTING, "RISKLESS" PORTIONOF "RISKLESS" PRINCIPAL TRANSACTIONS IN DESIGNATED SECURITIES,EITHER A CLEARING-ONLY REPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL," OR A NON-TAPE, NON-CLEARING REPORT WITH ACAPACITY INDICATOR OF "RISKLESS PRINCIPAL." THIS CONDUCTCONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD RULE 6620.THE FIRM FAILED TO REPORT TO THE NNTRF THE CANCELLATION OFTRADES PREVIOUSLY SUBMITTED TO NNTRF, AND FAILED TO REPORT TOTHE NNTRF LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATEDSECURITIES. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCTVIOLATIONS OF NASD RULE 4632. THE FIRM MADE AVAILABLE A REPORTON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIESTHAT IT RECEIVED FOR EXECUTION FROM ANY PERSON THAT INCLUDEDINCORRECT INFORMATION AS TO THE NUMBER OF COVERED ORDERS.THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OFSEC RULE 605 OF REGULATION NMS. THE FIRM FAILED, WITHIN 90SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTCRF LAST SALEREPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES. THISCONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASDRULE 6620, AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUTEXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE 2110.







Initiated By: FINRA







SEC RULE 605 OF REGULATION NMS, NASD RULES 2110, 4632, 6130(D) AND6620: RESPONDENT OSCAR GRUSS & SON, INCORPORATED FAILED TOREPORT TO THE NASD/NASDAQ TRADE REPORTING FACILITY (NNTRF) THECORRECT SYMBOL INDICATING WHETHER THE TRANSACTION WAS A BUY,SELL, SELL SHORT, OR CROSS FOR TRANSACTIONS IN REPORTABLESECURITIES AND FAILED TO REPORT TO THE OTC REPORTING FACILITY(OTCRF) THE CORRECT SYMBOL INDICATING WHETHER THE FIRMEXECUTED TRANSACTIONS IN REPORTABLE SECURITIES IN A PRINCIPALOR AGENCY CAPACITY. THIS CONDUCT CONSTITUTES SEPARATE ANDDISTINCT VIOLATIONS OF NASD RULE 6130(D). THE FIRM FAILED TOREPORT THE CORRECT TIME OF EXECUTION TO THE OTCRF IN LAST SALEREPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES, AND FAILEDTO SUBMIT TO THE OTCRF, FOR THE OFFSETTING, "RISKLESS" PORTIONOF "RISKLESS" PRINCIPAL TRANSACTIONS IN DESIGNATED SECURITIES,EITHER A CLEARING-ONLY REPORT WITH A CAPACITY INDICATOR OF "RISKLESS PRINCIPAL," OR A NON-TAPE, NON-CLEARING REPORT WITH ACAPACITY INDICATOR OF "RISKLESS PRINCIPAL." THIS CONDUCTCONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD RULE 6620.THE FIRM FAILED TO REPORT TO THE NNTRF THE CANCELLATION OFTRADES PREVIOUSLY SUBMITTED TO NNTRF, AND FAILED TO REPORT TOTHE NNTRF LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATEDSECURITIES. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCTVIOLATIONS OF NASD RULE 4632. THE FIRM MADE AVAILABLE A REPORTON THE COVERED ORDERS IN NATIONAL MARKET SYSTEM SECURITIESTHAT IT RECEIVED FOR EXECUTION FROM ANY PERSON THAT INCLUDEDINCORRECT INFORMATION AS TO THE NUMBER OF COVERED ORDERS.THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OFSEC RULE 605 OF REGULATION NMS. THE FIRM FAILED, WITHIN 90SECONDS AFTER EXECUTION, TO TRANSMIT TO THE OTCRF LAST SALEREPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES. THISCONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASDRULE 6620, AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUTEXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE 2110.


Resolution:



No







https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2007007959002


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.




Censure


FINE





Allegations: ALLEGED VIOLATIONS OF RULE 605 OF REGULATION NMS AND NASDRULES 2110, 4632, 6130(D), AND 6620



Resolution:


Sanction Details: FINE WAS PAID IN AUGUST 2009.




Disclosure 3 of 24

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Allegations: NASDAQ RULE 4755 - OSCAR GRUSS & SON, INCORPORATED ENTEREDPROPRIETARY ORDERS INTO NASDAQ SINGLEBOOK AND FAILED TO USETHE CORRECT SYMBOL INDICATING WHETHER THE TRANSACTION WAS ABUY, SHORT SELL OR LONG SELL.








Initiated By: NASDAQ STOCK MARKET





Principal Product Type: Other

Other Product Type(s): NASDAQ SECURITIES-PROPRIETARY ORDERS

NASDAQ RULE 4755 - OSCAR GRUSS & SON, INCORPORATED ENTEREDPROPRIETARY ORDERS INTO NASDAQ SINGLEBOOK AND FAILED TO USETHE CORRECT SYMBOL INDICATING WHETHER THE TRANSACTION WAS ABUY, SHORT SELL OR LONG SELL.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS FINED $5,000.


No

Sanctions Ordered: Monetary/Fine $5,000.00



Initiated By: NASDAQ STOCK MARKET


Civil and Administrative Penalt(ies) /Fine(s)





Allegations: ALLEGED VIOLATION OF NASDAQ STOCK MARKET RULE 4755











Resolution:


Sanction Details: FINE WAS PAID IN APRIL 2009.




Disclosure 4 of 24

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Initiated By: NASD






Other Product Type(s): UNKNOWN TYPE OF SECURITIES

Allegations: SEC RULE 10B-10, NASD RULE 6955(A) - OSCAR GRUSS & SON, INC.TRANSMITTED TO OATS REPORTS THAT CONTAINED INACCURATE,INCOMPLETE OR IMPROPERLY FORMATTED DATA AND FAILED TO SUBMITORDER INFORMATION TO OATS. THE FIRM FAILED ON CUSTOMERCONFIRMATIONS TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TOITS CUSTOMERS ITS CORRECT CAPACITY IN TRANSACTIONS, THAT THETRANSACTION WAS EXECUTED AT AN AVERAGE PRICE; AND/OR ACORRECT DESCRIPTION OF ITS COMPENSATION.


Resolution: Acceptance, Waiver & Consent(AWC)









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 $15,000.


No



Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS


Censure


FINE


Docket/Case Number: 20060040590-01



Allegations: ALLEGED VIOLATIONS OF RULE 10B-10 UNDER SECURITIES EXCHANGEACT OF 1934 AND NASD RULE 6955(A)



Resolution:












Disclosure 5 of 24

i


Initiated By: NASD






Other Product Type(s): ELIGIBLE SECURITIES

Allegations: SEC RULE 10B-10, NASD RULES 2110, 3010, 6130(D), 6955(A) - OSCARGRUSS & SON, INC. FAILED TO REPORT TO OATS REPORTABLE ORDEREVENTS (ROES); TRANSMITTED TO OATS REPORTS THAT CONTAINEDINACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA,SPECIFICALLY, THE REPORTS DID NOT INCLUDE THE CORRECT LIMITORDER DISPLAY INDICATOR; FAILED TO REPORT TO ACT THE CORRECTSYMBOL INDICATING WHETHER THE TRANSACTION WAS A BUY, SELL, SELLSHORT EXEMPT OR CROSS FOR TRANSACTIONS IN ELIGIBLE SECURITIES;FAILED TO REPORT TO THE NASDAQ MARKET CENTER THE CORRECTSYMBOL INDICATING WHETHER THE FIRM EXECUTED TRANSACTIONS INELIGIBLE SECURITIES IN A PRINCIPAL OR AGENCY CAPACITY; AND FAILEDTO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS ITSCORRECT CAPACITY IN A TRANSACTION, THAT THE TRANSACTION WASEXECUTED AT AN AVERAGE PRICE OR THAT THE FIRM WAS A MARKETMAKER. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULESCONCERNING BEST EXECUTION, TRADE REPORTING, SALESTRANSACTIONS, BACKING AWAY, OATS, AND BOOKS AND RECORDS.



Resolution:


No







Other Sanctions Ordered: UNDERTAKING

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 $28,000 AND REQUIRED TOREVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES CONCERNINGBEST EXECUTION, TRADE REPORTING, SALES TRANSACTIONS, BACKINGAWAY, OATS, AND BOOKS AND RECORDS WITHIN 30 BUSINESS DAYS OFACCEPTANCE OF THIS AWC BY THE NAC.


No





Censure


FINE AND UNDERTAKING





Allegations: ALLEGED VIOLATIONS OF RULE 10B-10 UNDER SECURITIES EXCHANGEACT OF 1934 AND NASD RULES 2110, 3010, 6130(D), AND 6955(A)



Resolution:

Other Sanctions Ordered: UNDERTAKING TO AMEND WRITTEN SUPERVISORY PROCEDURES

Sanction Details: FINE WAS PAID IN FEBRUARY 2007.










