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City of La Quinta Page 0 of 8 Finance Department Broker/Dealer RFI FY 2018/19 CITY OF LA QUINTA BROKER/DEALER REQUEST FOR INFORMATION FY 2018/19 FINANCE DEPARTMENT 78-495 Calle Tampico La Quinta, CA 92253 (760)777-7150 1 SECTION I: BACKGROUND INFORMATION AND SELECTION PROCESS The City of La Quinta (hereafter referred to as the "City") actively manages an operational portfolio in accordance with the California Government Code and the City’s Investment Policy. As of December 31, 2018, total assets of the portfolio were approximately $130 million consisting of U.S. Treasury, Corporate, and Agency obligations; investment in Local Government Investment Pools (LGIP); and negotiable Certificates of Deposit. The Investment Policy may be obtained at: https://laqlaserweb.laquintaca.gov/WebLink/DocView.aspx?id=483099&dbid =1&repo=CityofLaQuinta The Policy is also attached at the end of this document for your convenience. The City only transacts securities with broker/dealers that are on the City's Authorized Financial Dealers and Institutions list. To select new broker/dealers, the City uses an open process to ensure all interested brokers may compete for placement on the City’s approved list. During the Request for Information (RFI), prospective broker/dealers are required to provide information on their practice, financial condition, and other factors. The intent is to enter a long-term relationship, therefore, the integrity of the firm and the personnel assigned to the City's account is of primary importance. To be considered, broker/dealers must: • Confirm that they are a member of the Financial Industry Regulatory Authority (FINRA), are registered with the Securities & Exchange Commission (SEC), and possess all other required licenses. • State in writing their acceptance and understanding of the City’s written Investment Policy. • Provide the City with audited annual financial statements. All firms with whom the City does business must have a stable financial condition. • Have the ability to conduct transactions on a delivery vs. payment (DVP) basis. 2 •Have been in operation for more than five (5) years. •Have adequate financial strength and capital to support the level of trading that is approved. Adequate financial strength will be assessed by a review of the balance sheet and income statement of the broker/dealer. •Provide institutional or middle-market coverage. Retail-oriented offices without institutional client capabilities do not qualify. It is important that the firm provide related services that will enhance the account relationship, which could include: •An active secondary market for its securities. •Internal credit research analysis on commercial paper, bankers’ acceptances and other securities it offers for sale. •Be willing to purchase securities from the City’s portfolio. •Be capable of providing market analysis, economic projections, portfolio analysis, interest earnings projections, and newsletters. SECTION II: APPLICATION DEADLINE AND REQUIRED DOCUMENTS To be considered, each broker/dealer candidate must submit the completed application and all of the following required documents by no later than 5pm on March 29 , 2019. •A completed “Broker/Dealer Questionnaire and Certification.” •A resume on each firm employee with whom the City would be trading. •Copies of the firm’s most recent Annual Reports, Form 10-Ks, and audited financial statements. •Confirmation of registration with the Securities & Exchange Commission (SEC) •Confirmation that the account representative(s) and the firm are members of the Financial Industry Regulatory Authority (FINRA). 3 •Copy of the last two years of SEA rule 15c3-1 – net capital requirement for broker dealers. •Samples of fixed-income research reports or market information that the firm regularly provides to public sector clients. These documents may be delivered in person, electronically, by post, or by courier to: City of La Quinta Finance Department Attention: Rosemary Hallick 78495 Calle Tampico La Quinta CA, 92253 Finance@laquintaca.gov If a broker/dealer candidate fails to submit the above-referenced documents by the specified deadline, then its RFI shall be deemed to have been automatically rejected by the City. If you have any questions about this RFI, please contact Rosemary Hallick at (760) 777-7058 or Karla Campos at (760) 777-7073. SECTION III: SELECTION PROCESS An initial screening will be performed to ensure the firm meets the City’s minimum requirements. The applications of the broker/dealers that successfully pass the initial screening will be further reviewed for suitability by City Staff and members of the City’s Financial Advisory Commission. Final recommendations will be made to City Council for approval to be added to the Authorized Financial Dealers and Institutions list. Completion of this Request for Information is not a guarantee that a broker/dealer candidate will be authorized to provide financial service to the City. SECTION IV: BROKER/DEALER QUESTIONNAIRE 4 BROKER/DEALER QUESTIONNAIRE AND CERTIFICATION 1.Name of Firm: __BNP Paribas Securities Corp.________________ 2.Physical Address of Trading Office:__2527 Camino Ramon, San Ramon, CA 94583 3.Physical Address of Corporate Headquarters:_787 7th Avenue, New York, NY 10019_ 3.Telephone of Trading Office:(925)843_-__8743___ Telephone of Corporate Headquarters: (212) 841-_2000____ 4.Broker's Representative(s) to the City (attach resume(s)): Name: Craig Conley__________________________________ Title: Vice President Fixed Income_________________________ Telephone:(_925) _843_-__8743_______ 5.Manager/Partner-in-charge (attach resume): Name:________________________________________________________ Title:_________________________________________________________ Telephone:(___) _____-_________ 6.Please indicate the staffing level for your office: Management: ______ Trading: ______ Sales: ______ Operations/Clearing: ______ 7.Which of the above personnel have read the City's Investment Policy? _____________________________________________________________ 8.Which instruments are offered regularly by your local office? (Must equal 100%) _____% Repos _____% Reverse Repos _____% CMO’s _____% Derivatives _____% Stocks/Equities __x__% U.S. Treasuries _____% BA's __x__% Commercial Paper __x__% CD’s _____% Mutual Funds __x__% Agencies (specify):_____% Other (specify): ________________________________________________________________ ________________________________________________________________ Amit Jogal Director of Fixed Income Trading 925 843 8478 X X X X Craig Conley 5 9.References -- Please identify your most directly comparable public sector clients in our geographical area. Entity Riverside CountyContact Giovane PizanoTelephone (951) 955-3944__Client Since __ Entity_San Joaquin County Contact Mandy Matter _______________ Telephone (209) 468-2155 Client Since ________________ 10.Has your firm been subject to any litigation, arbitration, or regulatory proceedings, either pending, adjudicated, or settled, that involved allegations of improper, fraudulent, disreputable or unfair activities related to the sale of securities to or the purchase of securities from institutional clients? If so, explain. __ Due to the confidential nature of any pending enforcement and or criminal actions against BNPPSC, or against an officer, partner or member, by any governmental (SEC, or any state or foreign regulatory organization) agency filed against our firm, we are not at liberty to provide any information in response to such enquiries beyond the information that has been provided in publicly filed disclosure documents. 11.Has your firm or your local office, or representatives assigned to this account, been subject to a regulatory or state/ federal agency investigation for alleged improper, fraudulent, disreputable or unfair activities related to the sale of securities or money market instruments that resulted in a suspension or censure? If so, explain. _____________________________________________________________ _Regarding enquiries as to whether BNPPSC has ever been censored or punished by a regulatory State of Federal Agency for improper or fraudulent activities arising from the sale of securities, please refer "Form Broker Dealer" for BNPPSC and reference the Disclosure Reporting Section _http://brokercheck.finra.org/Search/ _______________________________________________________ 12.Are you aware of any current or pending complaints that are unreported to FINRA against you or your firm? If so, explain. _No__________________________________________________________ _____________________________________________________________ 13.Explain your clearing and safekeeping procedures, custody and delivery process. _BNP PARIBAS SECURITIES CORP, CUSTODY, DELIVERY & SETTLEMENT BNPPSC Tri-Party Custodian Bank of New York (BONY) Corporate HQ Address One Wall St, NY, NY 10286 Contact Person Keith Kochie, VP Relationship Manager Telephone Number 212 635 8342 Length of Relationship Greater than 5 Years_________________________ Who audits these fiduciary responsibilities? Internal Auditors and PWC________________________________________ Latest Audit Report Date ___March 2018_____________________ 14.Describe the method your firm would use to establish capital trading limits for the City of La Quinta. 6 15.Is your firm a member in the Securities Investor Protection Corporation (SIPC). insurance program? Yes___X_ No_____ If yes, explain primary and excess coverage and carriers. 16.Does your firm regularly report to the Market Reports Division of the Federal Reserve Bank of New York as a “primary dealer”? Yes__X_____ No ________ 17.Is your firm owned by a holding company? Yes__X____ No________ 18.Does your firm comply with the Federal Reserve Bank’s capital adequacy quidelines? Yes__X_______ No_________ 19.Does your firm offer investment training to clients? Yes_____ No__X___ 20.Does your firm have professional liability insurance? Yes______ No_______ If yes, please provide the insurance carrier, limits and expiration date. _____________________________________________________________ _____________________________________________________________ 21.Is your firm a member of the Financial Industry Regulatory Authority (FINRA)? List your FINRA/NASD Registration Number and attach current FINRA broker check report. __CRD 15794/SEC 8-32682___________________ 22.Do you have any relatives who work at the City of La Quinta? Yes______ No_______ If yes, please provide their full name, position and department. _____________________________________________________________ 23.Is your firm currently licensed as a broker/dealer by the State of California?Do you maintain an office in California? _____________________________________________________________ _____________________________________________________________ 24.Do you maintain an office in La Quinta or Riverside County? Yes____ No______ 25.Please enclose the following: Latest audited financial statements; Samples of reports, transaction confirmations and any other research/publications the City would receive if you were approved; Samples of research reports and/or publications that your firm regularly provides to clients; and Complete schedule of fees and charges for transactions. X X Yes, Yes X 7 SECTION V: ACKNOWLEDGEMENT and CERTIFICATION My firm will notify the City immediately, by telephone, and, in writing, in the event of a material adverse change in its financial condition, or of any violation of Municipal Securities Rulemaking Board Rule G-37. ***CERTIFICATION*** I hereby certify that I have personally read the Investment Policy of the City of La Quinta and the California Government Codes pertaining to the investments of the City. We have implemented reasonable procedures and a system of controls designed to prevent imprudent investment activities arising out of transactions conducted between our firm and the City of La Quinta. All sales personnel will be routinely informed of the City’s investment objectives, horizons, outlooks, strategies and risk constraints whenever we are so advised by the City. We pledge to exercise due diligence in informing the City of La Quinta of all foreseeable risks associated with financial transactions conducted with our firm. By signing this document, we authorize the City of La Quinta to conduct any and all background checks. Under penalties of perjury, I Certify that the responses to this questionnaire are true and accurate to the best of my knowledge and that I am authorized to execute this request for information. Firm Name:___________________________________________________ Broker Representative Signature: _______________________ Print Name: _________________ Date: ________________________________________________________ Title: ________________________________________________________ Sales Manager and/or Managing Partner Signature: ________________________ Print Name:_________________ Date: ________________________________________________________ Title: ________________________________________________________ *This form must be signed by a registered principal or an individual with signing authority on behalf of the firm. BNP Paribas SECURITIES CORP. Member NYSE, SIPC, NASD and other Principal Exchanges 787 Seventh Avenue New York, NY 10019-6016 (212) 841-3000 www.bnpparibas.us March 15, 2019 City Of La Quinta Finance Department 78-495 Calle Tampico La Quinta, Ca 92253 Dear Finance Department BNP Paribas Securities Corp. is in receipt of your Investment Policy, titled 2018/19 Investment Policy and understands the provisions and restrictions contained therein. However, it is your responsibility to comply with your own state statutes, internal investment guidelines, policies, procedures as well as any other state, federal or other relevant requirements. BNP Paribas Securities Corp. is not an investment advisor. Notwithstanding anything contrary in the Investment Policy, BNP Paribas Securities Corp. notes the following: BNP Paribas and the City of La Quinta are market professionals and trade with each other on that basis. Consistent with standard market practice, market professionals such as BNP Paribas Securities Corp and the City of La Quinta are responsible for the conduct of their employees, authorized agents and other persons that are vested with apparent authority ("Authorized Persons"). This responsibility includes monitoring and enforcing any restrictions or limitations on the authority of such Authorized Persons. BNP Paribas Securities Corp is prepared to accept the Investment Policy as outlined; however, in doing so, BNP Paribas Securities Corp does not absolve the City of La Quinta of its own responsibility of monitoring its own employees and BNP Paribas Securities Corp relies on the City of La Quinta fulfilling this responsibility notwithstanding anything to the contrary therein. Sincerely, BNP Paribas Securities Corp. **_BNPPSC has received City of La Quinta Investment Policy and understands the provisions and restrictions contained therein. However, it is your responsibility to comply with your own state statutes, internal investment guidelines, policies, procedures as well as any other state, federal or other relevant requirements. BNP Paribas Securities Corp. is not an investment advisor. 1 2018/19 INVESTMENT POLICY Fiscal year 2018/2019 Table of Contents Section Topic Page Executive Summary 2 I General Purpose 3 II Investment Policy 3 III Scope 3 IV Objectives 3 V Maximum Maturities 5 VI Prudence 5 VII Authority 5 VIII Ethics and Conflicts of Interest 6 IX Authorized Financial Dealers and Institutions 6 X Permissible Deposits and Investments 7 XI Investment Pools 9 XII Payment and Custody 10 XIII Interest Earning Distribution Policy 10 XIV Internal Controls and Independent Auditors 10 XV Reporting Standards 12 XVI Financial Assets and Investment Activity Not subject to this Policy 12 XVII Investment of Bond Proceeds 12 XVIII Financial Advisory Commission – City of La Quinta 12 XIX Investment Policy Adoption 13 Appendices Topic Page A City of La Quinta Municipal Code Ordinance 2.70 – Financial Advisory Commission 14 B City of La Quinta Municipal Code Ordinance 3.08 – Investment of Moneys and Funds 15 C Segregation of Major Investment Responsibilities 17 D Listing of Approved Financial Institutions 18 E Investment Management Process and Risk 19 F Glossary 20 1 of 24 CITY OF LA QUINTA Investment Policy FiscalYear2018/2019 Executive Summary The general purpose of this Investment Policy is to provide the rules and standards that must be followed in administering the City of La Quinta's (the “City”) deposits and investments. The City's Investment Policy conforms to all state and local statutes and applies to all deposits and investments of the City, with the exception of bond proceeds and those noted in section XVI herein. It is the City's policy to deposit and invest public funds in a manner that shall provide safety of principal, liquidity to meet all of the City’s obligations and requirements that may be reasonably anticipated, and a risk-based market rate of return. Authority to manage the City's investment portfolio is derived from the City Municipal Code. Management responsibility for the investment program is delegated to the City Treasurer, who shall establish and implement written procedures for the operation of the City's investment program consistent with the Investment Policy. The City Manager, City Treasurer and city employees involved in the City's banking and investment process shall conduct the City's business in an ethical manner and refrain from any activity or relationship that may be, or have the appearance of, a conflict of interest. The Investment Policy shall be adopted by resolution of the La Quinta City Council on an annual basis, before the end of each fiscal year (June). 2 of 24 City of La Quinta Statement of Investment Policy July 1, 2018 through June 30, 2019 Adopted by the City Council on May 15, 2018 I GENERAL PURPOSE The general purpose of this document is to provide the rules and standards that must be followed in administering the City of La Quinta's deposits and investments. II INVESTMENT POLICY It is the policy of the City of La Quinta to deposit and invest public funds in a manner that shall conform to all State and local statutes governing the investment of public funds and set forth the permissible deposits and investments of the City's funds and the limitations thereon. III SCOPE Except as further detailed in Sections XVI and XVII, this Investment Policy applies to all deposits and investments of the City of La Quinta, the Successor Agency to the City of La Quinta Redevelopment Agency, and the City of La Quinta Financing and Housing Authorities (hereafter referred to in this document as the "City" or the “Agency”). These funds are reported in the City's Comprehensive Annual Financial Report (CAFR) and include all funds within the following fund types: General Special Revenue Capital Projects Debt Service Enterprise Internal Service Trust and Agency Any new fund types and fund(s) that may be created. IV OBJECTIVES The objectives of the City's investment activity, in order of priority and importance, are: 1.Safety of Principal Safety of principal is the foremost objective of the City's investment program. Investments shall be undertaken in a manner that seeks to ensure the preservation of principal of the overall portfolio in accordance with the permissible deposits and investments. The City shall endeavor to preserve its investment principal by making only permissible deposits and investments, undertaken in a controlled manner to minimize the possibility of loss or misappropriation through malfeasance or otherwise. Investments not backed by the full faith and credit of the United States Government shall be diversified by allocating assets between different types of 3 of 24 permissible investments, maturities, and issuers as a means to mitigate credit risk and interest rate risk. a.Credit Risk is the risk of loss from the failure of the security issuer or backer. Credit risk may be mitigated by: Limiting investments to investment grade securities as permitted in Section X; and Diversifying the issuers of the securities in the investment portfolio so that potential losses due to issuer failure or individual securities downgrades may be minimized. b.Interest Rate Risk is the risk that market values of securities in the portfolio will decline due to changes in general interest rates. Interest rate risk may be mitigated by: Structuring the investment portfolio so that securities mature to meet cash requirements for ongoing operations, thereby avoiding the need to sell securities on the open market prior to maturity; and Investing operating funds primarily in shorter-term securities. c.Liquidity Risk is the risk that a security cannot be liquidated because of its unique features or structure or because it is thinly traded. Liquidity risk is not a material issue for the City's portfolio because of the permissible deposits and investments (see Section X). A discussion of the City's investment process and risk is presented in Appendix E. 2.Provide Liquidity The investment portfolio shall remain sufficiently liquid to meet all of the City's cash needs that may be reasonably anticipated. This is accomplished by structuring the portfolio so that sufficient liquid funds are available to meet anticipated demands. Furthermore, since all possible cash needs cannot be anticipated the portfolio should be diversified and consist of securities with active secondary or resale markets. The City's policy is to generally hold securities and other investments to maturity. Accordingly, securities may be sold prior to maturity under certain circumstances as follow: A security with declining credit quality can be sold early to minimize loss of principal. Unanticipated liquidity needs of the portfolio require that one or more securities be sold. When a sale/repurchase is fiscally advantageous based on market conditions and fits the needs of the portfolio 3.Yield a Risk-Based Market Rate of Return The City's investment portfolio shall be structured with the objective of yielding a risk- based market rate of return throughout budgetary and economic cycles. Return on investment is less important than the safety and liquidity objectives described above. The City's Investment Policy does not specify a single benchmark as a goal or target yield for a rate of return on its investment portfolio. The portfolio's rates of return will be influenced by several factors, including actions by the Federal Reserve Board, the 4 of 24 marketplace, and overall economic perceptions and conditions. As a basis for comparison only, the Treasurer's quarterly reports will display the rates of return on the three-month Bill, six-month Bill, and one and two-year U.S. Treasury Note, comparable-period rates for commercial paper, and the yield for the State Treasurer's Local Agency Investment Fund (LAIF). The Treasurer may use these or any other published rates of return that the Treasurer deems appropriate for comparison to the return on the City's investment portfolio. V MAXIMUM MATURITIES It is the City's policy to generally hold securities and other investments until maturity. This buy and-hold policy shall not prevent the sale of a security as listed in section IV.3 The general buy-and-hold strategy requires that the City's investment portfolio be structured so that sufficient liquid funds are available from maturing investments and other sources to meet all reasonably anticipated cash needs. To meet anticipated cash needs, it is essential that the Treasurer have reliable, diligently prepared cash flow projections. The City shall follow Title 5 of the California Government Code §53601 (the “State Code”) regarding maximum maturities, in that “ no investment shall be made in any security…that at the time of the investment has a term remaining to maturity in excess of five years”. VI PRUDENCE and FIDUCIARY DUTY The City shall follow the State Code §53600.3 regarding fiduciary duty and the Prudent Investment Standard as follows: Except as provided in subdivision (a) of Section 27000.3, all governing bodies of local agencies or persons authorized to make investment decisions on behalf of those local agencies investing public funds pursuant to this chapter are trustees and therefore fiduciaries subject to the prudent investor standard. When investing, reinvesting, purchasing, acquiring, exchanging, selling, or managing public funds, a trustee shall act with care, skill, prudence, and diligence under the circumstances then prevailing, including, but not limited to, the general economic conditions and the anticipated needs of the agency, that a prudent person acting in a like capacity and familiarity with those matters would use in the conduct of funds of a like character and with like aims, to safeguard the principal and maintain the liquidity needs of the agency. Within the limitations of this section and considering individual investments as part of an overall strategy, investments may be acquired as authorized by law. VII AUTHORITY Authority to manage the City's investment portfolio is derived from section 3.08 of the City's Municipal Code. Management responsibility for the investment program is delegated to the City Treasurer for a period of one year pursuant to the City Council's annual adoption of the Investment Policy. The City Treasurer shall establish written procedures for the operation of the investment program consistent with the Investment Policy. Procedures should include reference to safekeeping, wire transfer agreements, banking service contracts, and collateral/depository agreements. Such procedures shall include explicit delegation of authority to persons responsible for investment transactions. No person may engage in an investment transaction except as provided under the terms of this Investment Policy and the procedures established by 5 of 24 the City Treasurer. The City Treasurer shall be responsible for all transactions undertaken and shall establish a system of controls to regulate the activities of subordinate officials. VIII ETHICS AND CONFLICTS OF INTEREST The City Manager, City Treasurer and city employees involved in the City's banking and investment process shall conduct the City's business in an ethical manner and refrain from any activity or relationship that may be, or have the appearance of, a conflict of interest. Any questionable activity or relationship shall be reported immediately and in compliance with the procedures set forth in Section 1.40 - Conflicts of Interest and Acceptance of Gifts and other Gratuities of the City of La Quinta Personnel Manual. Reporting must be made in accordance with the personnel policies of the City and, until resolved, the officer or employee shall refrain from participating in the City's business related to the matter. The City Manager, City Treasurer and City employees may conduct personal business with banks, brokers, and other financial institutions that are authorized to conduct business with the City provided that the terms of the activity to the accountholder with the City are the same as those that are available to the public in general. IX AUTHORIZED FINANCIAL DEALERS AND INSTITUTIONS The City Treasurer maintains a listing of financial institutions which are approved for direct investment purposes. In addition a list will also be maintained of approved broker/dealers selected by credit worthiness. 1.Broker/Dealers who desire to become bidders for direct investment transactions must supply the City with the following: Current audited financial statements; Proof of Financial Industry Regulatory Authority (FINRA) Certification; Trading resolution; Resume of Financial broker; and Completion of the City of La Quinta Broker/Dealer questionnaire, which contains a certification of having read the City's Investment Policy. The City Treasurer shall evaluate the documentation submitted by the broker/dealer and independently verify existing reports on file for any firm and individual conducting investment related business. The City Treasurer will also contact the following agencies during the verification process: Financial Industry Regulatory Authority (FINRA) Public Disclosure Report File (1-800- 289-9999). State of California Department of Corporations (1-916-445-3062). A professional investment manager or management firm, if engaged by the City pursuant to Section X of this policy, may utilize their own list of approved broker/dealers on the condition that any such list is provided to the City upon request. All Broker/Dealers and financial institutions that provide investment services will be subject to City Council approval. 6 of 24 Each securities dealer shall provide monthly and quarterly reports filed pursuant to U.S. Treasury Department regulations. Each mutual fund shall provide a prospectus and statement of additional information. 2.Financial Institutions will be required to meet the following criteria in order to receive City funds for deposit or investment (see Appendix D, "Listing of Approved Financial Institutions"): Insurance - Public Funds shall be deposited only in financial institutions having accounts insured by the Federal Deposit Insurance Corporation (FDIC). Collateral- The amount of the City's deposits or investments not insured by the FDIC shall be collateralized by securities with market values of 110%, or by mortgages with market values 150%, of the amount of invested funds plus unpaid interest earnings. Disclosure - Each financial institution maintaining invested funds in excess of the FDIC insured amount shall furnish the City a copy of the most recent Call Report. The City shall not invest in excess of the FDIC insured amount in banking institutions which do not disclose to the city a current listing of securities pledged for collateralization in public monies. X PERMISSIBLE DEPOSITS AND INVESTMENTS It is the City’s policy to follow the applicable State Code in regard to allowable securities. Permissible deposits and investments, as allowed by Chapter 4, Part 1, Division 2, Title 5 (hereinafter cited by §), include, but are not limited to, the following: Checking. Savings. and Sweep Accounts - The City will only maintain checking and savings, accounts with state or national banks, savings associations, federal associations, and/or credit unions in accordance with §53635.2. In addition, the Treasurer may invest in an interest bearing active deposit account as approved in §53632. The deposit account must be collateralized with securities that are in accordance with §53632.5(c). In addition, the market value of the collateralized securities must be maintained in accordance with §53652 (a), and be held by a custodian in accordance with the requirements of §53656. The proposition of the City's share of the deposit account shall be determined in accordance with §53658. Certificates of Deposit (Negotiable and Non-negotiable) - The City may invest in Non- Negotiable and Negotiable Certificates of Deposits (CD) up to 30% of the overall portfolio §53601(i). In no instance shall a CD or combined CD’s with a single issuer exceed the FDIC or NCUSIF insurance limit of $250,000. U.S. Treasury Bills. Notes. and Bonds and Government National Mortgage Associations (GNMA) securities - The City may invest in U.S. Treasury bills, notes, and bonds and GNMA securities directly issued and backed by the full faith and credit of the U.S. Government. The City's Investment Policy provides for investments in U.S. Treasury issues and GNMA's of 100% of the portfolio §53601(b). 7 of 24 U.S. Government Agency Securities and Federal Government Securities - The City may invest in securities issued by U.S. Government instrumentalities and agencies (commonly referred to as government sponsored enterprises or GSE's) §53601(f). These securities are not backed by the full faith and credit of the U.S. Government. Publicly owned GSE's include Federal National Mortgage Association (FNMA), Federal Home Loan Mortgage Corporation (FHLMC) and Student Loan Marketing Association (SLMA). Non-publicly owned GSE's include the Federal Home Loan Bank (FHLB), Federal Farm Credit Bank (FFCB), Federal Land Bank (FLB) and Federal Intermediate Credit Bank (FICB). The City's Investment Policy allows investment only in securities of FNMA, FHLMC, FHLB and FFCB. For Fiscal Year 2018-19, the maximum face amount per issuer is $20 million and the maximum face amount per purchase is $10 million. Prime Commercial Paper - As authorized in §53601(h), a portion of the City's portfolio may be invested in commercial paper of the highest rating as provided for by a nationally recognized statistical rating organization (NRSRO; i.e. Moody’s, Fitch, or S&P) There are a number of other qualifications regarding investments in commercial paper based on the financial strength of the corporation and the size of the investment. Per state code, "Eligible commercial paper shall have a maximum maturity of 270 days or less. Local agencies, other than counties or a city and county, may invest no more than 25 percent of their moneys in eligible commercial paper. Local agencies, other than counties or city and county, may purchase no more than 10 percent of the outstanding commercial paper of any single issuer”. Local Agency Investment Fund (LAIF) - As authorized in §16429.1 and by LAIF procedures, local government agencies are each authorized to invest a maximum of $65 million per account in this investment program administered by the California State Treasurer. The City Treasurer may not invest more than $65 million per account in LAIF. Money Market Mutual Funds - As authorized in §53601(l), local agencies are authorized to invest in shares of beneficial interest issued by diversified management companies (mutual funds) in an amount not to exceed 20% of the agency's portfolio. There are a number of other qualifications and restrictions regarding allowable investments in corporate notes and shares of beneficial interest issued by mutual funds which include (1) attaining the highest ranking or the highest letter and numerical rating provided by not less than two of the three largest nationally recognized rating services, or (2) having an investment advisor registered with the Securities and Exchange Commission with not less than five years' experience investing in the securities and obligations and with assets under management in excess of five hundred million dollars ($500,000,000). Corporate Notes - As authorized in §53601(k), local agencies may invest in corporate notes. The notes must be issued by corporations organized and operating in the United States or by depository institutions licensed by the United States or any other state and operating in the United States. The City's Investment Policy allows investment in 8 of 24 corporate notes authorized by the Government Code with the following limitations: Maximum 30% of the portfolio; Maturities shall not exceed five years from date of purchase; Eligible notes shall be regularly quoted and traded in the marketplace; Eligible notes shall be rated "AA" or better; and The maximum aggregate investment in each issuer shall not exceed $5million (PAR value). Professionally Managed Account(s)- The City Treasurer may place up to 50% of the portfolio with a professional portfolio management/investment management firm (firm) The firm will be approved by the City Council based upon the City Treasurer's recommendation pursuant to completion of a public request for proposal (RFP). The firm shall have: An established professional reputation for asset or investment management; Knowledge and working familiarity with State and Federal laws governing and restricting the investment of public funds; Substantial experience providing investment management services to local public agencies whose investment policies and portfolio size are similar to those of the City; Professional liability (errors and omissions) insurance and fidelity bonding in such amounts as are required by the City; and Registration with the Securities and Exchange Commission under the Investment Advisers Act of 1940 Before engagement by the City and except as may be specifically waived or revised, the firm shall commit to adhere to the provisions of the City's Investment Policy with the following exceptions: The firm may be granted the discretion to purchase and sell investment securities in accordance with this Investment Policy; The firm is not required to adhere to a buy-and-hold policy; and The firm does not need City Manager or City Treasurer approval to make permissible investments. Local Agency Bonds and California Local Agency Obligations - The City may invest in California local agency obligations pursuant to §53601(a) and §53601(e). 53601(a) pertains to investing in bonds issued by a local agency, or by the department, board, agency or authority of the local agency. 53601(e) pertains to investing in bonds and other defined indebtedness of any local agency, or department, board, agency or authority of the local agency within the State of California. The Agency obligations must be invested in the long term rating of A or better by S&P, Moody's or Fitch. In the case of an initial public offering, including refinancings, the Treasurer may purchase directly from the Bond Underwriter. In the case of secondary issues, the Treasurer will rely on the approved Broker/Dealers. XI INVESTMENT POOLS There are three (3) types of investment pools: State-run pools (e.g., LAIF); Pools that are operated by a political subdivision whereallowed by law and the political subdivision is the trustee(e.g., County Pools); and 9 of 24 Pools that are operated for profit by third parties. The City's Investment Policy permits investment in pools authorized by Government Code. XII PAYMENT AND CUSTODY The City shall engage qualified third party custodians to act in a fiduciary capacity to maintain appropriate evidence of the City's ownership of securities and other eligible investments. Such custodians shall disburse funds, received from the City for a purchase, to the broker, dealer or seller only after receiving evidence that the City has legal, record ownership of the securities. Even though ownership is evidenced in book-entry form rather than by actual certificates, this procedure is commonly accepted as the delivery versus payment (DVP) method for the transfer of securities. XIII INTEREST EARNING DISTRIBUTION POLICY Interest earnings are generated from pooled investments and specific investments. The following provisions apply to the calculation and distribution of interest earnings. 1.Pooled Investments - It is the general policy of the City to pool all available operating cash of the City of La Quinta, Successor Agency to the City of La Quinta Redevelopment Agency, La Quinta Financing Authority, and La Quinta Housing Authority, and to allocate interest earnings in the following order, as follows: a.Payment to the General Fund of an amount equal to the total annual bank service charges as incurred by the general fund for all operating funds as included in the annual operating budget. b.Payment to the General Fund of a management fee equal to 5% of the annual pooled cash fund investment earnings. c.Payment to each fund of an amount based on the average computed daily cash balance included in the common portfolio for the earning period. 2.Specific Investments - Specific investments purchased by a fund shall incur all earnings and expenses to that particular fund. XIV INTERNAL CONTROLS AND INDEPENDENT AUDITOR The City Treasurer shall establish a system of internal controls to accomplish the following objectives: Safeguard assets; The orderly and efficient conduct of its business, including adherence tomanagement policies; Prevention or detection of errors and fraud; The accuracy and completeness of accounting records; and Timely preparation of reliable financial information. 10 of 24 While no internal control system, however elaborate, can guarantee absolute assurance that the City's assets are safeguarded, it is the intent of the City's internal control to provide a reasonable assurance that management of the investment function meets the City's objectives. The internal controls shall address the following: Control of collusion. Collusion is a situation where two or more employees are working in conjunction to defraud their employer. Separation of transaction authority from accounting and record keeping. By separating the person who authorizes or performs the transaction from the people who record or otherwise account for the transaction, a separation of duties is achieved. Custodial safekeeping. Securities purchased from any bank or dealer including appropriate collateral (as defined by State Law) shall be placed with an independent third party for custodial safekeeping. Avoidance of physical delivery securities. Book entry securities are much easier to transfer and account for since actual delivery of a document never takes place. Delivered securities must be properly safeguarded against loss or destruction. The potential for fraud and loss increases with physically delivered securities. Clear delegation of authority to subordinate staff members. Subordinate staff members must have a clear understanding of their authority and responsibilities to avoid improper actions. Clear delegation of authority also preserves the internal control structure that is contingent on the various staff positions and their respective responsibilities as outlined in the Segregation of Major Investment Responsibilities appendices. Written confirmation of telephone transactions for investments and wire transfers. Due to the potential for error and improprieties arising from telephone transactions, all telephone transactions shall be supported by written communications or electronic confirmations and approved by the appropriate person. Written communications may be via fax or email if on letterhead and the safekeeping institution has a list of authorized signatures. Fax correspondence must be supported by evidence of verbal or written follow-up. Development of a wire transfer agreement with the City's bank and third party custodian. This agreement should outline the various controls, security provisions, and delineate responsibilities of each party making and receiving wire transfers. The system of internal controls developed by the City shall be reviewed annually by the independent auditor in connection with the annual audit of the City's Financial Statements. The independent auditor's letter on internal control over financial reporting and compliance as it pertains to cash and investments, if any, shall be directed to the City Manager who will direct the City Treasurer to provide a written response to the independent auditor's letter. The auditor's letter, as it pertains, to cash and investment activities and the City Treasurer's response shall be provided to the City's Financial Advisory Commission for their consideration. Following the completion of each annual audit, the independent auditor shall meet with the Financial Advisory Commission and discuss the auditing procedures 11 of 24 performed and the review of internal controls for cash and investment activities. See Appendix C, "Segregation of Major Investment Responsibilities." XV REPORTING STANDARDS The City Treasurer shall submit a monthly Treasurers Report to the City Council and the Financial Advisory Commission that includes all cash and investments under the authority of the Treasurer. The Treasurer's Report shall summarize cash and investment activity and changes in balances and include the following: A certification by the City Treasurer; A listing of purchases and sales/maturities of investments; Cash and Investments categorized by authorized investments, except for LAIF which will be provided quarterly and show yield and maturity; Comparison of month end actual holdings to Investment Policy limitations; Distribution of cash and investment balances by fund; A two-year list of historical interest rates. XVI FINANCIAL ASSETS AND INVESTMENT ACTIVITY NOT SUBJECT TO THIS POLICY The City's Investment Policy does not apply to the following: Cash and Investments raised from Conduit Debt Financing; Funds held in trust in the City's name in pension or other post-retirement benefitprograms; Cash and Investments held in lieu of retention by banks or other financial institutions for construction projects; and Short or long term loans made to other entities by the City or Agency, Short term (Due to/from) or long term (Advances from/to) obligations made either between the City and its funds or between the City and Agency. XVII INVESTMENT OF BOND PROCEEDS The City's Investment Policy shall not govern bond proceeds and bond reserve fund investments. California Code Section 5922 (d) governs the investment of bond proceeds and reserve funds in accordance with bond indenture provisions. Arbitrage Requirement - The US Tax Reform Act of 1986 requires the City to perform arbitrage calculations as required and return excess earnings to the US Treasury from investments of proceeds of bond issues sold after the effective date of this law. These arbitrage calculations may be contracted with an outside source to provide the necessary technical assistance to comply with this regulation. Investable funds subject to the 1986 Tax Reform Act will be kept segregated from other funds and records will be kept in a fashion to facilitate the calculations. The City's investment position relative to the new arbitrage restrictions is to continue pursuing the maximum yield on applicable investments while ensuring the safety of capital and liquidity. It is the City's position to continue maximization of yield and to rebate excess earnings, if necessary. XVIII FINANCIAL ADVISORY COMMISSION - CITY OF LA QUINTA The Financial Advisory Commission (FAC) is composed of seven members from the public that 12 of 24 are appointed by the City Council. Background information will be requested and potential candidates must agree to a background check and verification. On an annual basis, in conjunction with the Political Reform Act disclosure statutes, or at any time if a change in circumstances warrants, each commissioner will provide the City Council with a disclosure statement which identifies any matters that have a bearing on the appropriateness of that member's service on the FAC. All commissioners shall report annually every June to the City Clerk on Form 700, Statement of Economic Interests, any activities, interests, or relationships that may be, or have the appearance of, a conflict of interest. The FAC must meet at least quarterly to: Review at least annually the City's Investment Policy and recommend appropriate changes; Review at least quarterly the treasury report and note compliance with the Investment Policy as well as adequacy of cash and investments for anticipated obligations; Receive and consider other reports provided by the City Treasurer; Meet with the independent auditor after completion of the annual audit of the City's financial statements, and receive and consider the auditor's comments on auditing procedures, internal controls and findings for cash and investment activities; Review at least annually the revenue derived from the one percent (1%) transactions and use tax instituted by voters in November 2016 to ensure these funds are used to provide services, programs, and capital projects in the city of La Quinta Serve as a resource for the City Treasurer on matters such as proposed investments, internal controls, use of or change of financial institutions, custodians, brokers and dealers. The FAC will report to the City Council after each meeting either in person or through correspondence at a regular City Council meeting. See Appendix A: "Financial Advisory Commission Provisions." XIX INVESTMENT POLICY ADOPTION The City's Investment Policy will be reviewed annually by the City's Financial Advisory Commission and the City Treasurer. The Financial Advisory Commission will forward the Investment Policy with any revisions to the City Manager and City Attorney for their review and comment. A joint meeting will be held with the Financial Advisory Commission, City Manager, City Attorney, and City Treasurer to review the Investment Policy and any comments prior to submission to the City Council for their consideration. The Investment Policy shall be adopted by resolution of the City Council annually before the end of June of each year. 13 of 24 Appendix A Chapter 2.70 FINANCIAL ADVISORY COMMISSION Sections: 2.70.010 2.70.020 2.70.030 2.70.040 General rules regarding the financial advisory commission. Number of members. Qualifications of members. Powers and duties. 