____________________________________________________________________________________ National Association of Securities Dealers 9509 Key West Avenue Rockville, MD 20850 (800) 289-9999 October 12, 2005 Zevon Odelberg 12702 Via Cortina Suite 100 Del Mar, CA 92014 NASD BROKERCHECK RESPONSE TO REQUEST FOR INFORMATION The Board of Governors of the National Association of Securities Dealers, Inc. (NASD) has adopted a public disclosure policy which permits certain types of disciplinary information on NASD member firms and their associated persons to be available to the general public. Section 15A(i) of the Securities Exchange Act of 1934, as amended, requires registered securities associations to respond to inquiries regarding disciplinary actions involving its members and their associated persons. 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The document is formatted to print 90 lines per page at the specified font. 6) Print the report. -------------------------------------------------------------------------------- NASD BrokerCheck October 12, 2005 Page 1 This information is current as of: 10/12/2005 ________________________________________________________________________________ NASD Member Firm: COLUMBIA MANAGEMENT DISTRIBUTORS, INC. CRD Number: 30683 ******************************************************************************** REPORT SUMMARY ******************************************************************************** ************************************************************ Administrative Information: ************************************************************ Admin Information: Information that is required to be reported to NASD by brokerage firms via Form BD (Uniform Application for Broker-Dealer Registration). The administrative information contained in this report includes: (a) types of business the brokerage firm is engaged in; (b) legal status (e.g., corporation, partnership, sole proprietorship, limited liability company, etc.), state/country of formation unless legal status is sole proprietorship, date of formation, and month in which the brokerage firm's fiscal year ends; and (c) all approved registrations with the SEC, NASD and state securities commissions. Types of Business: 7 Legal Status: 1 Registrations: 54 ************************************************************ Disclosure Events: Yes ************************************************************ Disclosure Event: Information that is required to be reported to NASD by individual brokers via Form U-4 (Uniform Application for Securities Industry Registration or Transfer) and brokerage firms via Form BD (Uniform Application for Broker-Dealer Registration). Some disclosure events may have multiple reporting sources. For example, some information required to be reported by an individual broker via Form U-4 may also be reported on the individual broker's record by a brokerage firm via Form U-5 (Uniform Termination Notice for Securities Industry Registration) and/or by a regulator via Form U-6 (Uniform Disciplinary Action Reporting Form). If a disclosure event is reported by multiple sources, all versions of the reported event will be disclosed on the individual broker's NASD BrokerCheck report. Similarly, some information required to be reported by a brokerage firm via Form BD may also be reported on the brokerage firm's record via Form U-6. If a disclosure event is reported by multiple sources, all versions of the reported event will be disclosed on the brokerage firm's NASD BrokerCheck report. Criminal Actions: 0 Regulatory Actions: 2 Civil Judicial Actions: 2 Arbitrations: 0 Bonds: 0 Bankruptcies: 0 Judgment/Liens: 