Disclosure 6 of 24

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Initiated By: NASD






Other Product Type(s): UNSPECIFIED TYPE OF SECURITIES

Allegations: SEC RULE 11AC1-1, 11AC1-6(B); NASD MARKETPLACE RULE 6955(A) ANDCONDUCT RULE 2110; RESPONDENT MEMBER FIRM TRANSMITTED TOOATS REPORTS THAT CONTAINED INACCURATE, INCOMPLETE ORIMPROPERLY FORMATTED DATA. THE FIRM FAILED TO DISPLAYIMMEDIATELY CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITSPUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE THATWOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SECURITY. ITFAILED TO IDENTIFY A VENUE ON ITS REPORT ON THE ROUTING OF ITSNON-DIRECTED ORDERS IN COVERED SECURITIES. THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOTHE APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULESCONCERNING BEST EXECUTION OF AGENCY ORDERS, REVIEW OFEXECUTION QUALITY, RISKLESS PRINCIPAL TRADE REPORTING ANDLONG/SHORT SALE REPORTING.



Resolution:


No








Other Sanctions Ordered: UNDERTAKINGS: REQUIRED WITHIN 30 BUSINESS DAYS TO REVISE ITSWRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO APPLICABLESECURITIES LAWS, REGULATIONS, AND NASD RULES CONCERNING BESTEXECUTION OF AGENCY ORDERS, REVIEW OF EXECUTION QUALITY,RISKLESS PRINCIPAL TRADE REPORTING AND LONG/SHORT SALEREPORTING.

Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENTMEMBER FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $30,000.


No





Censure




Docket/Case Number: 20042000193-01



Allegations: ALLEGED VIOLATIONS OF RULES 11AC1-1 AND 11AC1-6(B) UNDERSECURITIES EXCHANGE ACT OF 1934 AND NASD RULES 2110 AND 6955(A)



Resolution:










Sanction Details: FINE WAS PAID IN JANUARY 2006.


Disclosure 7 of 24

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Initiated By: NASD




Docket/Case Number: CMS040114


Other Product Type(s): SECURITIES

Allegations: NASD MARKETPLACE RULE 6130(D) AND SEC RULE 10B-10 AND 11AC1-4 -RESPONDENT MEMBER FAILED TO DISPLAY CUSTOMER LIMIT ORDERS INNASDAQ SECURITIES IN ITS PUBLIC QUOTATION WHEN EACH SUCHORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OROFFER IN EACH SUCH SECURITY; OR WHEN THE ORDER WAS PRICEDEQUAL TO THE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OROFFER FOR EACH SUCH SECURITY, AND THE SIZE OF THE ORDERREPRESENTED MORE THAN A DEMINIMIS CHANGE IN RELATION TO THESIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SUCHSECURITY; FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TOITS CUSTOMER ITS CORRECT CAPACITY IN THE TRANSACTION; PROVIDEDINCORRECT WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THATIT WAS A MARKET MAKER IN EACH SUCH SECURITY; FAILED TO PROVIDEWRITTEN NOTIFICATIN DISCLOSING TO ITS CUSTOMER THAT THETRANSACTION WAS EXECUTED AT AN AVERAGE PRICE; AND, FAILED TOREPORT TO ACT THE CORRECT SYMBOL INDICATING WHETHER THE FIRMEXECUTED TRANSACTIONS IN A PRINCIPAL, RISKLESS PRINCIPAL, ORAGENT CAPACITY.











Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENTMEMBER CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED$8,000.


No





Censure


FINE





Allegations: ALLEGED VIOLATIONS OF RULES 10B-10 AND 11AC1-4 UNDER SECURITIESEXCHANGE ACT OF 1934 AND NASD RULE 6130(D)



Resolution:












Disclosure 8 of 24

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Initiated By: NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT


Allegations: **4/11/03**CHARGE I OSCAR GRUSS & SON INC VIOLATED SEA RULES 8C-1(A)(2) & 15C3-3(B) PROMULGATED UNDER THE SECURITIES EXCHANGEACT OF 1934 BY:I.FAILING TO MAINTAIN PHYSICAL POSSESSION ORCONTROL OF ALL FULLY PAID & EXCESS MARGIN SECURITIES; II.

COMMINGLING OF CUSTOMER SECURITIES; &,III.PLEDGINGCUSTOMER SECURITIES FULLY PAID OR EXCESS MARGIN SECURITIES ASCOLLATERAL FOR FIRM BANK LOANS.CHARGE II OSCAR GRUSS & SON INCVIOLATED SEA RULE 15C3-3(E) PROMULGATED UNDER THE SECURITIESEXCHANGE ACT OF 1934 BY FAILING TO PROPERLY COMPUTE ITSRESERVE REQUIREMENT WHICH CAUSED THE FIRM TO UNDER FUND ITSSPECIAL RESERVE BANK ACCOUNT FOR THE EXCLUSIVE BENEFIT OFCUSTOMERS.CHARGE III OSCAR GRUSS & SON INC VIOLATED SEA RULE17A-5 PROMULGATED UNDER THE SECURITIES EXCHANGE ACT OF 1934 &EXCHANGE RULE 476(A)(10) BY FILING INACCURATE FOCUSREPORTS.CHARGE IV OSCAR GRUSS & SON INC VIOLATED SEA RULES17A-3 & 17A-4 PROMULGATED UNDER THE SECURITIES EXCHANGE ACT OF1934 & EXCHANGE RULE 440 BY FAILING TO MAKE &/OR PRESERVEACCURATE FINANCIAL &/OR OPERATIONAL BOOKS & RECORDSINCLUDING BOOKS & RECORDS ASSOCIATED WITH THE FIRMSPOSSESSION OR CONTROL OF SECURITIES, BANK LOAN OPERATIONS,NET CAPITAL COMPUTATIONS, CUSTOMER RESERVE COMPUTATIONS &PREPARATION OF ITS FOCUS REPORT, FORM 600TC & FORM 120-A.CHARGE V OSCAR GRUSS & SON INC VIOLATED EXCHANGE RULE 342 INTHAT ON ONE OR MORE OCCASIONS THE FIRM FAILED TO PROVIDE FOR,ESTABLISH & MAINTAIN ADEQUATE PROCEDURES & CONTROLS,INCLUDING A SYSTEM OF FOLLOW-UP & REVIEW OF ITS FINANCIAL &OPERATIONAL SYSTEMS 7 ACTIVITIES, TO ENSURE COMPLIANCE WITHRULES RELATING TO:I)HYPOTHECATION OF CUSTOMERS SECURITIES;II)COMPUTATION OF THE FIRMS CUSTOMER RESERVE FORMULA;III)PREPARATION &/OR COMPUTATION OF THE FIRMS NET CAPITAL &FOCUS REPORTS; IV)THE POSSESSION OR CONTROL OF CUSTOMERSECURITIES;&,V)MAKING &D MAINTAINING ACCURATE & COMPLETEBOOKS & RECORDS IN CONNECTION WITH THE FIRM'S FINANCIAL &OPERATIONAL BUSINESS ACTIVITIES.










Docket/Case Number: HPD#: 03-193




Resolution:


Sanction Details: **10/22/03**DECISION ISSUED BY NYSE HEARING PANEL(HEARING PANELDECISION NUMBER 03-193).DECISION:VIOLATED SEA RULES 8C-1(A)(2) AND15C3-3(B) PROMULGATED UNDER THE SECURITIES EXCHANGE ACT OF1934 BY:1.FAILING TO MAINTAIN PHYSICAL POSSESSION OR CONTROL OFALL FULLY PAID AND EXCESS MARGIN SECURITIES; II. COMMINGLING OFCUSTOMER SECURITIES; AND,III. PLEDGING CUSTOMER SECURITIES FULLY PAID OR EXCESS MARGINSECURITIES AS COLLATERAL FOR FIRM BANK LOANS.VIOLATED SEA RULE 15C3-3(E) PROMULGATED UNDER THE SECURITIESEXCHANGE ACT OF 1934 BY FAILING TO PROPERLY COMPUTE ITSRESERVE REQUIREMENT WHICH CAUSED THE FIRM TO UNDER FUND ITSSPECIAL RESERVE BANK ACCOUNT FOR THE EXCLUSIVE BENEFIT OFCUSTOMERS.VIOLATED SEA RULE 17A-5 PROMULGATED UNDER THESECURITIES EXCHANGE ACT OF 1934 AND EXCHANGE RULE 476(A)(10)BYFILING INACCURATE FOCUS REPORTS.VIOLATED SEA RULES 17A-3 AND 17A-4 PROMULGATED UNDER THESECURITIES EXCHANGE ACT OF 1934 AND EXCHANGE RULE 440 BYFAILING TO MAKE AND/OR PRESERVE ACCURATE FINANCIAL AND/OROPERATIONAL BOOKS AND RECORD INCLUDING BOOKS AND RECORDSASSOCIATED WITH THE FIRMS POSSESSION OR CONTROL OFSECURITIES, BANK LOAN OPERATIONS, NET CAPITAL COMPUTATIONS,CUSTOMER RESERVE COMPUTATIONS AND PREPARATION OF ITS FOCUSREPORT FORM 600TC AND FORM 120-A.VIOLATED EXCHANGE RULE 342 INTHAT ON ONE OR MORE OCCASIONS THE FIRM FAILED TO PROVIDE FORESTABLISH AND MAINTAIN ADEQUATE PROCEDURES AND CONTROLSINCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW OF ITS FINANCIAL ANDOPERATIONAL SYSTEMS AND ACTIVITIES TO ENSURE COMPLIANCE WITHRULES RELATING TO:I)HYPOTHECATION OF CUSTOMERS SECURITIES;II)COMPUTATION OF THE FIRMS CUSTOMER RESERVE FORMULA;III)PREPARATION AND/OR COMPUTATION OF THE FIRMS NET CAPITAL ANDFOCUS REPORTS; IV)THE POSSESSION OR CONTROL OF CUSTOMERSECURITIES; AND,V)MAKING AND MAINTAINING ACCURATE AND COMPLETEBOOKS AND RECORDS IN CONNECTION WITH THE FIRMS FINANCIAL ANDOPERATIONAL BUSINESS ACTIVITIES . SANCTION:CONSENT TO ACENSURE AND A FINE OF $200,000.


