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BrokerCheck Report ROBERT JAMES D'ANDRIA Section Title Report Summary Broker Qualifications Registration and Employment History Disclosure Events CRD# 1916172 1 2 - 4 6 - 7 8 Page(s)

ROBERT JAMES D'ANDRIA · ROBERT J. D'ANDRIA CRD# 1916172 Currently employed by and registered with the following Firm(s): INTERNATIONAL ASSETS ADVISORY, LLC 309 MORRIS AVENUE, SUITE

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Page 1: ROBERT JAMES D'ANDRIA · ROBERT J. D'ANDRIA CRD# 1916172 Currently employed by and registered with the following Firm(s): INTERNATIONAL ASSETS ADVISORY, LLC 309 MORRIS AVENUE, SUITE

BrokerCheck Report

ROBERT JAMES D'ANDRIA

Section Title

Report Summary

Broker Qualifications

Registration and Employment History

Disclosure Events

CRD# 1916172

1

2 - 4

6 - 7

8

Page(s)

Page 2: ROBERT JAMES D'ANDRIA · ROBERT J. D'ANDRIA CRD# 1916172 Currently employed by and registered with the following Firm(s): INTERNATIONAL ASSETS ADVISORY, LLC 309 MORRIS AVENUE, SUITE

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.

· What is included in a BrokerCheck report?· BrokerCheck reports for individual brokers include information such as employment history, professional

qualifications, disciplinary actions, criminal convictions, civil judgments and arbitration awards. BrokerCheckreports for brokerage firms include information on a firm’s profile, history, and operations, as well as many of thesame disclosure events mentioned above.

· Please note that the information contained in a BrokerCheck report may include pending actions orallegations that may be contested, unresolved or unproven. In the end, these actions or allegations may beresolved in favor of the broker or brokerage firm, or concluded through a negotiated settlement with no admissionor finding of wrongdoing.

· Where did this information come from?· The information contained in BrokerCheck comes from FINRA’s Central Registration Depository, or

CRD® and is a combination of: o information FINRA and/or the Securities and Exchange Commission (SEC) require brokers and

brokerage firms to submit as part of the registration and licensing process, and o information that regulators report regarding disciplinary actions or allegations against firms or brokers.

· How current is this information?· Generally, active brokerage firms and brokers are required to update their professional and disciplinary

information in CRD within 30 days. Under most circumstances, information reported by brokerage firms, brokersand regulators is available in BrokerCheck the next business day.

· What if I want to check the background of an investment adviser firm or investment adviserrepresentative?

· To check the background of an investment adviser firm or representative, you can search for the firm orindividual in BrokerCheck. If your search is successful, click on the link provided to view the available licensingand registration information in the SEC's Investment Adviser Public Disclosure (IAPD) website athttps://www.adviserinfo.sec.gov. In the alternative, you may search the IAPD website directly or contact your statesecurities regulator at http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/P455414.

· Are there other resources I can use to check the background of investment professionals?· FINRA recommends that you learn as much as possible about an investment professional before deciding

to work with them. Your state securities regulator can help you research brokers and investment adviserrepresentatives doing business in your state.

·Thank you for using FINRA BrokerCheck.

For more information aboutFINRA, visit www.finra.org.

Using this site/information meansthat you accept the FINRABrokerCheck Terms andConditions. A complete list ofTerms and Conditions can befound at

For 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

Page 3: ROBERT JAMES D'ANDRIA · ROBERT J. D'ANDRIA CRD# 1916172 Currently employed by and registered with the following Firm(s): INTERNATIONAL ASSETS ADVISORY, LLC 309 MORRIS AVENUE, SUITE

ROBERT J. D'ANDRIA

CRD# 1916172

Currently employed by and registered with thefollowing Firm(s):

INTERNATIONAL ASSETS ADVISORY,LLC309 MORRIS AVENUE, SUITE CSPRING LAKE, NJ 07762CRD# 10645Registered with this firm since: 07/02/2010

B

INTERNATIONAL ASSETS INVESTMENTMANAGEMENT, LLC309 Morris Ave Suite CSpring Lake, NJ 07762CRD# 144426Registered with this firm since: 01/08/2016

IA

Report Summary for this Broker

This report summary provides an overview of the broker's professional background and conduct. Additionalinformation can be found in the detailed report.