0 NASD BrokerCheck October 12, 2005 Page 2 This information is current as of: 10/12/2005 ________________________________________________________________________________ NASD Member Firm: COLUMBIA MANAGEMENT DISTRIBUTORS, INC. CRD Number: 30683 ******************************************************************************** ADDRESS/GENERAL INFORMATION ******************************************************************************** This section provides the brokerage firm's name, CRD number, SEC number, Applicant Name on Form BD, NASD District where the brokerage firm is located, and the brokerage firm's main and mailing addresses. Applicant Name on Form BD: COLUMBIA MANAGEMENT DISTRIBUTORS, INC. SEC Number: 8-044998 Prior Business Names: COLONIAL INVESTMENT SERVICES, INC. COLUMBIA FUNDS DISTRIBUTOR, INC. LIBERTY FINANCIAL INVESTMENTS, INC. LIBERTY FUNDS DISTRIBUTOR, INC. Business Phone Number: (617) 772-3058 Main Office Address Located in NASD District: 11-Boston ONE FINANCIAL CENTER BOSTON, MA 02111-2621 Mailing Address ONE FINANCIAL CENTER BOSTON, MA 02111-2621 ******************************************************************************** TYPES OF BUSINESS ******************************************************************************** This section lists the type(s) of business that the brokerage firm is currently engaged in as reported on the Form BD. Mutual fund retailer Mutual fund underwriter or sponsor Municipal securities broker Municipal securities dealer Private placements of securities Trading securities for own account Broker or dealer selling variable life insurance or annuities ******************************************************************************** LEGAL STATUS ******************************************************************************** This section details the brokerage firm's legal status (i.e, corporation, limited partnership, etc.), state or country where formed, date of formation, and the month the brokerage firm's fiscal year ends. Legal Status: CORPORATION State/Country of Formation: MA Date of Formation: 06/04/1992 Fiscal Year End: DEC ******************************************************************************** REGISTRATIONS ******************************************************************************** This section provides the jurisdictions in which the brokerage firm is registered or licensed to do business, the category of each registration, and the date on which the registration was granted. Jurisdiction/SRO Category Status As Of Date AK Broker Dealer Approved 04/22/1994 AL Broker Dealer Approved 04/12/1994 AR Broker Dealer Approved 04/21/1994 AZ Broker Dealer Approved 01/01/1994 CA Broker Dealer Approved 11/10/1993 CO Broker Dealer Approved 03/24/1994 CT Broker Dealer Limited 01/03/1994 DC Broker Dealer Approved 04/16/1994 DE Broker Dealer Approved 03/28/1994 FL Broker Dealer Approved 02/14/1994 GA Broker Dealer Approved 03/18/1994 HI Broker Dealer Approved 06/24/1994 IA Broker Dealer Approved 04/18/1994 ID Broker Dealer Approved 04/11/1994 IL Broker Dealer Approved 01/03/1994 IN Broker Dealer Approved 04/26/1994 NASD BrokerCheck October 12, 2005 Page 3 This information is current as of: 10/12/2005 ________________________________________________________________________________ NASD Member Firm: COLUMBIA MANAGEMENT DISTRIBUTORS, INC. CRD Number: 30683 REGISTRATIONS(cont.) Jurisdiction/SRO Category Status As Of Date KS Broker Dealer Approved 04/19/1994 KY Broker Dealer Approved 04/07/1994 LA Broker Dealer Approved 03/17/1994 MA Broker Dealer Approved 01/03/1994 MD Broker Dealer Approved 04/26/1994 ME Broker Dealer Approved 05/05/1994 MI Broker Dealer