2.70.010 General rules regarding the financial advisory commission. Except as set out below, see Chapter 2.06 for general provisions. 2.70.020 Number of members. The financial advisory commission ("FAC") shall initially consist of seven members appointed by, and serving at the will of the city council. The city council may increase or decrease the number of members from time to time but in no event shall the membership exceed nine members or be less than five members. 2.70.030 Qualifications of members. A.In addition to the qualification requirements set forth in Section 2.06.040 of this code, a minimum of three of the members shall be finance professionals and shall have a verifiable background in finance and/or securities, preferably with knowledge and/or experience in markets, financial controls and accounting for securities. B.For those applying for the professional position, background information will be requested and potential candidates must agree to a background check and verification by the city manager or designee. 2.70.040 Powers and duties. A.The principal functions of the FAC are: 1.Review at least annually the city's investment policy and recommend appropriate changes; 2.Review at least quarterly the treasury report and note compliance with the investment policy and adequacy of cash and investments for anticipated obligations; 3.Receive and consider other reports provided by the city treasurer; 4.Meet with the independent auditor after completion of the annual audit of the city's financial statements, and receive and consider the auditor's comments on auditing procedures, internal controls, and findings for cash and investment activities; 5.!Review at least annually the revenue derived from the one percent (1%) transactions and use tax instituted by voters in November 2016 to ensure these funds are used to provide services, programs and capital projects in the city of La Quinta. 6.!Serve as a resource for the city treasurer on matters such as proposed investments, internal controls, use of or change of financial institutions, custodians, brokers and dealers. B.!The FAC will report to the city council after each meeting either in person or through correspondence at a regular city council meeting. 2.70.050 References to the Investment Advisory Board. If any other chapter(s) or section(s) in this code refers to the Investment Advisory Board, that chapter(s) or section(s) shall be deemed to refer to the Financial Advisory Commission established by the ordinance amending chapter 2.70 of this code 14 of 24 Appendix B City of La Quinta Municipal Code Chapter 3.08 INVESTMENT OF MONEYS AND FUNDS Sections: 3.08.010 Investment of city moneys and deposit of securities. 3.08.020 Authorized investments. 3.08.030 Sales of securities. 3.08.040 City bonds. 3.08.050 Reports. 3.08.060 Deposits of securities. 3.08.070 Trust fund administration. 3.08.010 Investment of city moneys and deposit of securities. Pursuant to, and in accordance with, and to the extent allowed by Sections 53607 and 53608 of the California Government Code, the authority to invest and reinvest moneys of the city, to sell or exchange securities, and to deposit them and provide for their safekeeping, is delegated to the city treasurer, which, for purposes of this chapter, is defined in Section 2.12.010 of this code. (Ord. 529 § 1, 2015; Ord. 2 § 1, 1982) 3.08.020 Authorized investments. Pursuant to the delegation of authority in Section 3.08.010, the city treasurer is authorized to purchase, at their original sale or after they have been issued, securities which are permissible investments under the city council adopted city investment policy and any provision of state law relating to the investing of general city funds, including, but not limited to, Sections 53601 and 53635 of the California Government Code, as said sections now read or may hereafter be amended, from moneys in the city treasurer's custody which are not required for the immediate necessities of the city and as he or she may deem wise and expedient, and to sell or exchange for other eligible securities and reinvest the proceeds of the securities so purchased. (Ord. 529 § 1, 2015; Ord. 2 § 1, 1982) 3.08.030 Sales of Securities. From time to time the city treasurer shall sell the securities in which city moneys have been invested pursuant to this chapter, so that the proceeds may, as appropriate, be applied to the purchase for which the original purchase money may have been designated or placed in the city treasury. (Ord.2 § 1 (part), 3.08.040 City bonds. Bonds issued by the city and purchased pursuant to this chapter may be cancelled either in satisfaction of sinking fund obligations or otherwise if proper and appropriate; provided, however, that the bonds may be held uncancelled and while so held may be resold. (Ord. 2 § 1 (part), 1982) 15 of 24 3.08.050 Reports. The city treasurer shall make a quarterly report to the city council of all investments made pursuant to the authority delegated in this chapter and as permitted by Section 53646(b)(1) of the Government Code. (Ord. 529 § 1, 2015; Ord. 2 § 1, 1982) 3.08.060 Deposits of securities. Pursuant to the delegation of authority in Section 3.08.010, the city treasurer is authorized to deposit for safekeeping, the securities in which city moneys have been invested pursuant to this chapter, in any institution or depository authorized by the city council adopted investment policy and terms of any state law, including, but not limited to, Section 53608 of the Government Code, as it now reads or may hereafter be amended. In accordance with said section, the city treasurer shall take from the institution or depository a receipt for the securities so deposited and shall not be responsible for the securities delivered to and receipted for by the institution or depository until they are withdrawn therefrom by the city treasurer. (Ord. 529 § 1, 2015; Ord. 2 § 1, 1982) 3.08.070 Trust fund administration. Any departmental trust fund established by the city council pursuant to Section 36523 of the Government Code shall be administered by the city treasurer in accordance with Section 36523 and 36524 of the Government code and any other applicable provisions of law. (Ord. 2 § 1 (, 1982) 16 of 24 Appendix C SEGREGATION OF MAJOR INVESTMENT RESPONSIBILITIES Function Develop and Recommend Modifications to City's Formal Investment Policy Review City's Investment Policy and Recommend City Council Action Adopt Formal Investment Policy Implement Formal Investment Policy Review Financial Institutions & Select Investments Acknowledge Investment Selections Execute Investment Transactions Confirm Wires (if applicable) Responsible Parties Financial Advisory Commission and City Treasurer City Manager and City Attorney City Council City Treasurer City Treasurer or Financial Services Analyst City Manager or his/her designee City Treasurer or City Manager Senior Accountant or Financial Services Analyst Record Investment Transactions in City's Accounting Records Investment Verification (match broker confirmation to City investment records) Reconcile Investment Records to Accounting Records and Bank Statements Reconcile Investment Records to Treasurers Report of Investments Security of Investments at City Security of Investments outside City Review Internal Control Procedures Senior Accountant or Accountant City Treasurer and Financial Services Analyst Financial Services Analyst Senior Accountant or Financial Services Analyst Senior Accountant or Management Assistant Third Party Custodian External Auditor 17 of 24 Appendix D Listing of Approved Financial Institutions Banking Services Wells Fargo Bank, Government Services, Los Angeles, CA (Banking Services) Rabobank N.A., Government Banking Group, Roseville, CA (Collateralized Bank Deposits) Custodian Services The Bank of New York Mellon/Pershing LLC Deferred Compensation International City/County Management Association (ICCMA) Retirement Corporation Broker/Dealer Services Bank of America Securities/Merrill Lynch Morgan Stanley CitiGroup First Empire Securities Government Pool State of California Local Agency Investment Fund (LAIF) Bond Trustee US Bank (1) Other Post-Employment Benefits (OPEB) Trust California Employers' Retirement Benefits Trust (CERBT)/CalPERS (1) US Bank is the fiscal agent for all of the following bonds: 1996 Lease Revenue Bonds; 1998 RDA Project Area 1&2; 2001 RDA Project Area 1; 2002 RDA Project Area 1; 2003 RDA Project Area 1; 2004 Local Agency Revenue; 2013 Successor Agency; and 2016 Successor Agency to the La Quinta RDA Assessment Districts. 18 of 24 Appendix E Investment Management Process and Risk Except as provided for in Section 27000.3, Government Code Section 53600.3 declares as a trustee each person, treasurer, or governing body authorized to make investment decisions on behalf of local agencies. Trustees are subject to the prudent investor standard. These persons shall act with care, skill, prudence, and diligence under the circumstances then prevailing when investing, reinvesting, purchasing, acquiring, exchanging, selling, and managing funds. Section 53600.5 further stipulates that the primary objective of any person investing public funds is to safeguard principal; secondly, to meet liquidity needs of the depositor; and lastly, to achieve a return or yield on invested funds (Government Code Section 27000.5 specifies the same objectives for county treasurers and board of supervisors). Risk is inherent throughout the investment process. There is investment risk associated with any investment activity and opportunity risk related to inactivity. Market risk is derived from exposure to overall changes in the general level of interest rates while credit risk is the risk of loss due to the failure of the insurer of a security. The market value of a security varies inversely with the level of interest rates. If an investor is required to sell an investment with a five percent yield in a comparable seven percent rate environment, that security will be sold at a loss. The magnitude of that loss will depend on the amount of time until maturity. Purchasing certain allowable securities with a maturity of greater than five years requires approval of the governing board (see Government Code Section 53601). Part of that approval process involves assessing and disclosing the risk and possible volatility of longer-term investments Another element of risk is liquidity risk. Instruments with call features or special structures, or those issued by little known companies, are examples of "story bonds" and are often thinly traded. Their uniqueness often makes finding prospective buyers in a secondary market more difficult and, consequently, the securities' marketability and price are discounted. However, under certain market conditions, gains are also possible with these types of securities. Default risk represents the possibility that the borrower may be unable to repay the obligation as scheduled. Generally, securities issued by the federal government and its agencies are considered the most secure, while securities issued by private corporations or negotiable certificates of deposit issued by commercial banks have a greater degree of risk. Securities with additional credit enhancements, such as bankers acceptances, collateralized repurchase agreements and collateralized bank deposits are somewhere between the two on the risk spectrum. The vast majority of portfolios are managed within a buy and hold policy. Investments are purchased with the intent and capacity to hold that security until maturity. At times, market forces or operations may dictate swapping one security for another or selling a security before maturity. Continuous analysis and fine tuning of the investment portfolio are considered prudent investment management. The Government Code contains specific provisions regarding the types of investments and practices permitted after considering the broad requirement of preserving principal and maintaining liquidity before seeking yield. These provisions are intended to promote the use of reliable, diverse, and safe investment instruments to better ensure a prudently managed portfolio worthy of public trust. Chapter II. Fund Management from the Local Agency Investment Guidelines Issued by California Debt and Investment Advisory Commission 19 of 24 Appendix F GLOSSARY (Adopted from the Municipal Treasurers Association) The purpose of this glossary is to provide the reader of the City of La Quinta investment policies with a better understanding of financial terms used in municipal investing. AGENCIES: Federal agency securities and/or Government-sponsored enterprises. ASKED: The price at which securities are offered. BANKERS' ACCEPTANCE (BA): A draft or bill or exchange accepted by a bank or trust company. The accepting institution guarantees payment of the bill, as well as the issuer. BID: The price offered by a buyer of securities. (When you are selling securities, you ask for a bid.) See Offer. BROKER: A broker brings buyers and sellers together for a commission. CERTIFICATE OF DEPOSIT (CD): A time deposit with a specific maturity evidenced by a certificate. Large- denomination CD's are typically negotiable. COLLATERAL: Securities, evidence of deposit or other property which a borrower pledges to secure repayment of a loan. Also refers to securities pledged by a bank to secure deposits of public monies. COMMERCIAL PAPER: Short-term unsecured promissory notes issued by a corporation to raise working capital. These negotiable instruments are purchased at a discount to par value or at par value with interest bearing. Commercial paper is issued by corporations such as General Motors Acceptance Corporation, IBM, Bank America, etc. COMPREHENSIVE ANNUAL FINANCIAL REPORT (CAFR): The official annual report for the City of La Quinta. It includes five combined statements for each individual fund and account group prepared in conformity with GAAP. It also includes supporting schedules necessary to demonstrate compliance with finance-related legal and contractual provisions, extensive introductory material, and a detailed Statistical Section. CONDUIT FINANCING: A form of Financing in which a government or a government agency lends its name to a bond issue, although it is acting only as a conduit between a specific project and bond holders. The bond holders can look only to the revenues from the project being financed for repayment and not to the government or agency whose name appears on the bond. COUPON: (a) The annual rate of interest that a bond's issuer promises to pay the bondholder on the bond's face value. (b) A certificate attached to a bond evidencing interest due on a payment date. DEALER: A dealer, as opposed to a broker, acts as a principal in all transactions, buying and selling for his own account. DEBENTURE: A bond secured only by the general credit of the issuer. DELIVERY VERSUS PAYMENT: There are two methods of delivery of securities: delivery versus payment and delivery versus receipt. Delivery versus payment is delivery of securities with an exchange of money for the securities. Delivery versus receipt is delivery of securities with an exchange of a signed receipt for the securities. DERIVATIVES: (1) Financial instruments whose return profile is linked to, or derived from, the movement of one or more underlying index or security, and may include a leveraging factor, or (2) financial contracts based upon notional amounts whose value is derived from an underlying index or security (interest rates, foreign exchange rates, equities or commodities). DISCOUNT: The difference between the cost price of a security and its maturity when quoted at lower than face value. A security selling below original offering price shortly after sale also is considered to be at a discount. DISCOUNT SECURITIES: Non-interest bearing money market instruments that are issued at discount and redeemed at maturity for full face value 20 of 24 DIVERSIFICATION: Dividing investment funds among a variety of securities offering independent returns. FEDERAL CREDIT AGENCIES: Agencies of the Federal government set up to supply credit to various classes of institutions and individuals, e.g., S&L's, small business firms, students, farmers, farm cooperatives, and exporters. 1.FNMAs (Federal National Mortgage Association) -Like GNMA was chartered under the Federal National Mortgage Association Act in 1938. FNMA is a federal corporation working under the auspices of the Department of Housing and Urban Development (HUD). It is the largest single provider of residential mortgage funds in the United States. Fannie Mae, as the corporation is called, is a private stockholder owned corporation. The corporation's purchases include a variety of adjustable mortgages and second loans, in addition to fixed-rate mortgages. FNMA's securities are also highly liquid and are widely accepted. FNMA assumes and guarantees that all security holders will receive timely payment of principal and interest. 2.FHLBs (Federal Home Loan Bank Notes and Bonds) - Issued by the Federal Home Loan Bank System to help finance the housing industry. The notes and bonds provide liquidity and home mortgage credit to savings and loan associations, mutual savings banks, cooperative banks, insurance companies, and mortgage-lending institutions. They are issued irregularly for various maturities. The minimum denomination is $5,000. The notes are issued with maturities of less than one year and interest is paid at maturity. 3.FLBs (Federal Land Bank Bonds) - Long-term mortgage credit provided to farmers by Federal Land Banks. These bonds are issued at irregular times for various maturities ranging from a few months to ten years. The minimum denomination is $1,000. They carry semi annual coupons. Interest is calculated on a 360-day, 30 day month basis. 4.FFCBs (Federal Farm Credit Bank) - Debt instruments used to finance the short and intermediate term needs of farmers and the national agricultural industry. They are issued monthly with three- and six-month maturities. The FFCB issues larger issues (one to ten year) on a periodic basis. These issues are highly liquid. 5.FICBs (Federal Intermediate Credit Bank Debentures) - Loans to lending institutions used to finance the short-term and intermediate needs of farmers, such as seasonal production. They are usually issued monthly in minimum denominations of $3,000 with a nine-month maturity. Interest is payable at maturity and is calculated on a 360-day, 30-day month basis. 6.FHLMCs (Federal Home Loan Mortgage Corporation) - a government sponsored entity established in 1970 to provide a secondary market for conventional home mortgages. Mortgages are purchased solely from the Federal Home Loan Bank System member lending institutions whose deposits are insured by agencies of the United States Government. They are issued for various maturities and in minimum denominations of $10,000. Principal and interest is paid monthly. Other federal agency issues are Small Business Administration notes (SBA's), Government National Mortgage Association notes (GNMA's), Tennessee Valley Authority notes (TVA's), and Student Loan Association notes (SALLIE-MAE's). FEDERAL DEPOSIT INSURANCE CORPORATION(FDIC): A federal agency that insures bank deposits, currently up to $250,000 per deposit through December 31, 2013. FEDERAL FUNDS RATE: The rate of interest at which Fed funds are traded. This rate is currently pegged by the Federal Reserve through open market operations. FEDERAL HOME LOAN BANKS (FHLB): Government sponsored wholesale banks (currently 12 regional banks) which lend funds and provide 21 of 24 correspondent banking services to member commercial banks, thrift institutions, credit unions and insurance companies. The mission of the FHLBs is to liquefy the housing related assets of its members who must purchase stock in their district Bank. FEDERAL OPEN MARKET COMMITTEE (FOMC): Consists of seven members of the Federal Reserve Board and five of the twelve Federal Reserve Bank Presidents. The President of the New York Federal Reserve Bank is a permanent member, while the other Presidents serve on a rotating basis. The Committee periodically meets to set Federal Reserve guidelines regarding purchases and sales of Government Securities in the open market as a means of influencing the volume of bank credit and money. FEDERAL RESERVE SYSTEM: The central bank of the United States created by Congress and consisting of a seven member Board of Governors in Washington, D.C., 12 regional banks and about 5,700 commercial banks that are members of the system. GOVERNMENT NATIONAL MORTGAGE ASSOCIATION (GNMA or Ginnie Mae): Securities influencing the volume of bank credit guaranteed by GNMA and issued by mortgage bankers, commercial banks, savings and loan associations, and other institutions. Security holder is protected by full faith and credit of the U.S. Government. Ginnie Mae securities are backed by the FHA, VA or FMHM mortgages. The term "pass-throughs" is often used to describe Ginnie Maes. LAIF (Local Agency Investment Fund) - A special fund in the State Treasury which local agencies may use to deposit funds for investment. There is no minimum investment period and the minimum transaction is $5,000, in multiples of $1,000 above that, with a maximum balance of $50,000,000 for any agency. The City is restricted to a maximum of ten transactions per month. It offers high liquidity because deposits can be converted to cash in 24 hours and no interest is lost. All interest is distributed to those agencies participating on a proportionate share basis determined by the amounts deposited and the length of time they are deposited. Interest is paid quarterly. The State retains an amount for reasonable costs of making the investments, not to exceed one-half of one percent of the earnings. LIQUIDITY: A liquid asset is one that can be converted easily and rapidly into cash without a substantial loss of value. In the money market, a security is said to be liquid if the spread between bid and asked prices is narrow and reasonable size can be done at those quotes. LOCAL GOVERNMENT INVESTMENT POOL (LGIP): The aggregate of all funds from political subdivisions that are placed in the custody of the State Treasurer for investment and reinvestment MARKET VALUE: The price at which a security is trading and could presumably be purchased or sold. MASTER REPURCHASE AGREEMENT: A written contract covering all future transactions between the parties to repurchase--reverse repurchase agreements that establish each party's rights in the transactions. A master agreement will often specify, among other things, the right of the buyer lender to liquidate the underlying securities in the event of default by the seller-borrower. MATURITY: The date upon which the principal or stated value of an investment becomes due and payable MONEY MARKET: The market in which short-term debt instruments (bills, commercial paper, bankers' acceptances, etc.) are issued and traded. OFFER: The price asked by a seller of securities. (When you are buying securities, you ask for an offer.) See Asked and Bid. OPEN MARKET OPERATIONS: Purchases and sales of government and certain other securities in the open market by the New York Federal Reserve Bank as directed by the FOMC in order to influence the volume of money and credit in the economy. Purchases inject reserves into the bank system and stimulate growth of money and credit; sales have the opposite effect. Open market operations are the Federal Reserve's most important and most flexible monetary policy tool. PORTFOLIO: Collection of all cash and securities under the direction of the City Treasurer, including Bond Proceeds. 22 of 24 PRIMARY DEALER: A group of government securities dealers who submit daily reports of market activity and positions and monthly financial statements to the Federal Reserve Bank of New York and are subject to its informal oversight. Primary dealers include Securities and Exchange Commission (SEC) registered securities broker- dealers, banks and a few unregulated firms. QUALIFIED PUBLIC DEPOSITORIES: A financial institution which does not claim exemption from the payment of any sales or compensating use or ad valorem taxes under the laws of this state, which has segregated for the benefit of the commission eligible collateral having a value of not less than its maximum liability and which has been approved by the Public Deposit Protection Commission to hold public deposits. RATE OF RETURN: The yield obtainable on a security based on its purchase price or its current market price. This may be the amortized yield to maturity on a bond the current income return. REPURCHASE AGREEMENT (RP OR REPO): A holder of securities sells these securities to an investor with an agreement to repurchase them at a fixed price on a fixed date. The security "buyer" in effect lends the "seller" money for the period of the agreement, and the terms of the agreement are structured to compensate him for this. Dealers use RP extensively to finance their positions. Exception: When the Fed is said to be doing RP, it is lending money that is increasing bank reserves. REVERSE REPURCHASE AGREEMENTS (RRP or RevRepo) - A holder of securities sells these securities to an investor with an agreement to repurchase them at a fixed price on a fixed date. The security"buyer" in effect lends the"seller" money for the period of the agreement, and the terms of the agreement are structured to compensate him for this. Dealers use RRP extensively to finance their positions. Exception: When the Fed is said to be doing RRP, it is lending money that is increasing bank reserves. SAFEKEEPING: A service to customers rendered by banks for a fee whereby securities and valuables of all types and descriptions are held in the bank's vaults for protection. SECONDARY MARKET: A market made for the purchase and sale of outstanding issues following the initial distribution. SECURITIES & EXCHANGE COMMISSION: Agency created by Congress to protect investors in securities transactions by administering securities legislation. SEC RULE 15C3-1: See Uniform Net Capital Rule. STRUCTURED NOTES: Notes issued by Government Sponsored Enterprises (FHLB, FNMA, SLMA, etc.) and Corporations which have imbedded options (e.g., call features, step-up coupons, floating rate coupons, and derivative-based returns) into their debt structure. Their market performance is impacted by the fluctuation of interest rates, the volatility of the imbedded options and shifts in the shape of the yield curve. SURPLUS FUNDS: Section 53601 of the California Government Code defines surplus funds as any money not required for immediate necessities of the local agency. The City has defined immediate necessities to be payment due within one week. TREASURY BILLS: A non-interest bearing discount security issued by the U.S. Treasury to finance the national debt. Most bills are issued to mature in three months, six months or one year. TREASURY BONDS: Long-term coupon-bearing U.S. Treasury securities issued as direct obligations of the U.S. Government and having initial maturities of more than 10 years. TREASURY NOTES: Medium-term coupon-bearing U.S. Treasury securities issued as direct obligations of the U.S. Government and having initial maturities from two to 10 years. UNIFORM NET CAPITAL RULE: Securities and Exchange Commission requirement that member firms as well as nonmember broker-dealers in securities maintain a maximum ratio of indebtedness to liquid capital of 15 to 1; also called net capital rule and net capital ratio. Indebtedness covers all money owed to a firm, including margin loans and commitments to purchase securities, one reason new public issues are spread among members of underwriting syndicates. Liquid capital includes cash and assets easily converted into cash. UNIFORM PRUDENT INVESTOR ACT: The State of 23 of 24 California has adopted this Act. The Act contains the following sections: duty of care, diversification, review of assets, costs, compliance determinations, delegation of investments, terms of prudent investor rule, and application. YIELD: The rate of annual income return on an investment, expressed as a percentage. (a) INCOME YIELD is obtained by dividing the current dollar income by the current market price for the security. (b) NET YIELD or YIELD TO MATURITY is the current income yield minus any premium above par or plus any discount from par in purchase price, with the adjustment spread over the period from the date of purchase to the date of maturity of the bond 24 of 24 Fixed Income Innovative Solutions. Personalized Service. Equal Housing Lender. Member FDIC. © 2012 Bank of the West. CAPITAL MARKETS Craig Conley – Vice President, Fixed Income Investment Officer Mr. Conley comes to Bank of the West with over 20 years of experience in the investment services industry specializing in fixed income investments for high net worth individuals and corporate clients. He has a degree in Finance from Shippensburg University in Pennsylvania and held the position of Assistant Vice President at J.B. Hanauer and Company, a wholly-owned subsidiary of the Royal Bank of Canada. Mr. Conley is highly specialized in providing deposit and fixed income investment solutions to our clients and prospects. Capital Markets ©2010 Bank of the West. Member FDIC. Fixed Income Innovative Solutions. Personalized Service. Paul Montaquila – Vice President, Fixed Income Investment Officer Mr. Montaquila joins Bank of the West with over twenty years of Wall Street experience. After obtaining a degree in finance from Northeastern University, he entered the training program at Smith Barney and later moved to Lehman Brothers specializing in middle market institutional bond sales. His extensive fixed income background is derived from both a sales and trading perspective. Paul recently completed a 10-year stay at Charles Schwab where he managed the corporate bond trading desk. He currently holds Series 7, 9, 10, 55, and 63 licenses. BNP Paribas Securities Corp. (SEC I.D. No. 8-32682) STATEMENT OF FINANCIAL CONDITION AS OF DECEMBER 31, 2018 AND REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM * * * * * * * Filed pursuant to Rule 17a-5(e)(3) under the Securities Exchange Act of 1934 and Regulation 1.10(a) under the Commodity Exchange Act as a Public Document. PricewaterhouseCoopers LLP, 300 Madison Avenue, New York, NY 10017 T: (646) 471 3000, F: (646) 471 8320, www.pwc.com/us Report of Independent Registered Public Accounting Firm To the Board of Directors and Stockholder of BNP Paribas Securities Corp., Opinion on the Financial Statement – Statement of Financial Condition We have audited the accompanying statement of financial condition of BNP Paribas Securities Corp. (the “Company”) as of December 31, 2018, including the related notes (collectively referred to as the “financial statement”). In our opinion, the financial statement presents fairly, in all material respects, the financial condition of the Company as of December 31, 2018 in conformity with accounting principles generally accepted in the United States of America. Basis for Opinion The financial statement is the responsibility of the Company’s management. Our responsibility is to express an opinion on the Company’s financial statement based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit of this financial statement in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statement is free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statement, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statement. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as, evaluating the overall presentation of the financial statement. We believe that our audit provides a reasonable basis for our opinion. February 28, 2019 We have served as the Company's auditor since 2012. BNP Paribas Securities Corp. 2 (An indirectly wholly owned subsidiary of BNP PARIBAS) Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) The accompanying notes are an integral part of these financial statements 176,234$ 264,904 Securities segregated under regulations - at fair value 1,588,981 Financial instruments owned - at fair value 9,810,555 (includes securities pledged to counterparties of $8,575,089) Securities borrowed 9,143,965 Receivable from brokers, dealers, and clearing organizations 5,588,956 Receivable from customers 1,251,004 Securities purchased under agreements to resell 1,120,336 Securities received as collateral - at fair value 136,080 Other assets (includes $9,359 at fair value) 337,044 Total Assets 29,418,059$ Liabilities and Stockholder’s equity Liabilities Short-term borrowings 1,584,197$ Securities sold under agreements to repurchase 7,862,565 Payable to customers 5,640,446 Securities loaned 5,380,595 Payable to brokers, dealers, and clearing organizations 3,987,221 Financial instruments sold, not yet purchased - at fair value 1,425,389 Obligation to return securities received as collateral - at fair value 136,080 Accrued expenses and other liabilities (includes $8,642 at fair value) 366,857 Total Liabilities 26,383,350 Liabilities subordinated to the claims of general creditors 1,855,000 Stockholder’s Equity Common stock, $10,000 stated value - 1,000 shares authorized, 321 shares issued and outstanding 3,210 Additional paid-in capital 1,155,828 Retained earnings 20,671 Total Stockholder's Equity 1,179,709 Total Liabilities and Stockholder’s Equity 29,418,059$ Assets Cash and cash equivalents Cash segregated under regulations BNP Paribas Securities Corp. 3 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) 1. Organization and Nature of Business BNP Paribas Securities Corp. (the “Company” or “BNPPSC”) is a wholly-owned subsidiary of BNP Paribas US Wholesale Holdings, Corp. (“WHC”), which is a wholly-owned subsidiary of BNP Paribas USA, Inc. (“BNPPUSA”), the ultimate parent of which is BNP Paribas (“BNPP”). On March 12, 2018, the Company merged with BNP Paribas Prime Brokerage, Inc. (“PBI”) (see note 3). The Company is registered as a broker-dealer with the Securities and Exchange Commission (“SEC”) under the Securities Exchange Act of 1934. As a broker-dealer, the Company is a member of the New York Stock Exchange (“NYSE”) and the Financial Industry Regulatory Authority (“FINRA”). In addition, BNPPSC is registered as a futures commission merchant (“FCM”) with the Commodity Futures Trading Commission (“CFTC”), under the Commodity Exchange Act. As an FCM, the Company is a member of the Chicago Mercantile Exchange (“CME”), the New York Mercantile Exchange (“NYMEX”), the National Futures Association (“NFA”), LCH. Clearnet Limited, ICE Clear Credit LLC, ICE Futures US, ICE Futures Europe (“ICE”), Options Clearing Corporation (“OCC”) and various other commodity exchanges. The Company is approved by the ICE Clear Credit LLC as a clearing member for credit default swaps products and by CME to clear over-the-counter swap derivatives transactions. The Company engages in market making transactions and brokerage activities for its customers, primarily institutions, other broker-dealers, and affiliates. BNPPSC also engages in investment banking activities and provides certain operational services. In addition, the Company provides prime brokerage and FCM services. Prime brokerage services include secured financing, securities settlement, custody, capital introduction, and securities lending to hedge funds, investment companies, affiliates and others. FCM services include commodity clearing and execution services to various institutional customers, including affiliates. Standard & Poor’s (“S&P”) ratings services assigned an A/A-1 counterparty credit ratings to the Company. S&P based its rating of BNPPSC solely on the ratings of its ultimate parent BNPP. 2. Significant Accounting Policies Basis of Presentation The preparation of financial statements is in conformity with accounting principles generally accepted in the United States of America (U.S. GAAP). Use of Estimates The preparation of financial statements requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities, revenue and expense, and disclosures of contingent assets and liabilities. Significant estimates include the realization of a deferred tax asset, deferred compensation and the fair value measurement of Financial instruments owned and Financial instruments sold, not yet purchased. Actual results could differ materially from such estimates included in the financial statements. BNP Paribas Securities Corp. 4 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) Cash and Cash Equivalents Cash and cash equivalents include highly liquid investments not held for resale with original maturities of three months or less. The Company has all cash on deposit with major money center banks. Cash and cash equivalents are carried at cost, which approximates fair value. Cash segregated under regulations Cash segregated under regulations consists of cash in banks subject to withdrawal restrictions, cash segregated in compliance with regulations, and cash deposited in a special reserve bank account for the exclusive benefit of customers pursuant to SEC Rule 15c3-3. Securities segregated under regulations – at fair value The Company is required by its primary regulators, including the SEC and CFTC, to segregate qualified securities to satisfy rules regarding the protection of customer assets. Financial instruments owned and sold, not yet repurchased - at fair value Regular way securities transactions are recognized on trade date basis. Regular way securities transactions settle within the time frame generally established by regulation or market convention. Forward settling trades such as extended settlement and to be announced (“TBA”) securities are not considered regular way trades when settlement does not occur within the shortest period possible for the security type. These transactions are recorded as derivatives on trade date and only the mark-to-market is recognized on the Statement of Financial Condition. Financial instruments owned and Financial instruments sold, not yet purchased are recorded at fair value in accordance with the Accounting Standards Codification (“ASC”) 820-10 “Fair Value Measurements” with unrealized gains and losses included in Trading gains and losses, net. Commissions and related clearing expenses are recorded on trade date as securities transactions occur. Customers’ securities transactions are reported on settlement date with related commission revenue and expense reported on trade date. Commodity commissions are recorded on a half-turn basis. Customers’ commodity transactions are reported on trade date. Securities Borrowing and Lending Activities Securities borrowed and Securities loaned are recorded at the amount of cash collateral advanced or received. Securities borrowed transactions require the Company to deposit cash or similar collateral with the lender. With respect to Securities loaned, the Company receives collateral in the form of cash in an amount generally in excess of the fair value of securities loaned. The Company monitors the fair value of securities borrowed or securities loaned on a daily basis with additional collateral obtained or returned, as necessary. Interest receivable or interest payable on such transactions is accrued and included in the Statement of Financial Condition in Other assets or Accrued expenses and other liabilities, respectively. Receivables from and Payables to Broker-Dealers and Clearing Organizations Receivables from broker-dealers and clearing organizations include amounts receivable from clearing organizations relating to open transactions, non-customer receivables and margin deposits. Payables to broker-dealers and clearing organizations include amounts payable to clearing organizations relating to open transactions, non-customer payables, and amounts related to unsettled securities trading activity. These balances are reported net by counterparty when the right of offset exists. Amounts receivable and payable for securities transactions that have not reached their contractual settlement date are recorded net on the Statement of Financial Condition. BNP Paribas Securities Corp. 5 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) Receivables and Payables with Customers Customer receivables and payables represent amounts due from/to customers, primarily related to unsettled securities transactions, margin balances, unsettled commodities activity and cash deposits, which are reported net by customer. The Company does not include in the Statement of Financial Condition the securities owned by customers or the securities sold short by customers. Reverse Repurchase and Repurchase Agreements Securities purchased under agreements to resell (reverse repo) and securities sold under agreements to repurchase (repo) are treated as collateralized financing transactions and are carried at their contracted price plus accrued interest. It is the Company's policy to take possession of securities with a fair value equal to or in excess of the principal amount loaned plus accrued interest. The Company monitors the fair value of reverse repo and repo on a daily basis with additional collateral obtained or returned, as necessary. Where the requirements of ASC 210-20 offsetting are met, resell and repurchase agreements with the same counterparty are reported on a net basis in the Statement of Financial Condition. Such transactions are netted by counterparty where the right to offset exists. Securities Received as Collateral and Obligation to Return Securities Received as Collateral The Company receives and pledges securities as collateral in connection with non-cash transactions in which the Company is the lender. When the Company is permitted to sell or repledge these securities, the Company reports the fair value of the collateral received and the related obligation to return the collateral in the Statement of Financial Condition. Securities Received from Customers and Affiliates Securities received from customers and affiliates in lieu of cash margin are not reflected in the Statement of Financial Condition as the Company does not own such securities and they may only be sold or hypothecated to the extent the Company requires the equivalent funds to meet regulatory or counterparty requirements. Offsetting Assets and Liabilities To reduce credit exposures on derivatives and securities financing transactions, the Company may enter into master netting agreements or similar arrangements (collectively, netting agreements) with counterparties that permit it to offset receivables and payables with such counterparties. A netting agreement is a contract with a counterparty that permits net settlement of multiple transactions with that counterparty, including upon the exercise of termination rights by a non-defaulting party. Upon exercise of such termination rights, all transactions governed by the netting agreement are terminated and a net settlement amount is calculated. In addition, the Company receives and posts cash and securities collateral with respect to its derivatives and securities financing transactions, subject to the terms of the related credit support agreements or similar arrangements (collectively, credit support agreements). An enforceable credit support agreement grants the non-defaulting party exercising termination rights the right to liquidate the collateral and apply the proceeds to any amounts owed. Derivatives are reported on a net-by-counterparty basis (i.e., the net payable or receivable for derivative assets and liabilities for a given counterparty) in the Statement of Financial Condition when a legal right of setoff exists under an enforceable netting agreement. Reverse repo, repo and BNP Paribas Securities Corp. 6 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) securities borrowed and loaned transactions with the same term and currency are presented on a net-by-counterparty basis in the Statement of Financial Condition when such transactions meet certain settlement criteria and are subject to netting agreements. In the Statement of Financial Condition, derivatives are reported net of cash collateral received and posted under enforceable credit support agreements, when transacted under an enforceable netting agreement. In the Statement of Financial Condition, resale and repurchase agreements, and securities borrowed and loaned, are not reported net of the related cash and securities received or posted as collateral. See Note 5 for further information about collateral received and pledged, including rights to deliver or repledge collateral. See Notes 4 and 17 for further information about offsetting. Short-Term Borrowings The Company obtains short-term financing by borrowing from an affiliate or a major money center using an unsecured loan facility. The affiliated borrowing is on an overnight basis and term loans are up to one month in duration. The principal associated with these borrowings are recorded as Short-term borrowings in the Statement of Financial Condition. Income Taxes The Company is included in a consolidated tax group and tax is computed using a modified benefit for loss methodology. Under this methodology, the Company records an income tax provision equal to the total current and deferred tax provision / benefit, but (i) taking into account implications of certain unitary/combined state tax group, and (ii) considering whether the tax attributes of the Company are realizable by the consolidated or combined/unitary group even if the Company would not otherwise have realized such attributes on a stand-alone basis (see note 11). Deferred tax assets and liabilities are recognized for temporary differences between the financial reporting and the tax basis of the Company’s assets and liabilities. Valuation allowances are established, if applicable, to reduce deferred tax assets to the amount that more likely than not will be realized. The Company’s net tax assets or liabilities are presented as a component of either Other assets or Accrued expenses and other liabilities, respectively, in the Statement of Financial Condition. Uncertain tax positions are evaluated in accordance with ASC 740-10-25 “Income Taxes” which prescribes a comprehensive model for the financial statement recognition, measurement, presentation and disclosure of income tax uncertainties with respect to positions taken or expected to be taken in income tax returns. As permitted by Staff Accounting Bulletin No. 118, provisional amounts calculated based on information available as of December 31, 2017 were made for the adjustments to deferred tax assets and liabilities and certain valuation allowance assessments. These amounts were subject to change in 2018 as we obtained information necessary to complete the calculations. Such calculations were completed in 2018 and no material adjustments were made to the amounts originally booked in 2017. The Company recognizes interest and penalties related to unrecognized tax benefits within the appropriate interest expense and tax penalty line items within the Statement of Operations, as BNP Paribas Securities Corp. 7 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) applicable. Accrued interest and penalties, if any, are included in Accrued expenses and other liabilities in the Statement of Financial Condition. Exchange Memberships Membership shares and rights that are required by the Company to conduct its clearance and execution activities are recorded at cost, less any adjustments for permanent impairments and are included in Other assets in the Statement of Financial Condition. Foreign Currencies The Company’s functional base currency is U.S. dollar. At December 31, 2018, the Company has assets and liabilities balances denominated in foreign currencies which are translated at closing exchange rates at December 31, 2018 while the revenues and expenses are translated at average exchange rates with any resulting gain or loss reflected in the Statement of Operations classified as either Other revenue or Other expenses. Fair Value Measurement – Definition and Hierarchy Fair value is defined as the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. ASC 820 “Fair Value Measurements” established a hierarchy for inputs used in measuring fair value that maximizes the use of observable inputs and minimizes the use of unobservable inputs by requiring that the most observable inputs be used when available. Observable inputs are inputs that market participants would use in pricing the asset or liability developed based on market data obtained from sources independent of the Company. Unobservable inputs are inputs that reflect the assumptions that market participants would use in pricing the asset or liability developed based on the best information available in the circumstances. The hierarchy is broken down into three levels based on the reliability of inputs as follows: Level 1 – Valuations based on quoted prices in active markets for identical assets or liabilities that the Company has the ability to access. Valuation adjustments and block discounts are not applied to Level 1 instruments. Level 2 – Valuations based on quoted prices in markets that are not active or for which all significant inputs are observable, either directly or indirectly. Observable inputs include interest rates and yield curves observable at commonly quoted intervals, volatilities, prepayment speeds, loss severities, credit risks, and default rates. Level 3 – Valuations based on inputs that are unobservable and significant to the overall fair value measurement. The Company uses market quotes for pricing its trading portfolio, when available. When no active market exists the Company uses prices of comparable instruments to determine the fair value. In some instances, the Company may also employ a mark to model valuation methodology. During 2018, no trading positions were valued using a mark to model approach. BNP Paribas Securities Corp. 8 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) Recent Accounting Developments In August 2018, the FASB issued ASU 2018-13, “Fair Value Measurement (Topic 820)” (“ASU 2018-13”) to improve the effectiveness of fair value measurement disclosures. ASU 2018-13 removes disclosure requirements of the amount and reasons for transfers between Level 1 and Level 2 of the fair value hierarchy, the policy for timing of transfers between levels, and the valuation processes for Level 3 fair value measurements. The amendments are effective for fiscal years, and interim periods within those fiscal years, beginning after December 15, 2019. The Company is currently evaluating the potential impact of ASU 2018-13. In February 2018, the FASB issued ASU 2018-02, “Income Statement-Reporting Comprehensive Income (Topic 220)-Reclassification of Certain Tax Effects from Accumulated Other Comprehensive Income” (“ASU 2018-02”). ASU 2018-02 permits, but does not require, companies to reclassify stranded tax effects caused by 2017 tax reform from accumulated other comprehensive income to retained earnings. Additionally, it requires new disclosures by all companies, whether they opt to do the reclassification or not. ASU 2018-02 will be effective for fiscal years, and interim periods within those fiscal years, beginning after December 15, 2018, with early adoption permitted. The Company is currently evaluating the potential impact of ASU 2018-02. In August 2017, the FASB issued ASU 2017-12, “Derivatives and Hedging (Topic 815)” (“ASU 2017-12”), as amended by ASU 2018-16, “Derivatives and Hedging (Topic 815)” (“ASU 2018- 16”). ASU 2017-12, as amended, enables entities to better portray their risk management activities in the financial statements. The amendments expand an entity’s ability to hedge nonfinancial and financial risk components and reduce complexity in fair value hedges of interest rate risk. ASU 2017-12 eliminates the requirement to separately measure and report hedge ineffectiveness and generally requires the entire change in the fair value of a hedging instrument to be presented in the same income statement line as the hedged item. It also eases certain documentation and assessment requirements and modifies the accounting for components excluded from the assessment of hedge effectiveness. ASU 2018-16 permits the use of the Overnight Index Swap (“OIS”) rate based on Secured Overnight Financing Rate as a U.S. benchmark interest rate for hedge accounting purposes in addition to the United States Treasury, the London Inter-bank Offered Rate, the OIS rate based on the Fed Funds Effective Rate. The amendments should be adopted on a prospective basis for qualifying new or re-designated hedging relationships entered into on or after the date of adoption. ASU 2017-12 will be effective for fiscal years, and interim periods within those fiscal years, beginning after December 15, 2019, with early adoption permitted. The Company is currently evaluating the potential impact of ASU 2017-12. 