Disclosure Events

All 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? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 2

Customer Dispute 5

Termination 1

Broker Qualifications

This broker is registered with:

1 Self-Regulatory Organization

9 U.S. states and territories

This broker has passed:

0 Principal/Supervisory Exams

2 General Industry/Product Exams

2 State Securities Law Exams

Registration History

This broker was previously registered with thefollowing securities firm(s):

INTERNATIONAL ASSETS INVESTMENTMANAGEMENT, LLCCRD# 144426ORLANDO, FL08/2010 - 12/2015

IA

WESTMINSTER FINANCIAL ADVISORYCORPCRD# 110283DAYTON, OH04/2010 - 08/2010

IA

WESTMINSTER FINANCIAL SECURITIES,INC.CRD# 20677EATONTOWN, NJ03/2010 - 08/2010

B

www.finra.org/brokercheck User Guidance

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Broker Qualifications

Registrations

This section provides the self-regulatory organizations (SROs) and U.S. states/territories the broker is currently registered and licensed with, thecategory of each license, and the date on which it became effective. This section also provides, for every brokerage firm with which the broker iscurrently employed, the address of each branch where the broker works.

This individual is currently registered with 1 SRO and is licensed in 9 U.S. states and territories through his or her employer.

Employment 1 of 2Firm Name:

Main Office Address:

Firm CRD#:

INTERNATIONAL ASSETS ADVISORY, LLC

10645

390 NORTH ORANGE AVENUESTE 750ORLANDO, FL 32801

SRO Category Status Date

B FINRA General Securities Representative APPROVED 07/02/2010

BU.S. State/ Territory Category Status Date

B Florida Agent APPROVED 07/26/2010

B Maryland Agent APPROVED 08/03/2016

B Massachusetts Agent APPROVED 07/12/2010

B Minnesota Agent APPROVED 01/10/2017

B New Jersey Agent APPROVED 07/15/2010

B New York Agent APPROVED 07/02/2010

B Ohio Agent APPROVED 08/17/2016

B Pennsylvania Agent APPROVED 07/06/2010

B Texas Agent APPROVED 06/20/2017

Branch Office Locations

INTERNATIONAL ASSETS ADVISORY, LLC

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Broker Qualifications

Employment 1 of 2, continued309 MORRIS AVENUE, SUITE CSPRING LAKE, NJ 07762

Employment 2 of 2Firm Name:

Main Office Address:

Firm CRD#:

INTERNATIONAL ASSETS INVESTMENT MANAGEMENT, LLC

144426

390 NORTH ORANGE AVENUESUITE 750ORLANDO, FL 32801

BU.S. State/ Territory Category Status Date

IA New Jersey Investment Adviser Representative APPROVED 01/08/2016

Branch Office Locations

This individual does not have any registered Branch Office where the individual is located.

3�2020 FINRA. All rights reserved. Report about ROBERT J. D'ANDRIA.

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Broker Qualifications

Industry Exams this Broker has Passed

This individual has passed 0 principal/supervisory exams, 2 general industry/product exams, and 2 state securities law exams.

This section includes all securities industry exams that the broker has passed. Under limited circumstances, a broker may attain a registrationafter receiving an exam waiver based on exams the broker has passed and/or qualifying work experience. Any exam waivers that the broker hasreceived are not included below.

Exam Category Date

Principal/Supervisory Exams

No information reported.

Exam Category Date

General Industry/Product Exams

Securities Industry Essentials Examination 10/01/2018SIEB

General Securities Representative Examination 10/28/2003Series 7B

Exam Category Date

State Securities Law Exams

Uniform Combined State Law Examination 12/10/2003Series 66B IA

Uniform Securities Agent State Law Examination 06/16/1989Series 63B

Additional information about the above exams or other exams FINRA administers to brokers and other securities professionals can be found atwww.finra.org/brokerqualifications/registeredrep/.

4�2020 FINRA. All rights reserved. Report about ROBERT J. D'ANDRIA.

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Broker Qualifications

Professional Designations

This section details that the representative has reported 0 professional designation(s).

No information reported.

5�2020 FINRA. All rights reserved. Report about ROBERT J. D'ANDRIA.

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Registration and Employment History

Registration History

Registration Dates Firm Name CRD# Branch Location

The broker previously was registered with the following firms:

IA 08/2010 - 12/2015 INTERNATIONAL ASSETS INVESTMENTMANAGEMENT, LLC

144426 SPRING LAKE, NJ

IA 04/2010 - 08/2010 WESTMINSTER FINANCIAL ADVISORYCORP

110283 DAYTON, OH

B 03/2010 - 08/2010 WESTMINSTER FINANCIAL SECURITIES,INC.