Decision






**10/22/03**DECISION ISSUED BY NYSE HEARING PANEL(HEARING PANELDECISION NUMBER 03-193).DECISION:VIOLATED SEA RULES 8C-1(A)(2) AND15C3-3(B) PROMULGATED UNDER THE SECURITIES EXCHANGE ACT OF1934 BY:1.FAILING TO MAINTAIN PHYSICAL POSSESSION OR CONTROL OFALL FULLY PAID AND EXCESS MARGIN SECURITIES; II. COMMINGLING OFCUSTOMER SECURITIES; AND,III. PLEDGING CUSTOMER SECURITIES FULLY PAID OR EXCESS MARGINSECURITIES AS COLLATERAL FOR FIRM BANK LOANS.VIOLATED SEA RULE 15C3-3(E) PROMULGATED UNDER THE SECURITIESEXCHANGE ACT OF 1934 BY FAILING TO PROPERLY COMPUTE ITSRESERVE REQUIREMENT WHICH CAUSED THE FIRM TO UNDER FUND ITSSPECIAL RESERVE BANK ACCOUNT FOR THE EXCLUSIVE BENEFIT OFCUSTOMERS.VIOLATED SEA RULE 17A-5 PROMULGATED UNDER THESECURITIES EXCHANGE ACT OF 1934 AND EXCHANGE RULE 476(A)(10)BYFILING INACCURATE FOCUS REPORTS.VIOLATED SEA RULES 17A-3 AND 17A-4 PROMULGATED UNDER THESECURITIES EXCHANGE ACT OF 1934 AND EXCHANGE RULE 440 BYFAILING TO MAKE AND/OR PRESERVE ACCURATE FINANCIAL AND/OROPERATIONAL BOOKS AND RECORD INCLUDING BOOKS AND RECORDSASSOCIATED WITH THE FIRMS POSSESSION OR CONTROL OFSECURITIES, BANK LOAN OPERATIONS, NET CAPITAL COMPUTATIONS,CUSTOMER RESERVE COMPUTATIONS AND PREPARATION OF ITS FOCUSREPORT FORM 600TC AND FORM 120-A.VIOLATED EXCHANGE RULE 342 INTHAT ON ONE OR MORE OCCASIONS THE FIRM FAILED TO PROVIDE FORESTABLISH AND MAINTAIN ADEQUATE PROCEDURES AND CONTROLSINCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW OF ITS FINANCIAL ANDOPERATIONAL SYSTEMS AND ACTIVITIES TO ENSURE COMPLIANCE WITHRULES RELATING TO:I)HYPOTHECATION OF CUSTOMERS SECURITIES;II)COMPUTATION OF THE FIRMS CUSTOMER RESERVE FORMULA;III)PREPARATION AND/OR COMPUTATION OF THE FIRMS NET CAPITAL ANDFOCUS REPORTS; IV)THE POSSESSION OR CONTROL OF CUSTOMERSECURITIES; AND,V)MAKING AND MAINTAINING ACCURATE AND COMPLETEBOOKS AND RECORDS IN CONNECTION WITH THE FIRMS FINANCIAL ANDOPERATIONAL BUSINESS ACTIVITIES . SANCTION:CONSENT TO ACENSURE AND A FINE OF $200,000.

Regulator Statement **11/20/2003**THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY.CONTACT: MICHELE VAN TASSEL 212-656-5340.


Initiated By: NEW YORK STOCK EXCHANGE


Censure


FINE


Docket/Case Number: HPD 03-193

Principal Product Type: No Product


Allegations: ALLEGED VIOLATION OF RULES 8C-1(A)(2), 15C3-3(B), 15C3-3(E), 17A-3, 17A-4, AND 17A-5 UNDER SECURITIES EXCHANGE ACT OF 1934 AND NYSERULES 342, 440, AND 476(A)(10)



Resolution:


Sanction Details: FINE WAS PAID IN DECEMBER 2003.



Decision






Disclosure 9 of 24

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Allegations: NASD RULE 4613(E) - RESPONDENT MEMBER, A MARKET MAKER INSECURITIES, WITHOUT MAKING REASONABLE EFFORTS TO AVOID ALOCKED OR CROSSED MARKET BY EXECUTING TRANSACTIONS WITH ALLMARKET MAKERS WHOSE QUOTATIONS WOULD BE LOCKED ORCROSSED, ENTERED BID OR ASK QUOTATIONS IN THE NASDAQ STOCKMARKET, INC. WHICH CAUSED A LOCKED OR CROSSED MARKETCONDITION TO OCCUR IN EACH INSTANCE.



Resolution:


Sanction Details: CENSURE AND FINE $10,000







Allegations: ALLEGED VIOLATION OF NASD RULE 4613(E)








Censure


FINE





Resolution:


Sanction Details: FINE WAS PAID IN APPROXIMATELY DECEMBER 2000.




Disclosure 10 of 24

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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.


Docket/Case Number: C10000179


Allegations: 10-06-00, SEC RULE 11AC1-4, NASD RULES 2110, 3010, 6130 - RESPONDENTMEMBER RECEIVED CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIESWHICH WERE ELIGIBLE FOR DISPLAY AND FAILED TO PROPERLY DISPLAYTHE ORDER;FAILED TO REPORT TO ACT SHORT SALE TRANSACTIONSWITH A SHORT SALE INDICATOR;TRANSACTIONS IN ELIGIBLE SECURITIESREPORTED TO ACT WERE REPORTED WITH THE WRONG CAPACITY ANDDID NOT INCLUDE THE CONTRA BROKER IDENTIFICATION SYMBOL;FAILEDTO ACCEPT OR DECLINE TRADES WITHIN 20 MINUTES AFTER EXECUTIONIN ACT ELIGIBLE SECURITIES TRANSACTIONS; AND FAILED TO ESTABLISH,MAINTAIN, AND ENFORCE ADEQUATE WRITTEN SUPERVISORYPROCEDURES RELATING TO THE DISPLAY OF CUSTOMER LIMIT ORDERSAND ACT REPORTING.










Other Product Type(s): MARKET MAKING, EXECUTING TRANSACTIONS FOR CUSTOMERS ON APRINCIPAL AND AGENCY BASIS, LISTED TRANSACTIONS EXECUTED ONTHE EXCHANGE, UNDERWRITINGS, CORPORATE DEBT SECURITIES, ANDINVESTMENT COMPANY SECURITIES


Resolution:


Sanction Details: FINED $4,500

05-29-01, $4,500 PAID 11/07/00









Docket/Case Number: C10000179



Allegations: ALLEGED VIOLATIONS OF RULE 11AC1-4 UNDER SECURITIES EXCHANGEACT OF 1934 AND NASD RULES 2110, 3010, AND 6130



Resolution:









Sanction Details: FINE WAS PAID IN NOVEMBER 2000.


Disclosure 11 of 24

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Reporting Source: Firm






Docket/Case Number:



Allegations: ALLEGED VIOLATION OF NYSE RULE 132



Resolution:





Decision & Order of Offer of Settlement

Disclosure 12 of 24

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Allegations: ALLEGED VIOLATIONS OF RULES 15C3-3, 17A-3, 17A-5, AND 17A-13 UNDERSECURITIES EXCHANGE ACT OF 1934 AND NYSE RULES 342, 345A(B),409(A), AND 440









Censure


FINE


Docket/Case Number:



Allegations: ALLEGED VIOLATIONS OF RULES 15C3-3, 17A-3, 17A-5, AND 17A-13 UNDERSECURITIES EXCHANGE ACT OF 1934 AND NYSE RULES 342, 345A(B),409(A), AND 440


Resolution:


Sanction Details: FINE WAS PAID IN APPROXIMATELY AUGUST 1999.