Approved 04/07/1994 MN Broker Dealer Approved 05/24/1994 MO Broker Dealer Approved 05/03/1994 MS Broker Dealer Approved 01/03/1994 MT Broker Dealer Limited 04/19/1994 NASD Broker Dealer Approved 08/26/1993 NC Broker Dealer Limited 01/05/1994 ND Broker Dealer Limited 05/26/1994 NE Broker Dealer Limited 03/24/1994 NH Broker Dealer Approved 05/26/1994 NJ Broker Dealer Approved 01/05/1994 NM Broker Dealer Limited 04/29/1994 NV Broker Dealer Limited 05/10/1994 NY Broker Dealer Approved 11/22/1993 OH Broker Dealer Approved 04/27/1994 OK Broker Dealer Approved 03/24/1994 OR Broker Dealer Approved 04/08/1994 PA Broker Dealer Approved 05/04/1994 PR Broker Dealer Approved 07/24/1996 RI Broker Dealer Approved 01/04/1994 SC Broker Dealer Approved 03/22/1994 SD Broker Dealer Approved 04/01/1994 SEC Broker Dealer Approved 07/21/1992 TN Broker Dealer Approved 04/05/1994 TX Broker Dealer Limited 01/04/1994 UT Broker Dealer Approved 03/29/1994 VA Broker Dealer Approved 05/20/1994 VT Broker Dealer Approved 02/22/1994 WA Broker Dealer Limited 03/31/1994 WI Broker Dealer Approved 01/03/1994 WV Broker Dealer Approved 03/21/1994 WY Broker Dealer Approved 03/21/1994 NASD BrokerCheck October 12, 2005 Page 4 This information is current as of: 10/12/2005 ________________________________________________________________________________ NASD Member Firm: COLUMBIA MANAGEMENT DISTRIBUTORS, INC. CRD Number: 30683 ******************************************************************************** REGULATORY ACTIONS ******************************************************************************** DISCLOSURE INFORMATION This section lists regulatory actions that were reported to CRD and are disclosable through NASD BrokerCheck. Disclosable regulatory actions include formal proceedings initiated by a regulatory authority (i.e., a state securities agency, NASD, New York Stock Exchange, foreign regulatory body, etc.) for a violation of investment-related rules or regulations. In addition, revocations or suspensions of an individual broker's authority to act as an attorney, accountant or federal contractor will appear here. Some of the fields in this section of the report may be blank if the information was not provided to CRD. ** OCCURRENCE COUNTS ** 2 Record(s) ******************************************************************************** ** FIELD DEFINITIONS ** * Reporting Source: The form through which details of the regulatory action was reported to CRD. * Date Reported: The date the regulatory action was reported to CRD. * Initiated By: The name of the securities regulator that initiated the regulatory action (e.g., regulator, foreign financial regulatory authority, self-regulatory organization, federal agency such as SEC, state, etc.). * Date Initiated: Date the regulatory action was initiated. * Docket/Case Number: Docket or case number of the regulatory action. * Employing Brokerage Firm: Brokerage Firm where individual broker was employed when activity occurred that led to the regulatory action. * Allegations: Allegations made against the individual broker leading to the regulatory action. * Current Status: The current status of the regulatory action (i.e., pending, on appeal or final). * Resolution: The resolution of the regulatory action (e.g., acceptance, waiver and consent; decision; decision and order of offer of settlement; order; settled; etc.). * Resolution Date: The date the regulatory action was resolved. * Sanction Details: Additional details regarding any sanctions ordered. * Summary: A summary of the details related to the regulatory action. ******************************************************************************** ******** REGULATORY