3. Merger and Capital Actions On March 12, 2018, the Company merged with PBI. The merger was recorded as a merger of entities under common control, as both companies were wholly-owned subsidiaries of WHC. Based on ASC 805 “Business Combinations”, the assets, liabilities and additional paid in capital of PBI transferred to the Company were initially transferred at their respective carrying amounts in the accounts of PBI, at the date of transfer. No additional common stock was issued and the merged entities’ common parent, WHC, maintained 100% of the voting rights. PBI provided prime brokerage services including secured financing, secured settlement, custody, capital introduction and securities lending to hedge funds, investment companies, affiliates and BNP Paribas Securities Corp. 9 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) others. The presentation of these financial statements includes the results and activities of PBI as if the entities were combined from the beginning of the year. The merger was completed primarily to create a more efficient use of capital and for operational efficiencies. On December 28, 2018, the Company purchased back 179 of its 500 common shares owned by WHC for $646,318 resulting in a reduction of $1,790 in common stock and $644,528 in additional paid in capital. As of December 31, 2018, 1,000 shares remain authorized and 321 issued and outstanding. 4. Collateralized Transactions The Company enters into reverse repurchase agreements, repurchase agreements, securities borrowed and securities loaned transactions to, among other things, acquire securities to cover short positions and settle other securities obligations, to accommodate customers’ needs and to finance the Company’s inventory positions. The Company manages credit exposure arising from such transactions by, in appropriate circumstances, entering into master netting agreements and collateral agreements with counterparties that provide the Company, in the event of a counterparty default (such as bankruptcy or a counterparty’s failure to pay or perform), the right to net a counterparty’s rights and obligations under such agreement and liquidate and setoff collateral against the net amount owed by the counterparty. The Company’s policy is generally to take possession of securities purchased under agreements to resell and securities borrowed, and to receive securities and cash posted as collateral (with rights of rehypothecation). In certain cases the Company may agree for such collateral to be posted to a third party custodian under a tri- party arrangement that enables the Company to take control of such collateral in the event of a counterparty default. The Company also monitors the fair value of the underlying securities as compared with the related receivable or payable, including accrued interest, and, as necessary, requests additional collateral as provided under the applicable agreement to ensure such transactions are adequately collateralized. The Company is a netting member of the Government Securities Division of the Fixed Income Clearing Corporation ("FICC"), an industry clearing house for reverse repurchase and repurchase transactions. At the end of each business day, for every trade submitted to and matched by FICC, the transaction is novated to FICC, at which time FICC becomes the Company's counterparty. At December 31, 2018, included in Securities purchased under agreements to resell on the Statement of Financial Condition are amounts under contract with both affiliate and non-affiliate counterparties. In accordance with applicable accounting guidance, netting applied to these reverse repurchase and repurchase balances was $8,474,353. BNP Paribas Securities Corp. 10 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) The following table presents information about the offsetting of these instruments and related collateral amounts: As of December 31, 2018, the gross liabilities for Securities sold under agreements to repurchase and Securities loaned disaggregated by class of collateral pledged and by remaining contractual maturity of the agreements were: Gross Amounts Recognized Gross Amounts offset in the Statement of Financial Condition Net Amounts Presented in the Statement of Financial Condition Available Collateral* Counterparty Netting Net Amount Assets Securities Purchased under agreement to resell 9,594,689$ (8,474,353)$ 1,120,336$ (1,114,150)$ -$ 6,186$ Securities Borrowed 9,143,965 - 9,143,965 (8,830,912) (34,037) 279,016 Liabilities Securities sold under agreements to repurchase 16,336,918$ (8,474,353)$ 7,862,565$ (7,844,402)$ -$ 18,163$ Securities Loaned 5,380,595 - 5,380,595 (5,217,637) (34,037) 128,921 * Collateral is reflected at its fair value, but has been limited to the net exposure in the Statement of Financial Condition so as not to include any overcollateralization. Gross Amounts Not Offset in the Statement of Financial Condition Securities sold under agreements to repurchase Securities loaned Total U.S. Government and agency securities 9,102,284$ 98,062$ 9,200,346$ Corporate debt securities 2,523,778 265,945 2,789,723 Non-Agency Mortgage and Asset-backed securities 4,710,856 - 4,710,856 Equities - 5,016,588 5,016,588 16,336,918 5,380,595 21,717,513 Reverse Repos and Repos offset (ASC 210-20-45-11)(8,474,353) - (8,474,353) 7,862,565$ 5,380,595$ 13,243,160$ BNP Paribas Securities Corp. 11 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) 5. Financial Instruments Owned and Financial Instruments Sold, Not Yet Purchased – at Fair Value Financial instruments owned and Financial instruments sold, not yet purchased – at fair value as of December 31, 2018 consist of: Financial instruments owned that are pledged to counterparties represent proprietary positions which have been pledged as collateral to counterparties on terms which permit the counterparty to sell or repledge the securities to others. 6. Receivable from and Payable to Brokers, Dealers and Clearing Organizations Amounts receivable from and payable to brokers, dealers and clearing organizations as of December 31, 2018, consist of the following: Securities sold under agreements Securities to repurchase loaned Total Overnight and Open 1,525,337$ 4,873,077$ 6,398,414$ Up to 30 days 13,219,019 - 13,219,019 31 - 90 days 1,262,220 507,518 1,769,738 Greater than 90 days 330,342 - 330,342 16,336,918 5,380,595$ 21,717,513 Reverse Repos and Repos offset (ASC 210-20-45-11)(8,474,353) - (8,474,353) 7,862,565$ 5,380,595$ 13,243,160$ Owned Sold U.S. Government and agency securities 8,880,662$ 1,324,615$ Asset-backed securities 730,992 - U.S. agency securities TBA 102,899 66,840 Equities and convertibles 84,603 29,360 Listed equity options 4,796 3,704 Corporate debt securities 4,542 101 Extended settlement receivables/payables 2,061 769 9,810,555$ 1,425,389$ BNP Paribas Securities Corp. 12 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) The Company clears certain of its proprietary, non-customer, and customer transactions through various clearing organizations. Unsettled regular way trades relate to amounts receivable from or payable to clearing organizations for proprietary positions that had not yet reached settlement date. 7. Liabilities Subordinated to Claims of General Creditors The Company has six subordinated loan agreements totaling $1,855,000 with affiliates outstanding as of December 31, 2018. These loans have various rollover dates. The loans allow for prepayment of all or any part of the obligations at the option of the Company, and upon receipt of prior written approval of the FINRA and the CME. All loans bear interest based on the London Interbank Offered Rate (“LIBOR ”) rate, as defined by their lenders. The agreements covering the subordinated borrowings have been approved by the FINRA and the CME, and are thus available in computing net capital pursuant to Rule 15c3-1 under the Securities Exchange Act of 1934 and Regulation 1.17 under the Commodity Exchange Act. To the extent that such borrowings are required for the Company’s continued compliance with net capital requirements, they may not be repaid. The FINRA subordinated loan agreements have automatic annual rollover extensions with regard to maturity dates except for $500,000 maturing on June 28, 2019. FINRA requires more than six months advance notification of intent to not extend the maturity of a subordinated loan agreement. The Company has made no such notification. Receivable Payable Receivable/Payable from/to clearing organizations 3,070,896$ 94,812$ Receivable/Payable from/to non-customers 1,919,611 3,458,238 Receivable/Payable from/to brokers & dealers 326,709 4,668 Securities failed to deliver/receive 271,740 236,932 Unsettled trades receivable/payable, net - 192,571 5,588,956$ 3,987,221$ Rollover Date Affiliated Lender Rate Amount January 31, 2019 WHC Overnight LIBOR + 35bps 230,000$ June 28, 2019 WHC 3M LIBOR + 51bps 500,000 December 28, 2019 WHC 3M LIBOR + 120bps 275,000 December 31, 2019 WHC 1M LIBOR + 125bps 100,000 December 31, 2019 WHC 3M LIBOR + 120bps 300,000 December 31, 2019 BNPPUSA 3M LIBOR + 120bps 450,000 1,855,000$ BNP Paribas Securities Corp. 13 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) 8. Deferred Compensation BNPP sponsors numerous deferred compensation plans. Employees of the Company with annual discretionary bonus awards in excess of a certain fixed amount as defined by BNPP will receive a portion of such excess amount in units according to the specific award provisions of each plan. In 2014, BNPP established three new plans: (a) DCS 2015 Plan; (b) DCS Plus 2015 Plan; (c) KCDP 2015 Plan; and (d) US Regulated Plan 2015. All four plans are liability awards with grant dates in February 2015. Units are awarded based on the average closing price of BNPP shares over a specified period. The vesting of DCS Plus 2015 Plan is subject to fulfillment of specified performance conditions. The remaining three plans vest based on the fulfillment of service conditions. The vesting and payment periods for DCS 2015 Plan and DCS Plus 2015 Plan are March of 2016, 2017 and 2018 for cash deferred portions and September of 2016, 2017 and 2018 for cash-indexed deferred. The vesting and payment periods for KCDP 2015 plan and US Regulated Plan 2015 are June of 2016, 2017 and 2018 for both cash deferred and cash-indexed deferred portions. In 2015, BNPP established three new plans: (a) DCS 2016 Plan; (b) DCS Plus 2016 Plan; (c) KCDP 2016 Plan; and (d) US Regulated Plan 2016. All four plans are liability awards with grant dates in February 2016. Units are awarded based on the average closing price of BNPP shares over a specified period. The vesting of DCS Plus 2016 Plan is subject to fulfillment of specified performance conditions. The remaining three plans vest based on the fulfillment of service conditions. The vesting and payment periods for DCS 2016 Plan and DCS Plus 2016 Plan are March of 2017, 2018 and 2019 for cash deferred portions and September of 2017, 2018 and 2019 for cash-indexed deferred. The vesting and payment periods for KCDP 2016 plan and US Regulated Plan 2016 are June of 2017, 2018 and 2019 for both cash deferred and cash-indexed deferred portions. In 2015, BNPP established a buyout plan Buy out 2016. The value of the unvested and forfeited awards under deferred compensation arrangements from former employer is divided equally between Cash Buy Out and Cash Index Buy out. The remaining plans vest based on the fulfillment of service conditions. The remaining vesting and payment period for Buy Out 2016 Plan is June 2019. In 2016, BNPP established five plans: (a) DCS 2017 Plan; (b) DCS Plus 2017 Plan; (c) KCDP 2017 Plan; (d) DCS+G BE 2017; and (e) US Regulated Plan 2017. All five plans are liability awards with grant dates in February 2017. Units are awarded based on the average closing price of BNPP shares over a specified period. The vesting of DCS Plus 2017 Plan is subject to fulfillment of specified performance conditions. The remaining plans vest based on the fulfillment of service conditions. The vesting and payment periods for DCS 2017 Plan and DCS Plus 2017 Plan are March of 2018, 2019 and 2020 for cash deferred portions and September of 2018, 2019 and 2020 for cash-indexed deferred. The vesting and payment periods for KCDP 2017 plan and for US Regulated Plan 2017 are June of 2018, 2019 and 2020 for both cash deferred and cash-indexed deferred portions. The vesting and payment periods for DCS+G BE 2017 are April 2018, April 2019 and April 2020. In 2016, BNPP established a buyout plan Buy out 2017. The value of the unvested and forfeited awards under deferred compensation arrangements from former employer is divided equally BNP Paribas Securities Corp. 14 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) between Cash Buy Out and Cash Index Buy out. The remaining plans vest based on the fulfillment of service conditions. The vesting and payment periods for Buy Out 2017 Plan are June of 2018, 2019 and 2020. In 2017, BNPP established five plans: (a) DCS 2018 Plan; (b) DCS Plus 2018 Plan; (c) KCDP 2018 Plan; (d) DCS+G BE 2018; and (e) US Regulated Plan 2018. All four plans are liability awards with grant dates in February 2018. Units are awarded based on the average closing price of BNPP shares over a specified period. The vesting of DCS Plus 2018 Plan is subject to fulfillment of specified performance conditions. The remaining plans vest based on the fulfillment of service conditions. The vesting and payment periods for DCS 2018 Plan and DCS Plus 2018 Plan are March of 2019, 2020 and 2021 for cash deferred portions and September of 2019, 2020 and 2021 for cash-indexed deferred. The vesting and payment periods for KCDP 2018 plan and for US Regulated Plan 2018 are June of 2019, 2020 and 2021 for both cash deferred and cash-indexed deferred portions. The vesting and payment periods DCS+G BE 2018 are April 2019, April 2020 and April 2021. In 2017, BNPP established a buyout plan Buy out 2018. The value of the unvested and forfeited awards under deferred compensation arrangements from former employer is divided equally between Cash Buy Out and Cash Index Buy out. The remaining plans vest based on the fulfillment of service conditions. The vesting and payment periods for Buy Out 2018 Plan are June of 2019, 2020 and 2021. In 2015, 2016, 2017 BNPP granted selected key employees the International Sustainability and Incentive Scheme to receive a cash amount in June 2019, 2020 and 2021 subject to indexation, performance, and payment conditions. In addition, BNPP allows certain employees to defer up to 100% of their bonus through a voluntary deferred compensation plan (“Plan”). The assets of the Plan are owned by BNPP and recorded as an asset with an offsetting liability to the individual employees. 9. Employee Benefit Plans Substantially all employees of BNPP and its affiliates in the United States of America, who meet certain age and tenure requirements, are covered under various benefit plans in which BNPPSC participates. The plans include a funded noncontributory defined benefit plan, a supplemental executive retirement plan and a defined contribution 401(k) plan. The assets of the defined benefit plan are principally invested in fixed income and equity securities, held by a third-party trustee and managed by third party investment advisors. All defined benefit plans were frozen as of December 31, 2011. 10. Income Taxes The Company is a member of a consolidated group for U.S. federal income tax purposes and a member of multiple combined group tax return filings for state and local income tax purposes. Federal and state income taxes as well as benefits for federal and state net operating losses (“NOLs”) are allocated based on a formal tax sharing agreement between the Company and BNPPUSA. All current balances will be settled by the Company with BNPPUSA. The tax sharing agreement in place for the U.S. consolidated group outlines the arrangements amongst the members with respect to federal taxes and is consistent with the applicable federal BNP Paribas Securities Corp. 15 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) tax consolidation rules governing the tax sharing agreement. It outlines the allocation amongst the members of the consolidated federal tax liabilities (where there is consolidated taxable income for an income year). The Company’s tax is included in a consolidated tax group and computed using a modified benefit for loss methodology. Under this methodology, the Company records an income tax provision equal to the total current and deferred tax provision / benefit, but (i) taking into account implications of certain unitary/combined state tax group, and (ii) considering whether the tax attributes of the Company are realizable by the consolidated or combined/unitary group even if the Company would not otherwise have realized such attributes on a stand-alone basis. The difference between the Company’s federal statutory and effective tax rate is due to permanent differences such as dividend factoring basis disallowance, dividend received deductions, non-deductible penalty charges, non-deductible meals and entertainment, and state and local taxes. The resulting tax payable or benefit receivable is settled with BNPPUSA periodically. The Company received $43,747 in tax benefit payments from BNPPUSA during 2018. At December 31, 2018, the Company’s net deferred tax asset of $50,315 is comprised of $60,920 of deferred tax assets, $150 of deferred tax liabilities, and a valuation allowance of $10,455 against its New York City (“NYC”) and Pennsylvania (“PA”) net deferred tax asset. The net deferred tax asset is due to differences between the tax basis of assets and liabilities and their respective financial-reporting amounts arising primarily from differences in the timing of expenses for deferred compensation and cash bonuses, goodwill amortization, and reserves against certain investments. The valuation allowance increased by $1,443 from the balance of $9,012 at December 31, 2017. The Company has recorded a valuation allowance against the net deferred tax asset related to NYC and PA, as management believes that the benefit related to the deferred tax asset is not more likely than not to be realized in the future in those particular jurisdictions. The net deferred tax asset as of December 31, 2018 is included in Other Assets in the Statement of Financial Condition. As of December 31, 2018, the Company’s open tax years potentially subject to examination by the Internal Revenue Service, New York State (“NYS”) and NYC are 2015 through 2018. As of December 31, 2018, on a stand-alone basis, the Company has a PA post-apportioned NOL carryforward of $103,168, the majority of which will expire between 2030 and 2033; however, management does not expect to be able to utilize this NOL due to decreased tax apportionment and significant tax adjustments that generate losses in the State. As such, there is a valuation allowance against this deferred tax asset item. Members of the U.S. consolidated group that generate a current NOL contribute such loss against the U.S. consolidated group's income tax liability to the extent members of the U.S. consolidated group contributed taxable income. The loss member will be due an amount equal to the loss that has been utilized to offset taxable income in accordance with the terms of the tax sharing agreement. The settlement of the tax accounts between the Company and BNPPUSA are in line with the terms of the tax sharing agreement. BNP Paribas Securities Corp. 16 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) As of December 31, 2018, Management has evaluated the Company’s tax positions and determined that there are no remaining uncertain tax positions required to be recognized by the Company. The Company does not expect the unrecognized tax benefit to change significantly during the next twelve months. As stated, the Company is included in the consolidated tax return of BNPPUSA. The Company calculates the provision for income taxes by using a “separate return” method. Under this method, the Company is assumed to file a separate return with the tax authority, thereby reporting taxable income or loss and paying the applicable tax to or receiving the appropriate refund from BNPPUSA. Prior to 2016, the tax sharing agreement in place at that time was not based on the separate return method although it was the method used to calculate the tax provision. During 2016, the tax sharing agreement was amended with the formation of the Intermediate Holding Company and was now in line with the separate return method. Up until 2016 the company accrued a payable of $393,083 that represented the difference between the hypothetical tax calculation used for the US GAAP basis financial statements and actual amounts were paid to/received by the Company, based on the tax sharing agreement in place at that time. In accordance with ASC 740-10-30-27 differences between the tax provision calculated by the Company used for the US GAAP basis financial statements and the actuals payments that were made to BNPPUSA under the tax sharing agreement are treated as a capital contribution. Accordingly, the Company recorded a $393,083 capital contribution in 2018. 11. Transactions with Related Parties The Company engages in various transactions with BNPP and its affiliates. These transactions include financing agreements and operational support. At December 31, 2018, the Company has a formal unsecured line of credit with BNPP. Borrowings under this line of credit bear a rate of LIBOR plus a nominal interest rate. The borrowing limit under these arrangements is €3,500,000 or the U.S. dollar equivalent based on December 31, 2018 exchange rate is $4,009,600. On any date in which the equivalent in euros of the aggregate principal amount of all advances outstanding exceeds 105% of the maximum borrowing amount, BNPP may, at its sole discretion notify the Company of such excess and make demand for prepayment in respect thereof. At December 31, 2018, the Company borrowed $1,519,139 under this line. At December 31, 2018, the Company has a revolving loan facility of $100,000 with WHC. The total amount drawn at December 31, 2018 was $65,000 and is included in Short-term borrowings. BNP Paribas Securities Corp. 17 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) At December 31, 2018, assets and liabilities with related parties consist of: On June 29, 2018, the Company paid a dividend in the amount of $47,085 to WHC. Payable to brokers, dealers, and clearing organizations includes net unsettled regular way trade sales in the amount of $1,769,646. The Company executes various transactions with its affiliates, such as securities purchased under agreements to resell, securities sold under agreements to repurchase, securities borrowed, securities loaned, margin financing and clearance and settlement. The Company has been historically notified in late March of the following year regarding its final settlement amounts concerning its portion of the global transfer pricing flows. To mitigate the impact of this late notification, the Company has entered into an agreement with BNPPUSA, whereby BNPPUSA pays or receives the difference between the amount accrued at year end and the final settlement amount. In addition, the Company entered a separate agreement with its ultimate parent, BNPP, to limit the amount of its allocated global aggregate net loss from transfer pricing flows to a maximum level of $0 under these transfer pricing agreements. Assets Cash and cash equivalents 58,605$ Cash segregated under regulations 78,396 Receivable from brokers, dealers, and clearing organizations 2,286,107 Securities borrowed 390,123 Securities received as collateral - at fair value 72,713 Securities purchased under agreements to resell 7,652 Receivable from customers 2,437 Financial instruments owned - at fair value 72 Other assets 177,736 Total assets 3,073,841$ Liabilities Short-term borrowings 1,584,139$ Securities sold under agreements to repurchase 5,270,511 Securities loaned 3,437,287 Payable to brokers, dealers, and clearing organizations 1,773,521 Payable to customers 1,599,638 Obligation to return securities received as collateral - at fair value 72,713 Financial instrument sold, not yet purchased - at fair value 6,967 Accrued expenses and other liabilities 130,819 Total liabilities 13,875,595$ Liabilities subordinated to the claims of general creditors 1,855,000$ BNP Paribas Securities Corp. 18 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) The Company is a party to numerous service level agreements (“SLA”) with its affiliates. Due to the nature of these agreements, the Company could experience a significant impact on its financial statements from these cost allocations that follow a cost plus methodology. The Company is receiving fee-based compensation at cost plus a mark-up through SLAs with affiliates. At December 31, 2018, SLA receivable from affiliates of $95,671 is included in Other assets in the Statement of Financial condition. At December 31, 2018, the intercompany transfer pricing fee payable is $11,453 which is included in Accrued expenses and other liabilities in the Statement of Financial condition. The Company had a payable of $22,122 to BNPPUSA and other affiliates for cost and revenue sharing agreements and other general expenses, which is included in Accrued expenses and other liabilities. BNP Paribas Arbitrage SNC, acting through its US Branch (“BNPPA-US”), provides services on behalf of the Company to facilitate the Exchange Traded Fund financing business between BNPP-PBIL and the Company and their respective customers. At December 31, 2018, the Company accrued $576 shared revenue payable to BNPPA-US and is included in Accrued expenses and other liabilities. The Company settles with BNPPA-US on a periodic basis. The Company has a parental guarantee arrangement covering all obligations of the entity. The outstanding blanket guarantee fee payable of $885 as of December 31, 2018 is included in Accrued expenses and other liabilities in the Statement of Financial Condition. At December 31, 2018, the Company entered into forward starting securities borrowing agreements with affiliates which have a total contract value of $280. In addition, the Company entered into forward starting repurchase and securities lending agreements with contract values of $583,766 and $119,550, respectively. 12. Pledged Assets, Commitments and Contingencies At December 31, 2018, the approximate fair values of collateral received which may be sold or repledged by the Company were: At December 31, 2018, the approximate fair values of the portion of collateral received that were sold or repledged by the Company, including the collateral related to amounts netted under FASB ASC 210-20-45 (formerly FIN 41), were: Sources of collateral Securities purchased under agreements to resell 9,587,164$ Securities received in securities borrowed vs. cash transactions 8,831,003 Securities received in securities borrowed/reverse repo vs. pledged transactions 4,885,724 Securities received as collateral 136,080 Securities received from margin loan available to repledge 4,734,707 Total 28,174,678$ BNP Paribas Securities Corp. 19 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) Additionally, securities received as collateral for securities purchased under agreements to resell were segregated for regulatory requirements under 15c3-3, PAB and for liquidity purposes. The fair market value of the amounts segregated were $764,561, $55,114, and $1,994,667 respectively. The Company is required to maintain deposits with various clearing organizations and exchanges. At December 31, 2018, the Company has placed securities, on deposit, it owns which have a fair value of $1,733,287, of which $1,588,981 is included in Securities segregated under regulations- at fair value. In addition, the Company has cash deposits of $2,939,654 to satisfy customer and firm requirements. The BNP Paribas New York Branch funds the Company using a combination of cash and money market to cover the OCC requirement for option positions. At December 31, 2018, the Company has cash deposits of $10,000 and securities of $19,619 to satisfy such requirements. The Company has one outstanding letter of credit issued by a third–party bank in the amount of $40,000, which is posted at a clearing organization to satisfy firm margin requirements. The Company is contingently liable for this letter of credit which is used in lieu of depositing cash or securities. As of December 31, 2018, the Company had not drawn upon the letter of credit. The Company has committed reverse repurchase facilities agreements for a maximum amount of $300,000 with ICE Clear Europe Limited and ICE Clear credit for $200,000 and $100,000, respectively, which can be drawn at any time. Certain customers have credit facility agreements for collateralized borrowings with the Company in accordance with internal margin guidelines. As of December 31, 2018, the Company had commitments of $331,952 related to credit facilities of which $72,697 were not drawn. At December 31, 2018, the Company entered into forward starting reverse repurchase and securities borrowing agreements with contract values of $458 and $609,105, respectively. In addition, the Company entered into forward starting repurchase and securities lending agreements with contract values of $119,550 and $583,867, respectively. As a member of the Mortgage Backed Securities Division (“MBSD”) and Government Securities Division (“GSD”) of the Fixed Income Clearing Corp (“FICC”), the Company participates in the Capped Contingency Liquidity Facility (“CCLF”). The CCLF creates overnight repos between Uses of collateral Securities sold under agreements to repurchase 10,067,897$ Securities lent in securities loaned vs. cash transactions 5,234,311 Securities pledged in securities borrowed/reverse repo vs. pledged transactions 2,561,349 Obligation to return securities received as collateral 136,080 Pledged to clearing corporations 3,531,349 Short Sale 2,582,666 Total 24,113,652$ BNP Paribas Securities Corp. 20 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) the FICC and each of its solvent firms so that, if a firm fails, the funding to offset its portfolio would be sourced across FICC’s membership rather than dependent on an expensive, long-term line of credit. As of December 31, 2018, the Company’s commitment to the CCLF was $518,598 for MBSD and $64,552 for GSD, of which no utilization had occurred. This amount is calculated by FICC based on membership size and volumes and may fluctuate significantly. The Company is a member of numerous exchanges and clearinghouses. Under the membership agreements, members are generally required to guarantee the performance of other members. Additionally, if a member becomes unable to satisfy its obligations to the clearinghouse, other members would be required to meet shortfalls. To mitigate these performance risks, the exchanges and clearinghouses often require members to post collateral as well as meet certain minimum financial standards. The Company’s maximum potential liability under these arrangements cannot be quantified. However, the potential for the Company to be required to make payments under these arrangements is remote. Accordingly, no contingent liability is recorded in the Statement of Financial Condition for these arrangements. The Company, in the normal course of business, has been named as a defendant in various legal proceedings. In view of the inherent difficulty of predicting the outcome of legal matters, particularly where the claimants seek very large or indeterminate damages or where the cases present novel legal theories or involve a large number of parties, the Company cannot state with confidence what the eventual outcome of the pending matters will be, or that such outcome would not have a material adverse effect on the Company’s financial statements. 13. Net Capital Requirements As a registered broker-dealer, the Company is subject to the Uniform Net Capital Rule (“Rule 15c3-1”) under the Securities Exchange Act of 1934. The Company has elected to compute its net capital using the alternative method, which requires the maintenance of minimum net capital equal to the greater of $1,500 or 2% of aggregate debit balances arising from customer transactions, as defined. As a registered futures commission merchant, the Company is subject to the Minimum Financial Requirements Rule pursuant to Regulation 1.17 under the Commodity Exchange Act, which requires the maintenance of minimum net capital, as defined, equal to the greater of 8% of the total customer risk margin requirements plus 8% of the total non-customer risk margin requirements required to be segregated pursuant to the Commodity Exchange Act. At December 31, 2018, the 8% of the customer risk margin requirements plus 8% of the total non-customer risk margin requirements produced the greater net capital requirement. The Company had net capital of $2,106,145, which was $1,699,024 in excess of its required net capital. 14. Cash and Securities Segregated under Regulations As a registered broker-dealer, the Company is subject to the Customer Protection Rule (“Rule 15c3-3”) under the Securities Exchange Act of 1934. The Rule requires the deposit of cash and/or qualified securities, as defined, in a special reserve account for the exclusive benefit of customers. As of December 31, 2018, the Company made a computation related to Rule 15c3-3 and was required to maintain a balance of $596,327 in this account. The Company had segregated cash in a money market demand account with a value of $1,353 as of December 31, 2018. In addition, BNP Paribas Securities Corp. 21 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) the Company had qualified securities with a market value of $749,269 in a special reserve account for the exclusive benefit of customers as of December 31, 2018. The Company made a deposit of $249,671 of qualified securities on January 3, 2019 in order to meet the Company’s internal deposit requirements which are higher than what is required by the regulations. As of December 31, 2018, the Company made a computation related to the reserve requirement for Proprietary Accounts of Brokers (“PAB”). As of December 31, 2018, the Company made a computation related to PAB Rule 15c3-3 and was required to maintain a balance of $391 in this account. The Company had segregated cash in a money market demand account with a value of $1,044 as of December 31, 2018. In addition, the Company had qualified securities with a market value of $54,012 in a special reserve account for the exclusive benefit of brokers as of December 31, 2018. The Company is subject to Section 4d(2) and Regulation 30.7 under the Commodity Exchange Act (“CEA”), which requires a FCM to segregate, secure or sequester money, securities, funds and property related to customers’ regulated commodity futures accounts in a special bank account for the exclusive benefit of customers. As of December 31, 2018, the Company made a segregation computation related to Section 4d(2) and was required to maintain a balance of $2,953,075 in this account. The total amount segregated was $3,159,206, which consisted of segregated cash of $83,451, deposits at clearing organizations of $763,152 and funds and property related to customers’ regulated commodity balances with a fair value of $2,312,603. These assets have been segregated under the CEA and represent funds deposited by customers and funds accruing to customers as a result of trades or contracts. As of December 31, 2018, the Company made a secured computation related to Regulation 30.7 and was required to maintain a balance of $144,925. The total amount segregated was $183,146, which consisted of secured cash of $64,224, deposits at clearing organizations of $99,304, and funds and property related to customers’ regulated commodity balances with a fair value of $19,618. Both amounts have been segregated under the CEA and represent funds deposited by customers and funds accruing to customers as a result of trades or contracts. As of December 31, 2018, the Company made a customer cleared swaps computation under the CEA and was required to maintain a balance of $849,854 in this account. The total amount segregated was $999,530 which consisted of cash of $114,803, deposits at clearing organizations of $540,091, and funds and property related to customers’ cleared swaps balances with a fair value of $344,636 have been sequestered under the CEA and represent funds deposited by customers and funds accruing to customers as a result of trades. 15. Credit Risk and Financial Instruments with Off-Balance Sheet Risk In the normal course of business, the Company executes and settles securities and commodity activities with customers, non-customers, brokers and dealers, commodity exchanges and affiliates. These securities transactions are on a cash or margin basis. The Company is exposed to risk of loss on these transactions in the event the counterparty or affiliate fails to satisfy its obligations in which case the Company may be required to purchase or sell financial instruments at prevailing market prices. BNP Paribas Securities Corp. 22 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) The Company engages in various securities and commodity activities with a diverse group of domestic and foreign counterparties and affiliates. The Company’s exposure to credit risk associated with the nonperformance of these counterparties in fulfilling their contractual obligations pursuant to these activities can be directly impacted by volatile trading markets which may impair the ability of the counterparties to satisfy their obligations to the Company. In margin transactions, the Company extends credit to its affiliates, customers and non-customers, subject to various regulatory and internal margin guidelines, collateralized by cash and securities in the affiliates’, customers’ or non-customers’ accounts. In connection with these activities, the Company executes and clears affiliate, customer and non-customer transactions involving the sale of securities not yet purchased, substantially all of which are transacted on a margin basis subject to individual exchange regulations. Such transactions may expose the Company to significant off- balance sheet risk in the event margin requirements are not sufficient to fully cover losses that affiliates, customers and non-customers may incur. In the event the affiliate, customer or non- customer fails to satisfy its obligations, the Company may be required to purchase or sell financial instruments at the prevailing market prices to fulfill the affiliates’, customers’ and non- customers’ obligations. The Company seeks to control the risks associated with its affiliate, customer and non-customer activities by requiring counterparties to maintain margin collateral in compliance with various regulatory and internal guidelines. The Company monitors daily the required margin levels, and pursuant to such guidelines, requires the counterparties to deposit additional collateral or to reduce positions when necessary. In connection with securities financing activities, the Company enters into reverse repos and repos, primarily in U.S. government securities, and securities borrowing and lending arrangements which may result in significant credit exposure in the event the counterparty to the transaction is unable to fulfill its contractual obligations. In accordance with industry practice, reverse repos are generally collateralized by securities held by the Company with a fair value in excess of the customers’ or affiliates’ obligation under the contract and repos are collateralized by securities deposited by the Company with a fair value in excess of the Company’s obligation under the contract. Similarly, securities borrowed and loaned agreements are collateralized by deposits and receipts of cash. The Company attempts to minimize credit risk associated with these activities by monitoring customer credit exposure and collateral values on a daily basis and requiring additional collateral to be deposited with or returned to the Company when deemed necessary. Securities sold, but not yet purchased represent obligations of the Company to deliver the specified securities or underlying security at the contracted price, and thereby, create a liability to repurchase them in the market at prevailing prices. Accordingly, these transactions result in off- balance-sheet risk as the Company’s repurchase of such securities may exceed the amount recognized in the Company’s Statement of Financial Condition. The Company has entered into an irrevocable guarantee with BNPP for payment and performance of guaranteed obligations of BNPPSC (see Note 12). 