Decision & Order of Offer of Settlement

Disclosure 13 of 24

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Docket/Case Number:



Allegations: ALLEGED VIOLATION OF NYSE RULE 132-30











Resolution:





Order

Disclosure 14 of 24

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Allegations: **11/16/1999** STIPULATION AND CONSENT TO PENALTY FILED BY NYSEDIVISION OF ENFORCEMENT AND PENDING. CONSENTED TO FINDINGS:WITHOUT ADMITTING OR DENYING GUILT AS TO ANY OF THE MATTERS SETFORTH ABOVE, THE FIRM CONSENTS TO: A. FINDINGS BY THE HEARINGPANEL THAT THE FIRM: 1. VIOLATED EXCHANGE RULE 342 IN THAT ITFAILED TO REASONABLY SUPERVISE OR CONTROL CERTAIN OF ITSBUSINESS ACTIVITIES; TO PROVIDE FOR APPROPRIATE PROCEDURES OFSUPERVISION AND CONTROL; AND TO ESTABLISH A SEPARATE SYSTEM OFFOLLOW-UP AND REVIEW WITH REGARD TO ORDER TAKING PROCEDURESTO DETERMINE THAT DELEGATED AUTHORITY AND RESPONSIBILITY WASBEING PROPERLY EXERCISED. 2. ENGAGED IN CONDUCT INCONSISTENTWITH JUST AND EQUITABLE PRINCIPLES OF TRADE IN THAT: A. DURINGTHE PERIOD 1994 THROUGH 1996 THE FIRM PERMITTED AND/OR FAILEDTO PREVENT TRADING DESK CLERKS FROM CLOCKING BLANK ORDERTICKETS BEFORE OR WITHOUT HAVING ORDERS; B. DURING THE PERIOD1994 THROUGH AUGUST 1996 THE FIRM FAILED TO PREVENT A PUBLICCUSTOMER FROM ENTERING ORDERS DIRECTLY WITHFLOOR BROKERS AND/OR THEIR MEMBER ORGANIZATIONS, ONE ORMOREOF WHOM WERE NOT APPROVED AND/OR QUALIFIED TO CONDUCTPUBLICBUSINESS; AND C. DURING THE PERIOD 1996 THROUGH LATE 1997 THEFIRM FAILED TO TRANSMIT DISCRETIONARY ORDERS INITIATED BY FLOORBROKERS TO THE FLOOR FOR EXECUTION BY DIFFERENT BROKERS. 3.VIOLATED SEC REGULATIONS SECTIONS 240.17A-3 AND 240.17A-4 ANDEXCHANGE RULE 440 IN THAT THE FIRM FAILED TO MAKE AND PRESERVERECORDS RELATING TO THE RECEIPT AND EXECUTION OF ALLCUSTOMER ORDERS. 4. VIOLATED EXCHANGE RULE 410 IN THAT THE FIRMFAILED TO PROPERLY CREATE AND MAINTAIN RECORDS WITHRESPECT TO ALL ORDERS WHICH IT DIRECTLY OR INDIRECTLYTRANSMITTED TO THE FLOOR FOR EXECUTION. 5. VIOLATED EXCHANGERULE 405 IN THAT THE FIRM FAILED TO EXERCISE APPROPRIATE DUEDILIGENCE WITH RESPECT TO ONE OR MORE ACCOUNTS: A. OVER WHICHEXCHANGE MEMBERS EXERCISED DISCRETION; AND B. IN THAT IT FAILEDTO PREVENT A PUBLIC CUSTOMER FROM ENTERING ORDERS(CONTINUED #13)







Initiated By: NYSE DIVISION OF ENFORCEMENT




Docket/Case Number: HPD# 00-10



**11/16/1999** STIPULATION AND CONSENT TO PENALTY FILED BY NYSEDIVISION OF ENFORCEMENT AND PENDING. CONSENTED TO FINDINGS:WITHOUT ADMITTING OR DENYING GUILT AS TO ANY OF THE MATTERS SETFORTH ABOVE, THE FIRM CONSENTS TO: A. FINDINGS BY THE HEARINGPANEL THAT THE FIRM: 1. VIOLATED EXCHANGE RULE 342 IN THAT ITFAILED TO REASONABLY SUPERVISE OR CONTROL CERTAIN OF ITSBUSINESS ACTIVITIES; TO PROVIDE FOR APPROPRIATE PROCEDURES OFSUPERVISION AND CONTROL; AND TO ESTABLISH A SEPARATE SYSTEM OFFOLLOW-UP AND REVIEW WITH REGARD TO ORDER TAKING PROCEDURESTO DETERMINE THAT DELEGATED AUTHORITY AND RESPONSIBILITY WASBEING PROPERLY EXERCISED. 2. ENGAGED IN CONDUCT INCONSISTENTWITH JUST AND EQUITABLE PRINCIPLES OF TRADE IN THAT: A. DURINGTHE PERIOD 1994 THROUGH 1996 THE FIRM PERMITTED AND/OR FAILEDTO PREVENT TRADING DESK CLERKS FROM CLOCKING BLANK ORDERTICKETS BEFORE OR WITHOUT HAVING ORDERS; B. DURING THE PERIOD1994 THROUGH AUGUST 1996 THE FIRM FAILED TO PREVENT A PUBLICCUSTOMER FROM ENTERING ORDERS DIRECTLY WITHFLOOR BROKERS AND/OR THEIR MEMBER ORGANIZATIONS, ONE ORMOREOF WHOM WERE NOT APPROVED AND/OR QUALIFIED TO CONDUCTPUBLICBUSINESS; AND C. DURING THE PERIOD 1996 THROUGH LATE 1997 THEFIRM FAILED TO TRANSMIT DISCRETIONARY ORDERS INITIATED BY FLOORBROKERS TO THE FLOOR FOR EXECUTION BY DIFFERENT BROKERS. 3.VIOLATED SEC REGULATIONS SECTIONS 240.17A-3 AND 240.17A-4 ANDEXCHANGE RULE 440 IN THAT THE FIRM FAILED TO MAKE AND PRESERVERECORDS RELATING TO THE RECEIPT AND EXECUTION OF ALLCUSTOMER ORDERS. 4. VIOLATED EXCHANGE RULE 410 IN THAT THE FIRMFAILED TO PROPERLY CREATE AND MAINTAIN RECORDS WITHRESPECT TO ALL ORDERS WHICH IT DIRECTLY OR INDIRECTLYTRANSMITTED TO THE FLOOR FOR EXECUTION. 5. VIOLATED EXCHANGERULE 405 IN THAT THE FIRM FAILED TO EXERCISE APPROPRIATE DUEDILIGENCE WITH RESPECT TO ONE OR MORE ACCOUNTS: A. OVER WHICHEXCHANGE MEMBERS EXERCISED DISCRETION; AND B. IN THAT IT FAILEDTO PREVENT A PUBLIC CUSTOMER FROM ENTERING ORDERS(CONTINUED #13)


Resolution:

Other Sanctions Ordered: CONSENT TO SENSURE, $100,000 FINE AND AN UNDERTAKING.

Sanction Details: **2/1/2000**VIOLATED RULE 342 BY FAILING TO REASONABLY SUPERVISEAND CONTROL ITS ACTIVITIES;PERMITTED TRADING DESK CLERKS TOCLOCK BLANK ORDER TICKETS BEFORE OR WITHOUT HAVING ORDERS;FAILED TO PREVENT A PUBLIC CUSTOMER FROM ENTERING ORDERSDIRECTLY WITH FLOOR BROKERS; FAILED TO TRANSMIT DISCRETIONARYORDERS INITIATED BY FLOOR BROKERS FOR EXECUTION BY DIFFERENTBROKERS ON THE FLOOR; VIOLATED SEC REGS. 240.17A-3 AND 1-4 ANDEXCHANGE RULE 440 BY FAILING TO MAKE AND PRESERVE RECORDSRELATING TO RECEIPT AND EXECUTION OF ORDERS; VIOLATEDEXCHANGE RULE 410 BY FAILING TO CREATE AND MAINTAIN RECORDSFOR ORDERS TRANSMITTED TO THE FLOOR; VIOLATED RULE 405 BYFAILING TO EXERCISE DUE DILIGENCE OVER ACCOUNTS; VIOLATED RULE345.15 BY FAILING TO PREVENT NON-REGISTERED PERSONS FROMPERFORMING DUTIES CUSTOMARILY PERFORMED BY REGISTEREDREPRESENTATIVES; VIOLATED RULE 401 BY FAILING TO ADHERE TOPRINCIPLES OF GOOD BUSINESS PRACTICE; AND VIOLATD RULE 408(A) BYACCEPTING ORDERS FOR CUSTOMER ACCOUNTS FROM OTHERSWITHOUT WRITTEN AUTHORIZATION.-CONSENT TO CENSURE, $100,000FINE AND AN UNDERTAKING.CONTACT: PEGGY GERMINO (212) 656-8450.