ACTION (1 of 2) ******** Reporting Source: Brokerage Firm (Form BD) Date Reported: 02/28/2005 Initiated By: OFFICE OF THE NEW YORK ATTORNEY GENERAL Date initiated: 02/09/2005 Docket/ Case Number: N/A Allegations: ON 2/9/05, NEITHER ADMITTING NOR DENYING THE FINDINGS, CMA & CFDI ENTERED INTO AN ASSURANCE OF DISCONTINUANCE WITH THE OFFICE OF THE NYAG TO SETTLE ALLEGATIONS THAT CMA & CFDI HAD VIOLATED THE MARTIN ACT, EXECUTIVE LAW S.63(12), AND THE G.B.L. S.349. THE ASSURANCE OF DISCONTINUANCE FINDS THAT, FROM AT LEAST 1998 THROUGH OCTOBER 2003, CMA & CFDI ENTERED INTO ARRANGEMENTS WITH 9 INVESTORS THAT ALLOWED THEM TO ENGAGE IN SHORT-TERM OR EXCESSIVE TRADING, CONTRARY TO RESTRICTIONS AND/OR REPRESENTATIONS IN THE COLUMBIA FUNDS' PROSPECTUSES, ALLOWED OR FAILED TO PREVENT OTHER INVESTORS FROM ENGAGING IN A PRACTICE OF SHORT-TERM OR EXCESSIVE TRADING, AND FAILED TO NASD BrokerCheck October 12, 2005 Page 5 This information is current as of: 10/12/2005 ________________________________________________________________________________ NASD Member Firm: COLUMBIA MANAGEMENT DISTRIBUTORS, INC. CRD Number: 30683 REGULATORY ACTIONS(cont.) MAINTAIN POLICIES OR PROCEDURES TO PREVENT THE MISUSE OF MATERIAL NON-PUBLIC INFORMATION ABOUT PORTFOLIO HOLDINGS. Current Status: Final Resolution: Consent Resolution Date: 02/09/2005 Sanctions Ordered: Monetary/Fine, Cease and Desist/Injunction Monetary Amount: $70,000,000.00 Other Sanctions: SEE ITEM 13 Resolution Details: CMA & CFDI SHALL PAY, ON A JOINT AND SEVERAL BASIS, $70M IN DISGORGEMENT PLUS A CIVIL MONEY PENALTY OF $70M, TO A FUND TO BE ADMINSTERED UNDER THE DIRECTION OF THE SEC. THIS IS THE SAME PAYMENT AS TO BE PAID UNDER THE PARALLEL SEC ORDER DATED 2/9/2005. Summary: THE NYAG ASSURANCE OF DISCONTINUANCE PROVIDES THAT: (1) CMA AND CFDI AND AFFILIATE COLUMBIA WANGER ASSET MANAGEMENT LP, COLLECTIVELY, WITH AFFILIATE BANC OF AMERICA CAPITAL MANAGEMENT, LLC, AGREE TO REDUCE MANAGEMENT FEES CHARGED TO CERTAIN FUNDS DISTRIBUTED TO RETAIL INVESTORS BY $32M PER YEAR THROUGH 2009, FOR A TOTAL OF $160M IN FEE REDUCTIONS; (2) CMA AGREES NOT TO MANAGE OR ADVISE A FUND UNLESS THE FUND IMPLEMENTS CERTAIN CORPORATE GOVERNANCE PRACTICES, INCLUDING HAVING 75% OF TRUSTEES MEET INDEPENDENCE STANDARDS, HAVING AN INDEPENDENT CHAIRMAN, APPOINTING A SENIOR OFFICER WHO MEETS INDEPENDENCE STANDARDS TO, AMONG OTHERS, MONITOR COMPLIANCE WITH APPLICABLE FEDERAL AND STATE SECURITIES LAWS, STATE LAWS RESPECTING CONFLICTS OF INTEREST, FIDUCIARY DUTIES AND CODES OF ETHICS AND COMPLIANCE POLICIES AND MANAGE THE NEGOTIATION PROCESS FOR MANAGEMENT FEES; (3) CMA AGREES TO DEVELOP PROCEDURES FOR THE DISCLOSURE OF FEES AND COSTS; AND (4) CMA AND CFDI AGREE TO PAY, ON A JOINT AND SEVERAL BASIS, $70M IN DISGORGEMENT AND A CIVIL MONEY PENALTY OF $70M. ******** REGULATORY ACTION (2 of 2) ******** Reporting Source: Regulator (Form U-6) Date Reported: 06/24/2005 Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date initiated: 02/09/2005 Docket/ Case Number: 3-11814 Allegations: SEC ADMINISTRATIVE PROCEEDINGS RELEASE NO. 8534 DATED FEBRUARY 9, 2005; THE COMPLAINT ALLEGED THE RESPONDENT WILLFULLY AIDED AND ABETTED AND CAUSED VIOLATIONS OF SECTIONS 206(1) AND 206(2) OF THE ADVISERS ACT AND VIOLATED SECTION 17(D) OF THE INVESTMENT COMPANY ACT AND RULE 17D-1 THEREUNDER. COLUMBIA DISTRIBUTOR WILLFULLY AIDED AND ABETTED AND CAUSED VIOLATIONS OF, SECTION 34(B) OF THE INVESTMENT COMPANY ACT AND VIOLATED SECTION 17(A) OF THE SECURITIES ACT.COLUMBIA DISTRIBUTOR WILLFULLY VIOLATED SECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER AS WELL AS SECTION 15(C) OF THE EXCHANGE