16. Fair Value Disclosures Due to the nature of its operations, substantially all of the Company’s assets are comprised of cash and securities deposited with clearing organizations or segregated under regulations, reverse repos, securities borrowed, securities failed to deliver, receivables from customers, brokers, dealers, and clearing organizations, securities owned and U.S. agency securities TBA. Securities BNP Paribas Securities Corp. 23 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) deposited with clearing organizations or segregated under federal regulations, securities owned, and U.S. agency securities TBA are carried at fair value based on the fair value hierarchy described. All remaining assets are short-term in nature and the carrying amounts are a reasonable estimate of fair value. Similarly, substantially all of the Company’s liabilities arise from repos, securities loaned, securities failed to receive, payables to customers, brokers, dealers, and clearing organizations, securities sold, not yet purchased and U.S. agency securities TBA. Securities sold, not yet purchased, and U.S. agency securities TBA are carried at fair value based on the fair value hierarchy described below. All remaining liabilities are short-term in nature and the carrying amounts are a reasonable estimate of fair value. Due to the variable rate of interest charged on its subordinated loans the carrying value approximates the estimated fair value. Assets and liabilities measured at fair value on a recurring basis are disclosed in the table below. Level 1 – Assets and liabilities utilizing Level 1 inputs include U.S. Government and agencies securities, Listed equity options, Equities and convertibles, TBA contracts and Extended settlement contracts. Level 1 inputs are unadjusted quoted prices in active markets for assets or liabilities identical to those to be reported at fair value. Level 2 – Assets and liabilities utilizing Level 2 inputs include U.S. Government and agencies securities, Corporate debt securities, Equities and convertibles and asset-backed securities, TBA contracts and Extended settlement contracts. Level 2 inputs are inputs other than quoted prices within Level 1 inputs that are observable either directly or indirectly. The Company uses prices of comparable securities in determining the fair value of Level 2 securities. Observable inputs other than quoted prices for the asset or liability (e.g. interest rates and yield curves observable at commonly quoted intervals, volatilities, prepayment speeds, loss severities, credit risks, and default rates). Level 3 – During 2018, the Company had no activity in Level 3 assets. As of December 31, 2018, the Company has no assets or liabilities measured under Level 3 of the hierarchy. During 2018, there were no transfers between levels of the fair value hierarchy for any assets or liabilities. BNP Paribas Securities Corp. 24 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) The carrying values of certain financial assets and liabilities that are not carried at fair value on the Statement of Financial Condition are carried at amounts that approximate fair value due to their short-term nature and generally negligible credit risk. Level 1 Level 2 Level 3 Netting and collateral Total Securities segregated under regulations - at fair value U.S. Government securities 1,538,981$ -$ -$ -$ 1,538,981$ Money Market Fund 50,000 - - - 50,000 Financial instruments owned - at fair value U.S. Government and agencies securities 2,936,305 5,944,357 - - 8,880,662 Asset-backed securities - 730,992 - - 730,992 Equities and convertibles 83,397 1,206 - - 84,603 Listed equity options 4,796 - - - 4,796 Corporate debt securities - 4,542 - - 4,542 U.S. agency securities TBA 456,817 - - (353,918) 102,899 Extended settlement receivables 1,363 1,478 - (780) 2,061 Securities received as collateral - at fair value Equities 136,080 - - - 136,080 Other assets Excess rights 528 - - - 528 Investments in Mutual Funds 8,831 - - - 8,831 5,217,098$ 6,682,575$ -$ (354,698)$ 11,544,975$ Level 1 Level 2 Level 3 Netting and collateral Total Financial instruments sold, not yet purchased - at fair value U.S. Government and agencies securities 1,324,615$ -$ -$ -$ 1,324,615$ Equities 29,360 - - - 29,360 Listed equity options 3,704 - - - 3,704 Corporate debt securities - 101 - - 101 U.S. agency securities TBA 485,188 - - (418,348) 66,840 Extended settlement payables 1,289 260 - (780) 769 Obligation to return securities received as collateral - at fair value Equities 136,080 - - - 136,080 Accrued expenses & other liabilities Payables to Employees 8,642 - - - 8,642 1,988,878$ 361$ -$ (419,128)$ 1,570,111$ Assets Measured at Fair Value on a Recurring Basis as of December 31, 2018 Liabilities Measured at Fair Value on a Recurring Basis as of December 31, 2018 BNP Paribas Securities Corp. 25 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) 17. Derivative Instruments The derivative balances represent future commitments to exchange payment streams based on notional amounts or to purchase or sell other financial instruments at specific terms on a specific date. The Company enters into trading derivatives contracts to satisfy the needs of its clients, for trading purposes and to manage the Company’s exposure to market and credit risks resulting from its trading and market making activities. Derivative financial instruments used for trading purposes, including economic hedges of trading instruments, are carried at fair value. Fair values for exchange-traded derivatives, principally futures and equity options, are based on quoted market prices. Open equity in futures transactions are recorded as receivables from and payables to broker- dealers and clearing organizations, as applicable. Premiums and unrealized gains and losses for equity option contracts are recognized gross in the Statement of Financial Condition. The unrealized gains for TBA and extended settlement securities are recorded in the Statement of Financial Condition net of unrealized losses by counterparty where master netting agreements are in place. Carrying Value Level 1 Level 2 Level 3 Total Estimated Fair Value Cash and cash equivalents 176,234$ 176,234$ -$ -$ 176,234$ Cash segregated under regulations 264,904 264,904 - - 264,904 Securities purchased under agreements to resell 1,120,336 - 1,120,336 - 1,120,336 Receivable from brokers, dealers and clearing organizations 5,588,956 - 5,588,956 - 5,588,956 Securities borrowed 9,143,965 - 9,143,965 - 9,143,965 Receivable from customers 1,251,004 - 1,251,004 - 1,251,004 Other Assets DTC/Exchange Membership 5,970 - 10,630 - 10,630 17,551,369$ 441,138$ 17,114,891$ -$ 17,556,029$ Carrying Value Level 1 Level 2 Level 3 Total Estimated Fair Value Short-term borrowings 1,584,197$ -$ 1,584,197$ -$ 1,584,197$ Securities sold under agreements to repurchase 7,862,565 - 7,862,565 - 7,862,565 Payable to customers 5,640,446 - 5,640,446 - 5,640,446 Payable to brokers, dealers and clearing organizations 3,987,221 - 3,987,221 - 3,987,221 Securities loaned 5,380,595 - 5,380,595 - 5,380,595 Liabilities subordinated to the claims of general creditors 1,855,000 - 1,855,000 - 1,855,000 26,310,024$ -$ 26,310,024$ -$ 26,310,024$ Assets Not Measured at Fair Value as of December 31, 2018 Liabilities Not Measured at Fair Value as of December 31, 2018 BNP Paribas Securities Corp. 26 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) The following table sets out the fair value and the notional value of the Company’s derivative contracts by major product type as of December 31, 2018: The contractual or notional amounts related to these financial instruments are presented gross by transaction which reflect the volume and activity and generally do not reflect the amounts at risk. TBAs and extended settlement are reported on a net-by-counterparty basis (i.e., the net payable or receivable for derivative assets and liabilities for a given counterparty) when a legal right of setoff exists under an enforceable netting agreement (counterparty netting). For TBAs, the Company receives or posts cash collateral which mitigate counterparty credit risk. Derivatives are accounted for at fair value, net of cash collateral received or posted under enforceable netting agreements (cash collateral netting). Where amounts that are not subject to enforceable netting agreements and are not eligible for netting, those derivative receivables and payables are shown separately in the following table: Derivative Assets Derivative Liabilities Notional Listed equity options 4,796$ 3,704$ 100,044$ U.S. agency securities TBA 456,817 485,188 102,790,759 Extended settlement receivables/ payables 2,840 1,549 14,888,831 Futures - - 145 464,453 490,441 Counterparty netting within product category (354,698) (419,128) 109,755$ 71,313$ Total included in Financial instruments owned/sold, not yet purchased - at fair value Gross Amounts Amounts Offset (a) Net Amounts Presented in the Statement of Financial Condition Financial Collateral (b) Net Amount Amounts Not Subject to Enforceable Netting Agreements Statement of Financial Condition Total Derivative Assets 451,646$ (354,698)$ 96,949$ 389$ 96,560$ 12,808$ 109,756$ Derivative Liabilities 449,220 (419,084)30,136 5,010 25,126 41,177 71,313 Amounts Subject to Enforceable Netting Arrangements (b) Collateral is reflected at its fair value, but has been limited to the net exposure in the Statement of Financial Condition so as not to include any over-collateralization. Includes financial instrument collateral related to arrangements subject to an enforceable master netting agreement (a) Derivative receivable netting included cash collateral of $18,050 and derivative payable netting included cash collateral of $82,436 Related Amounts Not offset Effects of Offsetting on Statement of Financial Condition BNP Paribas Securities Corp. 27 (An indirectly wholly owned subsidiary of BNP PARIBAS) Notes to Statement of Financial Condition As of December 31, 2018 (in thousands, except for share amounts) In addition to the cash collateral received and transferred that is presented on a net basis with net derivative receivables and payables, the Company receives and transfers additional collateral (financial instruments and cash). These amounts mitigate counterparty credit risk associated with TBAs but are not eligible for net presentation, because (a) the collateral consists of non-cash financial instruments (generally U.S. government and agency securities) and, (b) the amount of collateral held or transferred exceeds the fair value exposure at the individual counterparty level, as of the date presented. 18. Subsequent Events Management performed an evaluation of subsequent events through February 28, 2019. There have been no material subsequent events that occurred during this period that would require disclosure or adjustment to these financial statements. ******* BANK OF THE WEST Securities Delivery Instructions Member FDIC 1 REVISED AS OF 12/14/10 TAX I.D. 94-0475440 The following are Bank of the West Security Transfer and Delivery Instructions: Government Securities settled via the Federal Reserve Book Entry System: Broker Dealer Account: BANK OF THE WEST/CUST (1020) ABA: 121100782 Depository Trust Company (DTC): Participant Number 901 Agent I.D. Number 26500 Institutional I.D. Number 26662 Ref: Bank of the West Broker Dealer Acct: 017683 EURO CLEAR ACCT 017683 MSRB Acct: 140060 WIRE INSTRUCTIONS: BANK OF THE WEST ABA: 121100782 ACCT: 148635-041 ATTN: Treasury Operations Unit Participant Trust Company (PTC) Book Entry: Broker Dealer Account: BYORK/017683/BK OF THE WEST Physical Issues (OTW): The Bank of New York One Wall Street – 3rd Floor Window A Broker Dealer Acct: 017683/BK OF THE WEST BANK OF THE WEST Securities Delivery Instructions Member FDIC 2 Physical Clearing: Participant 901 Customer Deposits by Mail (Securities only) Via First Class Mail (Registered, Certified & Postal Express): The Bank of New York P.O. Box 555 Bowling Green Station New York, NY 10286 Attn: Free Receive Dept. (OWS-3) Euro Dollar Deposits: Cayman Islands Branch Wire to: BANK OF THE WEST ABA 121100782 BNF: Paragon/AC-148635041 Ref: Cayman Islands Deposit Treasury Operations Contacts: Vicky Chan – (925) 843-8448 Broker Dealer (SKPG) Settlements Gina Picazo – (925) 843-8475 Broker Dealer (SKPG) Settlements Natalie Osaki – (925) 843-8457 Back-up to Portfolio / Broker Dealer Settlements Noeline Oh – (925) 843-8447 Supervisor (SKPG & PORTFOLIO) Miguel Nicolau – (925) 843-8445 Ops Mgr Bill Goodeill – (925) 843-8761 Ops Mgr, Sr. Capital Markets ©2010 Bank of the West. Member FDIC. Fixed Income Innovative Solutions. Personalized Service. SCHEDULE OF FEES SERVICE CHARGES: U.S. TREASURY SECURITIES PURCHASED AT AUCTION $100.00 SAFEKEEPING FEES: Securities Purchased or Sold with BOTW/BNPP $0.00 Securities not Purchased or Sold with BOTW/BNPP: Custody In ‐ U.S Treasury Securities, Federal Agency Securities, $100.00 Corporate Bonds, Tax‐Free Bonds, Mortgage Backed Securities $100.00 Custody Out ‐ U.S Treasury Securities, Federal Agency Securities, $100.00 Corporate Bonds, Tax‐Free Bonds, Mortgage Backed Securities $100.00 OTHER CHARGES: Accounts inactive over one year ‐ annual charge $100.00 Cashier's check or wire $35.00 Pledging or pledging of securities $100.00 Records research ‐ per hour (minimum 1 hour)$100.00 Out of cycle statement $30.00 Payment fee for monthly or quarterly payments $6.00 Adjustable coupon rate changes $6.00 Dividend payments $6.00 Any services not listed As quoted BrokerCheck ReportBNP PARIBAS SECURITIES CORP.Section TitleReport SummaryFirm HistoryCRD# 1579419Firm Profile 2 - 8Page(s)Firm Operations 10 - 46Disclosure Events 47 About BrokerCheck®BrokerCheck offers information on all current, and many former, registered securities brokers, and all current and formerregistered securities firms. FINRA strongly encourages investors to use BrokerCheck to check the background ofsecurities brokers and brokerage firms before deciding to conduct, or continue to conduct, business with them.āWhat is included in a BrokerCheck report?āBrokerCheck reports for individual brokers include information such as employment history, professionalqualifications, disciplinary actions, criminal convictions, civil judgments and arbitration awards. BrokerCheckreports for brokerage firms include information on a firm’s profile, history, and operations, as well as many of thesame disclosure events mentioned above.āPlease note that the information contained in a BrokerCheck report may include pending actions orallegations that may be contested, unresolved or unproven. In the end, these actions or allegations may beresolved in favor of the broker or brokerage firm, or concluded through a negotiated settlement with noadmission or finding of wrongdoing.āWhere did this information come from?āThe information contained in BrokerCheck comes from FINRA’s Central Registration Depository, orCRD® and is a combination of:Rinformation FINRA and/or the Securities and Exchange Commission (SEC) require brokers andbrokerage firms to submit as part of the registration and licensing process, andRinformation that regulators report regarding disciplinary actions or allegations against firms or brokers.āHow current is this information?āGenerally, active brokerage firms and brokers are required to update their professional and disciplinaryinformation in CRD within 30 days. Under most circumstances, information reported by brokerage firms, brokersand regulators is available in BrokerCheck the next business day.āWhat if I want to check the background of an investment adviser firm or investment adviserrepresentative?āTo check the background of an investment adviser firm or representative, you can search for the firm orindividual in BrokerCheck. If your search is successful, click on the link provided to view the available licensingand registration information in the SEC's Investment Adviser Public Disclosure (IAPD) website athttps://www.adviserinfo.sec.gov. In the alternative, you may search the IAPD website directly or contact yourstate securities regulator at http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/P455414.āAre there other resources I can use to check the background of investment professionals?āFINRA recommends that you learn as much as possible about an investment professional beforedeciding to work with them. Your state securities regulator can help you research brokers and investment adviserrepresentatives doing business in your state.āThank you for using FINRA BrokerCheck.For more information aboutFINRA, visit www.finra.org.Using this site/information meansthat you accept the FINRABrokerCheck Terms andConditions. A complete list ofTerms and Conditions can befound atFor additional information aboutthe contents of this report, pleaserefer to the User Guidance orwww.finra.org/brokercheck. Itprovides a glossary of terms and alist of frequently asked questions,as well as additional resources.brokercheck.finra.org BNP PARIBAS SECURITIES CORP.CRD# 15794SEC# 8-32682Main Office Location787 SEVENTH AVENUENEW YORK, NY 10019Regulated by FINRA New York OfficeMailing Address525 WASHINGTON BOULEVARDJERSEY CITY, NJ 07310Business Telephone Number212.841.2000Report Summary for this FirmThis report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.Disclosure EventsBrokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.Are there events disclosed about this firm?YesThe following types of disclosures have beenreported:TypeCountRegulatory Event 54Arbitration 1Bond 1Firm ProfileThis firm is classified as a corporation.This firm was formed in Delaware on 09/07/1984.Its fiscal year ends in December.Firm HistoryInformation relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.Firm OperationsIs this brokerage firm currently suspended with anyregulator?NoThis firm conducts 14 types of businesses.This firm is affiliated with financial or investmentinstitutions.This firm does not have referral or financialarrangements with other brokers or dealers.This firm is registered with:• the SEC• 18 Self-Regulatory Organizations• 52 U.S. states and territorieswww.finra.org/brokercheckUser Guidance1©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceThis firm is classified as a corporation.This firm was formed in Delaware on 09/07/1984.CRD#This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.Firm ProfileFirm Names and LocationsIts fiscal year ends in December.BNP PARIBAS SECURITIES CORP.SEC#157948-32682Main Office LocationMailing AddressBusiness Telephone NumberDoing business as BNP PARIBAS SECURITIES CORP.212.841.2000Regulated by FINRA New York Office787 SEVENTH AVENUENEW YORK, NY 10019525 WASHINGTON BOULEVARDJERSEY CITY, NJ 073102©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceThis section provides information relating to all direct owners and executive officers of the brokerage firm.Direct Owners and Executive OfficersFirm ProfilePositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?BNP PARIBAS US WHOLESALE HOLDINGS, CORPOWNER75% or moreNoDomestic Entity12/1984YesIs this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):PositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?ALTER, ANDREW WILLIAMGENERAL COUNSEL AND SECRETARYLess than 5%NoIndividual10/2008No4183449Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):PositionPosition Start DateDE LAMBILLY, HUBERT CHARLESCHIEF EXECUTIVE OFFICERIndividual10/20186948081Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):3©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceDirect Owners and Executive Officers (continued)Firm ProfilePercentage of OwnershipIs this a public reportingcompany?Does this owner direct themanagement or policies ofthe firm?Less than 5%NoYesPositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?FARRELL, MICHAEL FCHIEF FINANCIAL OFFICER, FINOPLess than 5%NoIndividual12/2017No2562352Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):PositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?HAWLEY, ROBERT WILLIAM JRCHAIRMANLess than 5%NoIndividual09/2017Yes828024Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):HAWLEY, ROBERT WILLIAM JRLegal Name & CRD# (if any):4©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceDirect Owners and Executive Officers (continued)Firm ProfilePositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?DIRECTORLess than 5%NoIndividual04/2014Yes828024Is this a domestic or foreignentity or an individual?PositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?LIST, LAWRENCE HARRISCHIEF CONDUCT AND CONTROL OFFICERLess than 5%NoIndividual04/2019Yes2713411Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):PositionPercentage of OwnershipPosition Start DateMARTINO, MICHAEL BENEDICTCHIEF OPERATIONS OFFICERLess than 5%Individual09/20174420944Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):5©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceDirect Owners and Executive Officers (continued)Firm ProfileIs this a public reportingcompany?Does this owner direct themanagement or policies ofthe firm?NoNoPositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?NUNN, GEORGE ALVAROCHIEF OPERATING OFFICERLess than 5%NoIndividual04/2019Yes2405499Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):PositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?PLENTY, LLOYD SAMUELDIRECTORLess than 5%NoIndividual06/2018Yes4679805Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):RICARD, PHILIPPE RAYMOND6986968Legal Name & CRD# (if any):6©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceDirect Owners and Executive Officers (continued)Firm ProfilePositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?DIRECTORLess than 5%NoIndividual06/2018YesIs this a domestic or foreignentity or an individual?PositionPercentage of OwnershipIs this a public reportingcompany?Position Start DateDoes this owner direct themanagement or policies ofthe firm?WYNN, HOWARD MCHIEF COMPLIANCE OFFICERLess than 5%NoIndividual12/2016No5836243Is this a domestic or foreignentity or an individual?Legal Name & CRD# (if any):7©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceThis section provides information relating to any indirect owners of the brokerage firm.Indirect OwnersFirm ProfileBNP PARIBASSHAREHOLDERBNP PARIBAS USA, INC.75% or moreNoForeign Entity05/2000YesLegal Name & CRD# (if any):Is this a domestic or foreignentity or an individual?Company through whichindirect ownership isestablishedRelationship to Direct OwnerRelationship EstablishedPercentage of OwnershipDoes this owner direct themanagement or policies ofthe firm?Is this a public reportingcompany?BNP PARIBAS USA, INC.SHAREHOLDERBNP PARIBAS US WHOLESALE HOLDINGS, CORP75% or moreNoDomestic Entity12/1984YesLegal Name & CRD# (if any):Is this a domestic or foreignentity or an individual?Company through whichindirect ownership isestablishedRelationship to Direct OwnerRelationship EstablishedPercentage of OwnershipDoes this owner direct themanagement or policies ofthe firm?Is this a public reportingcompany?8©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm HistoryThis section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.No information reported.9©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsRegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.This firm is currently registered with the SEC, 18 SROs and 52 U.S. states and territories.SEC Registration QuestionsThis firm is registered with the SEC as:A broker-dealer:A broker-dealer and government securities broker or dealer:A government securities broker or dealer only:This firm has ceased activity as a government securities broker or dealer:YesYesNoNoFederal Regulator Status Date EffectiveSEC Approved 10/11/1984Self-Regulatory Organization Status Date EffectiveFINRA Approved 12/27/1984BOX Exchange LLC Approved 05/07/2012Cboe BYX Exchange, Inc. Approved 09/15/2010Cboe BZX Exchange, Inc. Approved 08/18/2008Cboe C2 Exchange, Inc. Approved 10/15/2010Cboe EDGA Exchange, Inc. Approved 05/25/2010Cboe EDGX Exchange, Inc. Approved 05/27/2010Cboe Exchange, Inc. Approved 05/13/1997Miami International Securities Exchange,LLCApproved 04/21/2014NYSE American LLC Approved 01/03/2005NYSE Arca, Inc. Approved 12/15/2004NYSE Chicago, Inc. Approved 05/11/2006Nasdaq BX, Inc. Approved 01/12/2009Nasdaq GEMX, LLC Approved 02/24/2014Nasdaq ISE, LLC Approved 11/13/200110©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceNasdaq PHLX LLC Approved 12/02/2008Nasdaq Stock Market Approved 07/12/2006New York Stock Exchange Approved 01/03/200511©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsRegistrations (continued)U.S. States &TerritoriesStatus Date EffectiveAlabama Approved 09/20/2004Alaska Approved 02/23/2004Arizona Approved 05/21/2004Arkansas Approved 08/06/2004California Approved 12/02/1997Colorado Approved 03/16/1989Connecticut Approved 07/02/2004Delaware Approved 03/11/1988District of Columbia Approved 07/30/1986Florida Approved 07/26/1988Georgia Approved 08/25/2004Hawaii Approved 03/29/2004Idaho Approved 02/18/2004Illinois Approved 03/31/1986Indiana Approved 03/01/2004Iowa Approved 04/16/2004Kansas Approved 03/11/2004Kentucky Approved 02/23/2004Louisiana Approved 09/08/2004Maine Approved 09/22/2004Maryland Approved 05/05/2004Massachusetts Approved 05/13/1988Michigan Approved 04/01/1986Minnesota Approved 02/18/2004Mississippi Approved 02/24/2004Missouri Approved 06/30/2004Montana Approved 02/26/2004Nebraska Approved 08/17/2004Nevada Approved 02/19/2004New Hampshire Approved 09/10/2004New Jersey Approved 06/16/2004New Mexico Approved 08/19/2004New York Approved 04/02/1985U.S. States &TerritoriesStatusDate EffectiveNorth Carolina Approved 02/18/2004North Dakota Approved 05/25/2004Ohio Approved 05/19/1998Oklahoma Approved 02/18/2004Oregon Approved 03/10/2004Pennsylvania Approved 08/05/1986Puerto Rico Approved 08/20/2004Rhode Island Approved 05/19/2004South Carolina Approved 04/01/2004South Dakota Approved 02/17/2004Tennessee Approved 07/02/1986Texas Approved 01/06/1999Utah Approved 02/13/2004Vermont Approved 08/13/2004Virginia Approved 02/13/2004Washington Approved 08/11/1986West Virginia Approved 02/17/2004Wisconsin Approved 09/30/2004Wyoming Approved 03/24/200412©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsTypes of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.Other Types of BusinessThis firm does effect transactions in commodities, commodity futures, or commodity options.This firm does engage in other non-securities business.Non-Securities Business Description:FOR THE ACCOUNT OF PARIBAS AND ITS AFFILIATES, REGISTRANTARRANGES TRANSACTIONS IN A BROAD RANGE OF DERIVATIVEINSTRUMENTS WHICH INCLUDES BUT IS NOT LIMITED TO (1)CREDITDERIVATIVES, (2) CURRENCY & INTEREST RATE SWAPS, (3) EMERGINGMARKET LOANS AND OTHER INSTRUMENTS, AND BANK ASSETS ANDSYNDICATED LOAN POSITIONS.BNP PARIBAS IS AN "FCM" FUTURES COMMISION MERCHANT.This firm currently conducts 14 types of businesses.Types of BusinessExchange member engaged in exchange commission business other than floor activitiesBroker or dealer making inter-dealer markets in corporation securities over-the-counterBroker or dealer retailing corporate equity securities over-the-counterBroker or dealer selling corporate debt securitiesUnderwriter or selling group participant (corporate securities other than mutual funds)U S. government securities dealerU S. government securities brokerMunicipal securities dealerPut and call broker or dealer or option writerBroker or dealer selling tax shelters or limited partnerships in primary distributionsBroker or dealer selling tax shelters or limited partnerships in the secondary marketTrading securities for own accountPrivate placements of securitiesOther - FUTURES COMMISSION MERCHANT ("FCM")13©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsClearing ArrangementsThis firm does hold or maintain funds or securities or provide clearing services for other broker-dealer(s).Introducing ArrangementsThis firm does not refer or introduce customers to other brokers and dealers.14©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsIndustry ArrangementsThis firm does have books or records maintained by a third party.Name:UNITED INFORMATION SERVICES, INC (AN EXELA TECHNOLOGIESCOMPANY)Business Address:2701 E. GRAUWYLER ROADIRVING, TX 75061Effective Date:09/01/2018Description:PROVIDES WORM STORAGE AND ACTS AS THIRD PARTY PROVIDER TOSTORE ELECTRONIC RECORDS.Name:FIS EPROCESS INTELLIGENCE LLCBusiness Address:70 SOUTH ORANGE AVELIVINGSTON, NJ 07039Effective Date:12/23/2003Description:PROVIDES STORQM PLUS SOFTWARE AND ACTS AS THIRD PARTYPROVIDER TO STORE ELECTRONIC RECORDS. SUNGARD EPROCESSINTELLIGENCE INC.(NAME CHANGED TO FIS EPROCESS INTELLIGENCELLC)Name:BROADRIDGE INVESTOR COMMUNICATIONS SOLUTIONS, INC.Business Address:1155 LONG ISLAND AVENUEEDGEWOOD, NY 11717Effective Date:01/16/2001Description:THIRD PARTY ELECTRONIC STORAGE - PROXY RELATED RECORDS.RECONCILIATION REVEALED SERVICE SINCE 1/16/2001.GATEWAY ONLY GOESS BACK TO 2003.Name:MICRO FOCUS INTERNATIONAL PLCBusiness Address:ONE MARKET PLAZASPEAR TOWER, 19TH FLOORSAN FRANCISCO, CA 94105Effective Date:09/24/2012Description:THIRD PARTY ELECTRONIC STORAGE - HEWLETT PACKARDENTERPRISE (NAME CHANGED TO MICRO FOCUS INTERNATIONAL PLC)- AUTONOMY(NAME CHANGED TO HEWLETT PACKARD ENTERPRISE) E-MAIL APPLICATION BECAME THE RECORD AND REPLACEDASSENTOR/CAMM ON 9/24/201215©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsIndustry Arrangements (continued)This firm does not have accounts, funds, or securities maintained by a third party.This firm does not 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.This firm does not have individuals who wholly or partly finance the firm's business.Control Persons/FinancingName:PATRINA CORPORATIONBusiness Address:2 WALL STREETNEW YORK, NY 10005Effective Date:08/06/2012Description:ACTS AS THIRD PARTY PROVIDER TO ACCESS AND DOWNLOADELECTRONICALLY STORED RECORDS.Name:OMGEOBusiness Address:55 WATER STREETNEW YORK, NY 10041Effective Date:12/02/2010Description:OMGEO IS ACTING AS A THIRD PARTY RECORD KEEPER FORTRADESUITE CONFIRMATIONS.Name:IRON MOUNTAINBusiness Address:317 MADISON AVENUESUITE 900NEW YORK, NY 10017Effective Date:02/17/1999Description:1. MAINTAINS STORAGE OF PHYSICAL RECORDS.2. ACTS AS THIRD PARTY PROVIDER TO ACCESS AND DOWNLOADELECTRONICALLY STORED RECORDS.Name:NOVA RECORDS, LLCBusiness Address:9 EMPIRE BLVD.S. HACKENSACK, NJ 07606Effective Date:08/01/2008Description:MAINTAINS STORAGE FOR ARCHIVED PAPER RECORDS.16©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.This firm is, directly or indirectly:· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.YesNoCANADAYes08/23/20111155 RUE METCALFE2ND FLOORMONTREAL, CANADA H3B 5G2150564INNOCAP INVESTMENT MANAGEMENT INC. is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:CRD #:NoYesCAYMAN ISLANDSYes10/01/2008ROYAL BANK HOUSE, 3RD FLOORP.O. BOX 10632GEORGE TOWN, GRAND CAYMAN, CAYMAN ISLANDS KY1-1006BNP PARIBAS PRIME BROKERAGE INTERNATIONAL is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:BNP PARIBAS (CANADA) VALEURS MOBILIERES INC. is under common control with the firm.17©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesCANADAYes03/02/20061981 MCGILL COLLEGE AVENUESUITE 300MONTREAL, QC, CANADA H3A2W8INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesUKYes04/08/200420 ST. JAMES'S STREETLONDON, ENGLAND SW1A 1ESEXANE LIMITED is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesFRANCEYes04/08/200416, AVENUE MATIGNONPARIS, FRANCE 75008EXANE is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:18©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)YesNoENGLANDYes01/07/2008MEZZANINE FLOOR PEGASUS HOUSE37-43 SACKVILLE STREETLONDON, ENGLAND W1S 3 EHIMPAX ASSET MANAGEMENT GROUP, PLC is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBAS.Description:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:YesNoNo02/17/2000FIRST HAWAIIAN CENTER999 BISHOP STREET, SUITE 2806HONOLULU, HI 96813BISHOP STREET CAPITAL MANAGMENT CORPORATION is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBAS.Description:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:YesNoNo08/31/1999200 PARK AVENUE46TH FLOORNEW YORK, NY 10166FISCHER FRANCIS TREES & WATTS, INC. is under common control with the firm.Investment AdvisorySecurities Activities:Country:Foreign Entity:Effective Date:Business Address:19©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Activities:YesNoSINGAPOREYes08/31/199950 RAFFLES PLACE #22-01SINGAPORE LAND TOWERSINGAPORE, SINGAPORE 048623FISCHER FRANCIS TREES & WATTS SINGAPORE PTE LTD. is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:YesNoJAPANYes08/31/1999FUKOKU SEIMEI BUILDING 21 F,2-2, UCHISAIWAICHO 2 CHOMETOKYO, JAPAN 100FISCHER FRANCIS TREES & WATTS KABUSHIKI KAISHA is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:UKYes08/31/19992 ROYAL EXCHANGELONDON, UK EC3V 3RAFISCHER FRANCIS TREES & WATTS is under common control with the firm.Country:Foreign Entity:Effective Date:Business Address:20©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)YesNoINDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:NoYesTUNISIAYes12/09/20043 RUE JENNERPLACE D'AFRIQUETUNIS BELVEDERE, TUNISIA 1002UNION DE GESTION FINANCIERE is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesTUNISIAYes12/09/2004139 AE DE LA LIBERTETUNIS, TUNISIA 1002UNION BANCAIRE POUR LE COMMERCE ET I'INDUS. is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:12/09/2004PLAZA BAPINDO-BANK MANDIRI TOWER, 16TH FLOORJL. JENDRAL SUDIRMAN KAV. 54-55JAKARTA, INDONESIAPT BNP PARIBAS PEREGRINE is under common control with the firm.Effective Date:Business Address:21©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesINDONESIAYesINDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:NoYesINDONESIAYes12/09/2004MENARA BATAVIA, 20TH FLOORJL K H MAS MANSYUR KAV 126JAKARTA, INDONESIA 10220PT BANK BNP PARIBAS INDONESIA is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesLUXEMBOURGYes12/09/20045 RUE JEAN TONNETL-2952 LUXEMBOURGGRAND DUCH OF LUXEMBOURG, LUXEMBOURGEUROPHENIX MANAGEMENT COMPANY SA is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:ROOM 4901 JINMAO TOWERCHANGJIANG BNPP PEREGRINE SECURITIES is under common control with the firm.Business Address:22©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesCHINAYes12/09/2004PUDONGSHANGHAI, CHINA 200121INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:NoYesFRANCEYes12/09/200467 JULIETTE DODUSAINT DENIS, FRANCE 97400BNP PARIBAS REUNION is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesSWITZERLANDYes12/09/20042 PLACE DE HOLLANDEGENEVA, SWITZERLAND CH-1204BNP PARIBAS PRIVATE BANK SWITZERLAND is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:BNP PARIBAS PRIVATE BANK is under common control with the firm.23©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesFRANCEYes12/09/200410 BOULEVARD MALESHERBESPARIS, FRANCE 75008INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesSINGAPOREYes12/09/200420 COLLYER QUAY#08-01 TUNG CENTRE,SINGAPORE, SINGAPORE 049319BNP PARIBAS PEREGRINE SECURITIES PTE LTD is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesKOREAYes12/09/20047/F ORIENTAL CHEMICAL BUILDING, 50SO-KONG-DONG, CHOONG-KUSEOUL, KOREA 100D18BNP PARIBAS PEREGRINE SECURITIES KOREA CO. is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:24©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesPHILLIPINESYes12/09/200430/F PHILAM LIFE TOWER8767 PASEO DE ROXASMAKATA CITY, PHILLIPINESBNP PARIBAS PEREGRINE SECURITIES INC. is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesMALAYSIAYes12/09/2004VISTA TOWER, LEVEL 48CTHE INTERMARK, 348 JALAN TUN RAZAK,KUALA LUMPUR, MALAYSIA 50400BNP PARIBAS CAPITAL (MALAYSIA) SDN BHD is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:YesHONG KONGYes12/09/200436/F ASIA PACIFIC TOWERCITIBANK P3 GARDEN ROADHONG KONG, HONG KONGBNP PARIBAS PEREGRINE FUTURES LIMITED is under common control with the firm.Securities Activities:Country:Foreign Entity:Effective Date:Business Address:25©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoINDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:NoYesHUNGARYYes12/09/2004H-1055 BUDAPEST,HONVED U. 20REPUBLIC OF HUNGARY, HUNGARYBNP PARIBAS HUNGARIA BANK RT is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesHONG KONGYes12/09/200435/F, ASIA PACIFIC FINANCE TOWER3 GARDEN ROADCENTRAL, HONG KONGBNP PARIBAS FUTURES (HONG-KONG) LIMITED is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:Yes12/09/20043 RUE D'ANTINPARIS CEDEX 02, FRANCE 75078BNP PARIBAS EQUITY STRATEGIES is under common control with the firm.Foreign Entity:Effective Date:Business Address:26©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesFRANCEINDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:NoYesPOLANDYes12/09/2004UL ZIELNA 41/43WARSZAWA(WARSAW), POLSKA (POLAND) 00-108BNP PARIBAS BANK POLSKA SA is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesTHE NETHERLANDSYes12/09/2004HERENGRACHT 477AMSTERDAM, THE NETHERLANDS 1017 BSBNP PARIBAS BANK NV is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:Yes12/09/2004HERENGRACHT 477AMSTERDAM, THE NETHERLANDS 1017 BSBNP PARIBAS ARBITRAGE ISSUANCE B.V. is under common control with the firm.Foreign Entity:Effective Date:Business Address:27©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesTHE NETHERLANDSINDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:NoYesFRANCEYes12/09/20043 RUE D'ANTINPARIS CEDEX 02, FRANCE 75078BNP PARIBAS controls the firm.INDIRECTLY OWNS APPLICANTSDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesFRANCEYes12/09/200441 AVENUE DE L'OPERAPARIS, FRANCE 75002BNP PAM EUROPE is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:12/09/2004KURFIRSTENDAMM RR9BERLIN, GERMANY D-R07RRBERLINER FREIVERKEHR (AKTIEN) AG is under common control with the firm.Effective Date:Business Address:28©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesGERMANYYesINDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:NoYesBRAZILYes12/09/2004AV. JUSCELINO KUBITSCHEK, 510SAO PAULO, S.P., BRAZIL 04534-000BANCO CNP PARIBAS BRASIL S/A is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:YesYesNo11/10/200413505 CALFORNIA STREETOMAHA, NE 6815429357BANCWEST INVESTMENT SERVICES, INC. is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:CRD #:41784EXANE, INC. is under common control with the firm.CRD #:29©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesNo04/13/2004527 MADISON AVENUE26TH FLOORNEW YORK, NY 10022INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesFRANCEYes05/23/20005, AVENUE KLEBERPARIS, FRANCE 75116CORTAL BANK is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesITALYYes05/23/2000PIZZA SAN FEDELE 2MILAN, ITALY 20121BNP PARIBAS EQUITIES ITALIA SIM S.P.A. is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:30©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesHONG KONGYes05/23/200059-63/F II INTERNATIONAL FINANCE CENTRE8 FINANCE STREET,CENTRAL HONG KONG, HONG KONGBNP PARIBAS SECURITIES (ASIA) LTD is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesPHILIPPINESYes05/23/200030TH FLOOR, PHILAMLIFE TOWER - 8767 PASEO DE FUXASP.O.BOX 2265 MCPO - 1262 MAKATI CITYMAKATI CITY, PHILIPPINESBNP PARIBAS INVESTMENTS (PHILIPPINES) INC. is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesSWITZERLANDYes05/23/2000PLACE DE HOLLANDE 2 - CASE POSTALE1211 GENEVA 11GENEVA, SWITZERLANDBNP PARIBAS SUISSE S.A. is under common control with the firm.Investment AdvisorySecurities Activities:Country:Foreign Entity:Effective Date:Business Address:31©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Activities:NoYesCÔTE D'IVOIREYes05/23/2000AVENUE FRANCHET D'ESPEREY01 BP 1298 ABIDIAN 01ABIDJAN, CÔTE D'IVOIREBANQUE INTERNATIONALE POUR LE COMMERCE ET L'INDUSTRIE DE LA COTE D'IVOIRE is under commoncontrol with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesMOROCCOYes05/23/200026, PLACE DES NATIONS-UNIESCASABLANCA, MOROCCOBANQUE MAROCAINE POUR LE COMMERCE ET L'INDUSTRIE is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:EAST AFRICAYes05/23/2000BP 2122 DJIBOUTIDJIBOUTI, EAST AFRICABANQUE POUR LE COMMERCE ET L'INDUSTRIE-MER ROUGE is under common control with the firm.Country:Foreign Entity:Effective Date:Business Address:32©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesINDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:NoYesCORNORO ISLANDYes05/23/2000PLACE DE FRANCE - BP 175 ET 1009MORONI/FEDERAL ISLAMIC REPUBLIC OF CORNORO ISLANDFEDERAL ISLAMIC REPUBLIC, CORNORO ISLANDBANQUE POUR L'INDUSTRIE ET LE COMMERCE-COMORES is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesMADAGASCARYes05/23/2000IMMEUBLE VOGUE PLACE DE L'INDEPENDANCEBP 25 BISANTANANARIVO 101, MADAGASCARBANQUE MALGACHE DE L'OCEAN INDIEN is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:05/23/200020, BOULVARD DES ITALIENSPARIS, FRANCE 75009BNP INTERCONTINENTALE is under common control with the firm.Effective Date:Business Address:33©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesFRANCEYesINDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:NoYesFRANCEYes05/23/200018, QUAI DUGUAY - TROUIN35084 RENNES CEDEXCEDEX, FRANCEBANQUE DE BRETAGNE is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesFRANCEYes05/23/20001 BOULEVARD HAUSSMANN,PARIS, FRANCE 75009BNP PARIBAS MARTINIQUE is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:1 BOULEVARD HAUSSMANN,PARIS, FRANCE 75009BNP PARIBAS GUADELOUPE is under common control with the firm.Business Address:34©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesFRANCEYes05/23/2000INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:NoYesFRANCEYes05/23/20002, PLACE VICTOR SCHOELCHER9 7300 CAYENNEFRENCH GUIANA, FRANCEBNP PARIBAS GUYANE is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesFRANCEYes05/23/200020 BOULEVARD DES ITALIENS,PARIS, FRANCE 75009BNP PARIBAS NOUVELLE CALADONIE is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:32, AVENUE DE L'OPERAB*CAPITAL is under common control with the firm.Business Address:35©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)YesYesFRANCEYes05/23/2000PARIS, FRANCE 75002INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBAS.Description:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:NoYesUNITED KINGDOMYes05/23/200220-21 ST. JAMES STREETLONDON, UNITED KINGDOM SW IA IESBNP PARIBAS PRIVATE BANK PLC is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesBAHAMASYes05/23/2000BEAUMONT HOUSE, 3RD FL. - BAY ST. P.O. BOX N-4883NASSAU, BAHAMASBNP PARIBAS PRIVATE BANK AND TRUST COMPANY (NASSAU) is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:BNP PARIBAS (LIECHTENSTEIN) AG is under common control with the firm.36©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesLIECHTENSTEINYes05/23/2000AUSTRASSE 27 - FL3490 VADUX - PRINCIPALITY OF LIECVADUX, LIECHTENSTEININDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesCHANNEL ISLANDSYes05/23/2000LA PLAIDERIE HOUSE/LA PLAIDERIE ST. PETER PORTGUERNSEY, CHANNEL ISLANDSBNP PARIBAS GUERNSEY LTD. is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesBAHAMASYes05/23/2000APSLEY HOUSE 75 FREDERICK STREET/P.O. BOX N-4915NASSAU, BAHAMASUEB TRUST NASSAU is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:UEB LUXEMBOURG is under common control with the firm.37©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesGERMANYYes05/23/2000AVENUE DE LA PORTE-NEUVE 29 BOITE POSTALE 830LUXEMBOURG, GERMANYINDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesSWITZERLANDYes05/23/200015-17, QUAI DES BERGUES CASE POSTALE 1211 GENEVA 1GENEVA, SWITZERLANDUEB SWITZERLAND is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesFRANCEYes05/23/200066, RUE DE VICTOIREPARIS, FRANCE 75009BNP PARIBAS SECURITIES SERVICES S.A. is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:38©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesSPAINYes05/23/2000C/HERMANOS BECQUER, 3MADRID, SPAIN 28006BNP PARIBAS ESPANA is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:YesNoFRANCEYes05/23/200043, AVENUE DE L'OPERAPARIS, FRANCE 75002PAI MANAGEMENT is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesSINGAPOREYes05/23/200080 RAFFLES PLACE, 52ND FLOORUOB PLAZA 1SINGAPORE, SINGAPORE 048624BNP PAM SINGAPORE LTD. is under common control with the firm.Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:39©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:NoYesHONG KONGYes05/23/20004-18/F, CENTRAL TOWER28 QUEEN'S ROAD CENTRALHONG KONG, HONG KONGBNP PAM MANAGEMENT ASIA LTD is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:YesNoARGENTINAYes05/23/2000AV. CORRIENTES 3111002 BUENOS AIRESBUENOS AIRES, ARGENTINABNP PAM ARGENTINA is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:ITALYYes05/23/2000PIAZZA SAN FEDELE 220121 MILANMILAN, ITALYBNP PAM SGR SPA is under common control with the firm.Country:Foreign Entity:Effective Date:Business Address:40©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)YesNoINDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:YesNoBRAZILYes05/23/2000AVE. JUSCELINO KUBITSCHEK, 51004534000 SAO PAULOSAO PAULO, BRAZILBNP PAM BRAZIL is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesFRANCEYes05/23/200013, RUE LAFAYETTE75009 PARISPARIS, FRANCEBNP PARIBAS ARBITRAGE SNC is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:05/23/200016, BOULEVARD DES ITALIENS75009PARIS, FRANCEBNP PARIBAS EQUITIES SA is under common control with the firm.Effective Date:Business Address:41©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesFRANCEYesINDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:NoYesFRANCEYes05/23/2000131, AVENUE CHARLES DE GAULLE92200 NEUILLY-SUR-SEINEPARIS, FRANCECORTAL CONSORS is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesNETHERLANDSYes08/28/19991000 AMSTERDAMAMSTERDAM, NETHERLANDSPARIBAS NEDERLANDS, B.V. is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:10 HAREWOOD AVENUELONDON, UK NW1 6AABNP PARIBAS ASIA LIMITED (UK) is under common control with the firm.Business Address:42©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)NoYesCHINAYes08/28/1999INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:NoYesJAPANYes09/07/1984GRANTOKYO NORTH TOWER,1-9-1 MARUNOUCHI, CHIYODA-KUTOKYO, JAPAN 100-6740BNP PARIBAS SECURITIES (JAPAN) LTD. is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:NoYesSWITZERLANDYes09/07/19842 PLACE DE HOLLANDECH-1204 GENEVAGENEVA, SWITZERLAND CH-1204PARIBAS (SUISSE) S.A. is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:PARIBAS ASSET MANAGEMENT JAPAN LTD is under common control with the firm.43©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)YesNoJAPANYes09/07/1984YURAKUCHO DENKI BUILDING, 14TH FLOOR NORTH1-7-1 YURNKUCHO, CHIYODA-KU,TOKYO, JAPAN 100INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:YesNoMONACOYes09/07/19846 AVENUE DE LA MADONE,MONACO, MONACO 98000PARIBAS ASSET MANAGEMENT MONACO is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:YesNoFRANCEYes09/07/198441, AVENUE DE L'OPERAPARIS, FRANCE 75002BNP PARIBAS ASSET MANAGEMENT SAS is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:44©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)YesNoNo09/07/1984200 PARK AVENUENEW YORK, NY 10166105455BNP PARIBAS ASSET MANAGEMENT USA, INC. is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:CRD #:NoYesENGLANDYes09/07/198410 HAREWOOD AVENUELONDON, ENGLAND NW1 6AABNP PARIBAS (UK) LTD. is under common control with the firm.INDIRECTLY OWNED BY APPLICANT'S INDIRECT PARENT, BNP PARIBASDescription:Investment AdvisoryActivities:Securities Activities:Country:Foreign Entity:Effective Date:Business Address:This firm is 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 bankBNP PARIBAS is a Bank Holding Company and controls the firm.45©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFirm OperationsOrganization Affiliates (continued)Effective Date:Business Address:Description:PARENT05/23/20003 RUE D'ANTINPARIS, FRANCE 7500246©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceDisclosure EventsAll firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.Final On AppealPendingRegulatory Event 1 53 0Arbitration N/A 1 N/ABond N/A 1 N/A47©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceDisclosure Event DetailsWhat you should know about reported disclosure events:1.BrokerCheck provides details for any disclosure event that was reported in CRD. It also includessummary information regarding FINRA arbitration awards in cases where the brokerage firm wasnamed as a respondent.2.Certain thresholds must be met before an event is reported to CRD, for example:RA law enforcement agency must file formal charges before a brokerage firm is required to disclose aparticular criminal event.3.Disclosure events in BrokerCheck reports come from different sources:RDisclosure 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:RA disclosure event may have a status ofpending, on appeal,orfinal.A "pending" event involves allegations that have not been proven or formally adjudicated.An event that is "on appeal" involves allegations that have been adjudicated but are currentlybeing appealed.A "final" event has been concluded and its resolution is not subject to change.RA final event generally has a disposition ofadjudicated, settledorotherwise resolved.An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter,or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.A "settled" matter generally involves an agreement by the parties to resolve the matter.Please note that firms may choose to settle customer disputes or regulatory matters forbusiness or other reasons.A "resolved" matter usually involves no payment to the customer and no finding ofwrongdoing on the part of the individual broker. Such matters generally involve customerdisputes.5.You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure events contained in this BrokerCheck report.Regulatory - FinalThis type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission,foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation orsuspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federalcontractor.Disclosure 1 of 53Reporting Source:RegulatorCurrent Status:Final48©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:NYSE ARCA, INC.Principal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:Date Initiated:09/24/2018Docket/Case Number:2015044231301Principal Product Type:No ProductOther Product Type(s):Allegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMVIOLATED NYSE ARCA EQUITIES RULES 6.18 AND 6.3.03 BY FAILING TOESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEMREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE ARCARULES AND FAILING TO PROVIDE SUFFICIENT DOCUMENTARY EVIDENCETHAT IT PERFORMED THE SUPERVISORY REVIEWS SET FORTH IN ITSWRITTEN SUPERVISORY PROCEDURES.Resolution Date:09/24/2018Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $7,500.00.Regulator StatementTHIS CASE INCLUDES PROCEEDING NOS. 20160486118, 20180585411, AND20180587885.THIS MATTER IS FINAL UPON ISSUANCE OF THIS DECISION AND THESANCTIONS ARE EFFECTIVE IMMEDIATELY.FINRA CONDUCTED THIS REVIEW ON BEHALF OF NYSE ARCA, INC.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $7,500.00Decision & Order of Offer of Settlementi49©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceReporting Source:FirmInitiated By:NYSE ARCA, INC.Principal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:Date Initiated:09/24/2018Docket/Case Number:2015044231301Principal Product Type:No ProductOther Product Type(s):Allegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS ANDTO THE ENTRY OF FINDINGS THAT THE FIRM VIOLATED NYSE ARCAEQUITIES RULES 6.18 AND6.3.03 BY FAILING TO ESTABLISH, MAINTAIN, AND ENFORCE ASUPERVISORY SYSTEM REASONABLYDESIGNED TO ACHIEVE COMPLIANCE WITH NYSE ARCA RULES ANDFAILING TO PROVIDESUFFICIENT DOCUMENTARY EVIDENCE THAT IT PERFORMED THESUPERVISORY REVIEWS SETFORTH IN ITS WRITTEN SUPERVISORY PROCEDURES.Current Status:FinalResolution Date:09/24/2018Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $7,500.00.Sanctions Ordered:CensureMonetary/Fine $7,500.00Decision & Order of Offer of SettlementDisclosure 2 of 53iReporting Source:RegulatorAllegations:THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION") HASREASON TO BELIEVE THAT BNP PARIBAS SECURITIES CORP.("RESPONDENT," "BNPP," OR THE "FIRM") HAS VIOLATED THE COMMODITYCurrent Status:Final50©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceEXCHANGE ACT (THE "ACT" OR "CEA") AND COMMISSION REGULATIONS("REGULATIONS").THE COMMISSION FINDS THE FOLLOWING BEGINNING IN OR ABOUT MAY2007 AND CONTINUING THROUGH AT LEAST AUGUST 2012 (THE "RELEVANTPERIOD"), BNPP, BY AND THROUGH CERTAIN OF ITS TRADERS,ATTEMPTED TO MANIPULATE THE U.S. DOLLAR INTERNATIONAL SWAPSAND DERIVATIVES ASSOCIATION FIX ("USD ISDAFIX" OR THE "BENCHMARK"), A LEADING GLOBAL BENCHMARK REFERENCED IN ARANGE OF INTEREST RATE PRODUCTS, TO BENEFIT BNPP'S DERIVATIVESPOSITIONS IN INSTRUMENTS SUCH AS CASH-SETTLED OPTIONS ONINTEREST RATE SWAPS AND CERTAIN EXOTIC STRUCTURED PRODUCTS.DURING THE RELEVANT PERIOD, USD ISDAFIX WAS SET EACH DAY IN APROCESS THAT BEGAN AT 11:00 A.M. EASTERN TIME WITH THE CAPTUREAND RECORDING OF SWAP RATES AND SPREADS FROM A U.S. BASEDUNIT OF A LEADING INTEREST RATE SWAPS BROKING FIRM ("SWAPSBROKER"). SWAPS BROKER DISSEMINATED RATES AND SPREADSCAPTURED IN THIS SNAPSHOT AS REFERENCES TO A PANEL OF BANKS.MOST BANKS ON THE PANEL, INCLUDING BNPP, USUALLY SUBMITTEDSWAPS BROKER'S REFERENCE RATES AND SPREADS AS CAPTURED INTHE SNAPSHOT. AS A RESULT, AFTER AN AVERAGING OF THESUBMISSIONS, THE REFERENCE RATES AND SPREADS BECAME THEPUBLISHED USD ISDAFIX ALMOST EVERY DAY.ON CERTAIN DAYS ON WHICH BNPP HAD A DERIVATIVES POSITIONSETTLING OR RESETTING AGAINST USD ISDAFIX, CERTAIN INDIVIDUALS ATBNPP ATTEMPTED TO MANIPULATE USD ISDAFIX RATES THROUGHTRADING AT THE 11:00 A.M. FIXING AND, ON OCCASION, BY MAKING FALSESUBMISSIONS TO SWAPS BROKER THAT WERE SKEWED TO BENEFITDERIVATIVES POSITIONS HELD BY BNPP. BNPP'S UNLAWFUL CONDUCTINVOLVED MULTIPLE TRADERS, INCLUDING SUPERVISORS SUCH AS THETHEN-HEADS OF THE RELEVANT BNPP SWAPS AND OPTIONS DESKS INTHE UNITED STATES.FIRST, CERTAIN BNPP TRADERS BID, OFFERED, AND EXECUTEDTRANSACTIONS IN TARGETED INTEREST RATE PRODUCTS, INCLUDINGSWAP SPREADS, AT OR NEAR THE CRITICAL 11:00 A.M. FIXING TIME WITHTHE INTENT TO AFFECT THE REFERENCE RATES AND SPREADSCAPTURED BY SWAPS BROKER AND SENT TO SUBMITTING BANKS, ANDTHEREBY TO AFFECT THE PUBLISHED USD ISDAFIX. AS CAPTURED INCONTEMPORANEOUS COMMUNICATIONS, ON SOME OCCASIONS WHENBNPP HAD DERIVATIVES POSITIONS SETTLING OR PRICING AGAINST USDISDAFIX, ITS TRADERS DISCUSSED, BOTH AMONG THEMSELVES AND WITHSWAPS BROKER EMPLOYEES, THEIR INTENT TO MOVE USD ISDAFIXRATES IN WHICHEVER DIRECTION BENEFITTED THEIR POSITIONS.SECOND, ON OCCASION, CERTAIN TRADERS AT BNPP ATTEMPTED TOMANIPULATE USD ISDAFIX BY MAKING FALSE SUBMISSIONS TO SWAPSBROKER FOR BNPP AS A PANEL BANK, SKEWING THE RATES AND51©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:COMMODITY FUTURES TRADING COMMISSIONPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:N/ADate Initiated:08/29/2018Docket/Case Number:18-19Principal Product Type:OtherOther Product Type(s):SWAPSSPREADS SUBMITTED IN THE DIRECTION THAT COULD HAVE MOVED THEUSD ISDAFIX SETTING TO BENEFIT BNPP'S TRADING POSITIONS. BNPPTRADERS MADE USD ISDAFIX SUBMISSIONS HIGHER OR LOWER THANTHE REFERENCE VALUES DISSEMINATED BY SWAPS BROKER FOR THEPURPOSE OF BENEFITTING DERIVATIVES POSITIONS PRICED OR VALUEDAGAINST THE BENCHMARK. ON THESE OCCASIONS, BNPP'S USD ISDAFIXSUBMISSIONS CONSTITUTED FALSE, MISLEADING, OR KNOWINGLYINACCURATE REPORTS BECAUSE THEY PURPORTED TO REFLECT BNPP'SHONEST VIEW OF THE TRUE COSTS OF ENTERING INTO A STANDARDFIXED-FOR-FLOATING INTEREST RATE SWAP IN A PARTICULAR TENORWITH ANOTHER DEALER OF GOOD CREDIT IN THE INTERDEALER MARKET,BUT IN FACT REFLECTED TRADERS' DESIRE TO MOVE USD ISDAFIXHIGHER OR LOWER IN ORDER TO BENEFIT BNPP'S POSITIONS. THESESUBMISSIONS WERE FALSE, MISLEADING, OR KNOWINGLY INACCURATEBECAUSE THEY DID NOT REPORT WHERE BNPP WOULD ITSELF BID OROFFER INTEREST RATE SWAPS TO A DEALER OF GOOD CREDIT ABSENT ADESIRE TO MANIPULATE USD ISDAFIX, BUT RATHER REFLECTED PRICESTHAT WERE MORE FAVORABLE TO THE BANK ON SPECIFIC POSITIONS.BNPP VIOLATED SECTIONS 6(C)(1), 6(C)(1)(A), 6(C)(3), 6(D), AND 9(A)(2) OFTHE ACT AND REGULATIONS 180.1(A) AND 180.2.Resolution Date:08/29/2018Resolution:Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?YesSanctions Ordered:Monetary/Fine $90,000,000.00Order52©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanctions Ordered:UNDERTAKINGSSanction Details:BNPP IS ORDERED TO CEASE AND DESIST FROM VIOLATING SECTIONS6(C)(1), 6(C)(1)(A), 6(C)(3), 6(D), AND 9(A)(2) OF THE ACT AND REGULATIONS180.1(A) AND 180.2.BNPP SHALL PAY A CIVIL MONETARY PENALTY OF $90,000,000.BNPP IS ALSO ORDERED TO COMPLY WITH CERTAIN UNDERTAKINGS.Regulator StatementRESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT ("OFFER"),WHICH THE COMMISSION HAS DETERMINED TO ACCEPT.IT IS ORDERED THAT BNPP CEASE AND DESIST FROM VIOLATINGSECTIONS 6(C)(1), 6(C)(1)(A), 6(C)(3), 6(D), AND 9(A)(2) OF THE ACT ANDREGULATIONS 180.1(A) AND 180.2.BNPP SHALL PAY A CIVIL MONETARY PENALTY OF $90,000,000.BNPP IS ALSO ORDERED TO COMPLY WITH CERTAIN UNDERTAKINGS.Cease and Desist/InjunctioniReporting Source:FirmInitiated By:COMMODITY FUTURES TRADING COMMISSIONDate Initiated:08/29/2018Docket/Case Number:18-19Principal Product Type:OtherOther Product Type(s):USD ISDAFIXAllegations:ON AUGUST 29, 2018, THE COMMODITY FUTURES TRADING COMMISSION("CFTC") ISSUED AN ADMINISTRATIVE ORDER AGAINST BNP PARIBASSECURITIES CORP. ("BNPPSC") FINDING THAT, BEGINNING IN OR ABOUTMAY 2007 AND CONTINUING THROUGH AT LEAST AUGUST 2012, BNPPSC,BY AND THROUGH CERTAIN OF ITS TRADERS, ATTEMPTED TOMANIPULATE THE U.S. DOLLAR INTERNATIONAL SWAPS AND DERIVATIVESASSOCIATION FIX ("USD ISDAFIX") TO BENEFIT BNPPSC'S DERIVATIVESPOSITIONS IN INSTRUMENTS SUCH AS CASH-SETTLED OPTIONS ONINTEREST RATE SWAPS AND CERTAIN EXOTIC STRUCTURED PRODUCTS("ORDER"). IN THE ORDER, THE CFTC FOUND THAT BNPPSC VIOLATEDSECTION 9(A)(2) OF THE COMMODITY EXCHANGE ACT (THE "ACT"), 7 U.S.C.§ 13(A)(2) (2012); SECTIONS 6(C) AND 6(D) OF THE ACT, 7 U.S.C. §§ 9, 13B(2006), FOR CONDUCT OCCURRING BEFORE AUGUST 15, 2011; ANDSECTIONS 6(C)(1), 6(C)(3), AND 6(D) OF THE ACT, 7 U.S.C. §§ 9(1), 9(3), 13B(2012), AND REGULATIONS 180.1(A) AND 180.2, 17 C.F.R. §§ 180.1(A), 180.2(2018), FOR CONDUCT OCCURRING ON OR AFTER AUGUST 15, 2011.Current Status:Final53©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:CIVIL MONETARY PENALTY, UNDERTAKINGSResolution Date:08/29/2018Resolution:Other Sanctions Ordered:REMEDIATION, UNDERTAKINGS, AND OTHER CONDITIONSSanction Details:THE SETTLEMENT RESULTED IN THE CFTC ISSUING THE ORDER CAUSINGBNPPSC TO CEASE AND DESIST FROM VIOLATING SECTIONS 6(C)(1),6(C)(1)(A), 6(C)(3), 6(D), AND 9(A)(2) OF THE ACT, 7 U.S.C. §§ 9(1), 9(1)(A),9(3), 13B, 13(A)(2) (2012), AND REGULATIONS 180.1(A) AND 180.2, 17 C.F.R.§§ 180.1(A), 180.2 (2018). IN ADDITION, THE ORDER CAUSED BNPPSC TOPAY A CIVIL MONEY PENALTY OF $90 MILLION, WHICH WAS PAID ONSEPTEMBER 6, 2018. ALSO, THE ORDER CAUSED BNPPSC TO COMPLYWITH UNDERTAKINGS RELATED TO REMEDIATION AND ONGOINGCOOPERATION. RELATING TO REMEDIATION, BNPPSC AGREED TOCONTINUE TO UNDERTAKE EXTENSIVE REMEDIAL MEASURES TOIMPLEMENT AND STRENGTHEN ITS INTERNAL CONTROLS ANDPROCEDURES RELATING TO THE FIXING OF ANY INTEREST-RATE SWAPBENCHMARKS AND RELATED SUPERVISION OF ITS INTEREST-RATESWAPS AND OPTIONS DESKS.Firm StatementIN SETTLEMENT OF THIS MATTER, BNPPSC, WITHOUT ADMITTING ORDENYING THE FINDINGS OR CONCLUSIONS THEREIN, CONSENTED TO THEENTRY OF THE ORDER, WHICH THE CFTC HAS DETERMINED TO ACCEPTAND HAS ISSUED. THE ALLEGATIONS, DISPOSITIONS, FINDINGS ANDSANCTIONS OF THE ORDER ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.Sanctions Ordered:Monetary/Fine $90,000,000.00Cease and Desist/InjunctionSettledDisclosure 3 of 53iReporting Source:FirmAllegations:A SUBCOMMITTEE OF THE EXCHANGE'S BUSINESS CONDUCT COMMITTEEDETERMINED THAT, BETWEEN AUGUST 2016 AND JULY 2017, BNP PARIBAS;BNP PARIBAS COMMODITY FUTURES LTD; AND BNP PARIBAS PRIMEBROKERAGE, INC., (COLLECTIVELY, "BNP PARIBAS"), MAY HAVE VIOLATEDEXCHANGE RULE 6.15(A) IN NUMEROUS INSTANCES BY FAILING TOSUBMIT TO THE EXCHANGE DAILY LARGE TRADER REPORTS WITHRESPECT TO REPORTABLE CUSTOMER POSITIONS; EXCHANGE RULE 6.Current Status:Final54©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:ICE FUTURES US, INC.Principal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:Date Initiated:05/07/2018Docket/Case Number:ICE 2017-007Principal Product Type:Futures - CommodityOther Product Type(s):20(B) IN FIVE (5) INSTANCES BY MAINTAINING A FUTURES POSITION THATWAS IN EXCESS OF POSITION LIMITS; AND EXCHANGE RULE 4.01(A) BYFAILING TO DILIGENTLY SUPERVISE THE EXCHANGE-RELATED ACTIVITIESOF ITS EMPLOYEES WITH REGARD TO SPOT MONTH POSITION LIMITS ANDEXEMPTION EXPIRATION MONITORING AS WELL AS RELATEDCOMMUNICATIONS.Resolution Date:05/07/2018Resolution:Other Sanctions Ordered:Sanction Details:IN ACCORDANCE WITH THE TERMS OF SETTLEMENT, IN WHICH BNPPARIBAS NEITHER ADMITTED NOR DENIED THE RULEVIOLATIONS, BNP PARIBAS PAID A FINE IN THE AMOUNT OF $71,107.50,WHICH INCLUDES DISGORGEMENT OF PROFITS INTHE AMOUNT OF $21,107.50, AND AGREED TO CEASE AND DESIST FROMFUTURE VIOLATIONS OF RULE 6.20(B).Sanctions Ordered:Monetary/Fine $71,107.50Disgorgement/RestitutionCease and Desist/InjunctionSettledDisclosure 4 of 53iReporting Source:FirmAllegations:BNP PARIBAS USA, INC. LACKED ADEQUATE GOVERNANCE, RISKMANAGEMENT, COMPLIANCE AND AUDIT POLICIES AND PROCEDURES TOENSURE THAT THE FIRM'S COVERED FX ACTIVITIES (I.E., BUYING ANDSELLING U.S. DOLLARS AND FOREIGN CURRENCY FOR ITS OWN ACCOUNTAND SOLICITING AND RECEIVING ORDERS THROUGH COMMUNICATIONSCurrent Status:Final55©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEMPrincipal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:CIVIL MONEY PENALTYDate Initiated:07/17/2017Docket/Case Number:Principal Product Type:No ProductOther Product Type(s):BETWEEN CUSTOMERS AND SALES PERSONNEL THAT ARE EXECUTED BYTRADERS IN THE SPOT MARKET) COMPLIED WITH SAFE AND SOUNDBANKING PRACTICES, APPLICABLE U.S. LAWS AND REGULATIONS,INCLUDING POLICIES AND PROCEDURES TO PREVENT POTENTIALVIOLATIONS OF THE U.S. COMMODITIES, ANTITRUST AND CRIMINAL FRAUDLAWS, AND APPLICABLE INTERNAL POLICIES.Resolution Date:07/17/2017Resolution:Other Sanctions Ordered:Sanction Details:THE ORDER REQUIRED BNPP TO PAY A CIVIL MONETARY PENALTY IN THEAMOUNT OF $246,375,000.Firm StatementBNPP WAS REQUIRED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF$246, 375,000. THE BOARD ORDER FURTHER PROVIDED THAT BNPP, BNPPUSA AND BNP PARIBAS SECURITIES CORP. (THE "PARTIES") WOULD NOT,IN THE FUTURE, DIRECTLY OR INDIRECTLY, RETAIN IN ANY CAPACITY ANYOF THE INDIVIDUALS WHO PARTICIPATED IN THE MISCONDUCTUNDERLYING THE BOARD ORDER AND, HAVING BEEN SUBJECT TOFORMAL DISCIPLINARY ACTION AS A RESULT OF BNPP'S INTERNALREVIEW, WERE TERMINATED BY OR SEPARATED FROM BNPP. THE BOARDORDER ALSO REQUIRES THE PARTIES TO SUBMIT WRITTEN PROPOSALSFOR APPROVAL BY THE FEDERAL RESERVE BANK OF NEW YORKCOVERING ITS INTERNAL CONTROLS AND COMPLIANCE PROGRAM,COMPLIANCE RISK MANAGEMENT PROGRAM, AND INTERNAL AUDITPROGRAM REGARDING TO THE COVERED FX ACTIVITIES AND OTHER FXTRADING AND RELATED SALES ACTIVITIES.Sanctions Ordered:Monetary/Fine $246,375,000.00Cease and Desist/InjunctionOrderi56©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceDisclosure 5 of 53Reporting Source:RegulatorInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:02/02/2017Docket/Case Number:2015046695501Principal Product Type:OtherOther Product Type(s):UNSPECIFIED SECURITIESAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT SUBMITTEDAPPROXIMATELY 40 MILLION REPORTABLE ORDER EVENTS (ROES) TO THEORDER AUDIT TRAIL SYSTEM (OATS) WITHOUT THE REQUIRED "Y"PROGRAM TRADING CODE INDICATING THE ORDERS WERE PART OF APROGRAM TRADE. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORYPROCEDURES WERE NOT REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS AND TO FINRA RULES CONCERNING OATS. SPECIFICALLY,THE FIRM FAILED TO HAVE PROCEDURES TO COMPARE THE ACCEPTEDOATS DATA TO THE FIRM'S BOOKS AND RECORDS TO ENSURE ALL ROESWERE REPORTED ACCURATELY.Current Status:FinalResolution Date:02/02/2017Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $22,500. IN DETERMINING TORESOLVE THIS MATTER IN THE MANNER SET FORTH HEREIN, AND INDoes the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $22,500.00Acceptance, Waiver & Consent(AWC)57©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceDETERMINING THE APPROPRIATE MONETARY SANCTION, FINRA GAVESIGNIFICANT CONSIDERATION TO THE FIRM'S SELF-REPORTING OF THEOATS VIOLATIONS DESCRIBED ABOVE. THE FIRM FURTHER UNDERTOOKSTEPS TO REMEDIATE THE ISSUES AND CREATE AND IMPLEMENTADDITIONAL DAILY SURVEILLANCE PROCEDURES, INCLUDINGENHANCEMENTS TO SOME OF ITS SUPERVISORY SYSTEMS. FINE PAID INFULL ON 3/13/17.iReporting Source:FirmInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:02/02/2017Docket/Case Number:2015046695501Principal Product Type:OtherOther Product Type(s):UNSPECIFIED SECURITIESAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT SUBMITTEDAPPROXIMATELY 40 MILLION REPORTABLE ORDER EVENTS (ROES) TO THEORDER AUDIT TRAIL SYSTEM (OATS) WITHOUT THE REQUIRED "Y"PROGRAM TRADING CODE INDICATING THE ORDERS WERE PART OF APROGRAM TRADE. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORYPROCEDURES WERE NOT REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS ANDREGULATIONS AND TO FINRA RULES CONCERNING OATS. SPECIFICALLY,THE FIRM FAILED TO HAVE PROCEDURES TO COMPARE THE ACCEPTEDOATS DATA TO THE FIRM'S BOOKS AND RECORDS TO ENSURE ALL ROESWERE REPORTED ACCURATELY.Current Status:FinalResolution Date:02/02/2017Resolution:Other Sanctions Ordered:Sanctions Ordered:CensureMonetary/Fine $22,500.00Acceptance, Waiver & Consent(AWC)58©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceSanction Details:THE FIRM WAS CENSURED AND FINED $22,500. IN DETERMINING TORESOLVE THIS MATTER IN THE MANNER SET FORTH HEREIN, AND INDETERMINING THE APPROPRIATE MONETARY SANCTION, FINRA GAVESIGNIFICANT CONSIDERATION TO THE FIRM'S SELF-REPORTING OF THEOATS VIOLATIONS DESCRIBED ABOVE. THE FIRM FURTHER UNDERTOOKSTEPS TO REMEDIATE THE ISSUES AND CREATE AND IMPLEMENTADDITIONAL DAILY SURVEILLANCE PROCEDURES, INCLUDINGENHANCEMENTS TO SOME OF ITS SUPERVISORY SYSTEMS.Disclosure 6 of 53iReporting Source:RegulatorInitiated By:NYSE ARCA, INC.Allegations:A FINRA HEARING OFFICER CONSIDERED AN OFFER OF SETTLEMENT ANDCONSENT ENTERED INTO BETWEEN FINRA ON BEHALF OF NYSEREGULATION, INC. AND THE FIRM.THE FIRM SUBMITTED AN OFFER OF SETTLEMENT AND CONSENT FORTHE SOLE PURPOSE OF SETTLING THIS DISCIPLINARY PROCEEDING,WITHOUT ADJUDICATION OF ANY ISSUES OF LAW OR FACT, AND WITHOUTADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS REFERRED TOIN THE OFFER OF SETTLEMENT.THE HEARING OFFICER ACCEPTS THE OFFER OF SETTLEMENT ANDCONSENT AND ISSUES THIS DECISION.THIS MATTER INVOLVES A REVIEW BY FINRA OF THE FIRM'S COMPLIANCEWITH THE RULES RELATED TO THE ROUTING OF INTERMARKET SWEEPORDERS ("ISOS") DURING THE REVIEW PERIOD, AND FINRA FOUND THATDUE TO VARIOUS TECHNOLOGY SYSTEM ISSUES, THE FIRM ONNUMEROUS OCCASIONS SENT ISOS THAT TRADED THROUGH PROTECTEDQUOTATIONS.THE FINDINGS STATED THAT THE FIRM, AS AN EQUITIES TRADING PERMIT("ETP") HOLDER WITH NYSE ARCA EQUITIES, INC., FAILED TO TAKEREASONABLE STEPS TO ESTABLISH THAT THE ISOS IT ROUTED MET THEDEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OFREGULATION NMS.THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM DIDNOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO EXCHANGE ACT RULE 611(C) OFREGULATION NMS AND NYSE ARCA EQUITIES RULE 7.31(E)(2).Current Status:Final59©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:10/27/2016Docket/Case Number:2014043098802Principal Product Type:OptionsOther Product Type(s):Resolution Date:10/27/2016Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $45,000.Regulator StatementTHE FIRM VIOLATED (I) EXCHANGE ACT RULE 611(C) OF REGULATION NMSAND NYSE ARCA EQUITIES RULE 7.31(E)(2) BY FAILING TO ESTABLISH THATTHE ISOS IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTHIN RULE 600(B)(30) OF REGULATION NMS AND (II) NYSE ARCA EQUITIESRULES 6.18 AND 2010 IN THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO EXCHANGE ACT RULE 611(C) OFREGULATION NMS AND NYSE ARCA EQUITIES RULE 7.31(E)(2).Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $45,000.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmAllegations:A FINRA HEARING OFFICER CONSIDERED AN OFFER OF SETTLEMENT ANDCONSENT ENTERED INTO BETWEEN FINRA ON BEHALF OF NYSEREGULATION, INC. AND THE FIRM. THE FIRM SUBMITTED AN OFFER OFSETTLEMENT AND CONSENT FOR THE SOLE PURPOSE OF SETTLING THISDISCIPLINARY PROCEEDING, WITHOUT ADJUDICATION OF ANY ISSUES OFCurrent Status:Final60©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:NYSE ARCA, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:10/27/2016Docket/Case Number:2014043098802Principal Product Type:OptionsOther Product Type(s):LAW OR FACT, AND WITHOUT ADMITTING OR DENYING ANY ALLEGATIONSOR FINDINGS REFERRED TO IN THE OFFER OF SETTLEMENT. THEHEARING OFFICER ACCEPTS THE OFFER OF SETTLEMENT AND CONSENTAND ISSUES THIS DECISION. THIS MATTER INVOLVES A REVIEW BY FINRAOF THE FIRM'S COMPLIANCE WITH THE RULES RELATED TO THE ROUTINGOF INTERMARKET SWEEP ORDERS ("ISOS") DURING THE REVIEW PERIOD,AND FINRA FOUND THAT DUE TO VARIOUS TECHNOLOGY SYSTEM ISSUES,THE FIRM ON NUMEROUS OCCASIONS SENT ISOS THAT TRADEDTHROUGH PROTECTED QUOTATIONS. THE FINDINGS STATED THAT THEFIRM, AS AN EQUITIES TRADING PERMIT ("ETP") HOLDER WITH NYSE ARCAEQUITIES, INC., FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THATTHE ISOS IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTHIN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS ALSO STATEDTHAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHRESPECT TO EXCHANGE ACT RULE 611(C) OF REGULATION NMS ANDNYSE ARCA EQUITIES RULE 7.31(E)(2).Resolution Date:10/27/2016Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $45,000Sanctions Ordered:CensureMonetary/Fine $45,000.00Acceptance, Waiver & Consent(AWC)Disclosure 7 of 53iReporting Source:RegulatorCurrent Status:Final61©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:BATS EDGA EXCHANGE, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:10/27/2016Docket/Case Number:2014043098803Principal Product Type:OptionsOther Product Type(s):Allegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DUE TOVARIOUS TECHNOLOGY SYSTEM ISSUES, THE FIRM ON NUMEROUSOCCASIONS SENT INTERMARKET SWEEP ORDERS THAT TRADEDTHROUGH PROTECTED QUOTATIONS.THE FINDINGS STATED THAT SPECIFICALLY, THE FIRM FAILED TO TAKEREASONABLE STEPS TO ESTABLISH THAT INTERMARKET SWEEP ORDERSIT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE600(B)(30) OF REGULATION NMS.THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM DIDNOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO SEA RULE 611(C) OF REGULATION NMSAND EDGA RULE 11.8(C).Resolution Date:10/27/2016Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $22,500.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $22,500.00Acceptance, Waiver & Consent(AWC)i62©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceReporting Source:FirmInitiated By:BATS EDGA EXCHANGE, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:10/27/2016Docket/Case Number:2014043098803Principal Product Type:OptionsOther Product Type(s):Allegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DUE TOVARIOUS TECHNOLOGY SYSTEM ISSUES, THE FIRM ON NUMEROUSOCCASIONS SENT INTERMARKET SWEEP ORDERS THAT TRADEDTHROUGH PROTECTED QUOTATIONS. THE FINDINGS STATED THATSPECIFICALLY, THE FIRM FAILED TO TAKE REASONABLE STEPS TOESTABLISH THAT INTERMARKET SWEEP ORDERS IT ROUTED MET THEDEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OFREGULATION NMS. THE FINDINGS ALSO STATED THAT THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TOSEA RULE 611(C) OF REGULATION NMS AND EDGA RULE 11.8(C).Current Status:FinalResolution Date:10/27/2016Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $22,500.Sanctions Ordered:CensureMonetary/Fine $22,500.00Acceptance, Waiver & Consent(AWC)Disclosure 8 of 53iReporting Source:RegulatorAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DUE TOCurrent Status:Final63©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:BATS EDGX EXCHANGE, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:10/27/2016Docket/Case Number:2014043098804Principal Product Type:OptionsOther Product Type(s):VARIOUS TECHNOLOGY SYSTEM ISSUES, THE FIRM ON NUMEROUSOCCASIONS SENT INTERMARKET SWEEP ORDERS THAT TRADEDTHROUGH PROTECTED QUOTATIONS.THE FINDINGS STATED THAT SPECIFICALLY, THE FIRM FAILED TO TAKEREASONABLE STEPS TO ESTABLISH THAT INTERMARKET SWEEP ORDERSIT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN RULE600(B)(30) OF REGULATION NMS.THE FINDINGS ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM DIDNOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO SEA RULE 611(C) OF REGULATION NMSAND EDGX RULE 11.8(C).Resolution Date:10/27/2016Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $22,500.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $22,500.00Acceptance, Waiver & Consent(AWC)iReporting Source:Firm64©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:BATS EDGX EXCHANGE, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:10/27/2016Docket/Case Number:2014043098804Principal Product Type:OptionsOther Product Type(s):Allegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT DUE TOVARIOUS TECHNOLOGY SYSTEM ISSUES, THE FIRM ON NUMEROUSOCCASIONS SENT INTERMARKET SWEEP ORDERS THROUGH PROTECTEDQUOTATIONS. THE FINDINGS STATED THAT SPECIFICALLY, THE FIRMFAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT INTERMARKETSWEEP ORDERS IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SETFORTH IN RULE 600(B)(30) OF REGULATION NMS. THE FINDINGS ALSOSTATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHRESPECT TO SEA RULE 611(C) OF REGULATION NMS AND EDGX RULE 11.8(C).Current Status:FinalResolution Date:10/27/2016Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $22,500.Sanctions Ordered:CensureMonetary/Fine $22,500.00Acceptance, Waiver & Consent(AWC)Disclosure 9 of 53iReporting Source:RegulatorAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOTAKE REASONABLE STEPS TO ESTABLISH THAT THE INTERMARKETCurrent Status:Final65©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:10/27/2016Docket/Case Number:2014043098801Principal Product Type:OtherOther Product Type(s):UNSPECIFIED SECURITIESSWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONALREQUIREMENTS SET FORTH IN RULE 600(B) (30) OF REGULATION NMS.THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO SEA RULE 611(C) OF REGULATION NMS.Resolution Date:10/27/2016Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $135,000, OF WHICH $45,000 ISPAYABLE TO FINRA. FINES PAID IN FULL ON NOVEMBER 25, 2016.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $135,000.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOTAKE REASONABLE STEPS TO ESTABLISH THAT THE INTERMARKETSWEEP ORDERS (ISOS) IT ROUTED MET THE DEFINITIONALREQUIREMENTS SET FORTH IN RULE 600(B) (30) OF REGULATION NMS.THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOTCurrent Status:Final66©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:10/27/2016Docket/Case Number:2014043098801Principal Product Type:OtherOther Product Type(s):UNSPECIFIED SECURITIESPROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH RESPECT TO SEA RULE 611(C) OF REGULATION NMS.Resolution Date:10/27/2016Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $45,000.Sanctions Ordered:CensureMonetary/Fine $45,000.00Acceptance, Waiver & Consent(AWC)Disclosure 10 of 53iReporting Source:RegulatorAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)THE ACCURATE TIME OF EXECUTION FOR CORPORATE DEBT INTER-DEALER TRANSACTIONS. THE FINDINGS STATED THAT THE FIRM FAILEDTO RECORD THE CORRECT TIME OF EXECUTION ON THE MEMORANDUMOF BROKERAGE ORDERS OF CORPORATE DEBT TRANSACTIONS. THEFINDINGS ALSO STATED THAT THE FIRM FAILED TO REPORT TO TRACETRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIESWITHIN 15 MINUTES OF THE TIME OF EXECUTION. THE FINDINGS ALSOINCLUDED THAT THE FIRM FAILED TO REPORT TO TRACE TRANSACTIONSIN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES WITHIN 15 MINUTESOF THE TIME OF EXECUTION. FINRA FOUND THAT THE FIRM ALSO FAILEDTO REPORT TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE CORPORATEDEBT SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION.Current Status:Final67©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:10/17/2016Docket/Case Number:2015046334701Principal Product Type:Debt - CorporateOther Product Type(s):FINRA ALSO FOUND THAT THE FIRM FAILED TO ENFORCE ITS WRITTENSUPERVISORY PROCEDURES.Resolution Date:10/17/2016Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $85,000. FINES PAID IN FULL ONNOVEMBER 2, 2016.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $85,000.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)THE ACCURATE TIME OF EXECUTION FOR CORPORATE DEBT INTER-DEALER TRANSACTIONS. THE FINDINGS STATED THAT THE FIRM FAILEDTO RECORD THE CORRECT TIME OF EXECUTION ON THE MEMORANDUMOF BROKERAGE ORDERS OF CORPORATE DEBT TRANSACTIONS. THEFINDINGS ALSO STATED THAT THE FIRM FAILED TO REPORT TO TRACETRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIESCurrent Status:Final68©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:10/17/2016Docket/Case Number:2015046334701Principal Product Type:Debt - CorporateOther Product Type(s):WITHIN 15 MINUTES OF THE TIME OF EXECUTION. FINRA ALSO FOUNDTHAT THE FIRM FAILED TO ENFORCE ITS WRITTEN SUPERVISORYPROCEDURES.Resolution Date:10/17/2016Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $85,000Sanctions Ordered:CensureMonetary/Fine $85,000.00Acceptance, Waiver & Consent(AWC)Disclosure 11 of 53iReporting Source:RegulatorInitiated By:FINRADate Initiated:07/18/2016Docket/Case Number:2015044256201Allegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TRANSACTIONS IN TRADE REPORTING AND COMPLIANCE ENGINE(TRACE)-ELIGIBLE SPS TO TRACE WITHIN THE TIME REQUIRED BY FINRARULE 6730(A). THE FINDINGS STATED THAT THE FIRM, AS A MANAGINGUNDERWRITER, FAILED TO REPORT NEW ISSUE OFFERINGS IN TRACE-ELIGIBLE SPS TO FINRA ACCORDING TO THE TIME FRAME SET FORTH INFINRA RULE 6760(C).Current Status:Final69©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Principal Product Type:OtherOther Product Type(s):TRACE AGENCY/SECURITIZED PRODUCTS (SP)Resolution Date:07/18/2016Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $27,500. FINE PAID IN FULL ONAUGUST 2, 2016.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $27,500.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmInitiated By:FINRADate Initiated:07/18/2016Docket/Case Number:2015044256201Principal Product Type:OtherOther Product Type(s):TRACE AGENCY/SECURITIZED PRODUCTS (SP)Allegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TRANSACTIONS IN TRADE REPORTING AND COMPLIANCE ENGINE(TRACE)-ELIGIBLE SPS TO TRACE WITHIN THE TIME REQUIRED BY FINRARULE 6730(A). THE FINDINGS STATED THAT THE FIRM, AS A MANAGINGUNDERWRITER, FAILED TO REPORT NEW ISSUE OFFERINGS IN TRACE-ELIGIBLE SPS TO FINRA ACCORDING TO THE TIME FRAME SET FORTH INFINRA RULE 6760(C).Current Status:Final70©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Resolution Date:07/18/2016Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $27,500.Sanctions Ordered:CensureMonetary/Fine $27,500.00Acceptance, Waiver & Consent(AWC)Disclosure 12 of 53iReporting Source:RegulatorInitiated By:FINRADate Initiated:04/22/2016Docket/Case Number:2013035716201Principal Product Type:No ProductOther Product Type(s):Allegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMOVERSTATED ITS ADVERTISED TRADE VOLUME IN SECURITIES TOBLOOMBERG. THE FINDINGS STATED THAT THE OVERSTATED TRADEVOLUME RESULTED FROM A SYSTEM ISSUE THAT CAUSED THE FIRM TOCOMBINE THE ADVERTISED TRADE VOLUME IN UNRELATED SECURITIESTHAT HAD THE SAME TRADING SYMBOL IN THE CANADIAN MARKET ANDTHE UNITED STATES MARKET. A SECOND SYSTEM ERROR WAS CAUSEDBY THE MANNER IN WHICH COMMON STOCKS AND PREFERRED STOCKSWERE IDENTIFIED IN THE FIRM'S SYSTEMS BY FIRM CUSTOMERS. THISERROR CAUSED THE FIRM TO INACCURATELY ADVERTISE VOLUME IN ACOMMON STOCK WHEN THE VOLUME ACTUALLY TRADED BY THE FIRMWAS IN THE PREFERRED STOCK RELATED TO THE SAME ISSUER. THEFINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH ANDIMPLEMENT A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNEDTO ENSURE COMPLIANCE WITH REGULATORY REQUIREMENTS FORACCURACY IN THE FIRM'S ADVERTISING OF EXECUTED TRADE VOLUME.Current Status:Final71©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Resolution Date:04/22/2016Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $375,000. FINE PAID IN FULL ON MAY5, 2016.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $375,000.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmInitiated By:FINRAAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMOVERSTATED ITS ADVERTISED TRADE VOLUME IN SECURITIES TOBLOOMBERG. THE FINDINGS STATED THAT THE OVERSTATED TRADEVOLUME RESULTED FROM A SYSTEM ISSUE THAT CAUSED THE FIRM TOCOMBINE THE ADVERTISED TRADE VOLUME IN UNRELATED SECURITIESTHAT HAD THE SAME TRADING SYMBOL IN THE CANADIAN MARKET ANDTHE UNITED STATES MARKET. A SECOND SYSTEM ERROR WAS CAUSEDBY THE MANNER IN WHICH COMMON STOCKS AND PREFERRED STOCKSWERE IDENTIFIED IN THE FIRM'S SYSTEMS BY FIRM CUSTOMERS. THISERROR CAUSED THE FIRM TO INACCURATELY ADVERTISE VOLUME IN ACOMMON STOCK WHEN THE VOLUME ACTUALLY TRADED BY THE FIRMWAS IN THE PREFERRED STOCK RELATED TO THE SAME ISSUER. THEFINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH ANDIMPLEMENT A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNEDTO ENSURE COMPLIANCE WITH REGULATORY REQUIREMENTS FORACCURACY IN THE FIRM'S ADVERTISING OF EXECUTED TRADE VOLUME.Current Status:Final72©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:04/22/2016Docket/Case Number:2013035716201Principal Product Type:No ProductOther Product Type(s):Resolution Date:04/22/2016Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $375,000.Sanctions Ordered:CensureMonetary/Fine $375,000.00Acceptance, Waiver & Consent(AWC)Disclosure 13 of 53iReporting Source:RegulatorInitiated By:FINRADate Initiated:03/15/2016Docket/Case Number:2014039940401Principal Product Type:No ProductOther Product Type(s):Allegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITTRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTSTHAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLYFORMATTED DATA. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH RESPECT TO CERTAIN APPLICABLESECURITIES LAWS AND REGULATIONS, AND/OR FINRA RULES. THE FIRM'SWRITTEN SUPERVISORY PROCEDURES FAILED TO PROVIDE FOR ONE ORMORE OF THE FOUR MINIMUM REQUIREMENTS FOR ADEQUATE WRITTENSUPERVISORY PROCEDURES REGARDING OATS REPORTING.Current Status:Final73©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Resolution Date:03/15/2016Resolution:Other Sanctions Ordered:UNDERTAKING: REVISE THE FIRM'S WRITTEN SUPERVISORYPROCEDURESSanction Details:THE FIRM WAS CENSURED, FINED $40,000 AND UNDERTAKES TO REVISEITS WRITTEN SUPERVISORY PROCEDURES.FINE PAID IN FULL ON APRIL 20, 2016.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $40,000.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmInitiated By:FINRADate Initiated:03/15/2016Docket/Case Number:2014039940401Allegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITTRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) REPORTSTHAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLYFORMATTED DATA. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH RESPECT TO CERTAIN APPLICABLESECURITIES LAWS AND REGULATIONS, AND/OR FINRA RULES. THE FIRM'SWRITTEN SUPERVISORY PROCEDURES FAILED TO PROVIDE FOR ONE ORMORE OF THE FOUR MINIMUM REQUIREMENTS FOR ADEQUATE WRITTENSUPERVISORY PROCEDURES REGARDING OATS REPORTING.Current Status:Final74©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Principal Product Type:No ProductOther Product Type(s):Resolution Date:03/15/2015Resolution:Other Sanctions Ordered:UNDERTAKING: REVISE THE FIRM'S WRITTEN SUPERVISORYPROCEDURESSanction Details:THE FIRM WAS CENSURED, FINED $40,000 AND UNDERTAKES TO REVISEITS WRITTEN SUPERVISORY PROCEDURES.Sanctions Ordered:CensureMonetary/Fine $40,000.00Acceptance, Waiver & Consent(AWC)Disclosure 14 of 53iReporting Source:RegulatorAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITS TRADINGDESKS WERE ORGANIZED INTO SEPARATE AGGREGATION UNITS (AGUS),FOR PURPOSES OF COMPLIANCE WITH SEC RULE 200(1) AND PRE-EXISTING GUIDANCE CONCERNING THE PROPER USE OF AGUS. THEFINDINGS STATED THAT EACH OF THE SEPARATE AGUS CONTAINEDNUMEROUS TRADING BOOKS, FOR WHICH SECURITIES POSITIONS WERENETTED TOGETHER TO DETERMINE THE TOTAL NET POSITION OF THATAGU AND, ACCORDINGLY, WHETHER THE AGUS ORDERS SHOULD BEMARKED LONG OR SHORT. IN ADDITION TO THE FIRM'S PROPRIETARYPOSITIONS, THE AGUS ALSO IMPROPERLY INCLUDED THE TRADINGPOSITIONS OF NON-BROKER-DEALER AFFILIATES IN DETERMINING THEAGUS NET POSITIONS. AS A RESULT, THE FIRM'S AGUS FAILED TOACCURATELY REFLECT THE CORRECT POSITIONS WITHIN THEAPPROPRIATE TRADING BOOKS. THE FINDINGS ALSO STATED THAT THEFIRM'S WRITTEN PLAN OF ORGANIZATION FOR ITS AGGREGATION UNITSHAS FAILED TO ACCURATELY PROVIDE FOR THE OVERALL NET POSITIONOF THE SECURITIES THAT WERE TRADED AND MAINTAINED BY THE FIRM'SAGUS. MORE SPECIFICALLY, THE FIRM'S WRITTEN PLAN OFORGANIZATION FOR ITS AGUS IMPROPERLY PERMITTED THE INCLUSIONOF SECURITIES POSITIONS OF CERTAIN NON-BROKER-DEALERCurrent Status:Final75©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:11/16/2015Docket/Case Number:2012034389401Principal Product Type:OtherOther Product Type(s):UNSPECIFIED SECURITIESAFFILIATES IN DETERMINING THE NET POSITION OF THE FIRM'S AGUS ANDIMPROPERLY PERMITTED TRADERS TO BE ASSIGNED TO MULTIPLEAGGREGATION UNITS. THE FINDINGS ALSO INCLUDED THAT THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THEAPPLICABLE SECURITIES LAWS AND REGULATIONS, INCLUDING SEC ANDFINRA RULES, CONCERNING AGGREGATION OF POSITIONS IN A SECURITYTO DETERMINE THE NET POSITIONS OF THE FIRM'S AGUS. SPECIFICALLY,THE FIRM'S WRITTEN SUPERVISORY PROCEDURES REGARDINGAGGREGATION OF POSITIONS IN A SECURITY IMPROPERLY PERMITTEDTHE INCLUSION OF CERTAIN NON-BROKER-DEALER AFFILIATES' TRADINGPOSITIONS IN DETERMINING THE NET POSITIONS OF THE FIRM'S AGUS.Resolution Date:11/16/2015Resolution:Other Sanctions Ordered:UNDERTAKING: REQUIRED TO REVISE THE FIRM'S WRITTENSUPERVISORY PROCEDURESSanction Details:THE FIRM WAS CENSURED, FINED $475,000 AND UNDERTAKES TO REVISEITS WRITTEN SUPERVISORY PROCEDURES.FINE PAID IN FULL ON DECEMBER 15, 2015.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $475,000.00Acceptance, Waiver & Consent(AWC)i76©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceReporting Source:FirmInitiated By:FINRADate Initiated:11/16/2015Docket/Case Number:2012034389401Principal Product Type:OtherOther Product Type(s):UNSPECIFIED SECURITIESAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITS TRADINGDESKS WERE ORGANIZED INTO SEPARATE AGGREGATION UNITS (AGUS),FOR PURPOSES OF COMPLIANCE WITH SEC RULE 200(1) AND PRE-EXISTING GUIDANCE CONCERNING THE PROPER USE OF AGUS. THEFINDINGS STATED THAT EACH OF THE SEPARATE AGUS CONTAINEDNUMEROUS TRADING BOOKS, FOR WHICH SECURITIES POSITIONS WERENETTED TOGETHER TO DETERMINE THE TOTAL NET POSITION OF THATAGU AND, ACCORDINGLY, WHETHER THE AGUS ORDERS SHOULD BEMARKED LONG OR SHORT. IN ADDITION TO THE FIRM'S PROPRIETARYPOSITIONS, THE AGUS ALSO IMPROPERLY INCLUDED THE TRADINGPOSITIONS OF NON-BROKER-DEALER AFFILIATES IN DETERMINING THEAGUS NET POSITIONS. AS A RESULT, THE FIRM'S AGUS FAILED TOACCURATELY REFLECT THE CORRECT POSITIONS WITHIN THEAPPROPRIATE TRADING BOOKS. THE FINDINGS ALSO STATED THAT THEFIRM'S WRITTEN PLAN OF ORGANIZATION FOR ITS AGGREGATION UNITSHAS FAILED TO ACCURATELY PROVIDE FOR THE OVERALL NET POSITIONOF THE SECURITIES THAT WERE TRADED AND MAINTAINED BY THE FIRM'SAGUS. MORE SPECIFICALLY, THE FIRM'S WRITTEN PLAN OFORGANIZATION FOR ITS AGUS IMPROPERLY PERMITTED THE INCLUSIONOF SECURITIES POSITIONS OF CERTAIN NON-BROKER-DEALERAFFILIATES IN DETERMINING THE NET POSITION OF THE FIRM'S AGUS ANDIMPROPERLY PERMITTED TRADERS TO BE ASSIGNED TO MULTIPLEAGGREGATION UNITS. THE FINDINGS ALSO INCLUDED THAT THE FIRM'SSUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THEAPPLICABLE SECURITIES LAWS AND REGULATIONS, INCLUDING SEC ANDFINRA RULES, CONCERNING AGGREGATION OF POSITIONS IN A SECURITYTO DETERMINE THE NET POSITIONS OF THE FIRM'S AGUS. SPECIFICALLY,THE FIRM'S WRITTEN SUPERVISORY PROCEDURES REGARDINGAGGREGATION OF POSITIONS IN A SECURITY IMPROPERLY PERMITTEDTHE INCLUSION OF CERTAIN NON-BROKER-DEALER AFFILIATES' TRADINGPOSITIONS IN DETERMINING THE NET POSITIONS OF THE FIRM'S AGUS.Current Status:Final77©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Resolution Date:11/16/2015Resolution:Other Sanctions Ordered:UNDERTAKING: REQUIRED TO REVISE THE FIRM'S WRITTENSUPERVISORY PROCEDURESSanction Details:THE FIRM WAS CENSURED, FINED $475,000 AND UNDERTAKES TO REVISEITS WRITTEN SUPERVISORY PROCEDURES.Sanctions Ordered:CensureMonetary/Fine $475,000.00Acceptance, Waiver & Consent(AWC)Disclosure 15 of 53iReporting Source:RegulatorAllegations:CFTC RELEASE 7265-15, OCTOBER 20, 2015: THE COMMODITY FUTURESTRADING COMMISSION ("COMMISSION") HAS REASON TO BELIEVE THATBNP PARIBAS SECURITIES CORP. ("BNPP" OR "RESPONDENT") VIOLATEDCOMMISSION REGULATIONS ("REGULATIONS") 1.25(B)(3)(I)(F) AND 1.25(B)(3)(II)(D). THEREFORE, THE COMMISSION DEEMS IT APPROPRIATEAND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVEPROCEEDINGS BE, AND HEREBY ARE, INSTITUTED TO DETERMINEWHETHER BNPP ENGAGED IN THE VIOLATIONS SET FORTH HEREIN ANDTO DETERMINE WHETHER ANY ORDER SHOULD BE ISSUED IMPOSINGREMEDIAL SANCTIONS. ON THREE OCCASIONS BNPP VIOLATED THECOMMISSION'S REGULATIONS GOVERNING CONCENTRATION LIMITSAPPLICABLE TO THE INVESTMENT OF SEGREGATED COMMODITYCUSTOMER FUNDS. BNPP REPORTED TWO OF THE VIOLATIONS TO THECOMMISSION. AN ADDITIONAL VIOLATION WAS DISCOVERED INCONNECTION WITH A REVIEW BY BNPP'S DESIGNATED SELF-REGULATORYORGANIZATION. NONE OF THE VIOLATIONS RESULTED IN CUSTOMERLOSSES. BASED ON THE FOREGOING, THE COMMISSION FINDS THATBNPP VIOLATED COMMISSION REGULATIONS 1.25(B)(3)(I)(F) AND 1.25(B)(3)(II)(D), 1.25(B)(3)(I)(F), 1.25(B)(3)(II)(D). IN ACCEPTING BNPP'S OFFER,THE COMMISSION RECOGNIZES BNPP'S COOPERATION DURING THEINVESTIGATION BY THE STAFF OF THE DIVISION OF ENFORCEMENT. THECOMMISSION ALSO RECOGNIZES THAT BNPP VOLUNTARILY UNDERTOOKREMEDIAL ACTION TO STRENGTHEN ITS POLICIES AND PROCEDURESCurrent Status:Final78©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:COMMODITY FUTURES TRADING COMMISSIONPrincipal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:Date Initiated:10/20/2015Docket/Case Number:16-01Principal Product Type:No ProductOther Product Type(s):RELATED TO COMPLIANCE WITH REGULATIONS 1.25(B)(3)(I)(F) AND 1.25(B)(3)(II)(D). THE COMMISSION ALSO NOTES THAT THE CIVIL MONETARYPENALTY IMPOSED ON BNPP REFLECTS BNPP'S EARLY RESOLUTION OFTHIS MATTER.Resolution Date:10/20/2015Resolution:Other Sanctions Ordered:PLUS POST-JUDGMENT INTEREST; AND CONDITIONS AND UNDERTAKINGSAS DESCRIBED IN THE OFFER.Sanction Details:BNPP SHALL CEASE AND DESIST FROM VIOLATING COMMISSIONREGULATIONS 1.25(B)(3)(I)(F) AND 1.25(B)(3)(II)(D), 1.25(B)(3)(I)(F), 1.25(B)(3)(II)(D); SHALL PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF$140,000, PLUS POST-JUDGMENT INTEREST; AND ITS SUCCESSORS ANDASSIGNS SHALL COMPLY WITH THE CONDITIONS AND UNDERTAKINGS ASDESCRIBED IN THE OFFER.Regulator StatementIN ANTICIPATION OF THE INSTITUTION OF AN ADMINISTRATIVEPROCEEDING, BNPP HAS SUBMITTED AN OFFER OF SETTLEMENT("OFFER"), WHICH THE COMMISSION HAS DETERMINED TO ACCEPT.WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS ORCONCLUSIONS, BNPP CONSENTS TO THE ENTRY OF THE ORDERINSTITUTING PROCEEDINGS PURSUANT TO SECTIONS 6(C) AND 6(D) OFTHE COMMODITY EXCHANGE ACT, MAKING FINDINGS AND IMPOSINGDoes the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:Monetary/Fine $140,000.00Cease and Desist/InjunctionOrder79©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceREMEDIAL SANCTIONS ("ORDER") AND ACKNOWLEDGES SERVICE OF THEORDER. ACCORDINGLY, IT IS HEREBY ORDERED THAT: BNPP SHALL CEASEAND DESIST FROM VIOLATING COMMISSION REGULATIONS 1.25(B)(3)(I)(F)AND 1.25(B)(3)(II)(D), 1.25(B)(3)(I)(F), 1.25(B)(3)(II)(D). BNPP SHALL PAY ACIVIL MONETARY PENALTY IN THE AMOUNT OF $140,000, PLUS POST-JUDGMENT INTEREST. BNPP AND ITS SUCCESSORS AND ASSIGNS SHALLCOMPLY WITH THE CONDITIONS AND UNDERTAKINGS AS DESCRIBED INTHE OFFER.iReporting Source:FirmInitiated By:COMMODITY FUTURES TRADING COMMISSIONDate Initiated:10/20/2015Docket/Case Number:16-01Allegations:CFTC RELEASE 7265-15, OCTOBER 20, 2015: THE COMMODITY FUTURESTRADING COMMISSION ("COMMISSION") HAS REASON TO BELIEVE THATBNP PARIBAS SECURITIES CORP. ("BNPP" OR "RESPONDENT") VIOLATEDCOMMISSION REGULATIONS ("REGULATIONS") 1.25(B)(3)(I)(F) AND 1.25(B)(3)(II)(D). THEREFORE, THE COMMISSION DEEMS IT APPROPRIATEAND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVEPROCEEDINGS BE, AND HEREBY ARE, INSTITUTED TO DETERMINEWHETHER BNPP ENGAGED IN THE VIOLATIONS SET FORTH HEREIN ANDTO DETERMINE WHETHER ANY ORDER SHOULD BE ISSUED IMPOSINGREMEDIAL SANCTIONS. ON THREE OCCASIONS BNPP VIOLATED THECOMMISSION'S REGULATIONS GOVERNING CONCENTRATION LIMITSAPPLICABLE TO THE INVESTMENT OF SEGREGATED COMMODITYCUSTOMER FUNDS. BNPP REPORTED TWO OF THE VIOLATIONS TO THECOMMISSION. AN ADDITIONAL VIOLATION WAS DISCOVERED INCONNECTION WITH A REVIEW BY BNPP'S DESIGNATED SELF-REGULATORYORGANIZATION. NONE OF THE VIOLATIONS RESULTED IN CUSTOMERLOSSES. BASED ON THE FOREGOING, THE COMMISSION FINDS THATBNPP VIOLATED COMMISSION REGULATIONS 1.25(B)(3)(I)(F) AND 1.25(B)(3)(II)(D), 1.25(B)(3)(I)(F), 1.25(B)(3)(II)(D). IN ACCEPTING BNPP'S OFFER,THE COMMISSION RECOGNIZES BNPP'S COOPERATION DURING THEINVESTIGATION BY THE STAFF OF THE DIVISION OF ENFORCEMENT. THECOMMISSION ALSO RECOGNIZES THAT BNPP VOLUNTARILY UNDERTOOKREMEDIAL ACTION TO STRENGTHEN ITS POLICIES AND PROCEDURESRELATED TO COMPLIANCE WITH REGULATIONS 1.25(B)(3)(I)(F) AND 1.25(B)(3)(II)(D). THE COMMISSION ALSO NOTES THAT THE CIVIL MONETARYPENALTY IMPOSED ON BNPP REFLECTS BNPP'S EARLY RESOLUTION OFTHIS MATTER.Current Status:Final80©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Cease and DesistOther Sanction(s)/ReliefSought:Principal Product Type:No ProductOther Product Type(s):Resolution Date:10/20/2015Resolution:Other Sanctions Ordered:PLUS POST-JUDGMENT INTEREST; AND CONDITIONS AND UNDERTAKINGSAS DESCRIBED IN THE OFFER.Sanction Details:BNPP SHALL CEASE AND DESIST FROM VIOLATING COMMISSIONREGULATIONS 1.25(B)(3)(I)(F) AND 1.25(B)(3)(II)(D), 1.25(B)(3)(I)(F), 1.25(B)(3)(II)(D); SHALL PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF$140,000, PLUS POST-JUDGMENT INTEREST; AND ITS