Decision






**2/1/2000**VIOLATED RULE 342 BY FAILING TO REASONABLY SUPERVISEAND CONTROL ITS ACTIVITIES;PERMITTED TRADING DESK CLERKS TOCLOCK BLANK ORDER TICKETS BEFORE OR WITHOUT HAVING ORDERS;FAILED TO PREVENT A PUBLIC CUSTOMER FROM ENTERING ORDERSDIRECTLY WITH FLOOR BROKERS; FAILED TO TRANSMIT DISCRETIONARYORDERS INITIATED BY FLOOR BROKERS FOR EXECUTION BY DIFFERENTBROKERS ON THE FLOOR; VIOLATED SEC REGS. 240.17A-3 AND 1-4 ANDEXCHANGE RULE 440 BY FAILING TO MAKE AND PRESERVE RECORDSRELATING TO RECEIPT AND EXECUTION OF ORDERS; VIOLATEDEXCHANGE RULE 410 BY FAILING TO CREATE AND MAINTAIN RECORDSFOR ORDERS TRANSMITTED TO THE FLOOR; VIOLATED RULE 405 BYFAILING TO EXERCISE DUE DILIGENCE OVER ACCOUNTS; VIOLATED RULE345.15 BY FAILING TO PREVENT NON-REGISTERED PERSONS FROMPERFORMING DUTIES CUSTOMARILY PERFORMED BY REGISTEREDREPRESENTATIVES; VIOLATED RULE 401 BY FAILING TO ADHERE TOPRINCIPLES OF GOOD BUSINESS PRACTICE; AND VIOLATD RULE 408(A) BYACCEPTING ORDERS FOR CUSTOMER ACCOUNTS FROM OTHERSWITHOUT WRITTEN AUTHORIZATION.-CONSENT TO CENSURE, $100,000FINE AND AN UNDERTAKING.CONTACT: PEGGY GERMINO (212) 656-8450.

Regulator Statement DIRECTLY WITH FLOOR BROKERS AND/OR THEIR MEMBERORGANIZATIONS, ONE OR MORE OF WHOM WERE NOT APPROVEDAND/OR QUALIFIED TO CONDUCT PUBLIC BUSINESS. 6.VIOLATEDEXCHANGE RULE 345.15 IN THAT THE FIRM FAILED TO PREVENT ONE ORMORE PERSONS WHO WERE NOT REGISTERED WITH, QUALIFIED BY,AND/OR ACCEPTABLE TO THE EXCHANGE FROM PERFORMINGREGULARLY THE DUTIES CUSTOMARILY PERFORMED BY A REGISTEREDREPRESENTATIVE ASSOCIATED WITH THE FIRM.7. VIOLATED EXCHANGERULE 401 IN THAT IT FAILED TO ADHERE TO PRINCIPLES OF GOODBUSINESS PRACTICE IN THE CONDUCT OF ITS BUSINESS AFFAIRS WITHRESPECT TO ITS HANDLING OF CERTAIN CUSTOMER ACCOUNTS WHICHFAILURE FACILITATED THE ABILITY OF ONE OR MORE FLOOR BROKERS TOCONTRAVENE EXCHANGE RULES REGARDING DISCRETIONARY TRADINGAND PUBLIC BUSINESS. 8. VIOLATED EXCHANGE RULE 408(A) IN THAT ITACCEPTED ORDERS FOR ONE OR MORE CUSTOMER ACCOUNTS FROMPERSONS OTHER THAN THE CUSTOMERSWITHOUT FIRST OBTAINING THE WRITTEN AUTHORIZATION OF THECUSTOMERS. B. THE IMPOSITION BY THE EXCHANGE OF A PENALTY OF ACENSURE AND A FINE OF $100,0000 AND AN UNDERTAKING TO HIRE ANINDEPENDENT CONSULTANT AND IMPLEMENT THE RECOMMENDATIONSOF THE CONSULTANT AS THEY RELATE TO THE FIRM'S TRADING DESK,FLIPPING AND DAY TRADING ACCOUNTS, AND ACCOUNTS OVER WHICHEXCHANGE MEMBERS HAVE DISCRETION.**3/7/2000** THE DECISION IS NOW FINAL AND EFFECTIVE IMMEDIATELY.





Allegations: ALLEGED VIOLATIONS OF RULES 17A-3 AND 17A-4 UNDER SECURITIESEXCHANGE ACT OF 1934 AND NYSE RULES 342, 345.15, 401, 405, 408(A),410, AND 440








Censure




Principal Product Type: Equity Listed (Common & Preferred Stock)



Resolution:

Other Sanctions Ordered: UNDERTAKING TO RETAIN INDEPENDENT CONSULTANT TO PERFORMREVIEW OF POLICIES AND PROCEDURES WITH REGARD TO TRADINGDEPARTMENT

Sanction Details: FINE WAS PAID IN APPROXIMATELY MARCH 2000.



Consent

Disclosure 15 of 24

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Allegations: (NASD RULES 2110, 3010, MARKETPLACE RULES 4632AND 4642 - RESPONDENT MEMBER ERRONEOUSLY REPORTEDTRANSACTIONS TO THE ACT IN THAT TRANSACTIONS WERE SUBMITTEDLATER THAN 90 SECONDS AFTER EXECUTION WITHOUT AN SLD MODIFIER,TRADES WERE REPORTED THAT THE FIRM WAS NOT REQUIRED TOREPORT, BUNCHED TRADE REPORTS WERE NOT IDENTIFIED WITH A "B"MODIFIER, TRADES WERE REPORTED AFTER HOURS WITHOUT A TMODIFIER, AND A TRADE THAT WAS ENTERED AS A SELL WAS, IN FACT, ABUY; AND, FAILED TO ESTABLISH WRITTEN SUPERVISORY PROCEDURESTHAT WERE REASONABLYDESIGNED TO PROVIDE SUPERVISORY PERSONNEL WITH METHODS TOREVIEW THE FIRM'S TRADE REPORTING TO ACHIEVE COMPLIANCE WITHAPPLICABLE TRADE REPORTING REQUIREMENTS AND THE PREPARATIONOF BOOKS AND RECORDS).












Docket/Case Number: C3B990005




Resolution:


Sanction Details: ON MARCH 17, 1999, DISTRICT NO. 3 NOTIFIED RESPONDENT OSCARGRUSS & SON, INC. THAT THE LETTER OF AWC NO. C3B990005 WASACCEPTED; THEREFORE, THE FIRM IS CENSURED AND FINED $6,000 -






Censure


FINE


Docket/Case Number: C3B990005



Allegations: ALLEGED VIOLATIONS OF NASD RULES 2110, 3010, 4632, AND 4642











Sanction Details: FINE WAS PAID IN MARCH 1999.



Disclosure 16 of 24

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Docket/Case Number: MS-1019-AWC(A)

Principal Product Type:


Allegations:



Resolution:


Sanction Details:

Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-1019-AWC (A)LETTEROF ACCEPTANCE, WAIVER AND CONSENT FILED DECEMBER 3, 1990AGAINST RESPONDENT MEMBER OSCAR GRUSS & SON INC. ALLEGEVIOLATIONS OF PART VI, SECTION 5(a) OF SCHEDULE D IN THATRESPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME.

THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BYTHE MARKET SURVEILLANCE COMMITTEE ON JANUARY 29, 1991 AND BYTHE NATIONAL BUSINESS CONDUCT COMMITTEE ON MARCH 28, 1991.$250.00 FINE. ***$250.00 PAID ON 4/17/91 INVOICE #91-MS-452***

Sanctions Ordered: Monetary/Fine $250.00

Consent






MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-1019-AWC (A)LETTEROF ACCEPTANCE, WAIVER AND CONSENT FILED DECEMBER 3, 1990AGAINST RESPONDENT MEMBER OSCAR GRUSS & SON INC. ALLEGEVIOLATIONS OF PART VI, SECTION 5(a) OF SCHEDULE D IN THATRESPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME.

THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BYTHE MARKET SURVEILLANCE COMMITTEE ON JANUARY 29, 1991 AND BYTHE NATIONAL BUSINESS CONDUCT COMMITTEE ON MARCH 28, 1991.$250.00 FINE. ***$250.00 PAID ON 4/17/91 INVOICE #91-MS-452***







Docket/Case Number: MS-1019-AWC



Allegations: ALLEGED VIOLATION OF PART VI, SECTION 5(A) OF SCHEDULE D



Resolution:


Sanction Details: FINE WAS PAID IN APRIL 1991.




Disclosure 17 of 24

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Allegations:











Docket/Case Number: MS-1124-AWC(A)




Resolution:


Sanction Details:

Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-1124-AWC (A)LETTEROF ACCEPTANCE, WAIVER AND CONSENT FILED MAY 31, 1991 AGAINSTRESPONDENT MEMBER OSCAR GRUSS & SON INCORPORATED ALLEGINGVIOLATIONS OF PART VI, SECTION 5(a) OF SCHEDULE D IN THATRESPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME.

THE LETTER OF ACCEPTANCE, WAVIER AND CONSENT WAS ACCEPTED BYTHE MARKET SURVEILLANCE COMMITTEE ON JULY 1, 1991 AND BY THENATIONAL BUSINESS CONDUCT COMMITTEE ON 8/8/91. $250 FINE. ***$250.00 PAID ON 9/4/91 INVOICE #91-MS-992***


Consent




Docket/Case Number: MS-1124-AWC















Resolution:


Sanction Details: FINE WAS PAID IN JULY 1991.




Disclosure 18 of 24

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Docket/Case Number: N-V-280



Allegations:



Resolution:


Sanction Details:


Decision






Sanction Details:

Regulator Statement NASDAQ COMPLAINT N-V-280 FILED 4/9/737/20/73 - FINED $25.008/17/73 - PAID9-4-73 - FINAL







Docket/Case Number: N-V-280



Allegations: NASDAQ COMPLAINT



Resolution:



Firm Statement MATTER OCCURRED PRIOR TO INCORPORATION OF REGISTRANT.