20677 EATONTOWN, NJ

IA 01/2004 - 03/2010 GUNNALLEN FINANCIAL, INC 17609 EATONTOWN, NJ

B 11/2003 - 03/2010 GUNNALLEN FINANCIAL, INC 17609 EATONTOWN, NJ

B 04/2001 - 05/2001 JOHN HANCOCK FUNDS, INC. 28262 BOSTON, MA

B 08/1995 - 02/2000 MERRILL LYNCH, PIERCE, FENNER &SMITH INCORPORATED

7691 NEW YORK, NY

B 12/1990 - 06/1995 PAINEWEBBER INCORPORATED 8174 WEEHAWKEN, NJ

B 05/1989 - 11/1990 THE STUART-JAMES COMPANY,INCORPORATED

11691 DENVER, CO

Employment History

Employment Employer Name Investment RelatedPosition Employer Location

This section provides up to 10 years of an individual broker's employment history as reported by the individual broker on the most recently filedForm U4.

Please note that the broker is required to provide this information only while registered with FINRA or a national securities exchangeand 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.

07/2010 - Present INTERNATIONAL ASSETS ADVISORYLLC

REGISTEREDREPRESENTATIVE

Y SPRING LAKE, NJ, UnitedStates

07/2010 - Present INTERNATIONAL ASSETS INVESTMENTMANAGEMENT, LLC

INVESTMENTADVISORREPRESENTATIVE

Y SPRING LAKE, NJ, UnitedStates

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Registration and Employment History

Other Business Activities

This section includes information, if any, as provided by the broker regarding other business activities the broker is currently engaged in either asa proprietor, partner, officer, director, employee, trustee, agent or otherwise. This section does not include non-investment related activity that isexclusively charitable, civic, religious or fraternal and is recognized as tax exempt.

1) STERLINGNOBLE WEALTH MANAGEMENT 309 MORRIS AVE. SUITE C SPRING LAKE NJ 07762 - DBA FOR IAA BUSINESS -PRESIDENT/100% OWNER SINCE 04/2010 - APPROX 160 HRS/MO - COMMISSION BASED COMPENSATION  2) THE KEYARX GROUP732 NEWMAN SPRINGS RD, 2ND FLOOR, LINCROFT, NJ 07738 - LIFE, ACCIDENT, HEALTH INSURANCE SALES - AGENT SINCE 6/2015 -APPROX 5 HRS/MO - COMMISSION BASED COMPENSATION 3) INTERNATIONAL ASSETS INVESTMENT MANAGEMENT LLC - 390 NORANGE AVE STE 750 ORLANDO, FL 32801 - ORLANDO, FL 32801 - RIA AFFILIATE OF INTERNATIONAL ASSETS ADVISORS - ADVISORSINCE 8/2010 - APPROX 80 HRS/MO - FEE BASED COMPENSATION 4) ADP, LLC ONE ADP BLVD, ROSELAND, NJ 07068 - PAYROLLSERVICES COMPANY - REFFERRAL AGENT SINCE 9/2016 - APPROX 1 HR/MO - REFFERRAL FEES

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Disclosure Events

What you should know about reported disclosure events:

1. All individuals registered to sell securities or provide investment advice are required to disclose customer complaints and arbitrations,regulatory actions, employment terminations, bankruptcy filings, and criminal or civil judicial proceedings.

2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a broker is required to disclose a particular criminal event. o A customer dispute must involve allegations that a broker engaged in activity that violates certain rules or conduct governing the

industry and that the activity resulted in damages of at least $5,000. o

3. Disclosure events in BrokerCheck reports come from different sources: o As mentioned at the beginning of this report, information contained in BrokerCheck comes from brokers, brokerage firms and

regulators. When more than one of these sources reports information for the same disclosure event, all versions of the event willappear in the BrokerCheck report. The different versions will be separated by a solid line with the reporting source labeled.

o4. There are different statuses and dispositions for disclosure events:

o A disclosure event may have a status of pending, on appeal, or final.§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently being appealed.§ A "final" event has been concluded and its resolution is not subject to change.

o A final event generally has a disposition of adjudicated, settled or otherwise resolved.§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter, or (2) an administrative

panel in an action brought by a regulator that is contested by the party charged with some alleged wrongdoing.§ A "settled" matter generally involves an agreement by the parties to resolve the matter. Please note that brokers and

brokerage firms may choose to settle customer disputes or regulatory matters for business or other reasons.§ A "resolved" matter usually involves no payment to the customer and no finding of wrongdoing on the part of the

individual broker. Such matters generally involve customer disputes.

For your convenience, below is a matrix of the number and status of disclosure events involving this broker. Further informationregarding these events can be found in the subsequent pages of this report. You also may wish to contact the broker to obtain furtherinformation regarding these events.

Final On AppealPending

Regulatory Event 0 2 0

Customer Dispute 1 4 N/A

Termination N/A 1 N/A

8�2020 FINRA. All rights reserved. Report about ROBERT J. D'ANDRIA.