SUCCESSORS ANDASSIGNS SHALL COMPLY WITH THE CONDITIONS AND UNDERTAKINGS ASDESCRIBED IN THE OFFER.Firm StatementIN ANTICIPATION OF THE INSTITUTION OF AN ADMINISTRATIVEPROCEEDING, BNPP HAS SUBMITTED AN OFFER OF SETTLEMENT("OFFER"), WHICH THE COMMISSION HAS DETERMINED TO ACCEPT.WITHOUT ADMITTING OR DENYING ANY OF THE FINDINGS ORCONCLUSIONS, BNPP CONSENTS TO THE ENTRY OF THE ORDERINSTITUTING PROCEEDINGS PURSUANT TO SECTIONS 6(C) AND 6(D) OFTHE COMMODITY EXCHANGE ACT, MAKING FINDINGS AND IMPOSINGREMEDIAL SANCTIONS ("ORDER") AND ACKNOWLEDGES SERVICE OF THEORDER. ACCORDINGLY, IT IS HEREBY ORDERED THAT: BNPP SHALL CEASEAND DESIST FROM VIOLATING COMMISSION REGULATIONS 1.25(B)(3)(I)(F)AND 1.25(B)(3)(II)(D), 1.25(B)(3)(I)(F), 1.25(B)(3)(II)(D). BNPP SHALL PAY ACIVIL MONETARY PENALTY IN THE AMOUNT OF $140,000, PLUS POST-JUDGMENT INTEREST. BNPP AND ITS SUCCESSORS AND ASSIGNS SHALLCOMPLY WITH THE CONDITIONS AND UNDERTAKINGS AS DESCRIBED INTHE OFFER.Sanctions Ordered:Monetary/Fine $140,000.00Cease and Desist/InjunctionOrderDisclosure 16 of 53iReporting Source:RegulatorAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDCurrent Status:Final81©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRADate Initiated:10/07/2015Docket/Case Number:2012031320301Principal Product Type:OptionsTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT POSITIONS TO THE LARGE OPTIONS POSITION REPORTINGSYSTEM (LOPR) IN APPROXIMATELY 4,412,234 MILLION INSTANCES,UNDER-REPORTED POSITIONS TO THE LOPR WITH AN INCORRECTMULTIPLIER IN APPROXIMATELY 1,798,873 INSTANCES, AND INACCURATELYREPORTED POSITIONS TO THE LOPR WITH "TBA" IN CERTAIN DATA FIELDSIN APPROXIMATELY 248,760 INSTANCES. THE FINDINGS STATED THAT IN 10DIFFERENT OPTIONS SERIES, THE FIRM INACCURATELY REPORTEDPOSITIONS TO THE LOPR WITH AN INCORRECT STRIKE PRICE, AND INFOUR INSTANCES, THE FIRM EFFECTED OPENING TRANSACTIONS FORCUSTOMER ACCOUNTS THAT EXCEEDED THE APPLICABLE POSITION LIMITIN THREE DIFFERENT OVER-THE-COUNTER (OTC) OPTIONS, RANGINGFROM APPROXIMATELY 120 PERCENT TO 168 PERCENT OVER THEAPPLICABLE LIMIT AND FROM 54 TO 179 TRADE DATES IN DURATION. INAPPROXIMATELY 8,356,301 INSTANCES, THE FIRM INACCURATELYREPORTED POSITIONS TO THE LOPR WITHOUT ENTRIES IN THE TAXIDENTIFICATION AND/OR TAX TYPE DATA FIELDS, IN APPROXIMATELY69,757 INSTANCES, THE FIRM FAILED TO REPORT TO THE LOPR CERTAINOPTIONS TRANSACTIONS INVOLVING FOREIGN UNDERLYING SECURITIESAND TRANSACTIONS IN WHICH THEY MISCLASSIFIED THECOUNTERPARTIES, AND IN APPROXIMATELY 6,771 INSTANCES, THE FIRMINACCURATELY REPORTED POSITIONS TO THE LOPR WITH THEINCORRECT QUANTITY OF CONTRACTS. IN TWO INSTANCES, THE FIRMEFFECTED OPENING TRANSACTIONS FOR CUSTOMER AND PROPRIETARYACCOUNTS THAT EXCEEDED THE APPLICABLE POSITION LIMIT IN AN OTCOPTION BY APPROXIMATELY 186 PERCENT FOR A SINGLE TRADE DATE,AND IN 20 INSTANCES, THE FIRM EFFECTED OPENING TRANSACTIONSFOR CUSTOMER AND PROPRIETARY ACCOUNTS THAT EXCEEDED THEAPPLICABLE POSITION LIMIT IN EIGHT DIFFERENT OTC OPTIONS,RANGING FROM APPROXIMATELY 105 PERCENT TO 4922 PERCENT OVERTHE APPLICABLE LIMIT AND FROM 2 TO 419 TRADE DATES IN DURATION.THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH ANDMAINTAIN A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIES LAWS ANDREGULATIONS, AND FINRA RULES, CONCERNING POSITION LIMITS ANDTHE REPORTING OF POSITIONS TO THE LOPR. THE FIRM'S SUPERVISORYSYSTEM DID NOT INCLUDE SUFFICIENT WRITTEN SUPERVISORYPROCEDURES TO ENSURE THE PROPER REPORTING OF POSITIONS TOTHE LOPR.82©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Other Product Type(s):Resolution Date:10/07/2015Resolution:Other Sanctions Ordered:UNDERTAKING: ADDRESS THE LOPR REPORTING AND POSITION LIMITDEFICIENCIES DESCRIBED ABOVE TO ENSURE THAT THE FIRM HASIMPLEMENTED PROCEDURES THAT ARE REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH THE RULES AND REGULATIONS, INCLUDINGTHE PROPER REPORTING OF OPTIONS TRANSACTIONS INVOLVINGFOREIGN UNDERLYING SECURITIES.Sanction Details:THE FIRM WAS CENSURED, FINED $2.4 MILLION AND UNDERTAKES TOADDRESS THE LOPR REPORTING AND POSITION LIMIT DEFICIENCIESDESCRIBED ABOVE TO ENSURE THAT THE FIRM HAS IMPLEMENTEDPROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH THE RULES AND REGULATIONS, INCLUDING THEPROPER REPORTING OF OPTIONS TRANSACTIONS INVOLVING FOREIGNUNDERLYING SECURITIES. FINE PAID IN FULL OCTOBER 23, 2015.Regulator StatementIN DETERMINING TO RESOLVE THIS MATTER IN THE MANNER SET FORTHHEREIN, AND IN DETERMINING THE APPROPRIATE MONETARY SANCTION,FINRA SIGNIFICANTLY CONSIDERED: (I) THAT THE FIRM SELF-REPORTEDALL OF ITS LOPR VIOLATIONS; (II) THE SIGNIFICANT REMEDIAL STEPSUNDERTAKEN BY THE FIRM, INCLUDING VOLUNTARILY RETAINING ANINDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF THE FIRM'S LOPRSYSTEMS AND REPORTING LOGIC, IDENTIFY DEFICIENCIES ANDRECOMMEND REMEDIAL STEPS; (III) THE FIRM'S EFFORTS TO IMPLEMENTTHOSE RECOMMENDATIONS; AND (IV) THE DEGREE OF COOPERATION BYTHE FIRM DURING THE INVESTIGATION, INCLUDING PROVIDING ACALCULATION OF THE NUMBER OF UNREPORTED POSITIONS, A REPORTOF THE INDEPENDENT CONSULTANT'S ANALYSIS ANDRECOMMENDATIONS, AND STATUS REPORTS ON IMPLEMENTATION OFDoes the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $2,400,000.00Acceptance, Waiver & Consent(AWC)83©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceTHOSE RECOMMENDATIONS.iReporting Source:FirmAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT POSITIONS TO THE LARGE OPTIONS POSITION REPORTINGSYSTEM (LOPR) IN APPROXIMATELY 4,412,234 MILLION INSTANCES,UNDER-REPORTED POSITIONS TO THE LOPR WITH AN INCORRECTMULTIPLIER IN APPROXIMATELY 1,798,873 INSTANCES, AND INACCURATELYREPORTED POSITIONS TO THE LOPR WITH "TBA" IN CERTAIN DATA FIELDSIN APPROXIMATELY 248,760 INSTANCES. THE FINDINGS STATED THAT IN 10DIFFERENT OPTIONS SERIES, THE FIRM INACCURATELY REPORTEDPOSITIONS TO THE LOPR WITH AN INCORRECT STRIKE PRICE, AND INFOUR INSTANCES, THE FIRM EFFECTED OPENING TRANSACTIONS FORCUSTOMER ACCOUNTS THAT EXCEEDED THE APPLICABLE POSITION LIMITIN THREE DIFFERENT OVER-THE-COUNTER (OTC) OPTIONS, RANGINGFROM APPROXIMATELY 120 PERCENT TO 168 PERCENT OVER THEAPPLICABLE LIMIT AND FROM 54 TO 179 TRADE DATES IN DURATION. INAPPROXIMATELY 8,356,301 INSTANCES, THE FIRM INACCURATELYREPORTED POSITIONS TO THE LOPR WITHOUT ENTRIES IN THE TAXIDENTIFICATION AND/OR TAX TYPE DATA FIELDS, IN APPROXIMATELY69,757 INSTANCES, THE FIRM FAILED TO REPORT TO THE LOPR CERTAINOPTIONS TRANSACTIONS INVOLVING FOREIGN UNDERLYING SECURITIESAND TRANSACTIONS IN WHICH THEY MISCLASSIFIED THECOUNTERPARTIES, AND IN APPROXIMATELY 6,771 INSTANCES, THE FIRMINACCURATELY REPORTED POSITIONS TO THE LOPR WITH THEINCORRECT QUANTITY OF CONTRACTS. IN TWO INSTANCES, THE FIRMEFFECTED OPENING TRANSACTIONS FOR CUSTOMER AND PROPRIETARYACCOUNTS THAT EXCEEDED THE APPLICABLE POSITION LIMIT IN AN OTCOPTION BY APPROXIMATELY 186 PERCENT FOR A SINGLE TRADE DATE,AND IN 20 INSTANCES, THE FIRM EFFECTED OPENING TRANSACTIONSFOR CUSTOMER AND PROPRIETARY ACCOUNTS THAT EXCEEDED THEAPPLICABLE POSITION LIMIT IN EIGHT DIFFERENT OTC OPTIONS,RANGING FROM APPROXIMATELY 105 PERCENT TO 4922 PERCENT OVERTHE APPLICABLE LIMIT AND FROM 2 TO 419 TRADE DATES IN DURATION.THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH ANDMAINTAIN A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIES LAWS ANDREGULATIONS, AND FINRA RULES, CONCERNING POSITION LIMITS ANDTHE REPORTING OF POSITIONS TO THE LOPR. THE FIRM'S SUPERVISORYSYSTEM DID NOT INCLUDE SUFFICIENT WRITTEN SUPERVISORYPROCEDURES TO ENSURE THE PROPER REPORTING OF POSITIONS TOCurrent Status:Final84©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:10/07/2015Docket/Case Number:2012031320301Principal Product Type:OptionsOther Product Type(s):THE LOPR.Resolution Date:10/07/2015Resolution:Other Sanctions Ordered:UNDERTAKING: ADDRESS THE LOPR REPORTING AND POSITION LIMITDEFICIENCIES DESCRIBED ABOVE TO ENSURE THAT THE FIRM HASIMPLEMENTED PROCEDURES THAT ARE REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH THE RULES AND REGULATIONS, INCLUDINGTHE PROPER REPORTING OF OPTIONS TRANSACTIONS INVOLVINGFOREIGN UNDERLYING SECURITIES.Sanction Details:THE FIRM WAS CENSURED, FINED $2.4 MILLION AND UNDERTAKES TOADDRESS THE LOPR REPORTING AND POSITION LIMIT DEFICIENCIESDESCRIBED ABOVE TO ENSURE THAT THE FIRM HAS IMPLEMENTEDPROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVECOMPLIANCE WITH THE RULES AND REGULATIONS, INCLUDING THEPROPER REPORTING OF OPTIONS TRANSACTIONS INVOLVING FOREIGNUNDERLYING SECURITIES. FINE PAID IN FULL OCTOBER 23, 2015Firm StatementIN DETERMINING TO RESOLVE THIS MATTER IN THE MANNER SET FORTHHEREIN, AND IN DETERMINING THE APPROPRIATE MONETARY SANCTION,FINRA SIGNIFICANTLY CONSIDERED: (I) THAT THE FIRM SELF-REPORTEDALL OF ITS LOPR VIOLATIONS; (II) THE SIGNIFICANT REMEDIAL STEPSUNDERTAKEN BY THE FIRM, INCLUDING VOLUNTARILY RETAINING ANINDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF THE FIRM'S LOPRSYSTEMS AND REPORTING LOGIC, IDENTIFY DEFICIENCIES ANDRECOMMEND REMEDIAL STEPS; (III) THE FIRM'S EFFORTS TO IMPLEMENTTHOSE RECOMMENDATIONS; AND (IV) THE DEGREE OF COOPERATION BYTHE FIRM DURING THE INVESTIGATION, INCLUDING PROVIDING ACALCULATION OF THE NUMBER OF UNREPORTED POSITIONS, A REPORTSanctions Ordered:CensureMonetary/Fine $2,400,000.00Acceptance, Waiver & Consent(AWC)85©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOF THE INDEPENDENT CONSULTANT'S ANALYSIS ANDRECOMMENDATIONS, AND STATUS REPORTS ON IMPLEMENTATION OFTHOSE RECOMMENDATIONS.Disclosure 17 of 53iReporting Source:RegulatorInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:08/07/2015Docket/Case Number:2014040111801Principal Product Type:Debt - CorporateOther Product Type(s):AGENCY DEBT SECURITIES; SECURITIZED PRODUCTSAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT S1 TRANSACTIONS IN TRADE REPORTING AND COMPLIANCEENGINE (TRACE)-ELIGIBLE CORPORATE DEBT SECURITIES TO TRACEWITHIN 15 MINUTES OF THE TIME OF EXECUTION, FAILED TO REPORT THECORRECT MARKET IDENTIFIER FOR P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES TO TRACE, AND FAILED TOREPORT THE CORRECT TIME OF TRADE EXECUTION FOR P1TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES TOTRACE. THE FINDINGS STATED THAT THE FIRM FAILED TO REPORT THECORRECT TIME OF TRADE EXECUTION FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS TO TRACE AND FAILED TO SHOW THECORRECT TIME OF EXECUTION ON THE MEMORANDUM OF BROKERAGEORDERS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REPORTS1 TRANSACTIONS IN TRACE-ELIGIBLE AGENCY DEBT SECURITIES TOTRACE WITHIN 15 MINUTES OF THE TIME OF EXECUTION AND FAILED TOREPORT TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBTSECURITIES TO TRACE WITHIN 15 MINUTES OF THE TIME OF EXECUTION.Current Status:FinalResolution Date:08/07/2015Resolution:Acceptance, Waiver & Consent(AWC)86©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $50,000. FINE PAID IN FULL ONSEPTEMBER 10, 2015.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $50,000.00iReporting Source:FirmInitiated By:FINRADate Initiated:08/07/2015Docket/Case Number:2014040111801Principal Product Type:Debt - CorporateOther Product Type(s):AGENCY DEBT SECURITIES; SECURITIZED PRODUCTSAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT S1 TRANSACTIONS IN TRADE REPORTING AND COMPLIANCEENGINE (TRACE)-ELIGIBLE CORPORATE DEBT SECURITIES TO TRACEWITHIN 15 MINUTES OF THE TIME OF EXECUTION, FAILED TO REPORT THECORRECT MARKET IDENTIFIER FOR P1 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES TO TRACE, AND FAILED TOREPORT THE CORRECT TIME OF TRADE EXECUTION FOR P1TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES TOTRACE. THE FINDINGS STATED THAT THE FIRM FAILED TO REPORT THECORRECT TIME OF TRADE EXECUTION FOR TRANSACTIONS IN TRACE-ELIGIBLE SECURITIZED PRODUCTS TO TRACE AND FAILED TO SHOW THECORRECT TIME OF EXECUTION ON THE MEMORANDUM OF BROKERAGEORDERS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REPORTS1 TRANSACTIONS IN TRACE-ELIGIBLE AGENCY DEBT SECURITIES TOTRACE WITHIN 15 MINUTES OF THE TIME OF EXECUTION AND FAILED TOREPORT TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE DEBTSECURITIES TO TRACE WITHIN 15 MINUTES OF THE TIME OF EXECUTION.Current Status:Final87©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Resolution Date:08/07/2015Resolution:Other Sanctions Ordered:Sanction Details:CENSURED AND FINED $50,0000.FINE PAID SEPTEMBER 10, 2015Sanctions Ordered:CensureMonetary/Fine $50,000.00Acceptance, Waiver & Consent(AWC)Disclosure 18 of 53iReporting Source:RegulatorInitiated By:CHICAGO BOARD OPTIONS EXCHANGEDate Initiated:05/06/2015Docket/Case Number:15-0048 / 20150452247Allegations:BNP PARIBAS SECURITIES CORP. ("BNP"), AN EXCHANGE TPHORGANIZATION, WAS CENSURED AND FINED $55,000 FOR THE FOLLOWINGCONDUCT. BNP (I) FAILED TO REGISTER TEN (10) ASSOCIATED PERSONSAS PROPRIETARY TRADER (PT) WITH THE EXCHANGE IN WEBCRD, ONE OFWHOM WAS NOT QUALIFIED TO ACT IN THE CAPACITY OF A PROPRIETARYTRADER (PT); (II) FAILED TO REGISTER SEVEN (7) ASSOCIATED PERSONSAS A PROPRIETARY TRADER PRINCIPAL (TP) WITH THE EXCHANGE INWEBCRD, ONE OF WHOM WAS NOT QUALIFIED TO ACT IN THE CAPACITYOF A PROPRIETARY TRADER PRINCIPAL (TP); (III) FAILED TO REGISTER ITSFINANCIAL AND OPERATIONS PRINCIPAL AS A FINANCIAL AND OPERATIONSPRINCIPAL (FN) WITH THE EXCHANGE IN WEBCRD; (IV) FAILED TOREGISTER THE MINIMUM NUMBER OF INDIVIDUALS REQUIRED TOREGISTER AS A PROPRIETARY TRADER PRINCIPAL (TP) WITH THEEXCHANGE IN WEBCRD; (V) FAILED TO REGISTER ITS FORMER CHIEFCOMPLIANCE OFFICER ("CCO") AS PROPRIETARY TRADER COMPLIANCEOFFICER (CT) WITH THE EXCHANGE IN WEBCRD; AND (VI) FAILED TOQUALIFY AND REGISTER ITS CURRENT CCO AS PROPRIETARY TRADERCOMPLIANCE OFFICER (CT) WITH THE EXCHANGE IN WEBCRD..(EXCHANGE RULE 3.6A - QUALIFICATION AND REGISTRATION OF TRADINGPERMIT HOLDERS AND ASSOCIATED PERSONS)Current Status:Pending88©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Principal Product Type:OptionsOther Product Type(s):Resolution Date:08/10/2015Resolution:Other Sanctions Ordered:Sanction Details:A $55,000 FINE AND A CENSURE.Sanctions Ordered:CensureMonetary/Fine $55,000.00Decision & Order of Offer of SettlementiReporting Source:FirmInitiated By:CHICAGO BOARD OPTIONS EXCHANGEDate Initiated:05/06/2015Allegations:BNP PARIBAS SECURITIES CORP. ("BNP"), AN EXCHANGE TPHORGANIZATION, WAS CENSURED AND FINED $55,000 FOR THE FOLLOWINGCONDUCT. BNP (I) FAILED TO REGISTER TEN (10) ASSOCIATED PERSONSAS PROPRIETARY TRADER (PT) WITH THE EXCHANGE IN WEBCRD, ONE OFWHOM WAS NOT QUALIFIED TO ACT IN THE CAPACITY OF A PROPRIETARYTRADER (PT); (II) FAILED TO REGISTER SEVEN (7) ASSOCIATED PERSONSAS A PROPRIETARY TRADER PRINCIPAL (TP) WITH THE EXCHANGE INWEBCRD, ONE OF WHOM WAS NOT QUALIFIED TO ACT IN THE CAPACITYOF A PROPRIETARY TRADER PRINCIPAL (TP); (III) FAILED TO REGISTER ITSFINANCIAL AND OPERATIONS PRINCIPAL AS A FINANCIAL AND OPERATIONSPRINCIPAL (FN) WITH THE EXCHANGE IN WEBCRD; (IV) FAILED TOREGISTER THE MINIMUM NUMBER OF INDIVIDUALS REQUIRED TOREGISTER AS A PROPRIETARY TRADER PRINCIPAL (TP) WITH THEEXCHANGE IN WEBCRD; (V) FAILED TO REGISTER ITS FORMER CHIEFCOMPLIANCE OFFICER ("CCO") AS PROPRIETARY TRADER COMPLIANCEOFFICER (CT) WITH THE EXCHANGE IN WEBCRD; AND (VI) FAILED TOQUALIFY AND REGISTER ITS CURRENT CCO AS PROPRIETARY TRADERCOMPLIANCE OFFICER (CT) WITH THE EXCHANGE IN WEBCRD.(EXCHANGE RULE 3.6A - QUALIFICATION AND REGISTRATION OF TRADINGPERMIT HOLDERS AND ASSOCIATED PERSONS)Current Status:Final89©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Docket/Case Number:15-0048/20150452247Principal Product Type:OptionsOther Product Type(s):Resolution Date:08/10/2015Resolution:Other Sanctions Ordered:Sanction Details:A $55,000 FINE AND A CENSURE.Sanctions Ordered:CensureMonetary/Fine $55,000.00Decision & Order of Offer of SettlementDisclosure 19 of 53iReporting Source:RegulatorInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Date Initiated:04/08/2015Docket/Case Number:2012031657201Principal Product Type:No ProductOther Product Type(s):Allegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITTRANSMITTED REPORTS THAT CONTAINED INACCURATE, INCOMPLETE,OR IMPROPERLY FORMATTED DATA TO ORDER AUDIT TRAIL SYSTEM(OATS). THE FINDINGS STATED THAT PRIOR TO EXECUTING ORPERMITTING ORDERS TO BE EXECUTED, THE FIRM FAILED TO REDUCE,INCREASE OR ADJUST THE PRICE AND/OR NUMBER OF SHARES OF SUCHORDERS BY AN AMOUNT EQUAL TO THE DIVIDEND, PAYMENT ORDISTRIBUTION, ON THE DAY THAT THE SECURITY WAS QUOTED EX-DIVIDEND, EX-RIGHTS, EX-DISTRIBUTION OR EX-INTEREST.Current Status:Final90©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanction(s)/ReliefSought:Resolution Date:04/08/2015Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $15,000. FINE PAID IN FULL ON5/15/2015.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $15,000.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmAllegations:DURING THE REVIEW PERIOD SEPTEMPBER 11, 2012 AND SEPTEMBER 12,2012, THE FIRM TRANSMITTED TO OATS 54 REPORTS THAT CONTAINEDINACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA.SPECIFICALLY, THE FINN: (A) SUBMITTED INCORRECT ACCOUNT TYPECODES OF"A" FOR 34 REPORTS; (B) FAILED TO SUBMIT THE ''NOT HELD"SPECIAL HANDLING CODE FOR SIX REPORTS; (C) FAILED TO SUBMIT THE "DIRECTED" SPECIAL HANDLING CODE FOR FIVE REPORTS; (D) FAILED TOSUBMIT INFORMATION TO OATS FOR FOUR ORDERS; (E) FAILED TOSUBMIT THE "NOT HELD" SPECIAL HANDLING CODE AND SUBMITTEDINCORRECT ACCOUNT TYPE CODES OF "L" FOR THREE REPORTS; (F)FAILED TO SUBMIT THE "NOT HELD" SPECIAL HANDLING CODE ANDSUBMITTED AN INCORRECT ACCOUNT TYPE CODE OF "A" FOR ONEREPORT; AND (H) FAILED TO SUBMIT THE "DIRECTED" SPECIAL HANDLINGCODE AND SUBMITTED AN INCORRECT ACCOUNT TYPE CODE OF "A" FORONE REPORT. THE CONDUCT DESCRIBED IN THIS PARAGRAPHCONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 7450.DURING THE REVIEW PERIOD, THE FIRM FAILED- PRIOR TO EXECUTINGOR PERMITTING SEVEN ORDERS TO BE EXECUTED - TO REDUCE,INCREASE OR ADJUST THE PRICE AND/OR NUMBER OF SHARES OF SUCHORDERS BY AN AMOUNT EQUAL TO THE DIVIDEND, PAYMENT ORDISTRIBUTION, ON THE DAY THAT THE SECURITY WAS QUOTED EX-Current Status:Final91©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:03/06/2015Docket/Case Number:20120316572Principal Product Type:No ProductOther Product Type(s):DIVIDEND, EX-RIGHTS, EX-DISTRIBUTION OR EX-INTEREST. THE CONDUCTDESCRIBED IN THIS PARAGRAPH CONSTITUTES SEPARATE AND DISTINCTVIOLATIONS OF FINRA RULE 5330.Resolution Date:03/09/2015Resolution:Other Sanctions Ordered:Sanction Details:A CENSURE AND FINED $15,000.00Sanctions Ordered:CensureMonetary/Fine $15,000.00Acceptance, Waiver & Consent(AWC)Disclosure 20 of 53iReporting Source:RegulatorInitiated By:FINRADate Initiated:12/22/2014Docket/Case Number:2013036460801Allegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO FINRA ITS SHORT INTEREST IN 2,509 POSITIONS TOTALING6,051,974 SHARES. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLESECURITIES LAWS AND REGULATIONS, AND FINRA RULES, CONCERNINGSHORT INTEREST REPORTING.Current Status:Final92©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Principal Product Type:No ProductOther Product Type(s):Resolution Date:12/22/2014Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $30,000.FINE PAID IN FULL ON JANUARY 12, 2015.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $30,000.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmInitiated By:FINRADate Initiated:12/22/2014Docket/Case Number:2013036460801Principal Product Type:No ProductAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO FINRA ITS SHORT INTEREST IN 2,509 POSITIONS TOTALING6,051,974 SHARES. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORYSYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNEDTO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLESECURITIES LAWS AND REGULATIONS, AND FINRA RULES, CONCERNINGSHORT INTEREST REPORTING.Current Status:Final93©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Other Product Type(s):Resolution Date:12/22/2014Resolution:Other Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $30,000.Sanctions Ordered:CensureMonetary/Fine $30,000.00Acceptance, Waiver & Consent(AWC)Disclosure 21 of 53iReporting Source:RegulatorInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:12/05/2014Docket/Case Number:2013036731801Principal Product Type:Debt - CorporateOther Product Type(s):Allegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT AS MANAGINGUNDERWRITER, THE FIRM FAILED TO REPORT NEW ISSUE OFFERINGS INTRADE REPORTING AND COMPLIANCE ENGINE (TRACE)-ELIGIBLECORPORATE SECURITIES IN ACCORDANCE WITH THE REQUIREMENTS OFFINRA RULE 6760(C).Current Status:FinalResolution Date:12/05/2014Resolution:Acceptance, Waiver & Consent(AWC)94©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanctions Ordered:Sanction Details:THE FIRM WAS CENSURED AND FINED $7,500. FINE PAID IN FULL ONDECEMBER 29, 2014.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $7,500.00iReporting Source:FirmInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:12/05/2014Docket/Case Number:2013036731801Principal Product Type:Debt - CorporateOther Product Type(s):Allegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT AS MANAGINGUNDERWRITER, THE FIRM FAILED TO REPORT NEW ISSUE OFFERINGS INTRADE REPORTING AND COMPLIANCE ENGINE(TRACE)-ELIGIBLE CORPORATE SECURITIES IN ACCORDANCE WITH THEREQUIREMENTS OF FINRA RULE 6760(C).Current Status:FinalResolution Date:12/05/2014Resolution:Other Sanctions Ordered:Sanctions Ordered:CensureMonetary/Fine $7,500.00Acceptance, Waiver & Consent(AWC)95©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceSanction Details:CENSURED AND FINED $7,500Disclosure 22 of 53iReporting Source:FirmInitiated By:CBOTPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:10/09/2014Docket/Case Number:CBOT 13-9567-BCPrincipal Product Type:No ProductOther Product Type(s):Allegations:PURSUANT TO AN OFFER OF SETTLEMENT IN WHICH BNP PARIBASSECURITIES CORP. ("BNP") NEITHER ADMITTED NOR DENIED THE RULEVIOLATION UPON WHICH THE PENALTY IS BASED, A PANEL OF THE CBOTBUSINESS CONDUCT COMMITTEE ("PANEL") FOUND THAT IT HADJURISDICTION OVER BNP PURSUANT TO RULES 400 AND 402, AS BNP IS ACBOT CLEARING MEMBER. THE PANEL ALSO FOUND THAT ON JULY 6, 2012,BNP REPORTED TO THE EXCHANGE 128 LONG POSITIONS ELIGIBLE FORDELIVERY IN JULY 2012 WHEAT FUTURES EVEN THOUGH THOSEPOSITIONS HAD PREVIOUSLY BEEN CLOSED OUT, AND BNP WASASSIGNED TO TAKE PHYSICAL DELIVERY ON 114 OF THE 128 POSITIONS.THIS INACCURATE REPORT REPRESENTED 51.8% OF THE TOTAL INTENTSIN JULY 2012 WHEAT ON THAT DAY. AFTER DISCOVERING ITS ERROR, BNPRETENDERED THE 114 POSITIONS THE FOLLOWING BUSINESS DAY, JULY9, 2012. THE PANEL CONCLUDED THAT BNP THEREBY VIOLATED CBOTRULE 807.Current Status:FinalResolution Date:10/13/2014Resolution:Other Sanctions Ordered:Sanction Details:IN ACCORDANCE WITH THE SETTLEMENT OFFER, THE PANEL ORDEREDBNP TO PAY A FINE OF $25,000. FINE PAID 10/21/2014.Sanctions Ordered:Monetary/Fine $25,000.00Decision & Order of Offer of Settlement96©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceDisclosure 23 of 53iReporting Source:FirmInitiated By:CHICAGO BOARD OPTIONS TRADEPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:06/19/2014Docket/Case Number:14-CH-1401Principal Product Type:No ProductOther Product Type(s):Allegations:PURSUANT TO AN OFFER OF SETTLEMENT IN WHICH BNP PARIBASSECURITIES CORP. NEITHER ADMITTED NOR DENIED THE RULEVIOLATIONS UPON WHICH THE PENALTY IS BASED, ON JUNE 19, 2014, THECLEARING HOUSE RISK COMMITTEE FOUND THAT BNP PARIBASSECURITIES CORP. VIOLATED CBOT RULES 971.A.4 AND 980.B. FINED$75,000.Current Status:FinalResolution Date:06/20/2014Resolution:Other Sanctions Ordered:Sanction Details:FINED $75,000. FINE PAID JULY 7, 2014.Sanctions Ordered:Monetary/Fine $75,000.00Decision & Order of Offer of SettlementDisclosure 24 of 53iReporting Source:RegulatorAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRMTRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) EXECUTIONOR COMBINED ORDER/EXECUTION REPORTS THAT CONTAINEDINACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA. THEFINDINGS STATED THAT BECAUSE OF THE INACCURATE, MISSING, ORCurrent Status:Final97©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:04/07/2014Docket/Case Number:2012033873101Principal Product Type:No ProductOther Product Type(s):IMPROPERLY FORMATTED DATA, OATS WAS UNABLE TO LINK THEEXECUTION REPORTS TO THE RELATED TRADE REPORTS IN A FINRATRADE REPORTING SYSTEM.Resolution Date:04/07/2014Resolution:Other Sanctions Ordered:Sanction Details:SEE ABOVEFINES PAID IN FULL ON MAY 16, 2014.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:Monetary/Fine $5,000.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THEFIRM TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS)EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THATCONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTEDDATA. THE FINDINGS STATED THAT BECAUSE OF THE INACCURATE,MISSING, OR IMPROPERLY FORMATTED DATA, OATS WAS UNABLE TO LINKTHE EXECUTION REPORTS TO THE RELATED TRADE REPORTS INCurrent Status:Final98©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:04/07/2014Docket/Case Number:2012033873101Principal Product Type:No ProductOther Product Type(s):A FINRA TRADE REPORTING SYSTEM.Resolution Date:04/07/2014Resolution:Other Sanctions Ordered:Sanction Details:SEE ABOVESanctions Ordered:Monetary/Fine $5,000.00Acceptance, Waiver & Consent(AWC)Disclosure 25 of 53iReporting Source:RegulatorInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Date Initiated:03/12/2014Docket/Case Number:2013035848201Principal Product Type:OtherOther Product Type(s):NMS SECURITIESAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED,WITHIN 30 SECONDS AFTER EXECUTION, TO TRANSMIT TO THEFINRA/NASDAQ TRADE REPORTING FACILITY (FNTRF) LAST SALEREPORTS OF TRANSACTIONS IN NMS SECURITIES, AND FAILED TODESIGNATE THROUGH THE FNTRF THREE OF SUCH REPORTS AS LATE.Current Status:Final99©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanction(s)/ReliefSought:Resolution Date:03/12/2014Resolution:Other Sanctions Ordered:Sanction Details:SEE ABOVEDoes the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:Monetary/Fine $5,000.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:03/12/2014Docket/Case Number:2013035848201Principal Product Type:OtherOther Product Type(s):NMS SECURITIESAllegations:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED,WITHIN 30 SECONDS AFTER EXECUTION, TO TRANSMIT TO THEFINRA/NASDAQ TRADING REPORTING FACILITY (FNTRF) LAST SALEREPORTS OF TRANSACTIONS IN NMS SECURITIES, AND FAILED TODESIGNATE THROUGH THE FNTRF THREE OF SUCH REPORTS AS LATE.Current Status:FinalResolution Date:03/12/2014Resolution:Sanctions Ordered:Monetary/Fine $5,000.00Acceptance, Waiver & Consent(AWC)100©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED,WITHIN 30 SECONDS AFTER EXECUTION, TO TRANSMIT TO THEFINRA/NASDAQ TRADING REPORTING FACILITY (FNTRF) LAST SALEREPORTS OF TRANSACTIONS IN NMS SECURITIES, AND FAILED TODESIGNATE THROUGH THE FNTRF THREE OF SUCH REPORTS AS LATE.Disclosure 26 of 53iReporting Source:RegulatorAllegations:NYSE ARCA EQUITIES RULE 6.18 - BNP PARIBAS SECURITIES CORP. NON-EQUITIES TRADING PERMIT (ETP) HOLDER CUSTOMERS ENGAGED INPOTENTIALLY MANIPULATIVE TRADING AT OR NEAR THE CLOSE OFTRADING (MARKING THE CLOSE) THAT AFFECTED THE CLOSING PRICE OFCERTAIN STOCKS. ONE CUSTOMER ENGAGED IN WHAT APPEARED TO BEMARKING-THE-CLOSE ACTIVITY IN THREE SECURITIES OVER 22 TRADEDATES; A SECOND CUSTOMER ENGAGED IN WHAT APPEARED TO BEMARKING-THE-CLOSE ACTIVITY IN A SINGLE SECURITY ON FOUR TRADEDATES; AND A THIRD CUSTOMER ENGAGED IN WHAT APPEARED TO BEMARKING-THE-CLOSE ACTIVITY IN A SINGLE SECURITY ON THREE TRADEDATES. THE FIRM IDENTIFIED ONLY NINE OF THE 58 ALERTS NOTED FORTHIS ACTIVITY. THE FIRM'S MARKING-THE-CLOSE SURVEILLANCE WASINADEQUATE BECAUSE IT FAILED TO CAPTURE MOST OF ITS CUSTOMERS'POTENTIAL OR ACTUAL VIOLATIVE CONDUCT. PRIOR TO A CERTAIN DATE,THE FIRM DID NOT INCLUDE CUSTOMER ACCOUNTS IN ITS MARKING-THE-CLOSE REVIEWS AND DID NOT CONDUCT ANY REVIEWS FORAPPROXIMATELY ONE MONTH DURING A SYSTEMS MIGRATION.THEREAFTER, THE FIRM'S REVIEWS WERE NOT SUFFICIENTLY DESIGNEDTO CAPTURE AND REVIEW POTENTIALLY VIOLATIVE CONDUCT. THE FIRMEXCLUDED FROM ITS REVIEWS MARKET AND MARKETABLE LIMITORDERS, ORDERS VALUED AT LESS THAN $2,500, AND FULLY EXECUTEDAND/OR CANCELED ORDERS. THE FIRM DID NOT CONDUCT A SUFFICIENTREVIEW AND ANALYSIS OF THOSE TRADES THAT IT DID CAPTURE. FORAPPROXIMATELY 16 MONTHS, THE FIRM ESCALATED FOR FURTHERREVIEW AND ANALYSIS ONLY FIVE OF MORE THAN 15,000 ALERTSGENERATED BY ITS AUTOMATED SURVEILLANCE. THE FIRM'S WRITTENSUPERVISORY PROCEDURES DID NOT ADEQUATELY ADDRESS THE FULLREVIEW AND ESCALATION PROCEDURES FOR ITS MARKING-THE-CLOSESURVEILLANCE SYSTEM. THE FIRM DID NOT HAVE A SPECIFICSURVEILLANCE REVIEW FOR WASH TRAINING AND PRIOR TO A LATERDATE, ITS REVIEW DID NOT INCLUDE CUSTOMER ACCOUNTS.Current Status:Final101©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:NYSE ARCA, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:11/04/2013Docket/Case Number:20110278755Principal Product Type:Equity Listed (Common & Preferred Stock)Other Product Type(s):Resolution Date:11/04/2013Resolution:Other Sanctions Ordered:Sanction Details:A FINRA HEARING OFFICER CONSIDERED AN OFFER OF SETTLEMENT ANDCONSENT ENTERED INTO BETWEEN FINRA ON BEHALF OF NYSEREGULATION, INC. AND THE FIRM. THE HEARING OFFICER ACCEPTED THEOFFER OF SETTLEMENT AND CONSENT; THEREFORE, THE FIRM ISCENSURED AND FINED $150,000. IN DETERMINING TO RESOLVE THISMATTER, FINRA TOOK INTO CONSIDERATION THAT THE FIRM MADECHANGES TO ITS SUPERVISORY SYSTEMS AND PROCEDURES FORREVIEWING TRADING ACTIVITY AT OR NEAR THE CLOSE, WASH SALES,AND/OR MATCHED ORDERS, AS WELL AS THAT THE FIRM REPRESENTEDTO FINRA THAT IT WOULD IMPLEMENT FURTHER CHANGES TO ITSSUPERVISORY SYSTEMS AND PROCEDURES IN THIS AREA ON OR BEFOREA CERTAIN DATE. THE SANCTIONS SHALL TAKE EFFECT IMMEDIATELY. THEFINE MUST BE PAID WITHIN 30 DAYS OF THE DATE OF THE DECISION ORTHE FIRM MAY FACE SUSPENSION.Regulator StatementOTHER CASE NUMBERS: 20110279000, 20110291836, 20120346202, 13-ARCA-24Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $150,000.00Decision & Order of Offer of Settlementi102©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceReporting Source:FirmInitiated By:NYSE ARCA, INC.Principal Sanction(s)/ReliefSought:Date Initiated:11/04/2013Docket/Case Number:20110278755Principal Product Type:Equity Listed (Common & Preferred Stock)Other Product Type(s):Allegations:NYSE ARCA EQUITIES RULE 6.18 - BNP PARIBAS SECURITIES CORP. NON-EQUITIES TRADING PERMIT (ETP) HOLDER CUSTOMERS ENGAGED INPOTENTIALLY MANIPULATIVE TRADING AT OR NEAR THE CLOSE OFTRADING (MARKING THE CLOSE) THAT AFFECTED THE CLOSING PRICE OFCERTAIN STOCKS. ONE CUSTOMER ENGAGED IN WHAT APPEARED TO BEMARKING-THE-CLOSE ACTIVITY IN THREE SECURITIES OVER 22 TRADEDATES; A SECOND CUSTOMER ENGAGED IN WHAT APPEARED TO BEMARKING-THE-CLOSE ACTIVITY IN A SINGLE SECURITY ON FOUR TRADEDATES; AND A THIRD CUSTOMER ENGAGED IN WHAT APPEARED TO BEMARKING-THE-CLOSE ACTIVITY IN A SINGLE SECURITY ON THREE TRADEDATES. THE FIRM IDENTIFIED ONLY NINE OF THE 58 ALERTS NOTED FORTHIS ACTIVITY. THE FIRM'S MARKING-THE-CLOSE SURVEILLANCE WASINADEQUATE BECAUSE IT FAILED TO CAPTURE MOST OF ITS CUSTOMERS'POTENTIAL OR ACTUAL VIOLATIVE CONDUCT. PRIOR TO A CERTAIN DATE,THE FIRM DID NOT INCLUDE CUSTOMER ACCOUNTS IN ITS MARKING-THE-CLOSE REVIEWS AND DID NOT CONDUCT ANY REVIEWS FORAPPROXIMATELY ONE MONTH DURING A SYSTEMS MIGRATION.THEREAFTER, THE FIRM'S REVIEWS WERE NOT SUFFICIENTLY DESIGNEDTO CAPTURE AND REVIEW POTENTIALLY VIOLATIVE CONDUCT. THE FIRMEXCLUDED FROM ITS REVIEWS MARKET AND MARKETABLE LIMITORDERS, ORDERS VALUED AT LESS THAN $2,500, AND FULLY EXECUTEDAND/OR CANCELED ORDERS. THE FIRM DID NOT CONDUCT A SUFFICIENTREVIEW AND ANALYSIS OF THOSE TRADES THAT IT DID CAPTURE. FORAPPROXIMATELY 16 MONTHS, THE FIRM ESCALATED FOR FURTHERREVIEW AND ANALYSIS ONLY FIVE OF MORE THAN 15,000 ALERTSGENERATED BY ITS AUTOMATED SURVEILLANCE. THE FIRM'S WRITTENSUPERVISORY PROCEDURES DID NOT ADEQUATELY ADDRESS THE FULLREVIEW AND ESCALATION PROCEDURES FOR ITS MARKING-THE-CLOSESURVEILLANCE SYSTEM. THE FIRM DID NOT HAVE A SPECIFICSURVEILLANCE REVIEW FOR WASH TRAINING AND PRIOR TO A LATERDATE, ITS REVIEW DID NOT INCLUDE CUSTOMER ACCOUNTS.Current Status:Final103©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanction(s)/ReliefSought:Resolution Date:11/04/2013Resolution:Other Sanctions Ordered:Sanction Details:A FINRA HEARING OFFICER CONSIDERED AN OFFER OF SETTLEMENT ANDCONSENT ENTERED INTO BETWEEN FINRA ON BEHALF OF NYSEREGULATION, INC. AND THE FIRM. THE HEARING OFFICER ACCEPTED THEOFFER OF SETTLEMENT AND CONSENT; THEREFORE, THE FIRM ISCENSURED AND FINED $150,000.IN DETERMINING TO RESOLVE THISMATTER, FINRA TOOK INTO CONSIDERATION THAT THE FIRM MADECHANGES TO ITS SUPERVISORY SYSTEMS AND PROCEDURES FORREVIEWING TRADING ACTIVITY AT OR NEAR THE CLOSE, WASH SALES,AND/OR MATCHED ORDERS, AS WELL AS THAT THE FIRM REPRESENTEDTO FINRA THAT IT WOULD IMPLEMENT FURTHER CHANGES TO ITSSUPERVISORY SYSTEMS AND PROCEDURES IN THIS AREA ON OR BEFOREA CERTAIN DATE. THE SANCTIONS SHALL TAKE EFFECT IMMEDIATELY. FINEPAID ON 11/19/2013.Firm StatementTHE OFFER OF SETTLEMENT AND CONSENT WAS SUBMITTED WITHOUTADJUDICATION OF ANY ISSUES OF LAW OR FACT, AND WITHOUTADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGS. FINE PAID ON11/19/2013.Sanctions Ordered:CensureMonetary/Fine $150,000.00Decision & Order of Offer of SettlementDisclosure 27 of 53iReporting Source:RegulatorInitiated By:FINRADate Initiated:07/18/2013Allegations:FINRA RULE 6760(C) - BNP PARIBAS SECURITIES CORP., AS MANAGINGUNDERWRITER, FAILED TO REPORT NEW ISSUE OFFERINGS IN TRADEREPORTING AND COMPLIANCE ENGINE (TRACE)-ELIGIBLE CORPORATESECURITIES IN ACCORDANCE WITH FINRA RULE 6760(C) REQUIREMENTS.THESE NEW ISSUE OFFERINGS CONSTITUTED APPROXIMATELY 61PERCENT OF THE NEW ISSUE OFFERINGS IN TRACE-ELIGIBLECORPORATE SECURITIES THAT THE FIRM HAD AN OBLIGATION TOPROVIDE TO FINRA DURING THE REVIEW PERIOD.Current Status:Final104©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Docket/Case Number:2011030835801Principal Product Type:OtherOther Product Type(s):TRACE-ELIGIBLE CORPORATE SECURITIESResolution Date:07/18/2013Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $7,500. FINE PAID ONAUGUST 2, 2013.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $7,500.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmInitiated By:FINRADate Initiated:06/25/2013Docket/Case Number:20110308358Principal Product Type:OtherOther Product Type(s):Allegations:DURING THE REVIEW PERIOD MAY 10, 2011 THROUGH SEPTEMBER 30,2011, THE FIRM, AS MANAGING UNDERWRITER, FAILED TO REPORT 25NEW ISSUE OFFERINGS IN TRACE-ELIGIBLE CORPORATE SECURITIES INACCORDANCE WITH THE REQUIREMENTS OF FINRA RULE 6760(C).Current Status:Final105©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Resolution Date:06/25/2013Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND THE ENTRY OF FINDINGS,THEREFORE IT IS CENSURED AND FINED $7,500.Firm StatementWITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND THE ENTRY OF FINDINGS,THEREFORE IT IS CENSURED AND FINED $7,500.Sanctions Ordered:CensureMonetary/Fine $7,500.00Acceptance, Waiver & Consent(AWC)Disclosure 28 of 53iReporting Source:RegulatorAllegations:NYSE ARCA OPTIONS RULE 6.8 COMMENTARY .07(III)(F), NYSE ARCAOPTIONS RULE 11.18 - BNP PARIBAS SECURITIES CORP. SUBMITTED AREQUEST TO NYSE ARCA FOR APPROVAL TO USE THE DELTA HEDGEEXEMPTION FOR LISTED AND OVER-THE-COUNTER (OTC) OPTIONSPOSITIONS HELD IN ACCOUNTS AT THE FIRM BY ITS AFFILIATE, BASED ONAN APPROVED PROPRIETARY MODEL. THE FIRM CONFIRMED THATNEITHER FIRM HELD AN OWNERSHIP INTEREST IN THE OTHER. THE FIRMEXPRESSLY LIMITED ITS REQUEST TO TWO TRADING UNITS WITHIN THEAFFILIATE. THE FIRM REPRESENTED THAT, WHERE A POSITION EXCEEDEDTHE APPLICABLE LIMIT, IT WOULD DETERMINE HOW MUCH OF THEPOSITION, IF ANY, BELONGED TO EACH OF THE TWO UNITS ELIGIBLE FORTHE EXEMPTION AND THEN ADJUST THE POSITIONS ACCORDING TO ITSAPPROVED DELTA HEDGE MODEL. THE OPTIONS CONTRACT EQUIVALENTOF THE NET DELTA (OCEND) FROM THE TWO UNITS WOULD BE ADDED TOANY/ALL NON-DELTA HEDGED POSITIONS HELD BY OTHER UNITS WITHINTHE AFFILIATE TO ESTABLISH AN AGGREGATE/CONSOLIDATED OCENDPOSITION FOR SUBMISSION. FOR ALMOST TWO YEARS, THE FIRMINADVERTENTLY DID NOT INCLUDE ITS NON-DELTA HEDGED POSITIONSWITH ITS OCEND SUBMISSIONS TO THE OPTIONS CLEARINGCORPORATION (OCC) SO THAT IT FAILED TO SUBMIT ACCURATE OCENDCurrent Status:Final106©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:NYSE ARCA, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:05/23/2013Docket/Case Number:20110296479Principal Product Type:OptionsOther Product Type(s):CALCULATIONS TO THE OCC FOR EIGHT DIFFERENT SECURITIESTOTALING 1,909 INSTANCES. ALTHOUGH THE FIRM UPDATED ITS WRITTENSUPERVISORY PROCEDURES (WSPS) TO INCLUDE A DESCRIPTION OF ASUPERVISORY REVIEW OF OCEND DATA, THE FIRM DID NOT HAVEPROCEDURES IN PLACE TO VERIFY THE ACCURACY OF ITS OCENDSUBMISSIONS AND CONTINUED TO SUBMIT INACCURATE OCEND DATAFOR ALMOST NINE MONTHS. GIVEN THE NUMEROUS VIOLATIONS AND THEEXTENDED TIME PERIOD OVER WHICH THEY OCCURRED, THE FIRM'SSUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TOENSURE THE SUBMISSION OF ACCURATE OCEND DATA.Resolution Date:05/23/2013Resolution:Other Sanctions Ordered:Sanction Details:A FINRA HEARING OFFICER ACCEPTED AN OFFER OF SETTLEMENT ANDCONSENT ENTERED INTO BETWEEN FINRA, ON BEHALF OF NYSE ARCA,INC., AND THE FIRM WITHOUT ADMITTING OR DENYING ANY ALLEGATIONSOR FINDINGS REFERRED TO THEREIN; THEREFORE, THE FIRM ISCENSURED AND FINED $50,000. THE FINE MUST BE PAID WITHIN 30 DAYSOF THE DATE OF THE DECISION OR THE FIRM MAY FACE SUSPENSION.Regulator StatementOTHER CASE NUMBER: 13-ARCA-13Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $50,000.00Decision & Order of Offer of Settlement107©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceiReporting Source:FirmInitiated By:NYSE ARCA, INC.Principal Sanction(s)/ReliefSought:Date Initiated:05/23/2013Docket/Case Number:20110296479Principal Product Type:OptionsOther Product Type(s):Allegations:NYSE ARCA OPTIONS RULE 6.8 COMMENTARY .07(III)(F), NYSE ARCAOPTIONS RULE 11.18 - BNP PARIBAS SECURITIES CORP. SUBMITTED AREQUEST TO NYSE ARCA FOR APPROVAL TO USE THE DELTA HEDGEEXEMPTION FOR LISTED AND OVER-THE-COUNTER (OTC) OPTIONSPOSITIONS HELD IN ACCOUNTS AT THE FIRM BY ITS AFFILIATE, BASED ONAN APPROVED PROPRIETARY MODEL. THE FIRM CONFIRMED THATNEITHER FIRM HELD AN OWNERSHIP INTEREST IN THE OTHER. THE FIRMEXPRESSLY LIMITED ITS REQUEST TO TWO TRADING UNITS WITHIN THEAFFILIATE. THE FIRM REPRESENTED THAT, WHERE A POSITION EXCEEDEDTHE APPLICABLE LIMIT, IT WOULD DETERMINE HOW MUCH OF THEPOSITION, IF ANY, BELONGED TO EACH OF THE TWO UNITS ELIGIBLE FORTHE EXEMPTION AND THEN ADJUST THE POSITIONS ACCORDING TO ITSAPPROVED DELTA HEDGE MODEL. THE OPTIONS CONTRACT EQUIVALENTOF THE NET DELTA (OCEND) FROM THE TWO UNITS WOULD BE ADDED TOANY/ALL NON-DELTA HEDGED POSITIONS HELD BY OTHER UNITS WITHINTHE AFFILIATE TO ESTABLISH AN AGGREGATE/CONSOLIDATED OCENDPOSITION FOR SUBMISSION. FOR ALMOST TWO YEARS, THE FIRMINADVERTENTLY DID NOT INCLUDE ITS NON-DELTA HEDGED POSITIONSWITH ITS OCEND SUBMISSIONS TO THE OPTIONS CLEARINGCORPORATION (OCC) SO THAT IT FAILED TO SUBMIT ACCURATE OCENDCALCULATIONS TO THE OCC FOR EIGHT DIFFERENT SECURITIESTOTALING 1,909 INSTANCES. ALTHOUGH THE FIRM UPDATED ITS WRITTENSUPERVISORY PROCEDURES (WSPS) TO INCLUDE A DESCRIPTION OF ASUPERVISORY REVIEW OF OCEND DATA, THE FIRM DID NOT HAVEPROCEDURES IN PLACE TO VERIFY THE ACCURACY OF ITS OCENDSUBMISSIONS AND CONTINUED TO SUBMIT INACCURATE OCEND DATAFOR ALMOST NINE MONTHS. GIVEN THE NUMEROUS VIOLATIONS AND THEEXTENDED TIME PERIOD OVER WHICH THEY OCCURRED, THE FIRM'SSUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TOENSURE THE SUBMISSION OF ACCURATE OCEND DATA.Current Status:Final108©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanction(s)/ReliefSought:Resolution Date:05/23/2013Resolution:Other Sanctions Ordered:Sanction Details:A FINRA HEARING OFFICER ACCEPTED AN OFFER OF SETTLEMENT ANDCONSENT ENTERED INTO BETWEEN FINRA, ON BEHALF OF NYSE ARCA,INC., AND THE FIRM WITHOUT ADMITTING OR DENYING ANY ALLEGATIONSOR FINDINGS REFERRED TO THEREIN; THEREFORE, THE FIRM ISCENSURED AND FINED $50,000.Firm StatementNYSE ARCA OPTIONS RULE 6.8 COMMENTARY .07(III)(F), NYSE ARCAOPTIONS RULE 11.18 - BNP PARIBAS SECURITIES CORP. SUBMITTED AREQUEST TO NYSE ARCA FOR APPROVAL TO USE THE DELTA HEDGEEXEMPTION FOR LISTED AND OVER-THE-COUNTER (OTC) OPTIONSPOSITIONS HELD IN ACCOUNTS AT THE FIRM BY ITS AFFILIATE, BASED ONAN APPROVED PROPRIETARY MODEL. THE FIRM CONFIRMED THATNEITHER FIRM HELD AN OWNERSHIP INTEREST IN THE OTHER. THE FIRMEXPRESSLY LIMITED ITS REQUEST TO TWO TRADING UNITS WITHIN THEAFFILIATE. THE FIRM REPRESENTED THAT, WHERE A POSITION EXCEEDEDTHE APPLICABLE LIMIT, IT WOULD DETERMINE HOW MUCH OF THEPOSITION, IF ANY, BELONGED TO EACH OF THE TWO UNITS ELIGIBLE FORTHE EXEMPTION AND THEN ADJUST THE POSITIONS ACCORDING TO ITSAPPROVED DELTA HEDGE MODEL. THE OPTIONS CONTRACT EQUIVALENTOF THE NET DELTA (OCEND) FROM THE TWO UNITS WOULD BE ADDED TOANY/ALL NON-DELTA HEDGED POSITIONS HELD BY OTHER UNITS WITHINTHE AFFILIATE TO ESTABLISH AN AGGREGATE/CONSOLIDATED OCENDPOSITION FOR SUBMISSION. FOR ALMOST TWO YEARS, THE FIRMINADVERTENTLY DID NOT INCLUDE ITS NON-DELTA HEDGED POSITIONSWITH ITS OCEND SUBMISSIONS TO THE OPTIONS CLEARINGCORPORATION (OCC) SO THAT IT FAILED TO SUBMIT ACCURATE OCENDCALCULATIONS TO THE OCC FOR EIGHT DIFFERENT SECURITIESTOTALING 1,909 INSTANCES. ALTHOUGH THE FIRM UPDATED ITS WRITTENSUPERVISORY PROCEDURES (WSPS) TO INCLUDE A DESCRIPTION OF ASUPERVISORY REVIEW OF OCEND DATA, THE FIRM DID NOT HAVEPROCEDURES IN PLACE TO VERIFY THE ACCURACY OF ITS OCENDSUBMISSIONS AND CONTINUED TO SUBMIT INACCURATE OCEND DATAFOR ALMOST NINE MONTHS. GIVEN THE NUMEROUS VIOLATIONS AND THEEXTENDED TIME PERIOD OVER WHICH THEY OCCURRED, THE FIRM'SSUPERVISORY PROCEDURES WERE NOT REASONABLY DESIGNED TOENSURE THE SUBMISSION OF ACCURATE OCEND DATA. A FINRA HEARINGSanctions Ordered:CensureMonetary/Fine $50,000.00Decision & Order of Offer of Settlement109©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOFFICER ACCEPTED AN OFFER OF SETTLEMENT AND CONSENT ENTEREDINTO BETWEEN FINRA, ON BEHALF OF NYSE ARCA, INC., AND THE FIRMWITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR FINDINGSREFERRED TO THEREIN; THEREFORE, THE FIRM IS CENSURED AND FINED$50,000.Disclosure 29 of 53iReporting Source:RegulatorInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:N/ADate Initiated:04/24/2013Docket/Case Number:2011025773401Principal Product Type:No ProductOther Product Type(s):Allegations:FINRA RULES 2010, 4530(A) AND 4530(F) AND NASD RULES 3070(A) AND3070(F): THE FIRM FAILED TO REPORT OR FAILED TO TIMELY FILE WITHFINRA REGULATORY MATTERS, LEGAL SETTLEMENTS AND PRIVATE CIVILLITIGATIONS OF SECURITIES-RELATED MATTERS OF WHICH IT HADNOTICE. WHEN THE FIRM FINALLY MADE THE REQUISITE FILINGS, THEYWERE BETWEEN TWO MONTHS AND THREE AND A HALF YEARS LATE.Current Status:FinalResolution Date:04/24/2013Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDDoes the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $17,500.00Acceptance, Waiver & Consent(AWC)110©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE IT IS CENSURED AND FINED $17,500. FINE PAID ON JUNE 21,2013.iReporting Source:FirmInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:04/24/2013Docket/Case Number:2011025773401Principal Product Type:No ProductOther Product Type(s):Allegations:FINRA RULES 2010, 4530(A) AND 4530(F) AND NASD RULES 3070(A) AND3070(F); THE FIRM FAILED TO REPORT OR FAILED TO TIMELY FILE WITHFINRA REGULATORY MATTERS, LEGAL SETTLEMENTS AND PRIVATE CIVILLITIGATIONS OF SECURITIES-RELATED MATTERS OF WHICH IT HADNOTICE. WHEN THE FIRM FINALLY MADE THE REQUISITE FILINGS, THEYWERE BETWEEN TWO MONTHS AND THREE AND HALF YEARS LATE.Current Status:FinalResolution Date:04/24/2013Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND THE THE ENTRY OF FINDINGS,THEREFORE IT IS CENSURED AND FINED $17,500.FINE PAID ON JUNE 21,2013Firm StatementWITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND THE THE ENTRY OF FINDINGS,THEREFORE IT IS CENSURED AND FINED $17,500. FINE PAID ON JUNE 21,2013Sanctions Ordered:CensureMonetary/Fine $17,500.00Acceptance, Waiver & Consent(AWC)i111©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceDisclosure 30 of 53Reporting Source:RegulatorInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:04/05/2013Docket/Case Number:2010023892501Principal Product Type:OtherOther Product Type(s):UNSPECIFIED SECURITIESAllegations:SEC RULES 611(A)(1), 611(C) OF REGULATION NMS - BNP PARIBASSECURITIES CORP. FAILED TO TAKE REASONABLE STEPS TO ESTABLISHTHAT THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THEDEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OFREGULATION NMS. THE FIRM FAILED TO ESTABLISH, MAINTAIN ANDENFORCE WRITTEN POLICES AND PROCEDURES REASONABLY DESIGNEDTO PREVENT TRADE-THROUGHS OF PROTECTED QUOTATIONS IN NMSSTOCKS.Current Status:FinalResolution Date:04/05/2013Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $12,500.FINE PAID IN FULL ON APRIL 30, 2013Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $12,500.00Acceptance, Waiver & Consent(AWC)i112©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceReporting Source:FirmInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:04/05/2013Docket/Case Number:2010023892501Principal Product Type:OtherOther Product Type(s):UNSPECIFIED SECURITIESAllegations:SEC RULES 611(A)(1), 611(C) OF REGULATION NMS - BNP PARIBASSECURITIES CORP. FAILED TO TAKE REASONABLE STEPS TO ESTABLISHTHAT THE INTERMARKET SWEEP ORDERS (ISOS) IT ROUTED MET THEDEFINITIONAL REQUIREMENTS SET FORTH IN RULE 600(B)(30) OFREGULATION NMS. THE FIRM FAILED TO ESTABLISH, MAINTAIN ANDENFORCE WRITTEN POLICES AND PROCEDURES REASONABLY DESIGNEDTO PREVENT TRADE-THROUGHS OF PROTECTED QUOTATIONS IN NMSSTOCKS.Current Status:FinalResolution Date:04/05/2013Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $12,500. FINE PAID ONAPRIL 30, 2013.Firm StatementWITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $12,500. FINE PAID ONAPRIL 30, 2013.Sanctions Ordered:CensureMonetary/Fine $12,500.00Acceptance, Waiver & Consent(AWC)Disclosure 31 of 53iReporting Source:Regulator113©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:03/15/2013Docket/Case Number:2011026157801Principal Product Type:OtherOther Product Type(s):DESIGNATED SECURITIESAllegations:FINRA RULES 2010, 6380A(A), 6730(A), 7450 - BNP PARIBAS SECURITIESCORP. TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS)REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLYFORMATTED DATA. THE FIRM SUBMITTED INCORRECT ACCOUNT TYPECODES OF "R" ON SOME REPORTS AND FAILED TO SUBMIT A "NOT HELD"SPECIAL HANDLING CODE ON SOME OTHER REPORTS. THE FIRM FAILED,WITHIN 90 SECONDS AFTER EXECUTION (FOR CONDUCT PRIOR TONOVEMBER 1, 2010) OR WITHIN 30 SECONDS AFTER EXECUTION (FORCONDUCT ON OR AFTER NOVEMBER 1, 2010), TO TRANSMIT TO THEFINRA/NASDAQ TRADE REPORTING FACILITY (FNTRF) LAST SALEREPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES, AND FAILEDTO DESIGNATE THROUGH THE FNTRF SOME OF THE LAST SALE REPORTSAS LATE. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCTVIOLATIONS OF FINRA RULE 6380A(A) AND A PATTERN OR PRACTICE OFLATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATIONOF FINRA RULE 2010. THE FIRM FAILED TO REPORT TO THE TRADEREPORTING AND COMPLIANCE ENGINE (TRACE) S1 TRANSACTIONS INTRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE EXECUTIONTIME. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONSOF FINRA RULE 6730(A) AND A PATTERN OR PRACTICE OF LATEREPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OFFINRA RULE 2010.Current Status:FinalResolution Date:03/15/2013Resolution:Acceptance, Waiver & Consent(AWC)114©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $45,000.FINE PAID IN FULL ON APRIL 12, 2013Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $45,000.00iReporting Source:FirmInitiated By:FINRAAllegations:FINRA RULES 2010, 6380A(A), 6730(A), 7450 - BNP PARIBAS SECURITIESCORP. TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS)REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLYFORMATTED DATA. THE FIRM SUBMITTED INCORRECT ACCOUNT TYPECODES OF "R" ON SOME REPORTS AND FAILED TO SUBMIT A "NOT HELD"SPECIAL HANDLING CODE ON SOME OTHER REPORTS. THE FIRM FAILED,WITHIN 90 SECONDS AFTER EXECUTION (FOR CONDUCT PRIOR TONOVEMBER 1, 2010) OR WITHIN 30 SECONDS AFTER EXECUTION (FORCONDUCT ON OR AFTER NOVEMBER 1, 2010), TO TRANSMIT TO THEFINRA/NASDAQ TRADE REPORTING FACILITY (FNTRF) LAST SALEREPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES, AND FAILEDTO DESIGNATE THROUGH THE FNTRF SOME OF THE LAST SALE REPORTSAS LATE. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCTVIOLATIONS OF FINRA RULE 6380A(A) AND A PATTERN OR PRACTICE OFLATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATIONOF FINRA RULE 2010. THE FIRM FAILED TO REPORT TO THE TRADEREPORTING AND COMPLIANCE ENGINE (TRACE) S1 TRANSACTIONS INTRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE EXECUTIONTIME. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONSOF FINRA RULE 6730(A) AND A PATTERN OR PRACTICE OF LATEREPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OFFINRA RULE 2010.Current Status:Final115©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:03/15/2013Docket/Case Number:2011026157801Principal Product Type:OtherOther Product Type(s):DESIGNATED SECURITIESResolution Date:03/15/2013Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $45,000. FINE PAID ONAPRIL 12, 2013.Firm StatementWITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $45,000. FINE PAID ONAPRIL 12, 2013.Sanctions Ordered:CensureMonetary/Fine $45,000.00Acceptance, Waiver & Consent(AWC)Disclosure 32 of 53iReporting Source:RegulatorInitiated By:CHICAGO BOARD OPTIONS EXCHANGEDate Initiated:11/16/2012Docket/Case Number:12-0073Allegations:IT IS ALLEGED THAT BNP FAILED TO PROVIDE ACCURATE INFORMATION TOTHE OPTIONS CLEARING CORPORATION REGARDING ITS AGGREGATEOPTION POSITION FOR EACH SECURITY EXCEEDING THE APPLICABLEPOSITION LIMIT, IN THAT BNP FAILED TO REPORT ACCURATELY ITSPOSITION VIA THE OCEND AGGREGATOR FILE TO OCC. (VIOLATION OFEXCHANGE RULES 4.11 AND 4.22)Current Status:Pending116©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Principal Product Type:OptionsOther Product Type(s):iReporting Source:FirmInitiated By:CHICAGO BOARD OF OPTIONS EXCHANGEPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated:11/16/2012Docket/Case Number:12-0073Principal Product Type:OptionsOther Product Type(s):Allegations:BNP PARIBAS SECURITIES CORP.("BNP"), AN EXCHANGE TPHORGANIZATION, WAS CENSURED AND FINED $25,000 FOR THE FOLLOWINGCONDUCT. BNP FAILED TO PROVIDE ACCURATE INFORMATION TO THEOPTIONS CLEARING CORPORATION REGARDING ITS AGGREGATE OPTIONPOSITION FOR EACH SECURITY EXCEEDING THE APPLICABLE POSITIONLIMIT, IN THAT BNP FAILED TO REPORT ACCURATELY ITS POSITION VIA THEOCEND AGGREGATOR FILE TO OCC. (RULES 4.00 - POSITION LIMITS AND4.22-COMMUNICATIONS TO THE EXCHANGE OR THE CLEARINGCORPORATION)Current Status:FinalResolution Date:02/21/2013Resolution:Other Sanctions Ordered:Sanction Details:A $25,000 FINE AND A CENSURESanctions Ordered:CensureMonetary/Fine $25,000.00Decision & Order of Offer of Settlementi117©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceDisclosure 33 of 53Reporting Source:RegulatorInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:N/ADate Initiated:08/14/2012Docket/Case Number:2010021589201Principal Product Type:No ProductOther Product Type(s):Allegations:SEC RULE 10B-10, FINRA RULES 7230A(G), 7330(G): DURING THE TRADINGAND MARKET MAKING SURVEILLANCE (TMMS) REVIEW PERIOD, THE FIRM,ON SOME OCCASIONS, INCORRECTLY DISCLOSED COMPENSATIONTERMINOLOGY AS COMMISSION CHARGED FOR PRINCIPAL OR RISKLESSPRINCIPAL TRANSACTIONS. DURING THE TRADE REPORTING REVIEWPERIOD, THE FIRM FAILED TO PUNCTUALLY REPORT NUMEROUSTRANSACTIONS THAT ARE ASSESSED A REGULATORY TRANSACTION FEEUNDER SECTION 3 OF SCHEDULE A TO THE FINRA BY-LAWS.Current Status:FinalResolution Date:08/14/2012Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED AND FINED $50,000 (COMPRISED OF$12,500 FOR THE CUSTOMER CONFIRMATION VIOLATIONS IN MATTER20100215892; AND $37,500 FOR THE LATE TRADE REPORTING VIOLATIONSIN MATTER 20110263216). FINE PAID IN FULL ON SEPTEMBER 04, 2012.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $50,000.00Acceptance, Waiver & Consent(AWC)118©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceiReporting Source:FirmInitiated By:FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA")Principal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:N/ADate Initiated:08/14/2012Docket/Case Number:2010021589201Principal Product Type:No ProductOther Product Type(s):Allegations:SEC RULE 10B-10, FINRA RULES 7230A(G), 7330(G): DURING THE TRADINGAND MARKET MAKING SURVEILLANCE (TMMS) REVIEW PERIOD, THE FIRM,ON SOME OCCASIONS, INCORRECTLY DISCLOSED COMPENSATIONTERMINOLOGY AS COMMISSION CHARGED FOR PRINCIPAL OR RISKLESSPRINCIPAL TRANSACTIONS. DURING THE TRADE REPORTING REVIEWPERIOD, THE FIRM FAILED TO PUNCTUALLY REPORT NUMEROUSTRANSACTIONS THAT ARE ASSESSED A REGULATORY TRANSACTION FEEUNDER SECTION 3 OF SCHEDULE A TO THE FINRA BY-LAWS.Current Status:FinalResolution Date:08/14/2012Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED AND FINED $50,000 (COMPRISED OF$12,500 FOR THE CUSTOMER CONFIRMATION VIOLATIONS IN MATTER20100215892; AND $37,500 FOR THE LATE TRADE REPORTING VIOLATIONSIN MATTER 20110263216).Firm StatementWITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED AND FINED $50,000 (COMPRISED OF$12,500 FOR THE CUSTOMER CONFIRMATION VIOLATIONS IN MATTER20100215892; AND $37,500 FOR THE LATE TRADE REPORTING VIOLATIONSSanctions Ordered:CensureMonetary/Fine $50,000.00Acceptance, Waiver & Consent(AWC)119©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceIN MATTER 20110263216).Disclosure 34 of 53iReporting Source:FirmInitiated By:CBOTPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated:03/09/2012Docket/Case Number:CBOT FILE #09-03743-BCPrincipal Product Type:OtherOther Product Type(s):FUTURES CONTRACTSAllegations:ON MARCH 9, 2012, THE FIRM SUBMITTED AN OFFER OF SETTLEMENT TOTHE CHICAGO BOARD OF TRADE BUSINESS CONDUCT COMMITTEE FORALLEGED VIOLATIONS OF CBOT RULE 854 (CONCURRENT LONG ANDSHORT POSITIONS). WITHOUT ADMITTING OR DENYING, BNP PARIBASSECURITIES CORP AGREED TO PAY A $40K FINE.Current Status:FinalResolution Date:04/16/2012Resolution:Other Sanctions Ordered:Sanction Details:ON MARCH 9, 2012, THE FIRM SUBMITTED AN OFFER OF SETTLEMENT TOTHE CHICAGO BOARD OF TRADE BUSINESS CONDUCT COMMITTEE FORALLEGED VIOLATIONS OF CBOT RULE 854 (CONCURRENT LONG ANDSHORT POSITIONS). WITHOUT ADMITTING OR DENYING, BNP PARIBASSECURITIES CORP AGREED TO PAY A $40K FINE.Firm StatementON MARCH 9, 2012, THE FIRM SUBMITTED AN OFFER OF SETTLEMENT TOTHE CHICAGO BOARD OF TRADE BUSINESS CONDUCT COMMITTEE FORALLEGED VIOLATIONS OF CBOT RULE 854 (CONCURRENT LONG ANDSHORT POSITIONS). WITHOUT ADMITTING OR DENYING, BNP PARIBASSECURITIES CORP AGREED TO PAY A $40K FINE.Sanctions Ordered:Monetary/Fine $40,000.00ConsentDisclosure 35 of 53i120©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceReporting Source:FirmInitiated By:CHICAGO MERCANTILE EXCHANGEPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated:03/17/2010Docket/Case Number:02-CH-0210Principal Product Type:No ProductOther Product Type(s):Allegations:VIOLATION OF CME RULE 908A "EACH CLEARING MEMBER SHALLPREPARE, MAINTAIN AND KEEP CURRENT THOSE BOOKS AND RECORDSREQUIRED BY THE RULES OF THE EXCHANGE, THE COMMODITYEXCHANGE ACT AND THE REGULATIONS THEREUNDER. SUCH BOOKSAND RECORDS SHALL BE OPEN TO INSPECTION AND PROMPTLYPROVIDED TO THE EXCHANGE UPON REQUEST." THEME ACCEPTED OSETTLEMENT OF $25,000.Current Status:FinalResolution Date:06/18/2010Resolution:Other Sanctions Ordered:NONESanction Details:BNP PARIBAS SECURITIES CORP SETTLED WITH A PAYMENT OF $25K.Firm StatementWITHOUT ADMITTING OR DENYING THAT BNP PARIBAS SECURITIES CORPHAS VIOLATED ANY RULE OF THE EXCHANGE, BNPP AGREES TO PAY AFINE OF $25K TO SETTLE THE CHARGE OF VIOLATING THE CME RULE980A.Sanctions Ordered:Monetary/Fine $25,000.00SettledDisclosure 36 of 53iReporting Source:RegulatorAllegations:SEC RULE 611(C), NASDAQ RULES 3010, 4613(E), 4755(A)(4) - BNP PARIBASSECURITIES CORP. FAILED TO REASONABLY AVOID DISPLAYING ANDENGAGED IN A PATTERN OR PRACTICE OF DISPLAYING QUOTATIONS THATCurrent Status:Final121©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:NASDAQ STOCK MARKETPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:07/26/2011Docket/Case Number:2009018935501Principal Product Type:OtherOther Product Type(s):SWEEP ORDERS, NASDAQ SECURITIESLOCKED OR CROSSED A PROTECTED QUOTATION, IN THAT IT ENTEREDINTERMARKET SWEEP ORDERS INTO THE NASDAQ SINGLEBOOKEXECUTION SYSTEM THAT LOCKED OR CROSSED A QUOTATIONPREVIOUSLY DISSEMINATED PURSUANT TO AN EFFECTIVE NATIONALMARKET SYSTEM PLAN AND FAILED TO SIMULTANEOUSLY ROUTE ANINTERMARKET SWEEP ORDER TO EXECUTE AGAINST THE FULLDISPLAYED SIZE OF THE LOCKED OR CROSSED PROTECTED QUOTE. THEFIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND NASDAQ RULES CONCERNINGLOCKED OR CROSSED MARKETS.Resolution Date:07/26/2011Resolution:Other Sanctions Ordered:UNDERTAKINGSanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE, THE FIRM IS CENSURED, FINED $27,500 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING LOCKEDAND CROSSED MARKETS WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OFTHIS AWC BY THE NAC.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $27,500.00Acceptance, Waiver & Consent(AWC)122©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceiReporting Source:FirmInitiated By:NASDAQ STOCK MARKETPrincipal Sanction(s)/ReliefSought:UndertakingOther Sanction(s)/ReliefSought:Date Initiated:07/26/2011Docket/Case Number:2009018935501Principal Product Type:OtherOther Product Type(s):SWEEP ORDERS, NASDAQ SECURITIESAllegations:SEC RULE 611(C), NASDAQ RULES 3010, 4613(E), 4755(A)(4) - BNP PARIBASSECURITIES CORP. FAILED TO REASONABLY AVOID DISPLAYING ANDENGAGED IN A PATTERN OR PRACTICE OF DISPLAYING QUOTATIONS THATLOCKED OR CROSSED A PROTECTED QUOTATION, IN THAT IT ENTEREDINTERMARKET SWEEP ORDERS INTO THE NASDAQ SINGLEBOOKEXECUTION SYSTEM THAT LOCKED OR CROSSED A QUOTATIONPREVIOUSLY DISSEMINATED PURSUANT TO AN EFFECTIVE NATIONALMARKET SYSTEM PLAN AND FAILED TO SIMULTANEOUSLY ROUTE ANINTERMARKET SWEEP ORDER TO EXECUTE AGAINST THE FULLDISPLAYED SIZE OF THE LOCKED OR CROSSED PROTECTED QUOTE. THEFIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND NASDAQ RULES CONCERNINGLOCKED OR CROSSED MARKETS.Current Status:FinalResolution Date:07/26/2011Resolution:Other Sanctions Ordered:UNDERTAKINGSanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE, THE FIRM IS CENSURED, FINED $27,500 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING LOCKEDAND CROSSED MARKETS WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OFTHIS AWC BY THE NAC.Sanctions Ordered:CensureMonetary/Fine $27,500.00Acceptance, Waiver & Consent(AWC)123©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceDisclosure 37 of 53iReporting Source:RegulatorInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:06/10/2011Docket/Case Number:2008014672401Principal Product Type:OtherOther Product Type(s):UNSPECIFIED SECURITIESAllegations:NASD RULE 3360 - BNP PARIBAS SECURITIES CORP. FAILED TO REPORTSHORT INTEREST POSITIONS TO FINRA FOR A SETTLEMENT DATE. THEFIRM ALSO REPORTED SHORT INTEREST POSITIONS INCORRECTLY.Current Status:FinalResolution Date:06/10/2011Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $12,500.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $12,500.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmCurrent Status:Final124©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:06/10/2011Docket/Case Number:2008014672401Principal Product Type:OtherOther Product Type(s):UNSPECIFIED SECURITIESAllegations:NASD RULE 3360 - BNP PARIBAS SECURITIES CORP. FAILED TO REPORTSHORT INTEREST POSITIONS TO FINRA FOR A SETTLEMENT DATE. THEFIRM ALSO REPORTED SHORT INTEREST POSITIONS INCORRECTLY.Resolution Date:06/10/2011Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $12,500.Sanctions Ordered:CensureMonetary/Fine $12,500.00Acceptance, Waiver & Consent(AWC)Disclosure 38 of 53iReporting Source:RegulatorAllegations:SEC EXCHANGE ACT RULE 17A-3, NASD RULES 2110, 3010, 3110,INTERPRETATIVE MATERIAL-1000-1: THE FIRM FAILED TO ESTABLISH ANDMAINTAIN ADEQUATE SYSTEMS AND PROCEDURES IN ORDER TO MANAGECERTAIN RISKS AT ITS LISTED OPTIONS TRADING AND STOCK LOANDESKS. IN PARTICULAR, IT HAD INADEQUATE SYSTEMS ANDPROCEDURES TO REVIEW AND ASSESS THE RISK OF VALUATIONS OFCERTAIN MANUALLY MARKED POSITIONS IN TRADING ACCOUNTS OF THELISTED OPTION DESK (LO DESK), AND IT FAILED TO PROPERLY REVIEWAND ASSESS THE RISK ASSOCIATED WITH A TRADE MADE BY THE STOCKLOAN AND BORROW DESK (SLAB). THERE WAS NO INDEPENDENTVALUATION OR VERIFICATION BY THE FIRM OF THE VALUATIONS, OR THERISKS ASSOCIATED WITH THESE VALUATIONS AND THE FIRM FAILED TOCurrent Status:Final125©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:N/ADate Initiated:12/08/2010Docket/Case Number:2008013504201Principal Product Type:OptionsOther Product Type(s):HAVE ANY SYSTEM OR PROCEDURE FOR TRACKING AND ASSESSING THERISK OF LOSS TO THE FIRM FROM SLAB ARBITRAGE TRADES. THE FIRMFAILED TO HAVE AN ADEQUATE SYSTEM IN PLACE TO INDEPENDENTLYVERIFY THE MARKS MADE BY INDIVIDUAL TRADERS ON THE LO DESK ANDOTHER DESKS WHO HAD BEEN AUTHORIZED TO MANUALLY MARK THEIRBOOKS. ACCORDINGLY, BECAUSE OF THESE SUPERVISORY FAILURES,THE FIRM CREATED RECORDS REFLECTING THE INACCURATE VALUES OFCERTAIN POSITIONS IN THE LO DESK'S TRADING ACCOUNT AND WASUNAWARE OF LOSSES IN EXCESS OF $18 MILLION ON THE LO DESKINCURRED OVER A PERIOD OF APPROXIMATELY 11 WEEKS DUE TOINACCURATE MARKS. IN ADDITION, THE FIRM FURTHER FAILED TO LIMIT,MONITOR OR TRACK RISK ASSOCIATED WITH ARBITRAGE TRADES MADEBY THE SLAB DESK AND IT DID NOT ANTICIPATE A LOSS OFAPPROXIMATELY 3.4 MILLION EUROS OCCASIONED BY A SINGLE SLABARBITRAGE TRADE. THE FAILURES RELATING TO THE LO DESK ALSOCAUSED CERTAIN OF THE FIRM'S BOOKS AND RECORDS TO BEINACCURATE PRIOR TO NOVEMBER 2007. IN ADDITION, IN DECEMBER2007, WHEN THE FIRM FILED THE FORM U5 FOR THE TRADERRESPONSIBLE FOR THE INACCURATE MARKS ON THE LO DESK, ITINCORRECTLY INDICATED THAT THE TRADER'S TERMINATION WAS "VOLUNTARY" WHEN IN FACT THE TRADER WAS "PERMITTED TO RESIGN."THE FIRM FURTHER INCORRECTLY INDICATED, IN RESPONSE TO ADISCLOSURE QUESTION, THAT THE TRADER WAS NOT UNDER INTERNALREVIEW AT THE TIME OF HIS TERMINATION WHEN, IN FACT, HE HAD BEENUNDER SUCH REVIEW.Resolution Date:12/08/2010Resolution:Acceptance, Waiver & Consent(AWC)126©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther 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 $650,000.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $650,000.00iReporting Source:FirmAllegations:SEC EXCHANGE ACT RULE 17A-3, NASD RULES 2110, 3010, 3110,INTERPRETATIVE MATERIAL-1000-1: THE FIRM FAILED TO ESTABLISH ANDMAINTAIN ADEQUATE SYSTEMS AND PROCEDURES IN ORDER TO MANAGECERTAIN RISKS AT ITS LISTED OPTIONS TRADING AND STOCK LOANDESKS. IN PARTICULAR, IT HAD INADEQUATE SYSTEMS ANDPROCEDURES TO REVIEW AND ASSESS THE RISK OF VALUATIONS OFCERTAIN MANUALLY MARKED POSITIONS IN TRADING ACCOUNTS OF THELISTED OPTION DESK (LO DESK), AND IT FAILED TO PROPERLY REVIEWAND ASSESS THE RISK ASSOCIATED WITH A TRADE MADE BY THE STOCKLOAN AND BORROW DESK (SLAB). THERE WAS NO INDEPENDENTVALUATION OR VERIFICATION BY THE FIRM OF THE VALUATIONS, OR THERISKS ASSOCIATED WITH THESE VALUATIONS AND THE FIRM FAILED TOHAVE ANY SYSTEM OR PROCEDURE FOR TRACKING AND ASSESSING THERISK OF LOSS TO THE FIRM FROM SLAB ARBITRAGE TRADES. THE FIRMFAILED TO HAVE AN ADEQUATE SYSTEM IN PLACE TO INDEPENDENTLYVERIFY THE MARKS MADE BY INDIVIDUAL TRADERS ON THE LO DESK ANDOTHER DESKS WHO HAD BEEN AUTHORIZED TO MANUALLY MARK THEIRBOOKS. ACCORDINGLY, BECAUSE OF THESE SUPERVISORY FAILURES,THE FIRM CREATED RECORDS REFLECTING THE INACCURATE VALUES OFCERTAIN POSITIONS IN THE LO DESK'S TRADING ACCOUNT AND WASUNAWARE OF LOSSES IN EXCESS OF $18 MILLION ON THE LO DESKINCURRED OVER A PERIOD OF APPROXIMATELY 11 WEEKS DUE TOINACCURATE MARKS. IN ADDITION, THE FIRM FURTHER FAILED TO LIMIT,MONITOR OR TRACK RISK ASSOCIATED WITH ARBITRAGE TRADES MADEBY THE SLAB DESK AND IT DID NOT ANTICIPATE A LOSS OFAPPROXIMATELY 3.4 MILLION EUROS OCCASIONED BY A SINGLE SLABARBITRAGE TRADE. THE FAILURES RELATING TO THE LO DESK ALSOCurrent Status:Final127©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:N/ADate Initiated:12/08/2010Docket/Case Number:2008013504201Principal Product Type:OptionsOther Product Type(s):CAUSED CERTAIN OF THE FIRM'S BOOKS AND RECORDS TO BEINACCURATE PRIOR TO NOVEMBER 2007. IN ADDITION, IN DECEMBER2007, WHEN THE FIRM FILED THE FORM U5 FOR THE TRADERRESPONSIBLE FOR THE INACCURATE MARKS ON THE LO DESK, ITINCORRECTLY INDICATED THAT THE TRADER'S TERMINATION WAS "VOLUNTARY" WHEN IN FACT THE TRADER WAS "PERMITTED TO RESIGN."THE FIRM FURTHER INCORRECTLY INDICATED, IN RESPONSE TO ADISCLOSURE QUESTION, THAT THE TRADER WAS NOT UNDER INTERNALREVIEW AT THE TIME OF HIS TERMINATION WHEN, IN FACT, HE HAD BEENUNDER SUCH REVIEW.Resolution Date:12/08/2010Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED AND FINED $650,000.Sanctions Ordered:CensureMonetary/Fine $650,000.00Acceptance, Waiver & Consent(AWC)Disclosure 39 of 53iReporting Source:RegulatorAllegations:SEC RULE 10B-10, SEC RULE 606 OF REGULATION NMS, FINRA RULES2010, 6380A(A), 6380A(A)(2), 6380A(B), 6730(A), 7230A(B), 7230A(D), NASDRULES 2110, 4632(A), 4632(A)(2), 4632(B), 6130(B), 6130(D), 6230(A), 6955(A) -BNP PARIBAS SECURITIES CORP. FAILED TO TIMELY REPORT REPORTABLEORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS);Current Status:Final128©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRADate Initiated:08/25/2010Docket/Case Number:2008013545101Principal Product Type:OtherTRANSMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTSTO OATS THAT THE OATS SYSTEM WAS UNABLE TO LINK TO RELATEDTRADE REPORTS IN AN NASD TRADE REPORTING SYSTEM DUE TOINACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA;TRANSMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTS TO OATSTHAT THE OATS SYSTEM WAS UNABLE TO LINK TO THE RELATED ORDERROUTED TO NASDAQ DUE TO INACCURATE, INCOMPLETE OR IMPROPERLYFORMATTED DATA; AND TRANSMITTED NEW ORDER REPORTS ANDRELATED SUBSEQUENT REPORTS TO OATS WHERE THE TIMESTAMP FORTHE RELATED SUBSEQUENT REPORT OCCURRED PRIOR TO THE RECEIPTOF THE ORDER. THE FIRM FAILED TO ACCEPT OR DECLINE IN THEFINRA/NASDAQ TRADE REPORTING FACILITY (FNTRF) TRANSACTIONS INREPORTABLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION THATTHE FIRM HAD AN OBLIGATION TO ACCEPT OR DECLINE AS THE ORDERENTRY IDENTIFIER (OEID). THE FIRM MADE PUBLICLY AVAILABLE AREPORT ON ITS ROUTING OF NON-DIRECTED ORDERS IN COVEREDSECURITIES THAT INCLUDED INCORRECT INFORMATION AS TO ITSROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITIES. THEFIRM FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITSCUSTOMER ITS CORRECT CAPACITY IN A TRANSACTION. THE FIRMFAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THEFNTRF LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATEDSECURITIES. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCTVIOLATIONS OF NASD RULE 4632(A) AND A PATTERN OR PRACTICE OFLATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATIONOF NASD RULE 2110 AND FINRA RULES 2010, AND 6380A(A). THE FIRMDOUBLE REPORTED LAST SALE TRANSACTIONS IN DESIGNATEDSECURITIES TO THE FNTRF; INCORRECTLY DESIGNATED AS ".T" LASTSALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES TO THEFNTRF AND FAILED TO REPORT THE CORRECT EXECUTION TIME OFTRANSACTIONS IN REPORTABLE SECURITIES TO THE FNTRF. THE FIRMFAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE(TRACE) TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15MINUTES OF THE TIME OF EXECUTION. THIS CONDUCT CONSTITUTESSEPARATE AND DISTINCT VIOLATIONS OF NASD RULE 6230(A) AND APATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONALCIRCUMSTANCES IN VIOLATION OF NASD RULE 2110 AND FINRA RULES2010, AND 6730(A).129©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Other Product Type(s):REPORTABLE SECURITIES, DESIGNATED SECURITIES, COVEREDSECURITIES, TRACE-ELIGIBLE SECURITIESResolution Date:08/25/2010Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $77,500.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $77,500.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmAllegations:SEC RULE 10B-10, SEC RULE 606 OF REGULATION NMS, FINRA RULES2010, 6380A(A), 6380A(A)(2), 6380A(B), 6730(A), 7230A(B), 7230A(D), NASDRULES 2110, 4632(A), 4632(A)(2), 4632(B), 6130(B), 6130(D), 6230(A), 6955(A) -BNP PARIBAS SECURITIES CORP. FAILED TO TIMELY REPORT REPORTABLEORDER EVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS);TRANSMITTED EXECUTION OR COMBINED ORDER/EXECUTION REPORTSTO OATS THAT THE OATS SYSTEM WAS UNABLE TO LINK TO RELATEDTRADE REPORTS IN AN NASD TRADE REPORTING SYSTEM DUE TOINACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA;TRANSMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTS TO OATSTHAT THE OATS SYSTEM WAS UNABLE TO LINK TO THE RELATED ORDERROUTED TO NASDAQ DUE TO INACCURATE, INCOMPLETE OR IMPROPERLYFORMATTED DATA; AND TRANSMITTED NEW ORDER REPORTS ANDRELATED SUBSEQUENT REPORTS TO OATS WHERE THE TIMESTAMP FORTHE RELATED SUBSEQUENT REPORT OCCURRED PRIOR TO THE RECEIPTOF THE ORDER. THE FIRM FAILED TO ACCEPT OR DECLINE IN THECurrent Status:Final130©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:08/25/2010Docket/Case Number:2008013545101Principal Product Type:OtherOther Product Type(s):REPORTABLE SECURITIES, DESIGNATED SECURITIES, COVEREDSECURITIES, TRACE-ELIGIBLE SECURITIESFINRA/NASDAQ TRADE REPORTING FACILITY (FNTRF) TRANSACTIONS INREPORTABLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION THATTHE FIRM HAD AN OBLIGATION TO ACCEPT OR DECLINE AS THE ORDERENTRY IDENTIFIER (OEID). THE FIRM MADE PUBLICLY AVAILABLE AREPORT ON ITS ROUTING OF NON-DIRECTED ORDERS IN COVEREDSECURITIES THAT INCLUDED INCORRECT INFORMATION AS TO ITSROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITIES. THEFIRM FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITSCUSTOMER ITS CORRECT CAPACITY IN A TRANSACTION. THE FIRMFAILED, WITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THEFNTRF LAST SALE REPORTS OF TRANSACTIONS IN DESIGNATEDSECURITIES. THIS CONDUCT CONSTITUTES SEPARATE AND DISTINCTVIOLATIONS OF NASD RULE 4632(A) AND A PATTERN OR PRACTICE OFLATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATIONOF NASD RULE 2110 AND FINRA RULES 2010, AND 6380A(A). THE FIRMDOUBLE REPORTED LAST SALE TRANSACTIONS IN DESIGNATEDSECURITIES TO THE FNTRF; INCORRECTLY DESIGNATED AS ".T" LASTSALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES TO THEFNTRF AND FAILED TO REPORT THE CORRECT EXECUTION TIME OFTRANSACTIONS IN REPORTABLE SECURITIES TO THE FNTRF. THE FIRMFAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE(TRACE) TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15MINUTES OF THE TIME OF EXECUTION. THIS CONDUCT CONSTITUTESSEPARATE AND DISTINCT VIOLATIONS OF NASD RULE 6230(A) AND APATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONALCIRCUMSTANCES IN VIOLATION OF NASD RULE 2110 AND FINRA RULES2010, AND 6730(A).Resolution Date:08/25/2010Resolution:Sanctions Ordered:CensureAcceptance, Waiver & Consent(AWC)131©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $77,500.Monetary/Fine $77,500.00Disclosure 40 of 53iReporting Source:RegulatorInitiated By:NASDAQ STOCK MARKETPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:06/29/2010Docket/Case Number:2008015938801Principal Product Type:No ProductOther Product Type(s):Allegations:NASDAQ RULES 2110, 3010 - BNP PARIBAS SECURITIES' SUPERVISORYSYSTEM AND WRITTEN SUPERVISORY PROCEDURES WERE NOTREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS AND REGULATIONS (INCLUDING NASD NOTICE TOMEMBERS 04-66) AND NASDAQ RULES CONCERNING THE PREVENTION OFERRONEOUS ORDERS AND TRANSACTIONS AND FRIVOLOUS CLEARLYERRONEOUS TRANSACTION COMPLAINTS.Current Status:FinalResolution Date:06/29/2010Resolution:Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $10,000.00Acceptance, Waiver & Consent(AWC)132©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanctions Ordered:UNDERTAKINGSanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $10,000 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDINGCOMPLIANCE WITH NASD NOTICE TO MEMBERS 04-66 WITHIN 30BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NASDAQ REVIEWCOUNCIL.iReporting Source:FirmInitiated By:NASDAQ STOCK MARKETPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:06/29/2010Docket/Case Number:2008015938801Principal Product Type:No ProductOther Product Type(s):Allegations:NASDAQ RULES 2110, 3010 - BNP PARIBAS SECURITIES' SUPERVISORYSYSTEM AND WRITTEN SUPERVISORY PROCEDURES WERE NOTREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS AND REGULATIONS (INCLUDING NASD NOTICE TOMEMBERS 04-66) AND NASDAQ RULES CONCERNING THE PREVENTION OFERRONEOUS ORDERS AND TRANSACTIONS AND FRIVOLOUS CLEARLYERRONEOUS TRANSACTION COMPLAINTS.Current Status:FinalResolution Date:06/29/2010Resolution:Other Sanctions Ordered:UNDERTAKINGSanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $10,000 AND REQUIRED TOSanctions Ordered:CensureMonetary/Fine $10,000.00Acceptance, Waiver & Consent(AWC)133©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDINGCOMPLIANCE WITH NASD NOTICE TO MEMBERS 04-66 WITHIN 30BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NASDAQ REVIEWCOUNCIL.Disclosure 41 of 53iReporting Source:RegulatorInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Date Initiated:01/06/2010Docket/Case Number:2007008733501Principal Product Type:Equity - OTCOther Product Type(s):NASDAQ EQUITY SECURITIESAllegations:SEC RULE 10B-10, NASD RULES 2110, 3010, 3360, 6955 - BNP PARIBASSECURITIES CORP. FAILED TO TIMELY REPORT REPORTABLE ORDEREVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS);TRANSMITTED EXECUTION REPORTS TO OATS THAT CONTAINEDINACCURATE, INCOMPLETE OR IMPROPER FORMATTED DATA SO THATTHE OATS SYSTEM WAS UNABLE TO LINK THE EXECUTION REPORTS TOTHE RELATED TRADE REPORTS IN AN NASD TRADE REPORTING SYSTEM;THE FIRM TRANSMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTSTO OATS THAT THE OATS SYSTEM WAS UNABLE TO LINK TO THE RELATEDORDER ROUTED TO NASDAQ DUE TO INACCURATE; INCOMPLETE ORIMPROPERLY FORMATTED DATA; TRANSMITTED NEW ORDER REPORTSAND RELATED SUBSEQUENT REPORTS TO OATS WHERE THE TIMESTAMPFOR THE RELATED SUBSEQUENT REPORT OCCURRED PRIOR TO THERECEIPT OF THE ORDER; THE FIRM TRANSMITTED ROUTE OR COMBINEDORDER/ROUTE REPORTS TO OATS THAT THE OATS SYSTEM WAS UNABLETO LINK TO THE CORRESPONDING NEW ORDER TRANSMITTED BY THEDESTINATION MEMBER FIRM DUE TO INACCURATE, INCOMPLETE ORIMPROPERLY FORMATTED DATA. THE FIRM SUBMITTED INACCURATESHORT INTEREST POSITIONS TO NASD. THE FIRM'S SUPERVISORYSYSTEM PRIOR TO JUNE 29, 2004 DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING SHORTINTEREST REPORTING. THE FIRM FAILED TO PROVIDE WRITTENNOTIFICATION DISCLOSING TO ITS CUSTOMERS THAT TRANSACTIONSWERE EXECUTED AT AN AVERAGE PRICE.Current Status:Final134©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanction(s)/ReliefSought:Resolution Date:01/06/2010Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM WAS CENSURED AND FINED $82,500.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $82,500.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmAllegations:SEC RULE 10B-10, NASD RULES 2110, 3010, 3360, 6955 - BNP PARIBASSECURITIES CORP. FAILED TO TIMELY REPORT REPORTABLE ORDEREVENTS (ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS);TRANSMITTED EXECUTION REPORTS TO OATS THAT CONTAINEDINACCURATE, INCOMPLETE OR IMPROPER FORMATTED DATA SO THATTHE OATS SYSTEM WAS UNABLE TO LINK THE EXECUTION REPORTS TOTHE RELATED TRADE REPORTS IN AN NASD TRADE REPORTING SYSTEM;THE FIRM TRANSMITTED ROUTE OR COMBINED ORDER/ROUTE REPORTSTO OATS THAT THE OATS SYSTEM WAS UNABLE TO LINK TO THE RELATEDORDER ROUTED TO NASDAQ DUE TO INACCURATE; INCOMPLETE ORIMPROPERLY FORMATTED DATA; TRANSMITTED NEW ORDER REPORTSAND RELATED SUBSEQUENT REPORTS TO OATS WHERE THE TIMESTAMPFOR THE RELATED SUBSEQUENT REPORT OCCURRED PRIOR TO THERECEIPT OF THE ORDER; THE FIRM TRANSMITTED ROUTE OR COMBINEDORDER/ROUTE REPORTS TO OATS THAT THE OATS SYSTEM WAS UNABLETO LINK TO THE CORRESPONDING NEW ORDER TRANSMITTED BY THEDESTINATION MEMBER FIRM DUE TO INACCURATE, INCOMPLETE ORIMPROPERLY FORMATTED DATA. THE FIRM SUBMITTED INACCURATESHORT INTEREST POSITIONS TO NASD. THE FIRM'S SUPERVISORYSYSTEM PRIOR TO JUNE 29, 2004 DID NOT PROVIDE FOR SUPERVISIONCurrent Status:Final135©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:Date Initiated:01/06/2010Docket/Case Number:2007008733501Principal Product Type:Equity - OTCOther Product Type(s):NASDAQ EUITY SECURITIESREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING SHORTINTEREST REPORTING. THE FIRM FAILED TO PROVIDE WRITTENNOTIFICATION DISCLOSING TO ITS CUSTOMERS THAT TRANSACTIONSWERE EXECUTED AT AN AVERAGE PRICE.Resolution Date:01/06/2010Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM WAS CENSURED AND FINED $82,500.Sanctions Ordered:CensureMonetary/Fine $82,500.00Acceptance, Waiver & Consent(AWC)Disclosure 42 of 53iReporting Source:RegulatorAllegations:NASD RULES 2110, 3010, 4632(A), 4632(A)(4), 4632(A)(5)(E), 4632(B), 6130(G),6230, 6230(A) - BNP PARIBAS SECURITIES CORP. FAILED TO REPORT TOTHE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OFTIME OF EXECUTION AND REPORTED TRANSACTIONS IN TRACE-ELIGIBLESECURITIES TO TRACE IT WAS NOT REQUIRED TO REPORT. THISCONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASDRULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTINGWITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE2110. THE FIRM INCORRECTLY DESIGNATED AS ".ST" TO THECurrent Status:Final136©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:04/27/2009Docket/Case Number:2006006665701Principal Product Type:OtherOther Product Type(s):TRACE-ELIGIBLE SECURITIES, DESIGNATED SECURITIESNASD/NASDAQ TRADE REPORTING FACILITY (TRF) LAST SALE REPORTSOF TRANSACTIONS IN DESIGNATED SECURITIES BASED ON EXCHANGEFOR PHYSICAL TRANSACTIONS. THE FIRM FAILED, WITHIN 90 SECONDSAFTER EXECUTION, TO TRANSMIT TO THE TRF LAST SALE REPORTS OFTRANSACTIONS IN DESIGNATED SECURITIES. THIS CONDUCTCONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD RULE4632(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUTEXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE 2110. THEFIRM TRANSMITTED TO THE TRF LAST SALE REPORTS OF TRANSACTIONSIN DESIGNATED SECURITIES AND FAILED TO DESIGNATE THROUGH THETRF SUCH LAST SALE REPORTS AS REFLECTING THE TRADES OCCURREDAT A PRICE BASED ON AN AVERAGE WEIGHTING OR ANOTHER SPECIALPRICING FORMULA. THE FIRM FAILED TO REPORT TO THE TRF LAST SALEREPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES. THE FIRMFAILED TO REPORT BY 6:30 P.M. EASTERN TIME TRANSACTIONS THAT AREASSESSED A REGULATORY TRANSACTION FEE UNDER SECTION 3 OFSCHEDULE A TO THE FINRA BY-LAWS. [CONTINUED IN COMMENTS]Resolution Date:04/27/2009Resolution:Other Sanctions Ordered:UNDERTAKINGSanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDDoes the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $70,000.00Acceptance, Waiver & Consent(AWC)137©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $70,000 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING EQUITYTRADE REPORTING INCLUDING REPORTING THE FIRM'S GUARANTEEDVOLUME WEIGHTED AVERAGE PRICE (GVWAP) TRANSACTIONS, ANDTRADES REQUIRED TO BE REPORTED BY 6:30 P.M. UNDER NASD RULE6130(G) WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THENAC.Regulator StatementTHE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING TRADEREPORTING EQUITIES SECURITIES PURSUANT TO NASD RULE 4632(A),EQUITY TRADE REPORTING INCLUDING REPORTING THE FIRM'SGUARANTEED VOLUME WEIGHTED AVERAGE PRICE (GVWAP)TRANSACTIONS, AND TRADES REQUIRED TO BE REPORTED BY 6:30 P.M.UNDER NASD RULE 6130(G).iReporting Source:FirmAllegations:NASD RULES 2110, 3010, 4632(A), 4632(A)(4), 4632(A)(5)(E), 4632(B), 6130(G),6230, 6230(A) - BNP PARIBAS SECURITIES CORP. FAILED TO REPORT TOTHE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OFTIME OF EXECUTION AND REPORTED TRANSACTIONS IN TRACE-ELIGIBLESECURITIES TO TRACE IT WAS NOT REQUIRED TO REPORT. THISCONDUCT CONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASDRULE 6230(A) AND A PATTERN OR PRACTICE OF LATE REPORTINGWITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE2110. THE FIRM INCORRECTLY DESIGNATED AS ".ST" TO THENASD/NASDAQ TRADE REPORTING FACILITY (TRF) LAST SALE REPORTSOF TRANSACTIONS IN DESIGNATED SECURITIES BASED ON EXCHANGEFOR PHYSICAL TRANSACTIONS. THE FIRM FAILED, WITHIN 90 SECONDSAFTER EXECUTION, TO TRANSMIT TO THE TRF LAST SALE REPORTS OFTRANSACTIONS IN DESIGNATED SECURITIES. THIS CONDUCTCONSTITUTES SEPARATE AND DISTINCT VIOLATIONS OF NASD RULE4632(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUTEXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF NASD RULE 2110. THEFIRM TRANSMITTED TO THE TRF LAST SALE REPORTS OF TRANSACTIONSIN DESIGNATED SECURITIES AND FAILED TO DESIGNATE THROUGH THETRF SUCH LAST SALE REPORTS AS REFLECTING THE TRADES OCCURREDAT A PRICE BASED ON AN AVERAGE WEIGHTING OR ANOTHER SPECIALPRICING FORMULA. THE FIRM FAILED TO REPORT TO THE TRF LAST SALECurrent Status:Final138©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:04/27/2009Docket/Case Number:2006006665701Principal Product Type:OtherOther Product Type(s):TRACE-ELIGIBLE SECURITIES, DESIGNATED SECURITIESREPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES. THE FIRMFAILED TO REPORT BY 6:30 P.M. EASTERN TIME TRANSACTIONS THAT AREASSESSED A REGULATORY TRANSACTION FEE UNDER SECTION 3 OFSCHEDULE A TO THE FINRA BY-LAWS. [CONTINUED IN COMMENTS]Resolution Date:04/27/2009Resolution:Other Sanctions Ordered:UNDERTAKINGSanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $70,000 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING EQUITYTRADE REPORTING INCLUDING REPORTING THE FIRM'S GUARANTEEDVOLUME WEIGHTED AVERAGE PRICE (GVWAP) TRANSACTIONS, ANDTRADES REQUIRED TO BE REPORTED BY 6:30 P.M. UNDER NASD RULE6130(G) WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THENAC.Firm StatementTHE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISIONREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLESECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING TRADEREPORTING EQUITIES SECURITIES PURSUANT TO NASD RULE 4632(A),EQUITY TRADE REPORTING INCLUDING REPORTING THE FIRM'SGUARANTEED VOLUME WEIGHTED AVERAGE PRICE (GVWAP)TRANSACTIONS, AND TRADES REQUIRED TO BE REPORTED BY 6:30 P.M.UNDER NASD RULE 6130(G).Sanctions Ordered:CensureMonetary/Fine $70,000.00Acceptance, Waiver & Consent(AWC)Disclosure 43 of 53i139©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceReporting Source:RegulatorInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:03/30/2009Docket/Case Number:2007007861301Principal Product Type:OptionsOther Product Type(s):Allegations:NASD RULES 2110, 2860(B)(5), 3010 - BNP PARIBAS SECURITIES CORP.FAILED TO REPORT REPORTABLE POSITIONS IN CONVENTIONAL OPTIONSBY THE CLOSE OF BUSINESS ON THE NEXT BUSINESS DAY FOLLOWINGTHE DAY ON WHICH THE TRANSACTIONS TOOK PLACE AND FAILED INSOME INSTANCES TO RESPOND PROPERLY AFTER TRADES WEREREJECTED BY THE SECURITIES INDUSTRY AUTOMATION CORPORATION(SIAC). THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULESCONCERNING REPORTING OF OPTIONS POSITIONS.Current Status:FinalResolution Date:03/30/2009Resolution:Other Sanctions Ordered:UNDERTAKINGSanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE THE FIRM IS CENSURED, FINED $17,500 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING THEREPORTING OF OPTIONS POSITIONS WITHIN 30 BUSINESS DAYS OFDoes the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $17,500.00Acceptance, Waiver & Consent(AWC)140©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceACCEPTANCE OF THIS AWC BY THE NAC.iReporting Source:FirmInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:01/02/2009Docket/Case Number:20070078613Principal Product Type:OptionsOther Product Type(s):Allegations:NASD RULES 2110, 2860(B)(5), 3010 - BNP PARIBAS SECURITIES CORP.FAILED TO REPORT REPORTABLE POSITIONS IN CONVENTIONAL OPTIONSBY THE CLOSE OF BUSINESS ON THE NEXT BUSINESS DAY FOLLOWINGTHE DAY ON WHICH THE TRANSACTIONS TOOK PLACE AND FAILED INSOME INSTANCES TO RESPOND PROPERLY AFTER TRADES WEREREJECTED BY THE SECURITIES INDUSTRY AUTOMATION CORPORATION(SIAC). THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULESCONCERNING REPORTING OF OPTIONS POSITIONS.Current Status:FinalResolution Date:03/30/2009Resolution:Other Sanctions Ordered:UNDERTAKINGSanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE THE FIRM IS CENSURED, FINED $17,500 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING THEREPORTING OF OPTIONS POSITIONS WITHIN 30 BUSINESS DAYS OFACCEPTANCE OF THIS AWC BY THE NAC.Firm StatementWITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;Sanctions Ordered:CensureMonetary/Fine $17,500.00Acceptance, Waiver & Consent(AWC)141©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceTHEREFORE THE FIRM IS CENSURED, FINED $17,500 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING THEREPORTING OF OPTIONS POSITIONS WITHIN 30 BUSINESS DAYS OFACCEPTANCE OF THIS AWC BY THE NAC.Disclosure 44 of 53iReporting Source:FirmInitiated By:INTERNATIONAL SECURITIES EXCHANGEPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:10/10/2007Docket/Case Number:Principal Product Type:OptionsOther Product Type(s):Allegations:IN CONNECTION WITH 830 INSTANCES, BNP PARIBAS SECURITIES CRPFAILED TO PARTICIPATE ON THE OPENING ROTATION IN 60% OF THECLASSES TO WHICH IT WAS APPOINTED ON THE EXCHANGE. THISCONTITUTES A VIOLATION OF RULE 804(E)(2)(I). IN CONNECTION WITH15,421 INSTANCES, BNP PARIBAS SECURITIES CORP FAILED TO MAINTAINCONTINUOUS QUOTATIONS FOR ALL SERIES OF THE OPTIONS CLASSLISTED ON THE EXCHANGE UNTIL THE CLOSE OF TRADING THAT DAY,AFTER IT HAD ENTERED A QUOTE IN AN OPTIONS CLASS TO WHICH ITWAS APPOINTED. THIS CONSTITUTES A VIOLATION OF RULE 804(E)(2)(II).Current Status:FinalResolution Date:12/11/2007Resolution:Other Sanctions Ordered:Sanction Details:BNP PARIBAS WAS CENSORED AND FINED $45,000.00.Firm StatementIN CONNECTION WITH 830 INSTANCES, BNP PARIBAS SECURITIES CRPFAILED TO PARTICIPATE ON THE OPENING ROTATION IN 60% OF THECLASSES TO WHICH IT WAS APPOINTED ON THE EXCHANGE. THISCONTITUTES A VIOLATION OF RULE 804(E)(2)(I). IN CONNECTION WITHSanctions Ordered:CensureMonetary/Fine $45,000.00Acceptance, Waiver & Consent(AWC)142©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser Guidance15,421 INSTANCES, BNP PARIBAS SECURITIES CORP FAILED TO MAINTAINCONTINUOUS QUOTATIONS FOR ALL SERIES OF THE OPTIONS CLASSLISTED ON THE EXCHANGE UNTIL THE CLOSE OF TRADING THAT DAY,AFTER IT HAD ENTERED A QUOTE IN AN OPTIONS CLASS TO WHICH ITWAS APPOINTED. THIS CONSTITUTES A VIOLATION OF RULE 804(E)(2)(II).Disclosure 45 of 53iReporting Source:RegulatorInitiated By:FINRADate Initiated:12/13/2007Docket/Case Number:2005001797101Principal Product Type:OtherOther Product Type(s):ELIGIBLE SECURITIES, DESIGNATED SECURITIES, TRACE-ELIGIBLESECURITIESAllegations:SEC RULE 17A-3, NASD RULES 2110, 3010, 3110, 4632(E), 6230(B),6420(A)(1)(B), 6420(C)(5), 6955(A) - BNP PARIBUS SECURITIES CORP. FAILEDWITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE NASDAQMARKET CENTER (NMC) LAST SALE REPORTS OF TRANSACTIONS INELIGIBLE SECURITIES; FAILED WITHIN 90 SECONDS AFTER EXECUTION TOTRANSMIT TO THE NMC AND THE TRADE REPORTING FACILITY (TRF) LASTSALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES; FAILEDTO REPORT THE CORRECT TIME OF EXECUTION TO THE NMC IN LATE,LAST SALE REPORTS OF TRANSACTIONS IN ELIGIBLE SECURITIES;INCORRECTLY DESIGNATED AS ".ST" TO THE NMC LAST SALE REPORTS OFTRANSACTIONS IN DESIGNATED SECURITIES REPORTED TO THE NMCWITHIN 90 SECONDS OF EXECUTION. THE FIRM REPORTED TO THE NMCLAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES ITWAS NOT REQUIRED TO REPORT. THE FIRM TRANSMITTED TO OATSREPORTS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLYFORMATTED DATA; FAILED TO SHOW THE TERMS AND CONDITIONS ONBROKERAGE ORDER MEMORANDA. THE FIRM'S SUPERVISORY SYSTEMDID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS AND NASD RULES CONCERNING SUPERVISORY SYSTEM,PROCEDURES & QUALIFICATIONS; BEST EXECUTION; TRADE REPORTINGAND OATS REPORTING. THE FIRM FAILED TO REPORT TO TRACETRANSACTIONS IN TRACE-ELIGIBLE SECURITIES IT WAS REQUIRED TOREPORT.Current Status:Final143©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Resolution Date:12/13/2007Resolution:Other Sanctions Ordered:UNDERTAKINGSanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $38,000 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDINGSUPERVISORY SYSTEM, PROCEDURES & QUALIFICATIONS; BESTEXECUTION; TRADE REPORTING AND OATS REPORTING WITHIN 30BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $38,000.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmAllegations:SEC RULE 17A-3, NASD RULES 2110, 3010, 3110, 4632(E), 6230(B),6420(A)(1)(B), 6420(C)(5), 6955(A) - BNP PARIBUS SECURITIES CORP. FAILEDWITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE NASDAQMARKET CENTER (NMC) LAST SALE REPORTS OF TRANSACTIONS INELIGIBLE SECURITIES; FAILED WITHIN 90 SECONDS AFTER EXECUTION TOTRANSMIT TO THE NMC AND THE TRADE REPORTING FACILITY (TRF) LASTSALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES; FAILEDTO REPORT THE CORRECT TIME OF EXECUTION TO THE NMC IN LATE,LAST SALE REPORTS OF TRANSACTIONS IN ELIGIBLE SECURITIES;INCORRECTLY DESIGNATED AS ".ST" TO THE NMC LAST SALE REPORTS OFTRANSACTIONS IN DESIGNATED SECURITIES REPORTED TO THE NMCWITHIN 90 SECONDS OF EXECUTION. THE FIRM REPORTED TO THE NMCLAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES ITWAS NOT REQUIRED TO REPORT. THE FIRM TRANSMITTED TO OATSCurrent Status:Final144©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:CensureOther Sanction(s)/ReliefSought:MONETARY FINE IN THE AMOUNT OF $38,000.00.Date Initiated:12/13/2007Docket/Case Number:20050017971-01Principal Product Type:OtherOther Product Type(s):ELIGIBLE SECURITIES, DESIGNATED SECURITIES, TRACE-ELIGIBLESECURITIESREPORTS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLYFORMATTED DATA; FAILED TO SHOW THE TERMS AND CONDITIONS ONBROKERAGE ORDER MEMORANDA. THE FIRM'S SUPERVISORY SYSTEMDID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS AND NASD RULES CONCERNING SUPERVISORY SYSTEMS,PROCEDURES & QUALIFICATIONS; BEST EXECUTION; TRADE REPORTINGAND OATS REPORTING. THE FIRM FAILED TO REPORT TO TRACETRANSACTIONS IN TRACE-ELIGIBLE SECURITIES IT WAS REQUIRED TOREPORT.Resolution Date:12/13/2007Resolution:Other Sanctions Ordered:UNDERTAKINGSanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED, FINED $38,000 AND REQUIRED TOREVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDINGSUPERVISORY SYSTEMS, PROCEDURES & QUALIFICATIONS; BESTEXECUTION; TRADE REPORTING AND OATS REPORTING WITHIN 30BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC.Firm StatementSEC RULE 17A-3, NASD RULES 2110, 3010, 3110, 4632(E), 6230(B),6420(A)(1)(B), 6420(C)(5), 6955(A) - BNP PARIBUS SECURITIES CORP. FAILEDWITHIN 90 SECONDS AFTER EXECUTION, TO TRANSMIT TO THE NASDAQMARKET CENTER (NMC) LAST SALE REPORTS OF TRANSACTIONS INELIGIBLE SECURITIES; FAILED WITHIN 90 SECONDS AFTER EXECUTION TOTRANSMIT TO THE NMC AND THE TRADE REPORTING FACILITY (TRF) LASTSanctions Ordered:CensureMonetary/Fine $38,000.00Acceptance, Waiver & Consent(AWC)145©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceSALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES; FAILEDTO REPORT THE CORRECT TIME OF EXECUTION TO THE NMC IN LATE,LAST SALE REPORTS OF TRANSACTIONS IN ELIGIBLE SECURITIES;INCORRECTLY DESIGNATED AS ".ST" TO THE NMC LAST SALE REPORTS OFTRANSACTIONS IN DESIGNATED SECURITIES REPORTED TO THE NMCWITHIN 90 SECONDS OF EXECUTION. THE FIRM REPORTED TO THE NMCLAST SALE REPORTS OF TRANSACTIONS IN DESIGNATED SECURITIES ITWAS NOT REQUIRED TO REPORT. THE FIRM TRANSMITTED TO OATSREPORTS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLYFORMATTED DATA; FAILED TO SHOW THE TERMS AND CONDITIONS ONBROKERAGE ORDER MEMORANDA. THE FIRM'S SUPERVISORY SYSTEMDID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS,REGULATIONS AND NASD RULES CONCERNING SUPERVISORY SYSTEMS,PROCEDURES & QUALIFICATIONS; BEST EXECUTION; TRADE REPORTINGAND OATS REPORTING. THE FIRM FAILED TO REPORT TO TRACETRANSACTIONS IN TRACE-ELIGIBLE SECURITIES IT WAS REQUIRED TOREPORT.Disclosure 46 of 53iReporting Source:RegulatorInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:08/21/2007Docket/Case Number:2005000007101Principal Product Type:No ProductOther Product Type(s):Allegations:NASD RULE 6955(A) - BNP PARIBAS SECURITIES CORP. FAILED TO SUBMITNUMEROUS ROUTE REPORTS RELATED TO CANCEL/REPLACE REPORTS;AND SUBMITTED TO OATS ROUTE OR COMBINED ORDER/ROUTEREPORTS THAT THE OATS SYSTEM WAS UNABLE TO LINK TO THECORRESPONDING NEW ORDER SUBMITTED BY THE DESTINATIONMEMBER FIRM DUE TO INACCURATE, INCOMPLETE OR IMPROPERLYFORMATTED DATA.Current Status:Final146©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceResolution Date:08/21/2007Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $10,000.Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:CensureMonetary/Fine $10,000.