ACT. COLUMBIA DISTRIBUTOR KNEW OR WAS RECKLESS IN NOT KNOWING THAT ITS NEGOTIATION OF ARRANGEMENTS ALLOWING SHORT-TERM OR EXCESSIVE TRADING WOULD AID AND ABET OR CONTRIBUTE TO ANOTHER COMPANY'S VIOLATIONS BY RENDERING THE FUND PROSPECTUSES ISSUED BY THE OTHER COMPANY MATERIALLY MISLEADING, AND WOULD CAUSE THE COMPANY TO BREACH ITS FIDUCIARY DUTY TO ACT IN THE INTEREST OF FUND SHAREHOLDERS.WHILE ACTING AS PRINCIPALS, COLUMBIA DISTRIBUTOR PARTICIPATED IN AND EFFECTED TRANSACTIONS IN CONNECTION WITH JOINT ARRANGEMENTS IN WHICH THE FUNDS WERE PARTICIPANTS WITHOUT FILING AN APPLICATION WITH THE COMMISSION AND OBTAINING A COMMISSION ORDER APPROVING THE TRANSACTIONS. THESE PROVISIONS ARE DESIGNED TO PREVENT ABUSES ARISING FROM CONFLICTS OF INTEREST BETWEEN AN INVESTMENT COMPANY AND ANY AFFILIATED PERSON OF THE INVESTMENT COMPANY. AS AN AFFILIATED PERSON AND AS THE PRINCIPAL UNDERWRITER, COLUMBIA DISTRIBUTOR EFFECTED TRANSACTIONS IN WHICH THEY WERE JOINT PARTICIPANTS WITH THE FUNDS. THEY CAUSED CERTAIN FUNDS TO ENTER INTO JOINT TRANSACTIONS WHEREBY SOME FUNDS AGREED TO ACCEPT MARKET TIMING INVESTMENTS (TO THEIR DETRIMENT) IN RETURN FOR THE PLACEMENT OF LONG-TERM ASSETS IN OTHER AFFILIATED FUNDS. NASD BrokerCheck October 12, 2005 Page 6 This information is current as of: 10/12/2005 ________________________________________________________________________________ NASD Member Firm: COLUMBIA MANAGEMENT DISTRIBUTORS, INC. CRD Number: 30683 REGULATORY ACTIONS(cont.) Current Status: Final Resolution: Order Resolution Date: 02/09/2005 Sanctions Ordered: Monetary/Fine, Disgorgement/Restitution, Censure, Cease and Desist/Injunction Monetary Amount: $70,000,000.00 Other Sanctions: UNDERTAKINGS Resolution Details: PURSUANT TO SECTION 15(B)(4) OF THE EXCHANGE ACT, COLUMBIA DISTRIBUTOR IS HEREBY CENSURED. COLUMBIA DISTRIBUTOR SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE SECURITIES ACT, SECTIONS 10(B) AND 15(C) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER, SECTIONS 206(1) AND 206(2) OF THE ADVISERS ACT AND SECTIONS 17(D) AND 34(B) OF THE INVESTMENT COMPANY ACT AND RULE 17D-1 THEREUNDER.RESPONDENTS SHALL PAY, WITHIN 20 DAYS OF THE ENTRY OF THE ORDER, ON A JOINT AND SEVERAL BASIS, $70,000,000 IN DISGORGEMENT PLUS A CIVIL MONEY PENALTY OF $70,000,000, FOR A TOTAL PAYMENT OF $140,000,000. Summary: *********************************** Reporting Source: Brokerage Firm (Form BD) Date Reported: 06/28/2005 Initiated By: U.S. SECURITIES AD EXCHANGE COMMISSION Date initiated: 02/09/2005 Docket/ Case Number: 3-11814 Allegations: PURSUANT TO OFFERS OF SETTLEMENT BY CMA AND CFDI IN WHICH THEY NEITHER ADMITTED NOR DENIED THE FINDINGS, THE SEC ENTERED AN ORDER ON 2/9/05 FINDING THAT, FROM AT LEAST 1998 THROUGH OCTOBER, 2003, CMA AND CFDI VIOLATED THE FEDERAL SECURITIES LAWS BY ENTERING INTO ARRANGEMENTS WITH 9 INVESTORS THAT ALLOWED THEM TO ENGAGE IN SHORT-TERM OR EXCESSIVE TRADING, CONTRARY TO RESTRICTIONS AND/OR REPRESENTATIONS IN THE COLUMBIA FUNDS' PROSPECTUSES, AND ALLOWING OR FAILING TO PREVENT OTHER INVESTORS FROM ENGAGING IN A PRACTICE OF SHORT-TERM OR EXCESSIVE TRADING. THE ORDER ALSO FOUND THAT CMA FAILED TO MAINTAIN POLICIES AND PROCEDURES TO PREVENT MISUSE OF MATERIAL NON-PUBLIC INFORMATION ABOUT PORTFOLIO HOLDINGS. Current Status: Final Resolution: Consent Resolution Date: 02/09/2005 Sanctions Ordered: Monetary/Fine, Disgorgement/Restitution, Censure, Cease and Desist/Injunction Monetary Amount: $70,000,000.00 Other Sanctions: THE SEC ORDER PROVIDES THAT: CMA & CFDI ARE CENSURED; CMA SHALL CEASE & DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS & ANY FUTURE VIOLATIONS OF SS204A, 206(1) AND 