Page 11: ROBERT JAMES D'ANDRIA · ROBERT J. D'ANDRIA CRD# 1916172 Currently employed by and registered with the following Firm(s): INTERNATIONAL ASSETS ADVISORY, LLC 309 MORRIS AVENUE, SUITE

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Disclosure Event Details

When evaluating this information, please keep in mind that a discloure event may be pending or involve allegations that are contested and havenot been resolved or proven. The matter may, in the end, be withdrawn, dismissed, resolved in favor of the broker, or concluded through anegotiated settlement for certain business reasons (e.g., to maintain customer relationships or to limit the litigation costs associated with disputingthe allegations) with no admission or finding of wrongdoing.

This report provides the information exactly as it was reported to CRD and therefore some of the specific data fields contained in the report maybe blank if the information was not provided to CRD.

Regulatory - Final

This type of disclosure event may involve (1) a final, formal proceeding initiated by a regulatory authority (e.g., a state securities agency, self-regulatory organization, federal regulatory such as the Securities and Exchange Commission, foreign financial regulatory body) for a violation ofinvestment-related rules or regulations; or (2) a revocation or suspension of a broker's authority to act as an attorney, accountant, or federalcontractor.

Disclosure 1 of 2

Reporting Source: Regulator

Regulatory Action InitiatedBy:

FINRA

Sanction(s) Sought:

Date Initiated: 01/03/2020

Docket/Case Number: 2017056579502

Employing firm when activityoccurred which led to theregulatory action:

International Assets Advisory, LLC

Product Type: Other: non-traditional exchange traded products

Allegations: Without admitting or denying the findings, D' Andria consented to the sanctionsand to the entry of findings that he recommended the purchase of non-traditionalexchange traded products (NT-ETPs) to customers' without having a sufficientunderstanding of the risks and features associated with these NT-ETPs andthereby failing to have a reasonable basis to make these recommendations. Thefindings stated that D' Andria failed to perform a reasonable basis suitabilityanalysis of NT-ETPs to understand the unique features and specific risksassociated with these products before offering them to his customers. In fact, theprospectuses for the NT-ETPs that D'Andria recommended warned that theproducts were risky, intended to be daily trading tools for sophisticated investors,and should be actively and frequently monitored, even intra-day. Moreover, D'Andria did not understand that losses in NT-ETPs are compounded because ofhow the valuations reset each day. The findings also stated that the customersheld these positions for periods ranging from 30 to 758 days. The average holdingperiod was 327 days. These extended holding periods caused D' Andria'scustomers to incur approximately $93,000 in losses. D' Andria's member firmconsented to supervision charges in relation to his unsuitable recommendations ofNT-ETPs and agreed to a fine and order of restitution to be paid to the affectedcustomers.

9�2020 FINRA. All rights reserved. Report about ROBERT J. D'ANDRIA.

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Without admitting or denying the findings, D' Andria consented to the sanctionsand to the entry of findings that he recommended the purchase of non-traditionalexchange traded products (NT-ETPs) to customers' without having a sufficientunderstanding of the risks and features associated with these NT-ETPs andthereby failing to have a reasonable basis to make these recommendations. Thefindings stated that D' Andria failed to perform a reasonable basis suitabilityanalysis of NT-ETPs to understand the unique features and specific risksassociated with these products before offering them to his customers. In fact, theprospectuses for the NT-ETPs that D'Andria recommended warned that theproducts were risky, intended to be daily trading tools for sophisticated investors,and should be actively and frequently monitored, even intra-day. Moreover, D'Andria did not understand that losses in NT-ETPs are compounded because ofhow the valuations reset each day. The findings also stated that the customersheld these positions for periods ranging from 30 to 758 days. The average holdingperiod was 327 days. These extended holding periods caused D' Andria'scustomers to incur approximately $93,000 in losses. D' Andria's member firmconsented to supervision charges in relation to his unsuitable recommendations ofNT-ETPs and agreed to a fine and order of restitution to be paid to the affectedcustomers.

Current Status: Final

Resolution: Acceptance, Waiver & Consent(AWC)

Resolution Date: 01/03/2020

Sanctions Ordered:

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

No

Civil and Administrative Penalty(ies)/Fine(s)Suspension

If the regulator is the SEC,CFTC, or an SRO, did theaction result in a finding of awillful violation or failure tosupervise?

No

(1) willfully violated anyprovision of the SecuritiesAct of 1933, the SecuritiesExchange Act of 1934, theInvestment Advisers Act of1940, the InvestmentCompany Act of 1940, theCommodity Exchange Act, orany rule or regulation underany of such Acts, or any ofthe rules of the MunicipalSecurities Rulemaking Board,or to have been unable tocomply with any provision ofsuch Act, rule or regulation?

