____________________________________________________________________________________ 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. NASD believes that the general public should have access to information which will help them in their determination whether to conduct or continue to conduct business with an NASD member or any of the member's associated persons. In that regard, enclosed please find the information that you have requested. A list of the terms and conditions of NASD BrokerCheck is as follows: NASD BrokerCheck Terms and Conditions 1. NASD collects, compiles, organizes, indexes, digitally converts and maintains regulatory information from registered persons, member firms, government agencies and other sources and maintains information in the proprietary Central Registration Depository ("CRD(r)") database and system. NASD releases such information through NASD BrokerCheck, which provides information from CRD system to the investing public. Your access to NASD BrokerCheck information provided through NASD's CRD database and system does not transfer any rights in CRD, NASD BrokerCheck or related technologies to you. 2. Your use of NASD BrokerCheck information is conditioned upon your acceptance, without modification, of all terms and conditions of this Agreement. Any information accessed, requested or provided through NASD BrokerCheck must be accessed, requested and used in accordance with the terms and conditions specified in this Agreement. NASD reserves any rights not expressly granted under these terms and conditions. Additionally, NASD reserves the right, at its sole discretion, to modify the terms and conditions for use of NASD BrokerCheck information at any time by changing this Agreement, and any changes are effective immediately. Such changes will be posted on the NASD BrokerCheck web site. 3. CRD and NASD BrokerCheck are proprietary databases and employ proprietary software, but NASD makes no exclusive proprietary claim to the information in the NASD BrokerCheck system that is not created by NASD. You are neither restricted nor prohibited by NASD from obtaining a copy of any original filing or information from a non-NASD source. 4. 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Provision of information by NASD pursuant to NASD BrokerCheck does not constitute a waiver of any of NASD's rights, privileges, or immunities with respect to the furnishing of disciplinary or registration information. 8. NASD does not charge for this service, which is offered pursuant to NASD's responsibilities as a self-regulatory organization, and, in particular, pursuant to Section 15A(i) of the Securities Exchange Act of 1934. In the provision of this service, NASD makes no warranties of any kind, and disclaims liability to any person for any actions taken or omitted in good faith with respect to this NASD BrokerCheck. NASD is not responsible for and cannot verify information from sources other than NASD, and does not warrant or guarantee the accuracy or completeness of the information requested. Neither NASD nor any affiliate or supplier shall be liable for any cause of action in contract, tort, or otherwise, for more than the incremental telecommunications cost incurred to connect to the service. Notwithstanding the above, neither NASD nor any affiliate or supplier shall be liable for any loss of income, trading loss, or consequential, incidental, or indirect damages, regardless of whether NASD has been informed of the possibility of such damages. 9. Member firms, registered persons, government agencies, and other sources file disclosure information with NASD. Consistent with its responsibilities as a self-regulatory organization, NASD performs a regulatory review of the disclosure information filed before it makes the information available through NASD BrokerCheck. Most disclosure information is available through NASD BrokerCheck within two business days of being filed. In certain limited circumstances, disclosure information may not be available through NASD BrokerCheck within the usual timeframe, but will be made available as soon as practicable. 10. Consistent with policies and procedures approved by the Securities and Exchange Commission (SEC), NASD will disclose information on individuals and brokerage firms, through NASD BrokerCheck, for two years after the termination of the individual's or brokerage firm's NASD registration. Disclosure information reported to NASD after an individual or brokerage firm has terminated may not have been reviewed by the brokerage firm or individual; in addition, brokerage firms and individuals who are no longer registered are not required to independently report such information. 