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Schedule A to the FINRA Sanction Guidelines [Version up to May. 1, 2018]

Violations That Generally Are Not Subject to Censure When Monetary Sanctions of $7,000 or Less Are Imposed

Quality of Markets Violations

•   ACT Violations—FINRA Rules 7210A7280A, 73107380 and 7110B7170B
•   Backing Away
•   Best Execution and Interpositioning
•   Confirmation of Transactions (SEC Rule 10b-10)
•   ECN Display Rule
•   Failure to Display Minimum Size in NASDAQ® Securities, CQS Securities, and OTC Bulletin Board® Securities
•   Fixed Income Pricing SystemSM—Trade Reporting and Participant and Quotation Obligations
•   Limit Order Display Rule
•   Limit Order Protection Rule
•   Locked/Crossed Market
•   Options Exercise and Positions Limits
•   Options Positions Reporting—Late Reporting and Failing to Report
•   Order Audit Trail System (FINRA Rules 74007460)
•   Passive Market Making
•   Short Sale Violations
•   SOESSM Rules
•   Trades Executed During a Trading Halt
•   Trade Reporting—Late Reporting; Failing to Report; Inaccurate Reporting
•   1% Rule—SEC Rule 11Ac1-1(c)(1)

Qualification and Membership Violations

•   Continuing Education—Firm Element
•   Continuing Education—Regulatory Element
•   Registration Violations

Reporting/Provision of Information Violations

•   FOCUS Reports—Late Filing
•   Form BD-Y2K Reports—Late Filing
•   Forms U-4/U-5—Late Filing; Failing to File; Filing Inaccurate Forms or Amendments
•   MSRB Rule G-36—Untimely Filing of Offering Documents with MSRB; Late Filing; Failing to File
•   Reportable Events Under NASD Rule 3070—Late Reporting; Failing to Report; Filing Inaccurate Reports
•   MSRB Rule G-37 Reporting—Late Filing; Failing to File
•   Regulation M Reports—Late Filing; Failing to File
•   Request for Automated Transmission of Trading Data (Blue Sheets)—Failure to Respond in a Timely and Accurate Manner

Financial and Operational Practices Violations

•   Customer Protection Rule violations
•   Net Capital violations
•   Recordkeeping violations
•   Violations of SEC Rule 17a-11 (Notification Provisions for Broker-Dealers) Supervision Violations
•   Supervisory Procedures—Deficient Written Supervisory Procedures

1. Additionally, censures generally will not be imposed for violations disposed of under the Minor Rule Violation Plan pursuant to FINRA Rules 9216 and 9217.