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(1) willfully violated anyprovision of the SecuritiesAct of 1933, the SecuritiesExchange Act of 1934, theInvestment Advisers Act of1940, the InvestmentCompany Act of 1940, theCommodity Exchange Act, orany rule or regulation underany of such Acts, or any ofthe rules of the MunicipalSecurities Rulemaking Board,or to have been unable tocomply with any provision ofsuch Act, rule or regulation?

(2) willfully aided, abetted,counseled, commanded,induced, or procured theviolation by any person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any of suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board? or

(3) failed reasonably tosupervise another personsubject to your supervision,with a view to preventing theviolation by such person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board?

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(3) failed reasonably tosupervise another personsubject to your supervision,with a view to preventing theviolation by such person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board?

Capacities Affected: All Capacities

Duration: two months

Start Date: 02/03/2020

End Date: 04/02/2020

Sanction 1 of 1

Sanction Type: Suspension

Monetary Related Sanction: Civil and Administrative Penalty(ies)/Fine(s)

Total Amount: $5,000.00

Portion Levied againstindividual:

$5,000.00

Date Paid by individual: 02/05/2020

Was any portion of penaltywaived?

No

Amount Waived:

Monetary Sanction 1 of 1

Payment Plan:

Is Payment Plan Current:

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iReporting Source: Broker

Regulatory Action InitiatedBy:

FINRA

Sanction(s) Sought:

Date Initiated: 01/03/2020

Docket/Case Number: 2017056579502

Employing firm when activityoccurred which led to theregulatory action:

INTERNATIONAL ASSETS ADVISORY, LLC

Product Type: Other: NON-TRADITIONAL EXCHANGE TRADED PRODUCTS

Allegations: Without admitting or denying the findings, D' Andria consented to the sanctionsand to the entry of findings that he recommended the purchase of non-traditionalexchange traded products (NT-ETPs) to customers' without having a sufficientunderstanding of the risks and features associated with these NT-ETPs andthereby failing to have a reasonable basis to make these recommendations. Thefindings stated that D' Andria failed to perform a reasonable basis suitabilityanalysis of NT-ETPs to understand the unique features and specific risksassociated with these products before offering them to his customers. In fact, theprospectuses for the NT-ETPs that D'Andria recommended warned that theproducts were risky, intended to be daily trading tools for sophisticated investors,and should be actively and frequently monitored, even intra-day. Moreover, D'Andria did not understand that losses in NT-ETPs are compounded because ofhow the valuations reset each day. The findings also stated that the customersheld these positions for periods ranging from 30 to 758 days. The average holdingperiod was 327 days. These extended holding periods caused D' Andria'scustomers to incur approximately $93,000 in losses. D' Andria's member firmconsented to supervision charges in relation to his unsuitable recommendations ofNT-ETPs and agreed to a fine and order of restitution to be paid to the affectedcustomers.

Current Status: Final

Resolution: Acceptance, Waiver & Consent(AWC)

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

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Resolution Date: 01/03/2020

Sanctions Ordered:

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

No

Civil and Administrative Penalty(ies)/Fine(s)Suspension

Capacities Affected: ALL CAPACITIES

Duration: TWO MONTHS

Start Date: 02/03/2020

End Date: 04/02/2020

Sanction 1 of 1

Sanction Type: Suspension

Monetary Related Sanction: Civil and Administrative Penalty(ies)/Fine(s)

Total Amount: $5,000.00

Portion Levied againstindividual:

$5,000.00

Date Paid by individual:

Was any portion of penaltywaived?

No

Amount Waived:

Monetary Sanction 1 of 1

Payment Plan:

Is Payment Plan Current:

Disclosure 2 of 2

i

Reporting Source: Regulator

Regulatory Action InitiatedBy:

NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Sanction(s) Sought:

Date Initiated: 14�2020 FINRA. All rights reserved. Report about ROBERT J. D'ANDRIA.

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Date Initiated: 04/29/2003

Docket/Case Number: C9B030023

Employing firm when activityoccurred which led to theregulatory action:

(1)AETNA INVESTMENT SERVICES, LLC (2)JOHN HANCOCK FUNDS, LLC

Product Type: No Product

Allegations: NASD CONDUCT RULE IM-1000-1 AND 2110 - RESPONDENT FAILED TODISCLOSE MATERIAL FACTS ON HIS FORM U4.