206(2) OF THE ADVISERS ACT & SS17(D)& 34(B) OF THE INVESTMENT COMPANY ACT & RULE 17D-1 THEREUNDER; CFDI SHALL CEASE & DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS & ANY FUTURE VIOLATIONS OF S.17(A) OF THE SECURITIES ACT, SS10(B)& 15(C) OF THE EXCHANGE ACT & RULE 10B-5 THEREUNDER, S. 206(1) & 206(2) OF THE ADVISERS ACT & SS17(D) & 34(B)OF THE INVESTMENT COMPANY ACT & RULE 17D-1 THEREUNDER; CMA AND CFDI SHALL PAY ON A JOINT AND SEVERAL BASIS, $70M IN DISGORGEMENT PLUS A CIVIL MONEY PENALTY OF $70M; CMA & CFDI SHALL COMPLY WITH REMEDIAL UNDERTAKINGS AS DESCRIBED IN ITEM 13. Resolution Details: CMA AND CFDI SHALL PAY, ON A JOINT AND SEVERAL BASIS, $70M IN DISGORGEMENT AND A CIVIL MONEY PENALTY OF $70M WITHIN 20 DYAS OF ENTRY OF THE ORDER. THESE FUNDS ARE TO BE DISTRIBUTED UNDER DIRECTION FO THE DISTRIBUTION CONSULTANT. Summary: THE SEC ORDER PROVIDES THAT (1) CMA AND CFDI SHALL MAINTAIN A NASD BrokerCheck October 12, 2005 Page 7 This information is current as of: 10/12/2005 ________________________________________________________________________________ NASD Member Firm: COLUMBIA MANAGEMENT DISTRIBUTORS, INC. CRD Number: 30683 REGULATORY ACTIONS(cont.) COMPLIANCE AND ETHICS OVERSIGHT INFRASTRUCTURE HAVING, AMONG OTHER ELEMENTS, A CODE OF ETHICS OVERSIGHT COMMITTEE, AN INTERNAL COMPLIANCE CONTROLS COMMITTEE, A SENIOR LEVEL COMPLIANCE OFFICER FOR CONFLICTS OF INTEREST, AND A CORPORATE OMBUDSMAN; (2) CMA AND CFDI SHALL RETAIN INDEPENDENT COMPLIANCE CONSULTANTS TO, AMONG OTHER THINGS, REVIEW CMA AND CFDI COMPLIANCE, SUPERVISORY, AND OTHER POLICIES AND PROCEDURES; (3) CMA AND CFDI SHALL ADOPT THE RECOMMENDATIONS OF SUCH CONSULTANTS SUBJECT TO A MECHANISM FOR RESOLVING DISAGREEMENTS; (4) CMA AND CFDI SHALL UNDERGO THIRD PARTY COMPLIANCE REVIEW EVERY OTHER YEAR; (5) CMA AND CFDI SHALL RETAIN AN INDEPENDENT DISTRIBUTION CONSULTANT; AND (6)CMA AND CFDI SHALL PAY, ON A JOINT AND SEVERAL BASIS, $70M IN DISGORGEMENT PLUS A CIVIL MONEY PENALTY OF $70M. IN ADDITION, THE COLUMBIA FUNDS VOLUNTARILY HAVE UNDERTAKEN TO OPERATE IN ACCORDANCE WITH CERTAIN GOVERNANCE POLICIES AND PRACTICES INCLUDING REQUIRING 75% OF TRUSTEES MEET INDEPENDENCE STANDARDS, THE CHAIRMAN TO BE INDEPENDENT, AND COUNSEL TO THE INDEPENDENT TRUSTEES MEET INDEPENDENCE STANDARDS. NASD BrokerCheck October 12, 2005 Page 8 This information is current as of: 10/12/2005 ________________________________________________________________________________ NASD Member Firm: COLUMBIA MANAGEMENT DISTRIBUTORS, INC. CRD Number: 30683 ******************************************************************************** CIVIL JUDICIAL ACTIONS ******************************************************************************** DISCLOSURE INFORMATION This section contains information regarding civil judicial actions that were reported to CRD. These actions are disclosable through NASD BrokerCheck and include injunctions issued by a foreign or domestic court in connection with investment-related activity, a finding by a domestic or foreign court of a violation of any investment-related statute(s) or regulation(s), and actions dismissed by a domestic or foreign court pursuant to a settlement agreement. Some of the fields in this section of the report may be blank if the information was not provided to CRD. ** OCCURRENCE COUNTS ** 2 Record(s) ******************************************************************************** ** FIELD DEFINITIONS ** * Reporting Source: The form through which details of the civil judicial action was reported to CRD. * Date Reported: The date the civil judicial action was reported to CRD. * Initiated By: The party that initiated the civil