11. NASD BrokerCheck includes only information provided to CRD. In substantially all cases, the information provided through NASD BrokerCheck represents the verbatim record as it was reported to NASD. However, in certain limited circumstances, NASD combined information about a single event that was reported by different sources (e.g., a record reporting information on an event that was submitted by a brokerage firm may contain information reported on the same event that was submitted by a regulator). This condition occurred when the data in the Legacy CRD system was converted (i.e., reformatted and transferred) to Web CRD, the Internet-based Central Registration Depository. This condition affects a small percentage of records reported to NASD prior to August 1999. These converted records contain information that was reported to NASD in accordance with appropriate reporting protocols applicable to the source filers (e.g., brokerage firms and regulators); however, because of the combination of information from different reporting sources, a record disclosed through NASD BrokerCheck may not reflect the actual filing submitted to NASD. 12. The "Individual Broker comments," "Brokerage Firm comments" and "Regulator comments" appear verbatim as they were provided to CRD via Forms U-4, U-5, and U-6. These comments were not written by NASD and have not been edited by NASD in any way. NASD reserves the right to redact customer names, confidential customer information, or offensive or potentially defamatory language from an NASD BrokerCheck Report consistent with policies and procedures approved by the SEC. TC 02.1 General Information About this Report This report has been generated because you have requested information about an NASD Member Firm through NASD BrokerCheck. The information contained within this report has been provided by NASD brokerage firm and securities regulators as part of the securities industry's registration and licensing process. An NASD BrokerCheck report for a Brokerage Firm consists of: 1) a Report Summary; 2) General Administrative Information, which includes the Types of Business the Brokerage Firm is engaged in, the Brokerage Firm's Legal Status, and the Brokerage Firm's Approved Registrations. The report also includes the Brokerage Firm's Disclosure Event information, if any. NASD BrokerCheck discloses the following information on brokerage firms: * the brokerage firm's name, CRD number, SEC identification number, "applicant name" or legal name, NASD district office which oversees the brokerage firm, and the brokerage firm's main and mailing addresses * the types of business in which the brokerage firm is currently engaged * details of the brokerage firm's legal status (i.e, corporation, partnership, etc.), state or country and date of formation, and its fiscal year end * all approved registrations * disclosure matters involving certain criminal charges and convictions, regulatory actions, civil judicial actions, and certain financial actions (e.g., bankruptcies, unsatisfied judgment/liens.) When evaluating this report, please keep in mind that a number of items may involve pending actions or allegations that may be contested and have not been resolved or proven. The items may, in the end, be withdrawn or dismissed, or resolved in favor of the brokerage firm, or concluded through a negotiated settlement with no admission or conclusion of wrongdoing. Also remember that the information in this report is not the only resource you should consult. It is recommended that you learn as much as possible about the brokerage firm from other sources. Ask for references. Ask family members or friends who already have established investment business relationships. Get in touch with local consumer and investors groups. Should you have any questions concerning information contained within this report, call (800) 289-9999 - a toll-free NASD BrokerCheck hot-line operated by NASD - or visit NASD Web Site at www.nasd.com. When calling or visiting the NASD Web Site, the information you will need includes the brokerage firm's name or CRD number. For definition of terms contained within this report or answers to Frequently Asked Questions, visit the Glossary or FAQs sections of NASD BrokerCheck at www.nasd.com. NASD BrokerCheck Report Printing Instructions The report contained below can be printed as is. However, unless the following steps are taken, the report may not print with the headers aligned or the text may run off the page. For the following report to be printed correctly, the following formatting steps must be completed: 1) Copy the text of the report into a text editor. 2) Delete these instructions down to and including the first dashed line. 3) Set the Font for the entire report to Courier, 8 point. 4) Set the left and right margins to 0. 