Current Status: Final

Resolution: Acceptance, Waiver & Consent(AWC)

Resolution Date: 04/29/2003

Sanctions Ordered:

Regulator Statement WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE RESPONDENTROBERT D'ANDRIA CONSENTED TO THE FINDING OF THE ALLEGATIONSAND TO THE FOLLOWING SANCTIONS: FINED $5,000 AND SUSPENDED FOR10 DAYS FROM ASSOCIATION WITH ANY NASD MEMBER IN ANY CAPACITY.THE FINE SHALL BE DUE AND PAYABLE EITHER PRIOR TO REASSOCIATIONWITH A MEMBER FIRM FOLLOWING THE SUSPENSION OR PRIOR TO ANYAPPLICATION OR REQUEST FOR RELIEF FROM ANY STATUTORYDISQUALIFICATION RESULTING FROM THIS OR ANY OTHER EVENT ORPROCEEDING, WHICHEVER IS EARLIER. THE SUSPENSION WILLCOMMENCE WITH THE OPENING OF BUSINESS ON JUNE 2, 2003, AND WILLCONCLUDE AT THE CLOSE OF BUSINESS ON JUNE 11, 2003. FINES PAID11/04/2003.

Civil and Administrative Penalty(ies)/Fine(s)Suspension

iReporting Source: Broker

Regulatory Action InitiatedBy:

NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.

Sanction(s) Sought: Suspension

Other Sanction(s) Sought: $5000.00 FINE AND 10 DAY SUSPENSION

Date Initiated: 04/29/2003

Docket/Case Number: C9B030023

Employing firm when activityoccurred which led to theregulatory action: 15�2020 FINRA. All rights reserved. Report about ROBERT J. D'ANDRIA.

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Employing firm when activityoccurred which led to theregulatory action:

(1) AETNA INVESTMENT SERVICES,LLC (2) JOHN HANCOCK FUNDS, LLC

Product Type: No Product

Other Product Type(s):

Allegations: NASD CONDUCT RULE IM-1000 AND 2110- RESPONDENT FAILED TODISCLOSE MATERIAL FACTS ON HIS FORM U4.

Current Status: Final

Resolution: Acceptance, Waiver & Consent(AWC)

Resolution Date: 04/29/2003

Sanctions Ordered:

Other Sanctions Ordered: SUSPENDED FOR 10 DAYS FROM ASSOCIATION WITH ANY NASD MEMBERIN ANY CAPACITY

Sanction Details: FINED $5000.00 AND SUSPENDED FOR 10 DAYS FROM ASSOCIATION WITHANY NASD MEMBER IN ANY CAPACITY. THE FINE SHALL BE DUE ANDPAYABLE EITHER PRIOR TO REASSOCIATION WITH A MEMBER FIRMFOLLOWING THE SUSPENSION OR PRIOR TO ANY APPLICATION ORREQUEST FOR RELIEF FROM ANY STATUTORY DISQUALIFICATIONRESULTING FROM THIS OR ANY OTHER EVENT OR PROCEEDING,WHICHEVER IS EARLIER.THE SUSPENSION WILL COMMENCE WITH THEOPENING OF BUSINESS ON JUNE 2, 2003, AND WILL CONCLUDE AT THECLOSE OF BUSINESS ON JUNE 11,2003.

Monetary/Fine $5,000.00

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Customer Dispute - Settled

This type of disclosure event involves a consumer-initiated, investment-related complaint, arbitration proceeding or civil suit containing allegationsof sale practice violations against the broker that resulted in a monetary settlement to the customer.

Disclosure 1 of 2

Reporting Source: Firm

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

MERRILL LYNCH, PIERCE, FENNER & SMITH INC.

CUSTOMERS ALLEGE FINANCIAL CONSULTANT MISREPRESENTED FACTSABOUT DEBIT STRATEGIES FUND. CUSTOMERS FURTHER ALLEGE THATFINANCIAL CONSULTANT MADE AN UNAUTHORIZED PURCHASE OF ZEROCOUPON BONDS. CLAIMANTS FURTHER ALLEGE "INAPPROPRIATE USE OFMARGIN."

Product Type: Mutual Fund(s)

Other Product Type(s): DEBT-MUNICIPAL

Alleged Damages: $97,856.00

Date Complaint Received: 08/08/2000

Complaint Pending? No

Status:

Status Date: 03/30/2001

Settlement Amount:

Individual ContributionAmount:

Arbitration/Reparation Claimfiled with and Docket/CaseNo.:

NASD 01-07204

Date Notice/Process Served: 03/30/2001

Arbitration Pending? No

Disposition: Settled

Disposition Date: 03/26/2003

Monetary CompensationAmount:

$30,000.00

Customer Complaint Information

Arbitration Information

Arbitration/Reparation

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Monetary CompensationAmount:

$30,000.00

Firm Statement SETTLED.

Individual ContributionAmount:

$0.00

iReporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

MERRILL LYNCH

CUSTOMER ALLEGES MISREPRESENTATION OF A MUTUAL FUNDINVESTMENT TO THEM. CUSTOMER FURTHER ALLEGE UNAUTHORIZEDPURCHASE IN ONE OF THEIR ACCOUNTS AND USE OF MARGIN WITHOUTAUTORIZATION.