judicial action (e.g., regulator, foreign financial regulatory authority, self-regulatory organization, commodities exchange, etc.). * Date Initiated: Date the civil judicial action was initiated or filed. * Court Details: Details regarding the court the action was brought in (e.g., name and location of court, docket/case number, etc.). * Employing Brokerage Firm: Brokerage Firm where individual broker was employed when activity occurred that led to the civil judicial action. * Allegations: Allegations made against the individual broker leading to the civil judicial action. * Current Status: The current status of the civil judicial action (i.e., pending, on appeal or final). * Resolution: The resolution of the civil judicial action (e.g., consent, dismissed, judgment rendered, settled, withdrawn, etc.). * Resolution Date: The date the civil judicial action was resolved. * Sanction Details: Additional details regarding any sanctions ordered. * Summary: Details of the circumstances related to the civil judicial action. ******************************************************************************** ****** CIVIL JUDICIAL ACTION (1 of 2) ****** Reporting Source: Brokerage Firm (Form BD) Date Reported: 05/03/2005 Initiated By: STATE OF NEW YORK ATTORNEY GENERAL Date Initiated: 02/24/2004 Court Details: NEW YORK SUPREME COURT, COUNTY OF NEW YORK; INDEX NO. 04/00449 Allegations: ON FEBRUARY 24, 2004, THE NEW YORK ATTORNEY GENERAL FILED A CIVIL COMPLAINT IN NEW YORK SUPREME COURT, COUNTY OF NEW YORK, AGAINST COLUMBIA FUNDS DISTRIBUTOR, INC. ("CFDI") AND COLUMBIA MANAGEMENT ADVISORS, INC. ("CMA") ALLEGING THAT CFDI AND CMA VIOLATED CERTAIN NEW YORK ANTI-FRAUD STATUTES. THE COMPLAINT IS BASED ON ARRANGEMENTS BETWEEN 1998 AND 2003 WITH NINE INVESTORS FOR THE TRADING OF MUTUAL FUND SHARES. IN THEIR COMPLAINT, THE NEW YORK ATTORNEY GENERAL SOUGHT DISGORGEMENT OF PROFITS, RESTITUTION, MONETARY PENALTIES AND PERMANENT INJUNCTIONS. THE CASE WAS DISMISSED. SEE ITEM 14 BELOW. Current Status: Final NASD BrokerCheck October 12, 2005 Page 9 This information is current as of: 10/12/2005 ________________________________________________________________________________ NASD Member Firm: COLUMBIA MANAGEMENT DISTRIBUTORS, INC. CRD Number: 30683 CIVIL JUDICIAL ACTIONS(cont.) Resolution: Settled Resolution Date: 02/09/2005 Sanctions Ordered: Resolution Details: Summary: AMENDED TO CHANGE 11H2 PENDING LITIGATION REPORTING TO 11H1(C) REPORTING AS THE RESULT OF THE DISMISSAL OF THIS CIVIL PROCEEDING AGAINST COLUMBIA MANAGEMENT ADVISORS, INC. (CRD#105842)AND COLUMBIA FUNDS DISTRIBUTOR INC. (CRD#30683) AS A PART OF A SETTLEMENT WITH THE OFFICE OF THE NEW YORK ATTORNEY GENERAL. THIS CIVIL JUDICIAL ACTION WAS DISMISSED AS PART OF THE NYAG SETTLEMENT REFLECTED IN REGULATORY ACTION DISCLOSURE REPORTING PAGE FOR COLUMBIA MANAGEMENT ADVISORS, INC, (CRD#105842) AND COLUMBIA FUNDS DISTRIBUTOR, INC. (CRD#30683). ****** CIVIL JUDICIAL ACTION (2 of 2) ****** Reporting Source: Regulator (Form U-6) Date Reported: 03/02/2004 Initiated By: U.S. SECURITIES AND EXCHANGE COMMISSION Date Initiated: 02/24/2004 Court Details: THE U.S. DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS, CIVIL ACTION NO. 04 CV 10367-GAO. Allegations: SEC LITIGATION RELEASE NO. 18590, DATED 02/24/2004: THE SEC FILED A CIVIL FRAUD ACTION TODAY IN FEDERAL COURT ALLEGING THAT COLUMBIA FUNDS DISTRIBUTOR INC. ("COLOUMBIA FUNDS") AND A REGISTERED INVESTMENT ADVISER ("INVESTMENT ADVISER") (COLLECTIVELY, "DEFENDANTS") ALLOWED CERTAIN PREFERRED MUTUAL FUND CUSTOMERS TO ENGAGE IN SHORT-TERM AND EXCESSIVE TRADING, WHILE AT THE SAME TIME REPRESENTING PUBLICLY THAT IT PROHIBITED