Other

Disclosure 19 of 24

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Docket/Case Number: NY-479

Allegations:













Resolution:


Sanction Details:

Regulator Statement COMPLAINT #NY-479 FILED 10/03/61DEC. - 05/29/62 - RESPONDENT IS CENSURED AND FINED $300.00.TO BE FINAL 06/28/62.CHECK FOR $300.00 REC'D RE MEMO OF 06/22/62. FINE PAID REMEMO 06/28/62.

Sanctions Ordered: CensureMonetary/Fine $300.00

Decision




Censure


FINE





Allegations: NASD COMPLAINT



Resolution: Decision








Sanction Details: FINE WAS PAID IN JUNE 1962.


Sanctions Ordered: CensureMonetary/Fine $300.00

Disclosure 20 of 24

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Initiated By: NYSE DIVISION OF ENFORCEMENT





Allegations: **AUGUST 24, 1995** STIPULATION & CONSENT TOPENALTY FILED BY NYSE DIVISION OF ENFORCEMENT, AND PENDING.CONSENTED TO FINDINGS: 1. VIOLATED EXCHANGE RULE 440C.10 INTHAT ON FIVE OCCASIONS IT FAILED DELIVER AGAINST SHORT SALES OFA SECURITY ON A NATIONAL SECURITIES EXCHANGE WITHOUT HAVINGMADE A DILIGENT EFFORT TO BORROW THE NECESSARY SECURITIES TOMAKE DELIVERY. 2. VIOLATED EXCHANGE RULE 342(a) AND (b) INTHAT: a. IT FAILED TO PROVIDE FOR, ESTABLISH AND MAINTAINAPPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL, INCLUDINGASEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, WITH RESPECT TO ITSOBLIGATION TO MAKE DILIGENT EFFORTS TO BORROW SECURITIESNECESSARY TO MAKE DELIVERY AGAINST SHORT SALES EFFECTED BYTHEFIRM; AND b. FAILED TO MAINTAIN APPROPRIATE PROCEDURES OFSUPERVISION AND CONTROL WITH RESPECT TO ITS OBLIGATION TOPROMPTLY OBTAIN AND MAINTAIN PHYSICAL POSSESSION OR CONTROLCUSTOMERS' FULLY PAID AND EXCESS MARGIN SECURITIES. 3. VIOLATEDREGULATION 15c3-3(b) OF THE SECURITIES AND EXCHANGE ACT OF 1934AND EXCHANGE RULE 402(a) IN THAT ON FIVE OCCASIONS IT FAILED TOMAINTAIN PHYSICAL POSSESSION OR CONTROL OF CUSTOMER'S FULLYPAID AND EXCESS MARGIN SECURITIES. THE IMPOSITION BY THEEXCHANGE OF THE PENALTY OF A CENSURE AND A FINE OF $10,000.










Resolution:


Sanction Details: Not Provided

Regulator Statement CONTACT: PEGGY GERMINO (212) 656-8450


Stipulation and Consent




Censure


FINE





Allegations: ALLEGED VIOLATIONS OF RULE 15C3-3(B) UNDER SECURITIES EXCHANGEACT OF 1934 AND NYSE RULES 342(A), 342(B), 402(A), AND 440C.10



Resolution:


Sanction Details: FINE WAS PAID IN SEPTEMBER 1995.



Stipulation and Consent







Disclosure 21 of 24

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Allegations: VIOLATED SECTION 15(C) OF THE SECURITIES EXCHANGE ACT OF 1934(EXCHANGE ACT), RULE 15C2-11 THEREUNDER, ARTICLE III, SECTION 1 OFTHE NASD'S RULES OF FAIR PRACTICE (RFP) AND SCHEDULE H, SECTION4 OF NASD'S BY-LAWS AND VIOLATIONS OF ARTICLE III, SECTIONS 1 AND27 OF THE RFP BY OGRU AND MEER FOR HAVING INADEQUATE SEC RULE15C2-11 PROCEDURES AND IMPROPER AND INADEQUATE SUPERVISIONOF GALLAGHER AND MORRIS DURING THE ONUS FORM 211 APPLICATIONPROCESS.



Resolution:


Sanction Details: OGRU AND MEER ARE CENSURED AND FINED, ON A JOINT AND SEVERALBASIS, 10,000; AND OGRU IS ASSESSED COSTS OF THE PROCEEDINGS INTHE AMOUNT OF $5,142.20.

Regulator Statement [TOP] MARKET SURVEILLANCE COMMITTEE (MSC) COMPLAINT#CMS940014 OSCAR GRUSS & SONS, INC. (OGRU); FRANCIS X.GALLAGHER; JOHN P. MORRIS; AND JONAH M. MEER. THE COMPLAINT INTHIS MATTER WAS FILED ON 2/24/94, BY THE MSC AGAINST THE ABOVENAMED RESPONDENTS. IN CAUSE I OF TWO CAUSES OF COMPLAINTOGRU, GALLAHER AND MORRIS ARE ALLEGED TO HAVE VIOLATEDSECTION 15(C) OF THE SECURITIES EXCHANGE ACT OF 1934 (EXCHANGEACT), RULE 15C2-11 THEREUNDER, ARTICLE III, SECTION 1 OF THE NASD'SRULES OF FAIR PRACTICE (RFP) AND SCHEDULE H, SECTION 4 OF NASD'SBY-LAWS. SPECIFICALLY OGRU, GALLAGHER, AND MORRIS FAILED TOMEET THEIR OBLIGATIONS UNDER SEC RULE 15C2-11 BY SUBMITTING ANDCONTINOUSLY PURSING, WITHOUT INDEPENDENT INQUIRY ORVERIFICATION, A FORM 211 APPLICATION TO QUOTE THE COMMON STOCKOF ONE FINANCIAL USA, INC. (ONUS) IN THE NQB PINK SHEETS THAT THEYWERE AWARE, OR SHOULD HAVE BEEN AWARE, INCLUDED MATERIALLYINACCURATE AND UNRELIABLE INFORMATION REGARDING THE ISSUER.CAUSE II OF THE COMPLAINT ALLEGES VIOLATIONS OF ARTICLE III,SECTIONS 1 AND 27 OF THE RFP BY OGRU AND MEER FOR HAVINGINADEQUATE SEC RULE 15C2-11 PROCEDURES AND IMPROPER ANDINADEQUATE SUPERVISION OF GALLAGHER AND MORRIS DURING THEONUS FORM 211 APPLICATION PROCESS. A HEARING ATTENDED BY ALLRESPONDENTS WAS HELD ON 8/3/94 - 8/5/94. ALL EXCEPT MEER WASREPRESENTED BY COUNSEL. IN ITS DECISION ISSUED ON 11/14/94, THEMSC FOUND THE VIOLATIONS AS ALLEGED IN THE COMPLAINT ANDIMPOSED THE FOLLOWING: GALLAGHER IS CENSURED AND FINED $7,500;MORRIS IS CENSURED AND FINED $5,000; OGRU AND MEER ARECENSURED AND FINED, ON A JOINT AND SEVERAL BASIS, 10,000; ANDOGRU IS ASSESSED COSTS OF THE PROCEEDINGS IN THE AMOUNT OF$5,142.20.**$10,000 J&S PAID 1/17/95 INVOICE #95-MS-26** **$5,142.20 PAID1/17/95 INVOICE #95-MS-27**


Decision






[TOP] MARKET SURVEILLANCE COMMITTEE (MSC) COMPLAINT#CMS940014 OSCAR GRUSS & SONS, INC. (OGRU); FRANCIS X.GALLAGHER; JOHN P. MORRIS; AND JONAH M. MEER. THE COMPLAINT INTHIS MATTER WAS FILED ON 2/24/94, BY THE MSC AGAINST THE ABOVENAMED RESPONDENTS. IN CAUSE I OF TWO CAUSES OF COMPLAINTOGRU, GALLAHER AND MORRIS ARE ALLEGED TO HAVE VIOLATEDSECTION 15(C) OF THE SECURITIES EXCHANGE ACT OF 1934 (EXCHANGEACT), RULE 15C2-11 THEREUNDER, ARTICLE III, SECTION 1 OF THE NASD'SRULES OF FAIR PRACTICE (RFP) AND SCHEDULE H, SECTION 4 OF NASD'SBY-LAWS. SPECIFICALLY OGRU, GALLAGHER, AND MORRIS FAILED TOMEET THEIR OBLIGATIONS UNDER SEC RULE 15C2-11 BY SUBMITTING ANDCONTINOUSLY PURSING, WITHOUT INDEPENDENT INQUIRY ORVERIFICATION, A FORM 211 APPLICATION TO QUOTE THE COMMON STOCKOF ONE FINANCIAL USA, INC. (ONUS) IN THE NQB PINK SHEETS THAT THEYWERE AWARE, OR SHOULD HAVE BEEN AWARE, INCLUDED MATERIALLYINACCURATE AND UNRELIABLE INFORMATION REGARDING THE ISSUER.CAUSE II OF THE COMPLAINT ALLEGES VIOLATIONS OF ARTICLE III,SECTIONS 1 AND 27 OF THE RFP BY OGRU AND MEER FOR HAVINGINADEQUATE SEC RULE 15C2-11 PROCEDURES AND IMPROPER ANDINADEQUATE SUPERVISION OF GALLAGHER AND MORRIS DURING THEONUS FORM 211 APPLICATION PROCESS. A HEARING ATTENDED BY ALLRESPONDENTS WAS HELD ON 8/3/94 - 8/5/94. ALL EXCEPT MEER WASREPRESENTED BY COUNSEL. IN ITS DECISION ISSUED ON 11/14/94, THEMSC FOUND THE VIOLATIONS AS ALLEGED IN THE COMPLAINT ANDIMPOSED THE FOLLOWING: GALLAGHER IS CENSURED AND FINED $7,500;MORRIS IS CENSURED AND FINED $5,000; OGRU AND MEER ARECENSURED AND FINED, ON A JOINT AND SEVERAL BASIS, 10,000; ANDOGRU IS ASSESSED COSTS OF THE PROCEEDINGS IN THE AMOUNT OF$5,142.20.**$10,000 J&S PAID 1/17/95 INVOICE #95-MS-26** **$5,142.20 PAID1/17/95 INVOICE #95-MS-27**