Product Type: Mutual Fund(s)

Other Product Type(s): DEBT/MUNICIPAL

Alleged Damages: $97,856.00

Date Complaint Received: 08/08/2000

Complaint Pending? No

Status:

Status Date: 03/30/2001

Settlement Amount:

Individual ContributionAmount:

Arbitration/Reparation Claimfiled with and Docket/CaseNo.:

NASD 01-07204

Date Notice/Process Served: 03/30/2001

Arbitration Pending? No

Disposition: Settled

Disposition Date: 03/26/2003

Customer Complaint Information

Arbitration Information

Arbitration/Reparation

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Disposition Date: 03/26/2003

Monetary CompensationAmount:

$30,000.00

Broker Statement THIS TRANSACTION WAS IN THE CLIENT'S ACCOUNT 3 WEEKS BEFORE ACOMPLAINT WAS FILED. THE SECURITY DECREASED IN VALUE AND THEACCUSATION WAS MADE.

Individual ContributionAmount:

$0.00

Disclosure 2 of 2

i

Reporting Source: Firm

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

MERRILL LYNCH, PIERCE, FENNER & SMITH INC.

[CUSTOMERS] VERBALLY ALLEGED THAT MR. D'ANDRIA PURCHASED 2000SHARES OF ASHFORD.COM COMMON STOCK ON NOVEMBER 30, 1999WITHOUT THEIR AUTHORIZATION. NO SPECIFIC DAMAGES WERECLAIMED.

Product Type: Equity - OTC

Alleged Damages: $0.00

Date Complaint Received: 01/31/2000

Complaint Pending? No

Status:

Status Date: 02/07/2000

Settlement Amount: $41,363.17

Individual ContributionAmount:

$0.00

Firm Statement MERRILL LYNCH MADE A BUSINESS DECISION TO CORRECT THEPURCHASE OF ASHFORD.COM COMMON STOCK TO AVOID THE COSTSAND UNCERTAINTIES OF LITIGATION.

Customer Complaint Information

Settled

iReporting Source: Broker

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Employing firm whenactivities occurred which ledto the complaint:

Allegations:

MERRILL, LYNCH, PIERCE, FENNER AND SMITH INC.

[CUSTOMER] VERBALLY ALLEGED I PURCHASED 2000 SHARES OFASHFORD.COM STOCK ON 11/30/99 WITHOUT AUTHORIZATION (TWOMONTHS AFTER TRADE).

Product Type: Equity Listed (Common & Preferred Stock)

Alleged Damages: $0.00

Date Complaint Received: 01/31/2000

Complaint Pending? No

Status:

Status Date: 02/07/2000

Settlement Amount: $41,363.17

Individual ContributionAmount:

$0.00

Broker Statement MERRILL LYNCH MADE A BUSINESS DECISION TO CORRECT THEPURCHASE OF ASHFORD.COM TO AVOID COSTS AND UNCERTAINTY OFLITIGATION.

Customer Complaint Information

Settled

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Customer Dispute - Closed-No Action / Withdrawn / Dismissed / Denied

This type of disclosure event involves (1) a consumer-initiated, investment-related arbitration or civil suit containing allegations of sales practiceviolations against the individual broker that was dismissed, withdrawn, or denied; or (2) a consumer-initiated, investment-related written complaintcontaining allegations that the broker engaged in sales practice violations resulting in compensatory damages of at least $5,000, forgery, theft, ormisappropriation, or conversion of funds or securities, which was closed without action, withdrawn, or denied.

Disclosure 1 of 2

Reporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

INTERNATIONAL ASSETS ADVISORY, LLC

MISMANAGEMENT OF ACCOUNT

Product Type: Debt-CorporateEquity Listed (Common & Preferred Stock)

Alleged Damages: $130,000.00

Date Complaint Received: 04/09/2020

Complaint Pending? No

Status:

Status Date: 05/08/2020

Settlement Amount:

Individual ContributionAmount:

Customer Complaint Information

Denied

Alleged Damages AmountExplanation (if amount notexact):

APPROXIMATE AMOUNT

Is this an oral complaint? No

Is this a written complaint? Yes

Is this an arbitration/CFTCreparation or civil litigation?

No

Disclosure 2 of 2

i

Reporting Source: Firm

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Employing firm whenactivities occurred which ledto the complaint:

Allegations:

MERRILL LYNCH, PIERCE, FENNER & SMITH INC.

CUSTOMER ALLEGED THAT MR. D'ANDRIA BOUGHT KNIGHT/TRIMARK CALLOPTIONS IN AUGUST 1999 WITHOUT HIS AUTHORIZATION. IN ADDITION,CUSTOMER ALLEGED THAT THE PURCHASES OF 200 SHARES OF E TRADEGROUP COMMON STOCK ON MAY 6, 1999, AND 100 SHARES OF QUALCOMON JANUARY 4, 2000 WERE UNAUTHORIZED. CUSTOMER CLAIMEDDAMAGES OF $6,250.