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmInitiated By:FINRAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:08/21/2007Docket/Case Number:20050000071-01Principal Product Type:No ProductOther Product Type(s):Allegations:NASDD RULE 6955(A) - BNP PARIBAS SECURITIES CORP. FAILED TOSUBMIT NUMEROUS ROUTE REPORTS RELATED TO CANCEL/REPLACEREPORTS; AND SUBMITTED TO OATS ROUTE OR COMBINEDORDER/ROUTE THAT THE OATS SYSTEM WAS UNABLE TO LINK TO THECORRESPONDING NEW ORDER SUBMITTED BY THE DESTINATIONMEMBER FIRM DUE TO INACCURATE, INCOMPLETE OR IMPROPERLYFORMATTED DATA.Current Status:FinalResolution Date:08/21/2007Resolution:Acceptance, Waiver & Consent(AWC)147©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $10,000.Sanctions Ordered:CensureMonetary/Fine $10,000.00Disclosure 47 of 53iReporting Source:RegulatorInitiated By:NASDPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:10/02/2006Docket/Case Number:E1020050056-01Principal Product Type:Debt - MunicipalOther Product Type(s):Allegations:MSRB RULE G-14: THE FIRM REPORTED MUNICIPAL SECURITIESTRANSACTIONS TO THE MSRB INCORRECTLY, SPECIFICALLY IT EITHERFAILED TO REPORT THE EXECUTION TIME OR REPORTED THE INCORRECTEXECUTION TIME, AND ALSO REPORTED TRANSACTIONS LATE.Current Status:FinalResolution Date:10/02/2006Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT MEMBERFIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OFDoes the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?NoSanctions Ordered:Monetary/Fine $5,000.00Acceptance, Waiver & Consent(AWC)148©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceFINDINGS; THEREFORE, THE FIRM IS FINED $5,000.iReporting Source:FirmInitiated By:NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:ACCEPTANCE WAIVER AND CONSENT WITH A FINEDate Initiated:10/02/2006Docket/Case Number:E1020050056-01Principal Product Type:Debt - MunicipalOther Product Type(s):Allegations:MSRB RULE G-14: THE FIRM REPORTED MUNICIPAL SECURITIESTRANSACTIONS TO THE MSRB INCORRECTLY, SPECIFICALLY THE FIRMEITHER FAILED TO REPORT THE EXECUTION TIME OR REPORTEDTHEINCORRECT EXECUTION TIME, AND ALSO REPORTING TRANSACTIONSLATE.Current Status:FinalResolution Date:10/02/2006Resolution:Other Sanctions Ordered:Sanction Details:CHECK #238500 IN THE AMOUNT OF $5000. WAS SENT VIA FEDEX TO THENASD ON OCTOBER 17,2006.Firm StatementWITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT MEMBERFIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OFFINDINGS, THEREFORE, THE FIRM IS FINED $5,000.Sanctions Ordered:Monetary/Fine $5,000.00Acceptance, Waiver & Consent(AWC)Disclosure 48 of 53iReporting Source:FirmInitiated By:INTERNATIONAL SECURITIES EXCHANGEAllegations:VIOLATIONS OF ISE RULE 804Current Status:Final149©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:OtherOther Sanction(s)/ReliefSought:ACCEPTANCE WAIVER AND CONSENT WITH A FINEDate Initiated:12/14/2005Docket/Case Number:Principal Product Type:OptionsOther Product Type(s):Resolution Date:03/08/2006Resolution:Other Sanctions Ordered:Sanction Details:THE $10,000.00 FINE WAS PAID ON MARCH 15, 2006, CHECK # 225984.Firm StatementDURING THE REVIEW PERIOD (OCTOBER 20, 2003 THROUGH JULY 16, 2004)IN 55 INSTANCES BNP FAILED TO MAINTAIN A CONTINUOUS QUOTATION INAT LEAST 60 PERCENT OF THE OPTIONS CLASSES TO WHICH BNP WASAPPOINTED ON THE EXCHANGE. IN 596 INSTANCES, AFTER HAVINGENTERED A QUOTE OR ORDER IN AN OPTIONS CLASS TO WHICH BNP WASAPPOINTED, BNP FAILED TO MAINTAIN CONTINUOUD QUOTATIONS FOREXPIRING SERIES OF AN OPTIONS CLASS DURING THE MONTH IN WHICHTHE SERIES EXPIRED.Sanctions Ordered:Monetary/Fine $10,000.00Acceptance, Waiver & Consent(AWC)Disclosure 49 of 53iReporting Source:RegulatorInitiated By:NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Date Initiated:03/27/2003Allegations:NASD RULES 2110, 3010 AND 6955(A) - RESPONDENT MEMBER FAILED TOCORRECT OR REPLACE ANY OF THE SUBJECT REPORTS SUBMITTED TOOATS WITH RESPECT TO EQUITY SECURITIES TRADED ON THE NASDAQSTOCK MARKET THAT WERE NOT IN THE ELECTRONIC FORM PRESCRIBEDBY NASD; THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FORSUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHRESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, ANDNASD'S RULES CONCERNING OATS.Current Status:Final150©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Docket/Case Number:CMS030064Principal Product Type:No ProductOther Product Type(s):Resolution Date:03/27/2003Resolution:Other Sanctions Ordered: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$12,000.Sanctions Ordered:CensureMonetary/Fine $12,000.00Acceptance, Waiver & Consent(AWC)iReporting Source:FirmInitiated By:NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Date Initiated:03/27/2003Docket/Case Number:CMS030064Principal Product Type:No ProductOther Product Type(s):Allegations:NASD RULES 2110, 3010 AND 6955(A)-RESPONDENT MEMBERS FAILED TOCORRECT OR REPLACE ANY OF THE SUBJECT REPORTS SUBMITTED TOOATS WITH RESPECT TO EQUITY SECURITIES TRADED ON THE NASDAQSTOCK MARKET THAT WERE NOT IN THE ELECTRONIC FORM PRESCRIBEDBY NASD; THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE THESUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHRESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, ANDNASD'S RULES CONCERNING OATS.Current Status:Final151©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanction(s)/ReliefSought:Resolution Date:03/27/2003Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, RESPONDENTMEMBER CONSENTED TO THE DESCRIBED SANCTIONS AND TO THEENTRY OF FINDINGS, THEREFORE HTE FIRM IS CENSORED AND FINED$12,000.Sanctions Ordered:CensureMonetary/Fine $12,000.00Acceptance, Waiver & Consent(AWC)Disclosure 50 of 53iReporting Source:FirmInitiated By:THE BOARD OF TRADE OF THE CITY OF CHICAGO (THE "CBOT")Principal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated:08/21/1998Docket/Case Number:CBOT FILE NO. 98-MSR-27Principal Product Type:Futures - FinancialOther Product Type(s):Allegations:THE MATTER INVOLVED PRELIMINARY CHARGES BY THE BUSINESSCONDUCT COMMITTEE OF THE CBOT AS TO THE POSSIBLE VIOLATION OFTWO CBOT REGULATIONS (OR RULES), REGULATION 444.01 (THIS RULEREFERS TO THE EXCHANGE FOR PHYSICALS IN CONNECTION WITH AFUTURES TRANSACTION) AND RULE 332.00 (THIS RULE INVOLVES THEEXECUTION OF A FUTURES TRANSACTION BY OPEN OUTCRY IN THE OPENMARKT). WITHOUT ADMITTING OR DENYING ANY VIOLATIONS, THEAPPLICANT AGREED TO PAY $10,000.00 WITH RESPECT TO THE MATTER.Current Status:FinalResolution Date:09/18/1998Resolution:Settled152©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING ANY VIOLATION, THE APPLICANTAGREED TO PAY $10,000 WITH RESPECT TO THE MATTER.Sanctions Ordered:Monetary/Fine $10,000.00Disclosure 51 of 53iReporting Source:RegulatorInitiated By:NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Principal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:09/29/1998Docket/Case Number:C04980049Principal Product Type:Other Product Type(s):Allegations:Current Status:FinalResolution Date:09/29/1998Resolution:Other Sanctions Ordered:Sanction Details:Regulator StatementON SEPTEMBER 29, 1998, DISTRICT NO. 4 NOTIFIED RESPONDENTPARIBAS CORPORATION THAT THE LETTER OF ACCEPTANCE, WAIVER ANDCONSENT NO. C04980049 WAS ACCEPTED; THEREFORE, RESPONDENTMEMBER IS CENSURED AND FINED $20,000 - (NASD RULES 2110, 3010,3110, MARKETPLACE RULES 4632(a), 4642(a), 6420(a), 6620(a),6130(b), AND SEC RULES 10b-10(a)(2) AND 17a-3(6) - RESPONDENTMEMBER FAILED TO REPORT TRANSACTIONS IN NASDAQ NATIONALMARKET("NMS"), NASDAQ SMALLCAP, OVER-THE-COUNTER ("OTC"), AND LISTEDSECURITIES IN WHICH IT HAD REPORTING RESPONSIBILITY; FAILED TOSanctions Ordered:CensureMonetary/Fine $20,000.00Acceptance, Waiver & Consent(AWC)153©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceDESIGNATE AS LATE TO ACT, TRANSACTIONS IN NASDAQ NMSSECURITIES, IN THAT THE ORDER ENTRY FIRM REPORTED TO ACT INEACH SUCH TRANSACTION MORE THAN 90 SECONDS PRIOR TORESPONDENTMEMBER; FAILED TO DESIGNATE AS LATE TO ACT, TRANSACTIONS IN OTCSECURITIES AND ONE TRANSACTION IN A LISTED SECURITY, IN THATTHE ORDER ENTRY FIRM REPORTED TO ACT IN EACH SUCHTRANSACTIONMORE THAN 90 SECONDS PRIOR TO RESPONDENT MEMBER; IMPROPERLYDESIGNATED AS ".T" TO ACT ONE TRANSACTION IN A NASDAQ NMSSECURITY AND TRANSACTIONS IN OTC SECURITIES; FAILED TO ACCEPTOR DECLINE TRANSACTIONS ON THE ACT SYSTEM WITHIN 20 MINUTESAFTER EXECUTION; FAILED TO PROVIDE WRITTEN NOTIFICATIONACCURATELY DISCLOSING THE FIRM'S REPORTED PRICE AND THEDIFFERENCE BETWEEN THE PRICE TO THE CUSTOMER AND THEREPORTEDTRADE PRICE; FAILED TO CONSISTENTLY AND ACCURATELY REFLECT THETIME OF ENTRY AND TIME OF EXECUTION ON ORDER TICKETS; AND,FAILED TO IMPLEMENT AND ENFORCE ADEQUATE SUPERVISORYPROCEDURESREASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THEAPPLICABLESECURITIES LAWS AND REGULATIONS RELATING TO TRADE REPORTING).*** $20,000 PAID ON 11/14/98, INVOICE NO. 98-04-781 *****iReporting Source:FirmInitiated By:NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Date Initiated:09/01/1998Docket/Case Number:AWC NO. C04980049Principal Product Type:No ProductAllegations:IN SEPTEMBER 1998, THE NASD REGULATION, INC.'S DEPT. OFENFORCEMENT AND THE NATIONAL ADJUCIATORY COUNCIL ACCEPTED ALETTER OF ACCEPTANCE WAIVER AND CONSENT FROM PARIBASCORPORATION. WITHOUT ADMITTING OR DENYING THE ALLEGEDVIOLATIONS, PARIBAS CORPORATION CONSENTED TO A FINE OF$20,000.00 AND FINDINGS PERTAINING TO VIOLATIONS OF TRANSACTIONREPORTING REQUIREMENTS AND IMPLEMENTATION OF WRITTENSUPERVISORY PROCEDURES.Current Status:Final154©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Other Product Type(s):Resolution Date:09/01/1998Resolution:Other Sanctions Ordered:Sanction Details:WITHOUT ADMITTING OR DENYING THE ALLEGED VIOLATIONS, PARIBASCORPORATION CONSENTED TO A FINE OF $20,000 AND FINDINGSPERTAINING TO VIOLATIONS OF TRANSACTION REPORTINGREQUIREMENT & IMPLEMENTATION OF WRITTEN SUPERVISORYPROCEDURES.Sanctions Ordered:Monetary/Fine $20,000.00Acceptance, Waiver & Consent(AWC)Disclosure 52 of 53iReporting Source:RegulatorInitiated By:CAPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:08/12/1992Docket/Case Number:URL for Regulatory Action:Principal Product Type:Other Product Type(s):Allegations:DID NOT PAY ASSESSMENT FEECurrent Status:FinalResolution Date:08/12/1992Resolution:Sanctions Ordered:Revocation/Expulsion/DenialOrder155©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceOther Sanctions Ordered:Sanction Details:BROKER DEALER CERTIFICATE SUMMARILY REVOKED FORNON-PAYMENT OF ASSESSMENT FEERegulator StatementNot ProvidediReporting Source:FirmInitiated By:STATE OF CALIFORNIAPrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Date Initiated:08/12/1992Docket/Case Number:Principal Product Type:No ProductOther Product Type(s):Allegations:FAILURE OF PAYMENT OF $375.00 ANNUAL AASSESSMENT FEE.Current Status:FinalResolution Date:08/12/1992Resolution:Other Sanctions Ordered:CERTIFICATION AS BD IN THE STATE OF CALIFORNIA REVOKED.Sanction Details:CERTIFICATION AS BD IN THE STATE OF CALIFORNIA REVOKEDSanctions Ordered:SettledDisclosure 53 of 53iReporting Source:RegulatorInitiated By:NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Date Initiated:07/08/1988Docket/Case Number:MS-741-AWCAllegations:Current Status:Final156©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Principal Product Type:Other Product Type(s):Resolution Date:10/11/1988Resolution:Other Sanctions Ordered:Sanction Details:Regulator StatementMARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-741-AWC:LETTER OF ACCEPTANCE, WAIVER AND CONSENT FILED JULY 8, 1988AGAINST RESPONDENT PARIBAS CORPORATION ALLEGING VIOLATIONSOFPART VI, SECTION 4(a) OF SCHEDULE D IN THAT THE RESPONDENTFAILED TO REPORT ITS NASDAQ VOLUME.THE LETTER OF ACCEPTANCE, WAIVER AND CONSENT WAS ACCEPTED BYTHE MARKET SURVEILLANCE COMMITTEE ON OCTOBER 11, 1988 AND BYTHE NATIONAL BUSINESS CONDUCT COMMITTEE ON SEPTEMBER 21,1988.$500 FINE$500 PAID 8/26/88Sanctions Ordered:Monetary/Fine $500.00ConsentiReporting Source:FirmInitiated By:NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.Date Initiated:07/08/1988Docket/Case Number:MS-741-AWCAllegations:MARKET SURVEILLANCE COMMITTEE ALLEGING VIOLATIONS OF PART V1,SECTION 4(A) OF SCHEDULE D IN THAT THE RESPONDENTFAILED TOREPORT ITS NASDAQ VOLUME.Current Status:Final157©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidancePrincipal Sanction(s)/ReliefSought:Civil and Administrative Penalt(ies) /Fine(s)Other Sanction(s)/ReliefSought:Principal Product Type:No ProductOther Product Type(s):Resolution Date:10/11/1988Resolution:Other Sanctions Ordered:Sanction Details:A FINE IN THE AMOUNT OF $500.00 WAS PAID 8/26/88Firm StatementMARKET SURVEILLANCE COMMITTEE COMPLAINT #MS-741-AWC LETTEROF ACCEPTANCE, WAIVER AND CONSENT FILED JULY 8, 1988 AGAINSTRESPONSDENT PARIBAS CORPORATION ALLEGING VIOLATIONS OF PARTV1, SECTION 4(A) OF SCHEDULE D IN THAT THE RESPONSDENT FAILED TOREPORT ITS NASDAQ VOLUME. THE LETTER OF ACCEPTANCE, WAIVERAND CONSENT WAS ACCEPTED BY THE MARKET SURVEILLANCECOMMITTEE ON OCTOBER 11, 1988 AND BY THE NATIONAL BUSINESSCONDUCT COMMITTEE ON SEPTEMBER 21, 1988 $500 FINE PAID 8/26/1988.Sanctions Ordered:Monetary/Fine $500.00Consent158©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceRegulatory - PendingThis type of disclosure event may include a pending formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulatory agency such as the Securities and ExchangeCommission, foreign financial regulatory body) for alleged violations of investment-related rules or regulations.Disclosure 1 of 1Reporting Source:FirmInitiated By:NOTIFICATION FROM FINRA ON BEHALF OF NYSE REGULATIONPrincipal Sanction(s)/ReliefSought:Other Sanction(s)/ReliefSought:Date Initiated:12/04/2012Docket/Case Number:Principal Product Type:OptionsOther Product Type(s):Allegations:ON DECEMBER 4, 2012 BNP PARIBAS SECURITIES CORP ("BNPS")RECEIVED NOTIFICATION FROM FINRA ON BEHALF OF THE NYSEREGULATION FOR ALLEGED VIOLATIONS OF NYSE ARCA OPTIONS RULES6.8 (POSITION LIMITS) AND 11.18 (SUPERVISION) DURING THE PERIODFEBRUARY 4, 2010 THROUGH MARCH 28, 2012 FOR SUBMITTINGINACCURATE OPTIONS CONTRACT EQUIVALENT OF THE NET DELTA("OCEND") DATA AND FAILURE TO ADOPT AND MAINTAIN ADEQUATESUPERVISORY PROCEDURES RELATED TO THE ACCURATE REPORTINGOF SUCH DATA. BNPS SUBMITTED A RESPONSE TO SUCH ALLEGATIONSON JANUARY 4, 2013, WHICH IS PENDING FINRA/NYSE REGULATIONREVIEWCurrent Status:PendingFirm StatementBNPS SUBMITTED A RESPONSE TO SUCH ALLEGATIONS ON JANUARY 4,2013, WHICH IS PENDING FINRA/NYSE REGULATION REVIEW159©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceArbitration Award - Award / JudgmentBrokerage firms are not required to report arbitration claims filed against them by customers; however, BrokerCheckprovides summary information regarding FINRA arbitration awards involving securities and commodities disputesbetween public customers and registered securities firms in this section of the report. The full text of arbitration awards issued by FINRA is available at www.finra.org/awardsonline.Disclosure 1 of 1Reporting Source:RegulatorType of Event:ARBITRATIONArbitration Forum:Case Initiated:Case Number:Allegations:Disputed Product Type:Sum of All Relief Requested:Disposition:Disposition Date:Sum of All Relief Awarded:FINRA11/01/201010-04744ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNTRELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCEHEDGE FUND$12,950,000.00AWARD AGAINST PARTY06/26/2015$16,600,000.00There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.160©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceCivil BondThis type of disclosure event involves a civil bond for the brokerage firm that has been denied, paid, or revoked by abonding company.Disclosure 1 of 1Reporting Source:FirmPolicy Holder:PARIBASBonding Company Name:UNION FIRE INSURANCE COMPANYDisposition:PayoutDisposition Date:12/01/1988Payout Details:$410,000.00 IN DECEMBER 1988Firm StatementIN DECEMBER 1988, UNION FIRE INSURANCE COMPANY PAID PARIBAS$410,000 FOR A LOSS SUSTAINED AS A DIRECT RESULT OF ANUNAUTHORIZED TRANSACTION EFFECTED BY AN EMPLOYEE OF PARIBAS.THE EMPLOYEE WAS DISMISSED WITH CAUSE.161©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. www.finra.org/brokercheckUser GuidanceEnd of ReportThis page is intentionally left blank.162©2019 FINRA. All rights reserved. Report about BNP PARIBAS SECURITIES CORP. BrokerCheck ReportCRAIG WRIGHT CONLEYSection TitleReport SummaryBroker QualificationsRegistration and Employment HistoryDisclosure EventsCRD# 238915412 - 567Page(s) About BrokerCheck®BrokerCheck offers information on all current, and many former, registered securities brokers, and all current and formerregistered securities firms. FINRA strongly encourages investors to use BrokerCheck to check the background ofsecurities brokers and brokerage firms before deciding to conduct, or continue to conduct, business with them.āWhat is included in a BrokerCheck report?āBrokerCheck reports for individual brokers include information such as employment history, professionalqualifications, disciplinary actions, criminal convictions, civil judgments and arbitration awards. BrokerCheckreports for brokerage firms include information on a firm’s profile, history, and operations, as well as many of thesame disclosure events mentioned above.āPlease note that the information contained in a BrokerCheck report may include pending actions orallegations that may be contested, unresolved or unproven. In the end, these actions or allegations may beresolved in favor of the broker or brokerage firm, or concluded through a negotiated settlement with no admissionor finding of wrongdoing.āWhere did this information come from?āThe information contained in BrokerCheck comes from FINRA’s Central Registration Depository, orCRD® and is a combination of:Rinformation FINRA and/or the Securities and Exchange Commission (SEC) require brokers andbrokerage firms to submit as part of the registration and licensing process, andRinformation that regulators report regarding disciplinary actions or allegations against firms or brokers.āHow current is this information?āGenerally, active brokerage firms and brokers are required to update their professional and disciplinaryinformation in CRD within 30 days. Under most circumstances, information reported by brokerage firms, brokersand regulators is available in BrokerCheck the next business day.āWhat if I want to check the background of an investment adviser firm or investment adviserrepresentative?āTo check the background of an investment adviser firm or representative, you can search for the firm orindividual in BrokerCheck. If your search is successful, click on the link provided to view the available licensingand registration information in the SEC's Investment Adviser Public Disclosure (IAPD) website athttps://www.adviserinfo.sec.gov. In the alternative, you may search the IAPD website directly or contact your statesecurities regulator at http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/P455414.āAre there other resources I can use to check the background of investment professionals?āFINRA recommends that you learn as much as possible about an investment professional before decidingto work with them. Your state securities regulator can help you research brokers and investment adviserrepresentatives doing business in your state.āThank you for using FINRA BrokerCheck.For more information aboutFINRA, visit www.finra.org.Using this site/information meansthat you accept the FINRABrokerCheck Terms andConditions. A complete list ofTerms and Conditions can befound atFor additional information aboutthe contents of this report, pleaserefer to the User Guidance orwww.finra.org/brokercheck. Itprovides a glossary of terms and alist of frequently asked questions,as well as additional resources.brokercheck.finra.org CRAIG W. CONLEYCRD# 2389154Currently employed by and registered with thefollowing Firm(s):BNP PARIBAS SECURITIES CORP.787 SEVENTH AVENUENEW YORK, NY 10019CRD# 15794Registered with this firm since: 09/16/2010BNP PARIBAS SECURITIES CORP.2527 CAMINO RAMON2ND FLOORSAN RAMON, CA 94583CRD# 15794Registered with this firm since: 09/16/2010Report Summary for this BrokerThis report summary provides an overview of the broker's professional background and conduct. Additionalinformation can be found in the detailed report.Disclosure EventsAll individuals registered to sell securities or provideinvestment advice are required to disclose customercomplaints and arbitrations, regulatory actions,employment terminations, bankruptcy filings, andcriminal or civil judicial proceedings.Are there events disclosed about this broker?YesThe following types of disclosures have beenreported:TypeCountCustomer Dispute1Broker QualificationsThis broker is registered with:18 Self-Regulatory Organizations52 U.S. states and territoriesThis broker has passed:0 Principal/Supervisory Exams2 General Industry/Product Exams1 State Securities Law ExamRegistration HistoryThis broker was previously registered with thefollowing securities firm(s):RBC CAPITAL MARKETS CORPORATIONCRD# 31194PHILADELPHIA, PA10/2009 - 02/2010J. B. HANAUER & CO.CRD# 6958PHILADELPHIA, PA08/1994 - 10/2009OLDE DISCOUNT CORPORATIONCRD# 5979DETROIT, MI11/1993 - 02/1994www.finra.org/brokercheckUser Guidance1©2019 FINRA. All rights reserved. Report about CRAIG W. CONLEY. www.finra.org/brokercheckUser GuidanceBroker QualificationsRegistrationsThis section provides the self-regulatory organizations (SROs) and U.S. states/territories the broker is currentlyregistered and licensed with, the category of each license, and the date on which it became effective. This section alsoprovides, for every brokerage firm with which the broker is currently employed, the address of each branch where thebroker works.This individual is currently registered with 18 SROs and is licensed in 52 U.S. states and territories through hisor her employer.Employment 1 of 1Firm Name:Main Office Address:Firm CRD#:BNP PARIBAS SECURITIES CORP.15794787 SEVENTH AVENUENEW YORK, NY 10019SRO Category Status DateFINRAGeneral Securities RepresentativeAPPROVED09/16/2010BOX Exchange LLCGeneral Securities RepresentativeAPPROVED02/14/2019Cboe BYX Exchange, Inc.General Securities RepresentativeAPPROVED02/14/2019Cboe BZX Exchange, Inc.General Securities RepresentativeAPPROVED02/14/2019Cboe C2 Exchange, Inc.General Securities RepresentativeAPPROVED02/14/2019Cboe EDGA Exchange, Inc.General Securities RepresentativeAPPROVED02/14/2019Cboe EDGX Exchange, Inc.General Securities RepresentativeAPPROVED02/14/2019Cboe Exchange, Inc.General Securities RepresentativeAPPROVED09/16/2010Miami International SecuritiesExchange, LLCGeneral Securities RepresentativeAPPROVED02/14/2019NYSE American LLCGeneral Securities RepresentativeAPPROVED09/16/2010NYSE Arca, Inc.General Securities RepresentativeAPPROVED09/16/2010NYSE Chicago, Inc.General Securities RepresentativeAPPROVED02/14/2019Nasdaq BX, Inc.General Securities RepresentativeAPPROVED09/16/2010Nasdaq GEMX, LLCGeneral Securities RepresentativeAPPROVED02/14/2019Nasdaq ISE, LLCGeneral Securities RepresentativeAPPROVED09/16/2010Nasdaq PHLX LLCGeneral Securities RepresentativeAPPROVED04/25/2012Nasdaq Stock MarketGeneral Securities RepresentativeAPPROVED09/16/20102©2019 FINRA. All rights reserved. Report about CRAIG W. CONLEY. www.finra.org/brokercheckUser GuidanceBroker QualificationsEmployment 1 of 1, continuedSRO Category Status DateNew York Stock ExchangeGeneral Securities RepresentativeAPPROVED09/16/2010U.S. State/TerritoryCategory Status DateAlabama AgentAPPROVED09/21/2010Alaska AgentAPPROVED09/20/2010Arizona AgentAPPROVED09/24/2010Arkansas AgentAPPROVED09/22/2010California AgentAPPROVED09/20/2010Colorado AgentAPPROVED09/20/2010Connecticut AgentAPPROVED09/21/2010Delaware AgentAPPROVED09/20/2010District ofColumbiaAgentAPPROVED09/27/2010Florida AgentAPPROVED09/17/2010Georgia AgentAPPROVED09/22/2010Hawaii AgentAPPROVED09/21/2010Idaho AgentAPPROVED09/20/2010Illinois AgentAPPROVED09/17/2010Indiana AgentAPPROVED09/21/2010Iowa AgentAPPROVED09/20/2010Kansas AgentAPPROVED09/17/2010Kentucky AgentAPPROVED09/17/2010Louisiana AgentAPPROVED09/27/2010Maine AgentAPPROVED09/17/2010Maryland AgentAPPROVED09/21/2010Massachusetts AgentAPPROVED09/21/2010U.S. State/TerritoryCategory Status DateMichigan AgentAPPROVED10/07/2010Minnesota AgentAPPROVED09/24/2010Mississippi AgentAPPROVED09/22/2010Missouri AgentAPPROVED09/17/2010Montana AgentAPPROVED09/20/2010Nebraska AgentAPPROVED09/22/2010Nevada AgentAPPROVED09/24/2010New Hampshire AgentAPPROVED09/17/2010New Jersey AgentAPPROVED09/20/2010New Mexico AgentAPPROVED09/20/2010New York AgentAPPROVED09/20/2010North Carolina AgentAPPROVED09/21/2010North Dakota AgentAPPROVED09/20/2010Ohio AgentAPPROVED09/23/2010Oklahoma AgentAPPROVED09/23/2010Oregon AgentAPPROVED09/20/2010Pennsylvania AgentAPPROVED09/20/2010Puerto Rico AgentAPPROVED09/20/2010Rhode Island AgentAPPROVED09/17/2010South Carolina AgentAPPROVED09/20/2010South Dakota AgentAPPROVED09/23/2010Tennessee AgentAPPROVED09/23/20103©2019 FINRA. All rights reserved. Report about CRAIG W. CONLEY. www.finra.org/brokercheckUser GuidanceBroker QualificationsEmployment 1 of 1, continuedU.S. State/TerritoryCategory Status DateTexas AgentAPPROVED01/06/2017Utah AgentAPPROVED09/20/2010Vermont AgentAPPROVED09/21/2010Virginia AgentAPPROVED09/17/2010Washington AgentAPPROVED09/17/2010West Virginia AgentAPPROVED09/28/2010Wisconsin AgentAPPROVED09/20/2010Wyoming AgentAPPROVED09/17/2010Branch Office LocationsBNP PARIBAS SECURITIES CORP.2527 CAMINO RAMON2ND FLOORSAN RAMON, CA 945834©2019 FINRA. All rights reserved. Report about CRAIG W. CONLEY. www.finra.org/brokercheckUser GuidanceBroker QualificationsIndustry Exams this Broker has PassedThis individual has passed 0 principal/supervisory exams, 2 general industry/product exams, and 1 statesecurities law exam.This section includes all securities industry exams that the broker has passed. Under limited circumstances, a brokermay attain a registration after receiving an exam waiver based on exams the broker has passed and/or qualifying workexperience. Any exam waivers that the broker has received are not included below.Exam Category DatePrincipal/Supervisory ExamsNo information reported.Exam Category DateGeneral Industry/Product ExamsSecurities Industry Essentials Examination10/01/2018SIEGeneral Securities Representative Examination10/04/1993Series 7Exam Category DateState Securities Law ExamsUniform Securities Agent State Law Examination10/12/1993Series 63Additional information about the above exams or other exams FINRA administers to brokers and other securitiesprofessionals can be found at www.finra.org/brokerqualifications/registeredrep/.5©2019 FINRA. All rights reserved. Report about CRAIG W. CONLEY. www.finra.org/brokercheckUser GuidanceRegistration and Employment HistoryRegistration HistoryRegistration Dates Firm Name CRD# Branch LocationThe broker previously was registered with the following firms:10/2009 - 02/2010 RBC CAPITAL MARKETS CORPORATION 31194 PHILADELPHIA, PA08/1994 - 10/2009 J. B. HANAUER & CO. 6958 PHILADELPHIA, PA11/1993 - 02/1994 OLDE DISCOUNT CORPORATION 5979 DETROIT, MI10/1993 - 10/1993 PRINCETON SECURITIES CORPORATION 21613 SYOSSET, NYEmployment HistoryEmployment Dates Employer Name Employer LocationThis section provides up to 10 years of an individual broker's employment history as reported by the individual broker onthe most recently filed Form U4.Please note that the broker is required to provide this information only while registered with FINRA or a nationalsecurities exchange and the information is not updated via Form U4 after the broker ceases to be registered.Therefore, an employment end date of "Present" may not reflect the broker's current employment status.08/2010 - Present BNPPSC WALNUT CREEK, CA11/2009 - Present BANK OF THE WEST WALNUT CREEK, CA10/2009 - 11/2009 RBC CAPITAL MARKETS CORPORATION PHILADELPHIA, PA08/1994 - 10/2009 J. B. HANAUER & CO. PHILADELPHIA, PAOther Business ActivitiesThis section includes information, if any, as provided by the broker regarding other business activities the broker iscurrently engaged in either as a proprietor, partner, officer, director, employee, trustee, agent or otherwise. This sectiondoes not include non-investment related activity that is exclusively charitable, civic, religious or fraternal and isrecognized as tax exempt.No information reported.6©2019 FINRA. All rights reserved. Report about CRAIG W. CONLEY. www.finra.org/brokercheckUser GuidanceDisclosure EventsWhat you should know about reported disclosure events:1.All individuals registered to sell securities or provide investment advice are required to disclose customercomplaints and arbitrations, regulatory actions, employment terminations, bankruptcy filings, and criminal or civiljudicial proceedings.2.Certain thresholds must be met before an event is reported to CRD, for example:RA law enforcement agency must file formal charges before a broker is required to disclose a particularcriminal event.RA customer dispute must involve allegations that a broker engaged in activity that violates certain rulesor conduct governing the industry and that the activity resulted in damages of at least $5,000.R3.Disclosure events in BrokerCheck reports come from different sources:RAs mentioned at the beginning of this report, information contained in BrokerCheck comes from brokers,brokerage firms and regulators. When more than one of these sources reports information for the samedisclosure event, all versions of the event will appear in the BrokerCheck report. The different versionswill be separated by a solid line with the reporting source labeled.R4.There are different statuses and dispositions for disclosure events:RA disclosure event may have a status ofpending, on appeal,orfinal.A "pending" event involves allegations that have not been proven or formally adjudicated.An event that is "on appeal" involves allegations that have been adjudicated but are currentlybeing appealed.A "final" event has been concluded and its resolution is not subject to change.RA final event generally has a disposition ofadjudicated, settledorotherwise resolved.An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter, or(2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.A "settled" matter generally involves an agreement by the parties to resolve the matter. Pleasenote that brokers and brokerage firms may choose to settle customer disputes or regulatorymatters for business or other reasons.A "resolved" matter usually involves no payment to the customer and no finding of wrongdoingon the part of the individual broker. Such matters generally involve customer disputes.For your convenience, below is a matrix of the number and status of disclosure events involving this broker.Further information regarding these events can be found in the subsequent pages of this report. You also maywish to contact the broker to obtain further information regarding these events.Final On AppealPendingCustomer Dispute 0 1 N/A7©2019 FINRA. All rights reserved. Report about CRAIG W. CONLEY. www.finra.org/brokercheckUser Guidance8©2019 FINRA. All rights reserved. Report about CRAIG W. CONLEY. www.finra.org/brokercheckUser GuidanceDisclosure Event DetailsWhen evaluating this information, please keep in mind that a discloure event may be pending or involve allegationsthat are contested and have not been resolved or proven. The matter may, in the end, be withdrawn, dismissed,resolved in favor of the broker, or concluded through a negotiated settlement for certain business reasons (e.g., tomaintain customer relationships or to limit the litigation costs associated with disputing the allegations) with noadmission or finding of wrongdoing.This report provides the information exactly as it was reported to CRD and therefore some of the specific data fieldscontained in the report may be blank if the information was not provided to CRD.Customer Dispute - SettledThis type of disclosure event involves a consumer-initiated, investment-related complaint, arbitration proceeding or civilsuit containing allegations of sale practice violations against the broker that resulted in a monetary settlement to thecustomer.Disclosure 1 of 1Reporting Source:FirmEmploying firm whenactivities occurred which ledto the complaint:Allegations:J.B. HANAUER & CO.CLIENT ALLEGED THAT HE WASN'T ADVISED OF A CORPORATE BONDISSUER'S RIGHT TO SUSPEND PAYMENTS PRIOR TO HIS DECISION TOPURCHASE IN JANUARY 2008.Product Type:Debt-CorporateAlleged Damages:$0.00Date Complaint Received:09/03/2009Complaint Pending?NoCustomer Complaint InformationAlleged Damages AmountExplanation (if amount notexact):NO SPECIFIC DAMAGES WERE ALLEGED BUT ESTIMATED LOSSES IN THESECURITY IN QUESTION AT THE TIME OF THIS FILING EXCEEDED $5,000.Is this an oral complaint?NoIs this a written complaint?YesIs this an arbitration/CFTCreparation or civil litigation?No9©2019 FINRA. All rights reserved. Report about CRAIG W. CONLEY. www.finra.org/brokercheckUser GuidanceStatus:Status Date:12/02/2009Settlement Amount:$4,800.00Individual ContributionAmount:$0.00SettlediReporting Source:BrokerEmploying firm whenactivities occurred which ledto the complaint:Allegations:J.B. HANAUER & CO.CLIENT ALLEGED THAT HE WASN'T ADVISED OF A CORPORATE BONDISSUER'S RIGHT TO SUSPEND PAYMENTS PRIOR TO HIS DECISION TOPURCHASE IN JANUARY 2008.Product Type:Debt-CorporateAlleged Damages:$0.00Date Complaint Received:09/03/2009Complaint Pending?NoStatus:Status Date:12/02/2009Settlement Amount:$4,800.00Individual ContributionAmount:$0.00Customer Complaint InformationSettledAlleged Damages AmountExplanation (if amount notexact):NO SPECIFIC DAMAGES WERE ALLEGED BUT ESTIMATED LOSSES IN THESECURITY IN QUESTION AT THE TIME OF THIS FILING EXCEEDED $5,000.Is this an oral complaint?NoIs this a written complaint?YesIs this an arbitration/CFTCreparation or civil litigation?No10©2019 FINRA. All rights reserved. Report about CRAIG W. CONLEY. www.finra.org/brokercheckUser GuidanceEnd of ReportThis page is intentionally left blank.11©2019 FINRA. All rights reserved. Report about CRAIG W. CONLEY. BrokerCheck ReportPAUL THOMAS MONTAQUILASection TitleReport SummaryBroker QualificationsRegistration and Employment HistoryCRD# 218745412 - 78Page(s) About BrokerCheck®BrokerCheck offers information on all current, and many former, registered securities brokers, and all current and formerregistered securities firms. FINRA strongly encourages investors to use BrokerCheck to check the background ofsecurities brokers and brokerage firms before deciding to conduct, or continue to conduct, business with them.āWhat is included in a BrokerCheck report?āBrokerCheck reports for individual brokers include information such as employment history, professionalqualifications, disciplinary actions, criminal convictions, civil judgments and arbitration awards. BrokerCheckreports for brokerage firms include information on a firm’s profile, history, and operations, as well as many of thesame disclosure events mentioned above.āPlease note that the information contained in a BrokerCheck report may include pending actions orallegations that may be contested, unresolved or unproven. In the end, these actions or allegations may beresolved in favor of the broker or brokerage firm, or concluded through a negotiated settlement with no admissionor finding of wrongdoing.āWhere did this information come from?āThe information contained in BrokerCheck comes from FINRA’s Central Registration Depository, orCRD® and is a combination of:Rinformation FINRA and/or the Securities and Exchange Commission (SEC) require brokers andbrokerage firms to submit as part of the registration and licensing process, andRinformation that regulators report regarding disciplinary actions or allegations against firms or brokers.āHow current is this information?āGenerally, active brokerage firms and brokers are required to update their professional and disciplinaryinformation in CRD within 30 days. Under most circumstances, information reported by brokerage firms, brokersand regulators is available in BrokerCheck the next business day.āWhat if I want to check the background of an investment adviser firm or investment adviserrepresentative?āTo check the background of an investment adviser firm or representative, you can search for the firm orindividual in BrokerCheck. If your search is successful, click on the link provided to view the available licensingand registration information in the SEC's Investment Adviser Public Disclosure (IAPD) website athttps://www.adviserinfo.sec.gov. In the alternative, you may search the IAPD website directly or contact your statesecurities regulator at http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/P455414.āAre there other resources I can use to check the background of investment professionals?āFINRA recommends that you learn as much as possible about an investment professional before decidingto work with them. Your state securities regulator can help you research brokers and investment adviserrepresentatives doing business in your state.āThank you for using FINRA BrokerCheck.For more information aboutFINRA, visit www.finra.org.Using this site/information meansthat you accept the FINRABrokerCheck Terms andConditions. A complete list ofTerms and Conditions can befound atFor additional information aboutthe contents of this report, pleaserefer to the User Guidance orwww.finra.org/brokercheck. Itprovides a glossary of terms and alist of frequently asked questions,as well as additional resources.brokercheck.finra.org PAUL T. MONTAQUILACRD# 2187454Currently employed by and registered with thefollowing Firm(s):BNP PARIBAS SECURITIES CORP.787 SEVENTH AVENUENEW YORK, NY 10019CRD# 15794Registered with this firm since: 09/15/2010BNP PARIBAS SECURITIES CORP.2527 CAMINO RAMON2ND FLOORSAN RAMON, CA 94583CRD# 15794Registered with this firm since: 09/15/2010Report Summary for this BrokerThis report summary provides an overview of the broker's professional background and conduct. Additionalinformation can be found in the detailed report.Disclosure EventsAll individuals registered to sell securities or provideinvestment advice are required to disclose customercomplaints and arbitrations, regulatory actions,employment terminations, bankruptcy filings, andcriminal or civil judicial proceedings.Are there events disclosed about this broker?NoBroker QualificationsThis broker is registered with:18 Self-Regulatory Organizations52 U.S. states and territoriesThis broker has passed:4 Principal/Supervisory Exams3 General Industry/Product Exams1 State Securities Law ExamRegistration HistoryThis broker was previously registered with thefollowing securities firm(s):CHARLES SCHWAB & CO., INC.CRD# 5393SAN FRANCISCO, CA04/2000 - 03/2009CANTOR FITZGERALD & CO.CRD# 134NEW YORK, NY02/1999 - 07/1999CHARLES SCHWAB & CO., INC.CRD# 5393SAN FRANCISCO, CA10/1995 - 01/1998www.finra.org/brokercheckUser Guidance1©2019 FINRA. All rights reserved. Report about PAUL T. MONTAQUILA. www.finra.org/brokercheckUser GuidanceBroker QualificationsRegistrationsThis section provides the self-regulatory organizations (SROs) and U.S. states/territories the broker is currentlyregistered and licensed with, the category of each license, and the date on which it became effective. This section alsoprovides, for every brokerage firm with which the broker is currently employed, the address of each branch where thebroker works.This individual is currently registered with 18 SROs and is licensed in 52 U.S. states and territories through hisor her employer.Employment 1 of 1Firm Name:Main Office Address:Firm CRD#:BNP PARIBAS SECURITIES CORP.15794787 SEVENTH AVENUENEW YORK, NY 10019SRO Category Status DateFINRAGeneral Securities PrincipalAPPROVED03/01/2012FINRAGeneral Securities RepresentativeAPPROVED09/15/2010FINRAGeneral Securities Sales SupervisorAPPROVED09/15/2010FINRASecurities TraderAPPROVED01/04/2016BOX Exchange LLCGeneral Securities PrincipalAPPROVED02/14/2019BOX Exchange LLCGeneral Securities RepresentativeAPPROVED02/14/2019BOX Exchange LLCGeneral Securities Sales SupervisorAPPROVED02/14/2019Cboe BYX Exchange, Inc.General Securities PrincipalAPPROVED02/14/2019Cboe BYX Exchange, Inc.General Securities RepresentativeAPPROVED02/14/2019Cboe BZX Exchange, Inc.General Securities PrincipalAPPROVED02/14/2019Cboe BZX Exchange, Inc.General Securities RepresentativeAPPROVED02/14/2019Cboe C2 Exchange, Inc.General Securities RepresentativeAPPROVED02/14/2019Cboe C2 Exchange, Inc.General Securities Sales SupervisorAPPROVED02/14/2019Cboe EDGA Exchange, Inc.General Securities PrincipalAPPROVED02/14/2019Cboe EDGA Exchange, Inc.General Securities RepresentativeAPPROVED02/14/2019Cboe EDGA Exchange, Inc.General Securities Sales SupervisorAPPROVED02/14/2019Cboe EDGX Exchange, Inc.General Securities PrincipalAPPROVED02/14/2019Cboe EDGX Exchange, Inc.General Securities RepresentativeAPPROVED02/14/20192©2019 FINRA. All rights reserved. Report about PAUL T. MONTAQUILA. www.finra.org/brokercheckUser GuidanceBroker QualificationsEmployment 1 of 1, continuedSRO Category Status DateCboe EDGX Exchange, Inc.General Securities Sales SupervisorAPPROVED02/14/2019Cboe Exchange, Inc.General Securities RepresentativeAPPROVED09/15/2010Cboe Exchange, Inc.General Securities Sales SupervisorAPPROVED09/15/2010Miami International SecuritiesExchange, LLCGeneral Securities PrincipalAPPROVED02/14/2019Miami International SecuritiesExchange, LLCGeneral Securities RepresentativeAPPROVED02/14/2019Miami International SecuritiesExchange, LLCGeneral Securities Sales SupervisorAPPROVED02/14/2019NYSE American LLCGeneral Securities PrincipalAPPROVED03/01/2012NYSE American LLCGeneral Securities RepresentativeAPPROVED09/15/2010NYSE American LLCGeneral Securities Sales SupervisorAPPROVED10/01/2018NYSE American LLCSecurities TraderAPPROVED01/04/2016NYSE Arca, Inc.General Securities PrincipalAPPROVED03/01/2012NYSE Arca, Inc.General Securities RepresentativeAPPROVED09/15/2010NYSE Arca, Inc.General Securities Sales SupervisorAPPROVED09/15/2010NYSE Chicago, Inc.General Securities PrincipalAPPROVED02/14/2019NYSE Chicago, Inc.General Securities RepresentativeAPPROVED02/14/2019Nasdaq BX, Inc.General Securities PrincipalAPPROVED03/01/2012Nasdaq BX, Inc.General Securities RepresentativeAPPROVED09/15/2010Nasdaq BX, Inc.General Securities Sales SupervisorAPPROVED09/15/2010Nasdaq GEMX, LLCGeneral Securities PrincipalAPPROVED02/14/2019Nasdaq GEMX, LLCGeneral Securities RepresentativeAPPROVED02/14/2019Nasdaq GEMX, LLCGeneral Securities Sales SupervisorAPPROVED02/14/2019Nasdaq ISE, LLCGeneral Securities PrincipalAPPROVED03/01/2012Nasdaq ISE, LLCGeneral Securities RepresentativeAPPROVED09/15/2010Nasdaq ISE, LLCGeneral Securities Sales SupervisorAPPROVED10/01/2018Nasdaq PHLX LLCGeneral Securities PrincipalAPPROVED04/27/20123©2019 FINRA. All rights reserved. Report about PAUL T. MONTAQUILA. www.finra.org/brokercheckUser GuidanceBroker QualificationsEmployment 1 of 1, continuedSRO Category Status DateNasdaq PHLX LLCGeneral Securities RepresentativeAPPROVED04/27/2012Nasdaq PHLX LLCGeneral Securities Sales SupervisorAPPROVED04/27/2012Nasdaq Stock MarketGeneral Securities PrincipalAPPROVED03/01/2012Nasdaq Stock MarketGeneral Securities RepresentativeAPPROVED09/15/2010Nasdaq Stock MarketGeneral Securities Sales SupervisorAPPROVED09/15/2010Nasdaq Stock MarketSecurities TraderAPPROVED01/04/2016New York Stock ExchangeGeneral Securities PrincipalAPPROVED03/01/2012New York Stock ExchangeGeneral Securities RepresentativeAPPROVED09/15/2010New York Stock ExchangeGeneral Securities Sales SupervisorAPPROVED10/01/2018New York Stock ExchangeSecurities TraderAPPROVED01/04/2016U.S. State/TerritoryCategory Status DateAlabama AgentAPPROVED09/15/2010Alaska AgentAPPROVED09/15/2010Arizona AgentAPPROVED09/15/2010Arkansas AgentAPPROVED09/15/2010California AgentAPPROVED09/15/2010Colorado AgentAPPROVED09/15/2010Connecticut AgentAPPROVED09/15/2010Delaware AgentAPPROVED09/15/2010District ofColumbiaAgentAPPROVED09/15/2010Florida AgentAPPROVED09/15/2010Georgia AgentAPPROVED09/15/2010Hawaii AgentAPPROVED09/15/2010Idaho AgentAPPROVED09/15/2010U.S. State/TerritoryCategory Status DateIllinois AgentAPPROVED09/15/2010Indiana AgentAPPROVED09/15/2010Iowa AgentAPPROVED09/15/2010Kansas AgentAPPROVED09/15/2010Kentucky AgentAPPROVED09/15/2010Louisiana AgentAPPROVED09/15/2010Maine AgentAPPROVED09/15/2010Maryland AgentAPPROVED09/15/2010Massachusetts AgentAPPROVED09/15/2010Michigan AgentAPPROVED09/15/2010Minnesota AgentAPPROVED09/15/2010Mississippi AgentAPPROVED09/15/2010Missouri AgentAPPROVED09/15/2010Montana AgentAPPROVED09/15/20104©2019 FINRA. All rights reserved. Report about PAUL T. MONTAQUILA. www.finra.org/brokercheckUser GuidanceBroker QualificationsEmployment 1 of 1, continuedU.S. State/TerritoryCategory Status DateNebraska AgentAPPROVED09/15/2010Nevada AgentAPPROVED09/15/2010New Hampshire AgentAPPROVED09/15/2010New Jersey AgentAPPROVED09/15/2010New Mexico AgentAPPROVED09/15/2010New York AgentAPPROVED09/15/2010North Carolina AgentAPPROVED09/15/2010North Dakota AgentAPPROVED09/15/2010Ohio AgentAPPROVED09/16/2010Oklahoma AgentAPPROVED09/15/2010Oregon AgentAPPROVED09/15/2010Pennsylvania AgentAPPROVED09/15/2010Puerto Rico AgentAPPROVED09/15/2010Rhode Island AgentAPPROVED09/15/2010South Carolina AgentAPPROVED09/15/2010South Dakota AgentAPPROVED09/15/2010Tennessee AgentAPPROVED09/15/2010Texas AgentAPPROVED09/15/2010Utah AgentAPPROVED09/15/2010Vermont AgentAPPROVED09/15/2010Virginia AgentAPPROVED09/15/2010Washington AgentAPPROVED09/15/2010West Virginia AgentAPPROVED09/15/2010Wisconsin AgentAPPROVED09/15/2010Wyoming AgentAPPROVED09/15/2010U.S. State/TerritoryCategory Status Date5©2019 FINRA. All rights reserved. Report about PAUL T. MONTAQUILA. www.finra.org/brokercheckUser GuidanceBroker QualificationsEmployment 1 of 1, continuedBranch Office LocationsBNP PARIBAS SECURITIES CORP.2527 CAMINO RAMON2ND FLOORSAN RAMON, CA 945836©2019 FINRA. All rights reserved. Report about PAUL T. MONTAQUILA. www.finra.org/brokercheckUser GuidanceBroker QualificationsIndustry Exams this Broker has PassedThis individual has passed 4 principal/supervisory exams, 3 general industry/product exams, and 1 statesecurities law exam.This section includes all securities industry exams that the broker has passed. Under limited circumstances, a brokermay attain a registration after receiving an exam waiver based on exams the broker has passed and/or qualifying workexperience. Any exam waivers that the broker has received are not included below.Exam Category DatePrincipal/Supervisory ExamsGeneral Securities Principal Examination02/29/2012Series 24Municipal Securities Principal Examination08/05/2010Series 53General Securities Sales Supervisor - General Module Examination02/22/2001Series 10General Securities Sales Supervisor - Options Module Examination12/05/2000Series 9Exam Category DateGeneral Industry/Product ExamsSecurities Industry Essentials Examination10/01/2018SIELimited Representative-Equity Trader Exam10/22/2004Series 55General Securities Representative Examination11/05/1991Series 7Exam Category DateState Securities Law ExamsUniform Securities Agent State Law Examination11/19/1991Series 63Additional information about the above exams or other exams FINRA administers to brokers and other securitiesprofessionals can be found at www.finra.org/brokerqualifications/registeredrep/.7©2019 FINRA. All rights reserved. Report about PAUL T. MONTAQUILA. www.finra.org/brokercheckUser GuidanceRegistration and Employment HistoryRegistration HistoryRegistration Dates Firm Name CRD# Branch LocationThe broker previously was registered with the following firms:04/2000 - 03/2009 CHARLES SCHWAB & CO., INC. 5393 SAN FRANCISCO, CA02/1999 - 07/1999 CANTOR FITZGERALD & CO. 134 NEW YORK, NY10/1995 - 01/1998 CHARLES SCHWAB & CO., INC. 5393 SAN FRANCISCO, CA03/1995 - 09/1995 OLDE DISCOUNT CORPORATION 5979 DETROIT, MI03/1993 - 04/1995 LEHMAN BROTHERS INC. 7506 NEW YORK, NY11/1991 - 03/1993SMITH BARNEY, HARRIS UPHAM & CO.,INCORPORATED7059 NEW YORK, NYEmployment HistoryEmployment Dates Employer Name Employer LocationThis section provides up to 10 years of an individual broker's employment history as reported by the individual broker onthe most recently filed Form U4.Please note that the broker is required to provide this information only while registered with FINRA or a nationalsecurities exchange and the information is not updated via Form U4 after the broker ceases to be registered.Therefore, an employment end date of "Present" may not reflect the broker's current employment status.08/2010 - Present BNPPSC WALNUT CREEK, CA03/2008 - Present BANK OF THE WEST WALNUT CREEK, CAOther Business ActivitiesThis section includes information, if any, as provided by the broker regarding other business activities the broker iscurrently engaged in either as a proprietor, partner, officer, director, employee, trustee, agent or otherwise. This sectiondoes not include non-investment related activity that is exclusively charitable, civic, religious or fraternal and isrecognized as tax exempt.No information reported.8©2019 FINRA. All rights reserved. Report about PAUL T. MONTAQUILA. www.finra.org/brokercheckUser GuidanceEnd of ReportThis page is intentionally left blank.9©2019 FINRA. All rights reserved. Report about PAUL T. MONTAQUILA.