5) Set the top and bottom margins to 0. Because every printer allows a different number of lines per page, the margins may have to be adjusted differently to get the headers to line up at the top of each page. 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: PRUDENTIAL INVESTMENT MANAGEMENT SERVICES LLC CRD Number: 18353 ******************************************************************************** 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: 16 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: 1 Civil Judicial Actions: 0 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: PRUDENTIAL INVESTMENT MANAGEMENT SERVICES LLC CRD Number: 18353 ******************************************************************************** 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: PRUDENTIAL INVESTMENT MANAGEMENT SERVICES LLC SEC Number: 8-036540 Prior Business Names: PAMCO SECURITIES CORPORATION PRUDENTIAL ASSET MANAGEMENT COMPANY SECURITIES CORPORATION Business Phone Number: 973 802-6000 Main Office Address Located in NASD District: 9-Woodbridge THREE GATEWAY CENTER 14TH FLOOR NEWARK, NJ 07102-4077 Mailing Address THREE GATEWAY CENTER 14TH FLOOR NEWARK, NJ 07102-4077 ******************************************************************************** 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. Broker or dealer selling corporate debt securities Broker or dealer retailing corporate equity securities over-the-counter Government securities broker Investment advisory services Mutual fund retailer Mutual fund underwriter or sponsor Municipal securities broker Municipal securities dealer Put and call broker or dealer or option writer Private placements of securities Solicitor of time deposits in a financial institution Broker or dealer selling tax shelters or limited partnerships in primary distributions Underwriter or selling group participant (corporate securities other than mutual funds) Broker or dealer selling variable life insurance or annuities 12(Z) IN ACCORDANCE WITH THE REQUEST OF NASD DISTRICT 10, FURTHER INFORMATION HAS BEEN PROVIDED RELATING TO SECURITIES ISSUED BY THE FOLLOWING ENTITIES THAT APPLICANT BELIEVES CONSTITUTE "TAX SHELTERS" AS THAT TERM IS USED IN ITEM 12.T1,STRATEGIC PERFORMANCE FUND-II INC., THE TEXT FUNDS, PCM INT'L GROUP DIRECTED TRUST AND THE SOUTH EAST ASIA PROPERTY CO.LTD. ALSO BROKER-DEALER SELLS SHARES OF LIMITED LIABILITY COMPANIES IN PRIMARY DISTRIBUTIONS. 13B APPLICANT HAS AN OFFICE IN JAPAN THAT DOES NOT ENGAGE IN ANY SECURITIES RELATED ACTIVITIES. THIS OFFICE IS ENGAGED IN LIASION AND RESEARCH ACTIVITIES ON BEHALF OF THE PRUDENTIAL INSURANCE COMPANY OF AMERICA AND ITS SUBSIDIARIES, INCLUDING THE PRUDENTIAL INVESTMENT CORPORATION. ******************************************************************************** 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: LIMITED State/Country of Formation: DE, UNITED STATES Date of Formation: 10/09/1996 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. NASD BrokerCheck October 12, 2005 Page 3 This information is current as of: 10/12/2005 ________________________________________________________________________________ NASD Member Firm: PRUDENTIAL INVESTMENT MANAGEMENT SERVICES LLC CRD Number: 18353 REGISTRATIONS(cont.) Jurisdiction/SRO Category Status As Of Date AK Broker Dealer Approved 01/27/1995 AL Broker Dealer Approved 01/12/1995 AR Broker Dealer Approved 12/01/1996 AZ Broker Dealer Approved 04/25/1995 CA Broker Dealer Approved 02/04/1997 CO Broker Dealer Approved 01/03/1995 CT Broker Dealer Approved 02/03/1995 DC Broker Dealer Approved 02/05/1995 DE Broker Dealer Approved 12/05/1994 FL Broker Dealer Approved 01/06/1994 GA Broker Dealer Approved 01/13/1995 HI Broker Dealer Approved 02/10/1997 IA Broker Dealer Approved 10/14/1992 ID Broker Dealer Approved 01/28/1995 IL Broker Dealer Approved 12/31/1991 IN Broker Dealer Approved 01/20/1995 KS Broker Dealer Approved 12/05/1994 KY Broker Dealer Approved 11/09/1994 LA Broker Dealer Approved 03/22/1995 MA Broker Dealer Approved 12/23/1994 MD Broker Dealer Approved 01/10/1995 ME Broker Dealer Approved 12/13/1996 MI Broker Dealer Approved 12/05/1996 MN Broker Dealer Approved 04/06/1995 MO Broker Dealer Approved 04/20/1995 MS Broker Dealer Approved 12/19/1994 MT Broker Dealer Approved 10/21/1994 NASD Broker Dealer Approved 11/16/1987 NC Broker Dealer Approved 10/28/1992 ND Broker Dealer Approved 02/10/1995 NE Broker Dealer Approved 12/10/1996 NH Broker Dealer Approved 05/19/1995 NJ Broker Dealer Approved 10/27/1991 NM Broker Dealer Approved 04/17/1995 NV Broker Dealer Approved 01/12/1995 NY Broker Dealer Approved 12/01/1996 OH Broker Dealer Approved 01/16/1997 OK Broker Dealer Approved 01/18/1995 OR Broker Dealer Approved 10/22/1992 PA Broker Dealer Approved 07/05/1995 PR Broker Dealer Approved 11/21/1997 RI Broker Dealer Approved 01/23/1995 SC Broker Dealer Approved 11/30/1994 SD Broker Dealer