Censure





Allegations: ALLEGED VIOLATIONS OF SECTION 15(C) OF SECURITIES EXCHANGE ACTOF 1934, RULE 15C2-11 THEREUNDER, SCHEDULE H, SECTION 4 OF NASDBY-LAWS, AND ARTICLE III, SECTIONS 1 AND 27 OF NASD RULES OF FAIRPRACTICE








Censure


FINE


Resolution:


Sanction Details: FINE WAS PAID IN NOVEMBER 1994.




Disclosure 22 of 24

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Docket/Case Number: CMS920010 AWC(A)



Allegations:



Resolution:


Sanction Details:


Consent






Regulator Statement 5/29/92: MARKET SURVEILLANCE COMMITTEE COMPLAINT #CMS920010AWC(A) LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED FEBRUARY 11,1992 AGAINST RESPONDENT MEMBER OSCAR GRUSS & SONS, INC.ALLEGING VIOLATIONS OF PART VI, SECTION 2(d) OF SCHEDULED D FORENTERING NASDAQ QUOTATIONS CONTAINING EXCESS SPREADS.

THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BYTHE MARKET SURVEILLANCE COMMITTEE ON APRIL 30, 1992 AND BY THENATIONAL BUSINESS CONDUCT COMMITTEE ON MAY 15, 1992. $1,000.00FINE. **$1,000.00 PAID ON 6/5/92 INVOICE #92-MS-516**







Docket/Case Number: CMS920010-AWC



Allegations: ALLEGED VIOLATION OF PART VI, SECTION 2(D) OF SCHEDULE D



Resolution:






Disclosure 23 of 24

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Disclosure 23 of 24









Allegations:



Resolution:


Sanction Details:

Regulator Statement MARKET SURVEILLANCE COMMITTEE COMPLAINT #CMS910196 AWC (A):LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED DECEMBER 4,1991AGAINST RESPONDENT MEMBER OSCAR GRUSS & SON INC. ALLEGINGVIOLATIONS OF PART VI, SECTION 5(a) OF SCHEDULE D IN THAT THEFOLLOWING RESPONDENTS FAILED TO REPORT THEIR NASDAQ VOLUME:

THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BYTHE MARKET SURVEILLANCE COMMITTEE ON FEBRUARY 20, 1992 AND BYTHE NATIONAL BUSINESS CONDUCT COMMITTEE ON MARCH 25, 1992. ***$500.00 FINED*** ***$500.00 PAID ON 4/17/92 INVOICE #92-MS-369***




















Resolution:


Sanction Details: FINE WAS PAID IN MARCH 1992.




Disclosure 24 of 24

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Docket/Case Number: MV-11



Allegations:


Resolution: Decision57©2020 FINRA. All rights reserved. Report about OSCAR GRUSS & SON INCORPORATED






Resolution:


Sanction Details:

Regulator Statement COMPLAINT #MV-11 - DIST. 12, FILED 06/06/6106/08/61 ACCEPTED MV PROCEDURECENSURED, FINAL 06/08/61

Sanctions Ordered: Censure

Decision




Censure



Docket/Case Number: MV-11



Allegations: DISTRICT 12 COMPLAINT



Resolution:


Sanction Details: NO FINE.


Sanctions Ordered: Censure

Consent






Arbitration Award - Award / Judgment

Brokerage 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 5


Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

12/18/2000

00-05493

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE

$240,000.00

AWARD AGAINST PARTY

04/05/2002

$74,000.00

There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.

Disclosure 2 of 5

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:


NASD

02/11/2003

03-00749

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-NEGLIGENCE

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE59©2020 FINRA. All rights reserved. Report about OSCAR GRUSS & SON INCORPORATED




www.finra.org/awardsonline

https://www.finra.org/arbitration-mediation/arbitration-awards-online?search=00-05493





Disposition:

Disposition Date:



$5,200,000.00

AWARD AGAINST PARTY

05/21/2004

$648,000.01


Disclosure 3 of 5

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

11/12/1997

97-05328

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT RELATED-BREACH OF CONTRACT; DO NOT USE-NOOTHER CONTROVERSY INVOLVED


$1,100,000.00

AWARD AGAINST PARTY

06/07/1999

$94,898.00


Disclosure 4 of 5

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Arbitration Forum:

Case Initiated:

Allegations:

NASD

09/28/1998

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT RELATED-BREACH OF CONTRACT; EMPLOYMENT-BREACH OF CONTRACT







Case Initiated:

Case Number:



Disposition:

Disposition Date:


09/28/1998

98-03453

COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE;OPTIONS

$118,000.00

AWARD AGAINST PARTY

06/21/2002

$27,929.69


Disclosure 5 of 5

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Arbitration Forum:

Case Initiated:

Case Number:

Allegations:



Disposition:

Disposition Date:


NASD

03/14/2000

99-04632

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-CHURNING; ACCOUNT ACTIVITY-UNAUTHORIZED TRADING; DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE


$150,000.01

AWARD AGAINST PARTY

08/09/2005

$31,500.00









Judgment / Lien

This type of disclosure event involves an unsatisfied and outstanding judgment or lien against the brokerage firm.

Disclosure 1 of 10


Judgment/Lien Amount: $4,148.49

Judgment/Lien Holder: FRANK MILLER

Judgment/Lien Type: Default

Date Filed: 02/15/2008

Court Details: LANDGERICHT KREFELD, FEDERAL REPUBLIC OF GERMANY

Firm Statement MORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE ABOVE DESCRIBED REASONS THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM 1 REPRESENTS 2,101.98 EUROS, PLUS 324.00 EUROSIN COURT FEES, PLUS 621.78 EUROS IN LAWYER FEES, CONVERTED INTOUS DOLLARS ON JULY 8, 2014. THE AMOUNT DOES NOT INCLUDEINTEREST, AS THE AMOUNT OF INTEREST CANNOT BE CALCULATEDBASED ON THE TRANSLATION THAT OGSI POSSESSES.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.

Disclosure 2 of 10

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Disclosure 2 of 10



Judgment/Lien Holder: STEPHAN GARTENMANN




Firm Statement MORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE ABOVE DESCRIBED REASONS THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM 1 REPRESENTS 178,210.10 SWISS FRANCS, PLUS1,146.00 EUROS IN COURT FEES, PLUS 4,748.10 EUROS IN LAWYER FEES,CONVERTED INTO US DOLLARS ON JULY 8, 2014. THE AMOUNT DOES NOTINCLUDE INTEREST, AS THE AMOUNT OF INTEREST CANNOT BECALCULATED BASED ON THE TRANSLATION THAT OGSI POSSESSES.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.

Disclosure 3 of 10

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Judgment/Lien Holder: BEAT MOSER

Judgment/Lien Type: Default63©2020 FINRA. All rights reserved. Report about OSCAR GRUSS & SON INCORPORATED









Firm Statement MORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE REASONS DESCRIBED ABOVE THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM 1 REPRESENTS 36,488.05 EUROS, PLUS 1,428.00EUROS IN COURT FEES, PLUS 3,037.48 EUROS IN LAWYER FEES,CONVERTED INTO US DOLLARS ON JULY 8, 2014. THE AMOUNT DOES NOTINCLUDE INTEREST, AS THE AMOUNT OF INTEREST CANNOT BECALCULATED BASED ON THE TRANSLATION THAT OGSI POSSESSES.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.

Disclosure 4 of 10

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Judgment/Lien Holder: FRANCOIS MALHERBE









Court Details: LANDGERICHT KREFELD 5 O 207/09

Firm Statement MORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE REASONS DESCRIBED ABOVE THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM 1 REPRESENTS 100,676.20 SWISS FRANCS, PLUS786.00 EUROS IN COURT FEES, PLUS 3,989.48 EUROS IN LAWYER FEES,CONVERTED INTO US DOLLARS ON JULY 8, 2014. THE AMOUNT DOES NOTINCLUDE INTEREST, AS THE AMOUNT OF INTEREST CANNOT BECALCULATED BASED ON THE TRANSLATION THAT OGSI POSSESSES.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.