Product Type: Options

Other Product Type(s): EQUITY-OTC

Alleged Damages: $6,250.00

Date Complaint Received: 05/12/2000

Complaint Pending? No

Status:

Status Date: 05/19/2000

Settlement Amount:

Individual ContributionAmount:

Firm Statement MERRILL LYNCH FOUND CUSTOMER'S CLAIMS FOUR MONTHS TO A YEARAFTER THE TRADES IN QUESTION TO BE WITHOUT MERIT.

Customer Complaint Information

Denied

iReporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

MERRILL, LYNCH, PIERCE, FENNER AND SMITH INC.

AFTER MONTHS THE CUSTOMER ALLEGED I PURCHASED CALL OPTIONS,200 SHARES OF E-TRADE STOCK AND 100 SHARES OF QUALCOMM STOCKWITHOUT AUTHORIZATION.

Product Type: Options

Other Product Type(s): STOCK

Alleged Damages: $6,250.00

Customer Complaint Information22�2020 FINRA. All rights reserved. Report about ROBERT J. D'ANDRIA.

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Date Complaint Received: 05/12/2000

Complaint Pending? No

Status:

Status Date: 05/19/2000

Settlement Amount: $0.00

Individual ContributionAmount:

$0.00

Broker Statement MERRILL DETERMINED CLAIMS WERE WITHOUT MERIT.

Customer Complaint Information

Closed/No Action

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Customer Dispute - Pending

This type of disclosure event involves (1) a pending consumer-initiated, investment-related arbitration or civil suit that contains allegations of salespractice violations against the broker; or (2) a pending, consumer-initiated, investment-related written complaint containing allegations that thebroker engaged in, sales practice violations resulting in compensatory damages of at least $5,000, forgery, theft, or misappropriation, orconversion of funds or securities.

Disclosure 1 of 1

Reporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

INTERNATIONAL ASSETS ADVISORY, LLC

UNSUITABILITY, UNAUTHORIZED TRADING, FRAUD, BREACH OFCONTRACT, NEGLIGENT SUPERVISION, BREACH OF FIDUCIARY DUTY

Product Type: Other: NON TRADITIONAL EXCHANGE TRADED PRODUCTS

Alleged Damages: $5,000.00

Date Complaint Received: 09/14/2020

Complaint Pending? Yes

Settlement Amount:

Individual ContributionAmount:

Customer Complaint Information

Alleged Damages AmountExplanation (if amount notexact):

CLAIMANT SEEKS UNSPECIFIED DAMAGES BELIEVED TO BE GREATERTHAN $5000.

Is this an oral complaint? No

Is this a written complaint? No

Is this an arbitration/CFTCreparation or civil litigation?

Yes

Arbitration/Reparation forumor court name and location:

FINRA

Docket/Case #: 20-03043

Filing date ofarbitration/CFTC reparationor civil litigation:

09/08/2020

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Employment Separation After Allegations

This type of disclosure event involves a situation where the broker voluntarily resigned, was discharged, or was permitted to resign after beingaccused of (1) violating investment-related statutes, regulations, rules or industry standards of conduct; (2) fraud or the wrongful taking ofproperty; or (3) failure to supervise in connection with investment-related statutes, regulations, rules, or industry standards of conduct.

Disclosure 1 of 1

Reporting Source: Broker

Employer Name: MERRILL LYNCH

Termination Type: Discharged

Termination Date: 01/27/2001

Allegations: TERMINATED FOR VIOLATING MERRILL LYNCH POLICY AFTER CLIENTAUTHORIZED DOCUMENT TO BE INITIALED TO TRANSFER FUNDS FROMHER SINGLE ACCOUNT TO HER JOINT ACCOUNT FOR A REAL ESTATECLOSING. AGAINST MY BETTER JUDGEMENT I AIDED THE CLIENT IN HERREQUEST AND IT COST ME MY CAREER AT MERRIL LYNCH.

Product Type: Other

Other Product Types: NOT A PRODUCT TYPE

Broker Statement TERMINATED FOR VIOLATING MERRILL LYNCH POLICY AFTER CLIENTAUTHORIZED DOCUMENT TO BE INITIALED TO TRANSFER FUNDS FROMHER SINGLE ACCOUNT TO HER JOINT ACCOUNT FOR A REAL ESTATECLOSING. AGAINST MY BETTER JUDGEMENT I AIDED THE CLIENT IN HERREQUEST AND IT COST ME MY CAREER AT MERRIL LYNCH. - THETRANACTION WAS NEVER RECINDED.

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