Approved 11/17/1994 SEC Broker Dealer Approved 10/30/1986 TN Broker Dealer Approved 05/08/1995 TX Broker Dealer Approved 01/24/1997 UT Broker Dealer Approved 01/09/1995 VA Broker Dealer Approved 10/22/1992 VT Broker Dealer Approved 02/21/1995 WA Broker Dealer Approved 02/03/1995 WI Broker Dealer Approved 08/01/1996 WV Broker Dealer Approved 09/09/1994 WY Broker Dealer Approved 09/12/1994 NASD BrokerCheck October 12, 2005 Page 4 This information is current as of: 10/12/2005 ________________________________________________________________________________ NASD Member Firm: PRUDENTIAL INVESTMENT MANAGEMENT SERVICES LLC CRD Number: 18353 ******************************************************************************** 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 ** 1 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 1) ******** Reporting Source: Regulator (Form U-6) Date Reported: 01/30/2004 Initiated By: NASD Date initiated: 01/29/2004 Docket/ Case Number: C05040008/C9B040005 Allegations: SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934, SEC RULES 17A-3, 17A-4 PROMULGATED THEREUNDER, NASD RULES 2110, 2210, 3010, 3110 - RESPONDENT MEMBER EFFECTED ANNUITY REPLACEMENT SALES IN CONTRAVENTION OF REGULATION 60 OF THE NEW YORK STATE INSURANCE DEPARTMENT, FAILED TO OBSERVE HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE; FAILED TO ADEQUATELY SUPERVISE THE ACTIVITIES OF ITS ASSOCIATED PERSONS RELATING TO ANNUITY REPLACEMENT SALES SUBJECT TO REGULATION 60; FAILED TO MANTAIN ACCURATE RECORDS OF ANNUITY REPLACEMENT SALES SUBJECT TO REGULATION NO. 60; AND PREPARED INCORRECT ANNUITY PERFORMANCE ILLUSTRATIONS AND IN NASD BrokerCheck October 12, 2005 Page 5 This information is current as of: 10/12/2005 ________________________________________________________________________________ NASD Member Firm: PRUDENTIAL INVESTMENT MANAGEMENT SERVICES LLC CRD Number: 18353 REGULATORY ACTIONS(cont.) SOME INSTANCES USED SUCH ILLUSTRATIONS IN THE SALE OF ANNUITIES. (REGULATION 60 ESTABLISHES CERTAIN STANDARDS OF CONDUCT TO BE OBSERVED IN THE REPLACEMENT OR PROPOSED REPLACEMENT OF ANNUITY CONTRACTS AND LIFE INSURANCE POLICIES IN THE STATE OF NEW YORK AND SEEKS TO ENSURE THAT APPLICANTS FOR INSURANCE AND ANNUITIES HAVE FULL AND CLEAR INFORMATION PRIOR TO MAKING A DECISION TO REPLACE AN EXISTING CONTRACT.) Current Status: Final Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/29/2004 Sanctions Ordered: Monetary/Fine, Disgorgement/Restitution, Censure Monetary Amount: $2,000,000.00 Resolution Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, PRUDENTIAL INVESTMENT MANAGEMENT SERVICES LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED, ORDERED TO PAY JOINTLY AND SEVERALLY,A MONETARY SANCTION AS FOLLOWS: REMEDIATION PAYMENTS OF NO LESS THAN AN AGGREGATE AMOUNT OF $8,000,000 TO PUBLIC CUSTOMERS WHO EFFECTED ANNUITY REPLACEMENT TRANSACTIONS SUBJECT TO REGULATION NO. 60 DURING THE PERIOD FROM NOVEMBER 1998 THROUGH JUNE 2002; AND FINED $2,000,000 PAYABLE TO NASD, JOINTLY AND SEVERALLY. THE FIRM WILL PROVIDE NASD STAFF WITH SATISFACTORY PROOF OF PAYMENT OF THE RESTITUTION AMOUNTS WITHIN 120 DAYS. Summary: *********************************** Reporting Source: Brokerage Firm (Form BD) Date Reported: 02/06/2004 Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS (NASD) Date initiated: 01/29/2004 Docket/ Case Number: C05040008/C9B040005 Allegations: THE ACTION ALLEGES THAT CERTAIN ASSOCIATED PERSONS OF THE FIRM CIRCUMVENTED A NY STATE INSURANCE DEPARTMENT REGULATION GOVERNING REPLACEMENT SALES OF ANNUITIES AND THEN ALTERED FIRM RECORDS TO DISGUISE THE CIRCUMVENTION. ALSO, SOME ASSOCIATED PERSONS OF THE FIRM CREATED INCORRECT ILLUSTRATIONS IN CONNECTION WITH THE SALE OF ANNUITIES. Current Status: Final Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 01/29/2004 Sanctions Ordered: Monetary/Fine, Disgorgement/Restitution, Censure Monetary Amount: $2,000,000.00 Resolution Details: WITHOUT ADMITTING OR DENYING WRONGDOING, THE FIRM AGREED TO A $2 MILLION FINE AND AGREED TO MAKE REMEDIATION PAYMENTS TO CLIENTS IN THE AMOUNT OF $9.5 MILLION. THE FINE AND THE REMEDIATION PAYMENTS WERE ASSESSED JOINTLY AND SEVERALLY AGANST THE FIRM AND PRUDENTIAL SECURITIES, INC., AN AFFILIATED COMPANY NOW KNOWN AS PRUDENTIAL EQUITY GROUP, INC. Summary: THE FIRM AGREED TO AN NASD LETTER OF ACCEPTANCE,WAIVER, AND CONSENT. WITHOUT ADMITTING OR DENYING WRONGDOING, THE FIRM AGREED TO A CENSURE, A $2 MILLION FINE AND REMEDIATION PAYMENTS TO CLIENTS IN THE AMOUNT OF $9.5 MILLION. THIS MATTER WAS FILED AGAINST BOTH THE FIRM AND PRUDENTIAL SECURITIES, INC., AN AFFILIATED COMPANY NOW KNOWN AS PRUDENTIAL EQUITY GROUP, INC. THE FINE AND THE REMEDIATION PAYMENTS WERE ASSESSED AGAINST BOTH ENTITIES JOINTLY AND SEVERALLY ON JANUARY 29, 2004. ************ END OF REPORT ************