Disclosure 5 of 10

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Judgment/Lien Holder: ANDREAS DOUBECK



Court Details: LANDGERICHT KREFELD 5 O 213/09, FEDERAL REPUBLIC OF GERMANY

Firm Statement MORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE REASONS DESCRIBED ABOVE THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM 1 REPRESENTS 50,011.76 EUROS, PLUS 666.00 EUROSIN COURT COSTS, PLUS 3,736.60 EUROS IN LAWYER FEES, CONVERTEDINTO US DOLLARS AS OF JULY 8, 2014. THE AMOUNT DOES NOT INCLUDEINTEREST, AS THE AMOUNT OF INTEREST CANNOT BE CALCULATEDBASED ON THE TRANSLATION THAT OGSI POSSESSES.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.






Firm Statement MORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE REASONS DESCRIBED ABOVE THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM 1 REPRESENTS 50,011.76 EUROS, PLUS 666.00 EUROSIN COURT COSTS, PLUS 3,736.60 EUROS IN LAWYER FEES, CONVERTEDINTO US DOLLARS AS OF JULY 8, 2014. THE AMOUNT DOES NOT INCLUDEINTEREST, AS THE AMOUNT OF INTEREST CANNOT BE CALCULATEDBASED ON THE TRANSLATION THAT OGSI POSSESSES.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.

Disclosure 6 of 10

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Judgment/Lien Holder: JULIUS WERNE




Firm Statement MORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE REASONS DESCRIBED ABOVE THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM 1 REPRESENTS 58,366.90 EUROS, PLUS 1,998.00EUROS IN COURT FEES, PLUS 3,736.60 EUROS IN LAWYER FEES,CONVERTED INTO US DOLLARS ON JULY 8, 2014. THE JUDGMENT ALSOPROVIDES FOR INTEREST AT 4% PER ANNUM.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.





www.finra.org/brokercheck User GuidanceMORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE REASONS DESCRIBED ABOVE THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM 1 REPRESENTS 58,366.90 EUROS, PLUS 1,998.00EUROS IN COURT FEES, PLUS 3,736.60 EUROS IN LAWYER FEES,CONVERTED INTO US DOLLARS ON JULY 8, 2014. THE JUDGMENT ALSOPROVIDES FOR INTEREST AT 4% PER ANNUM.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.

Disclosure 7 of 10

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Judgment/Lien Holder: MARTIN HEILINGENMANN




Firm Statement MORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE ABOVE DESCRIBED REASONS THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM 1 REPRESENTS 41,163.80 EUROS, PLUS 1,533.00EUROS IN COURT COSTS, PLUS 3,260.60 EUROS IN LAWYER FEES,CONVERTED INTO US DOLLARS ON JULY 8, 2014. THE JUDGMENT ALSOPROVIDES FOR INTEREST AT 4% PER ANNUM.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.






MORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE ABOVE DESCRIBED REASONS THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM 1 REPRESENTS 41,163.80 EUROS, PLUS 1,533.00EUROS IN COURT COSTS, PLUS 3,260.60 EUROS IN LAWYER FEES,CONVERTED INTO US DOLLARS ON JULY 8, 2014. THE JUDGMENT ALSOPROVIDES FOR INTEREST AT 4% PER ANNUM.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.

Disclosure 8 of 10

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Judgment/Lien Holder: JURGEN ZENTSCH




Firm Statement MORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE REASONS DESCRIBED ABOVE THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM 1 REPRESENTS 10,105.27 EUROS, PLUS 267.00 EUROSIN COURT FEES, PLUS 1,820.70 EUROS IN LAWYER FEES, CONVERTEDINTO US DOLLARS ON JULY 8, 2014. THE AMOUNT DOES NOT INCLUDEINTEREST, AS THE AMOUNT OF INTEREST CANNOT BE CALCULATEDBASED ON THE TRANSLATION THAT OGSI POSSESSES.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.






MORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE REASONS DESCRIBED ABOVE THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM 1 REPRESENTS 10,105.27 EUROS, PLUS 267.00 EUROSIN COURT FEES, PLUS 1,820.70 EUROS IN LAWYER FEES, CONVERTEDINTO US DOLLARS ON JULY 8, 2014. THE AMOUNT DOES NOT INCLUDEINTEREST, AS THE AMOUNT OF INTEREST CANNOT BE CALCULATEDBASED ON THE TRANSLATION THAT OGSI POSSESSES.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.

Disclosure 9 of 10

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Judgment/Lien Holder: SAMUEL MEIER




Firm Statement MORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE ABOVE DESCRIBED REASONS THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM 1 REPRESENTS 96,246.00 SWISS FRANCS, PLUS2,358.00 EUROS IN COURT FEES, PLUS 3,989.48 EUROS IN LAWYER FEES,CONVERTED INTO US DOLLARS ON JULY 8, 2014. THE AMOUNT DOES NOTINCLUDE INTEREST, AS THE AMOUNT OF INTEREST CANNOT BECALCULATED BASED ON THE TRANSLATION THAT OGSI POSSESSES.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.






MORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE ABOVE DESCRIBED REASONS THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM 1 REPRESENTS 96,246.00 SWISS FRANCS, PLUS2,358.00 EUROS IN COURT FEES, PLUS 3,989.48 EUROS IN LAWYER FEES,CONVERTED INTO US DOLLARS ON JULY 8, 2014. THE AMOUNT DOES NOTINCLUDE INTEREST, AS THE AMOUNT OF INTEREST CANNOT BECALCULATED BASED ON THE TRANSLATION THAT OGSI POSSESSES.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.

Disclosure 10 of 10

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Judgment/Lien Holder: FRANZ STILLER




Firm Statement MORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE REASONS DESCRIBED ABOVE THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM REPRESENTS 154,892.31 EUROS, PLUS 4,158.00EUROS IN COURT FEES, PLUS 3,789.44 EUROS IN LAWYER FEES,CONVERTED INTO US DOLLARS AS OF JULY 9, 2014. THE AMOUNT DOESNOT INCLUDE INTEREST, AS THE AMOUNT OF INTEREST CANNOT BECALCULATED BASED ON THE TRANSLATION THAT OGSI POSSESSES.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.






MORE THAN 15 YEARS AGO, PLAINTIFF, A CUSTOMER OF A FOREIGNINTRODUCING BROKER, ENGAGED IN OPTIONS TRADING IN THE UNITEDSTATES USING OSCAR GRUSS & SON INCORPORATED ("OGSI") AS HISEXECUTING BROKER. BEFORE ANY TRANSACTIONS WERE EFFECTED,PLAINTIFF SIGNED A STANDARD OGSI CUSTOMER AGREEMENTPROVIDING THAT NEW YORK LAW GOVERNED AND THAT ALLCONTROVERSIES RELATING TO HIS ACCOUNT WOULD BE SUBJECT TOARBITRATION IN THE US UNDER THE FEDERAL ARBITRATION ACT. IN 2010,MORE THAN 10 YEARS AFTER ENGAGING IN THESE TRANSACTIONS, ANDNOTWITHSTANDING THE ARBITRATION PROVISIONS OF HIS CUSTOMERAGREEMENT, THAT GERMAN COURTS HAD NO JURISDICTION OVER OGSI,AND THAT THE STATUTE OF LIMITATIONS UNDER APPLICABLE NEW YORKLAW HAD EXPIRED, PLAINTIFF COMMENCED AN ACTION IN A GERMANCOURT AND SECURED A DEFAULT JUDGMENT IN GERMANY AGAINST OGSI.OGSI WAS ADVISED AND CONTINUES TO BE ADVISED BY OUTSIDECOUNSEL THAT FOR THE REASONS DESCRIBED ABOVE THE JUDGMENT ISWITHOUT ANY LEGAL EFFECT IN THE US AND MAY BE DISREGARDED.BASED ON THIS ADVICE, OGSI'S AUDITING ACCOUNTANTS DID NOTREQUIRE THE DEFAULT JUDGMENT TO BE TREATED AS A LIABILITY OR ANYRESERVE TO BE ESTABLISHED FOR IT. THE AMOUNT SET FORTH INRESPONSE TO ITEM REPRESENTS 154,892.31 EUROS, PLUS 4,158.00EUROS IN COURT FEES, PLUS 3,789.44 EUROS IN LAWYER FEES,CONVERTED INTO US DOLLARS AS OF JULY 9, 2014. THE AMOUNT DOESNOT INCLUDE INTEREST, AS THE AMOUNT OF INTEREST CANNOT BECALCULATED BASED ON THE TRANSLATION THAT OGSI POSSESSES.AS OF 8/7/2014, THE NEW SHAREHOLDERS AND OSCAR GRUSS & SONINCORPORATED, HAVE BEEN INDEMNIFIED BY THE PRIORSHAREHOLDERS OF THIS LIEN. THIS IS OUTLINED IN THE PURCHASEAGREEMENT DATED NOVEMBER 25, 2013.






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OSCAR GRUSS & SON INCORPORATED · OSCAR GRUSS & SON INCORPORATED CRD# 2091 SEC# 8-22371 Main Office Location 430 PARK AVENUE 6TH FLOOR NEW YORK, NY 10022 Regulated by FINRA New York