SUCH TRADING. THE INVESTMENT ADVISER MANAGES MUTUAL FUNDS AND COLUMBIA FUNDS IS A REGISTERED BROKER-DEALER THAT IS THE PRINCIPAL UNDERWRITER AND ENTITY RESPONSIBLE FOR SELLING THE FUNDS. COLUMBIA FUNDS SECRETLY ENTERED INTO ARRANGEMENTS WITH COMPANIES AND INDIVIDUALS ALLOWING THEM TO ENGAGE IN FREQUENT SHORT-TERM TRADING IN AT LEAST SEVEN FUNDS. IN CONNECTION WITH CERTAIN OF THE ARRANGEMENTS, DEFENDANTS ACCEPTED SO-CALLED "STICKY ASSETS" ? LONG-TERM INVESTMENTS THAT WERE TO REMAIN IN PLACE IN RETURN FOR ALLOWING THE INVESTORS TO ACTIVELY TRADE IN THE FUNDS. AFTER ENTERING INTO THESE ARRANGEMENTS, THE COMPANIES AND INDIVIDUALS ENGAGED IN FREQUENT SHORT-TERM OR EXCESSIVE TRADING IN AT LEAST SIXTEEN DIFFERENT MUTUAL FUNDS. THE SEC ALLEGES THAT EXECUTIVES OF COLUMBIA FUNDS ENTERED INTO THE ARRANGEMENTS, AND THAT INVESTMENT ADVISORS KNEW AND APPROVED OF ALL BUT ONE OF THE ARRANGEMENTS AND ALLOWED THEM TO CONTINUE DESPITE KNOWING SUCH SHORT-TERM TRADING COULD BE DETRIMENTAL TO LONG-TERM SHAREHOLDERS IN THE FUNDS. THE DEFENDANTS ACTED IMPROPERLY IN ENTERING AND ACCEPTING THE SHORT-TERM TRADING ARRANGEMENTS, BECAUSE THEY WERE CONTRARY TO DISCLOSURES MADE IN THE PROSPECTUSES USED TO SELL THE MUTUAL FUNDS. THE DEFENDANT VIOLATED SECTION 17(A) OF THE SECURITIES ACT OF 1933; SECTIONS 10(B) AND 15(C) OF THE SECURITIES EXCHANGE ACT OF 1934, AND RULE 10B-5 THEREUNDER; SECTION 17(D) AND RULE 17D-1 OF THE INVESTMENT COMPANY ACT OF 1940; AND AIDED AND ABETTED VIOLATION OF SECTIONS 206(1) AND 206(2) OF THE INVESTMENT ADVISERS ACT OF 1940. Current Status: Pending Summary: *********************************** Reporting Source: Brokerage Firm (Form BD) Date Reported: 05/03/2005 Initiated By: U.S. SECURITIES AND EXCHANGE COMMISSION Date Initiated: 02/24/2004 Court Details: U.S. DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS CIVIL ACTION NO. 04-CV-10367-GAO NASD BrokerCheck October 12, 2005 Page 10 This information is current as of: 10/12/2005 ________________________________________________________________________________ NASD Member Firm: COLUMBIA MANAGEMENT DISTRIBUTORS, INC. CRD Number: 30683 CIVIL JUDICIAL ACTIONS(cont.) Allegations: ON FEBRUARY 24, 2004, THE SEC FILED A CIVIL COMPLAINT IN THE U.S. DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS AGAINST COLUMBIA FUNDS DISTRIBUTOR, INC. ("CFDI") AND COLUMBIA MANAGEMENT ADVISORS, INC. ("CMA"), ALLEGING THAT CFDI AND CMA HAVE VIOLATED CERTAIN PROVISIONS OF THE FEDERAL SECURITIES LAWS. THE COMPLAINT IS BASED ON ARRANGEMENTS BETWEEN 1998 AND 2003 WITH NINE INVESTORS FOR THE TRADING OF MUTUAL FUND SHARES. IN THEIR COMPLAINT, THE SEC IS SEEKING DISGORGEMENT OF PROFITS, RESTITUTION, MONETARY PENALTIES AND PERMANENT INJUNCTIONS, INCLUDING A PERMANENT INJUNCTION FROM SERVING OR ACTING AS INVESTMENT ADVISER OR DISTRIBUTOR OF ANY REGISTERED FUND. THE CASE WAS DISMISSED. SEE ITEM 14 BELOW. CFDI AND CMA ARE ENGAGED IN DISCUSSIONS WITH THE SEC STAFF IN AN EFFORT TO REACH A SATISFACTORY RESOLUTION OF THESE MATTERS. Current Status: Final Resolution: Settled Resolution Date: 02/09/2005 Sanctions Ordered: Resolution Details: Summary: AMENDED TO CHANGE 11H2 PENDING LITIGATION REPORTING TO 11H1(C) REPORTING AS THE RESULT OF THE DISMISSAL OF THIS CIVIL PROCEEDING AGAINST COLUMBIA MANAGEMENT ADVISORS, INC. (CRD#105842) AND COLUMBIA FUNDS DISTRIBUTOR, INC. (CRD#30683) AS A PART OF A SETTLEMENT WITH THE SEC. THIS CIVIL JUDICIAL ACTION WAS DISMISSED AS PART OF THE SEC SETTLEMENT REFLECTED IN REGULATORY ACTION DISCLOSURE REPORTING PAGE FOR COLUMBIA MANAGEMENT ADVISORS, INC. (CRD#105842) AND COLUMBIA FUNDS DISTRUBUTOR, INC. (CRD#30683). ************ END OF REPORT ************