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Broker Name: William J. Money

This Broker Currently Works For: Average Brokerage Firm
Mr. Money was born in 1949. He maintains a post office box in Little Rock, Arkansas, but has lived in Litchfield Park, Arizona (a suburb west of Phoenix) since February 2006. He holds an Airline Transport Pilot’s license. Property records show that he owns at least two boats, one manufactured by Polaris and the other by Wellcraft.


He is involved in at least two outside businesses, one of which appears to be a company that owns real estate in and around Little Rock, Arkansas. He also owns a fireworks company, Sunflower Fireworks, Inc. NASD records also disclose that he sells non-variable insurance products through a separate business.
In 1981, Mr. Money became licensed to sell securities, although NASD records do not indicate where he worked at the time. In 1985, he became a registered representative of Average Brokerage (“Average”). In March 1989 and again in August 1989 he failed the test that would have authorized him to supervise other brokers. He finally passed that exam in November 1989.


We found one customer complaint against Mr. Money. In 2003 a customer filed an arbitration action accusing Mr. Money of unauthorized trading, churning, and unsuitability. NASD records reflect a settlement of that arbitration with a payment of $200,000 to the customer.


In addition, the publicly available records contain a significant gap in Mr. Money’s employment history. NASD records do not reflect who he worked for between 1981, when he first became licensed to sell securities, and 1985, when he went to work for Average.

A clean disciplinary record is important. Mr. Money has one arbitration action on his record. In IW’s experience, Average rarely settles claims unless there is a good chance that the arbitration panel will find against the broker.

IW is also concerned with the sale of variable annuity products to this client. Such products are expensive to the customer, lucrative to the broker, rarely outperform alternative investments, even after taxes are considered, and are almost never suitable for senior citizens seeking income and safety of principal.

Another area of concern is Mr. Money’s operation of outside businesses. Through many years of protecting investors, IW has learned that problem brokers often have outside business activities.

Mr. Money’s firm, Average, is an independent broker-dealer headquartered in Boston. Average has been sanctioned numerous times by securities regulators.

In May 1997, the Kansas Securities Commissioner sanctioned Average for failure to adequately supervise one of its registered representatives who had mistreated no fewer than four Average customers.

In June 1999, the New Hampshire Bureau of Securities Regulation sanctioned Average and ordered it to refund excess commissions it had collected.

In March 2000, the North Dakota Securities Commissioner sanctioned Average for failure to adequately supervise and failure to prevent sales practice irregularities.

In February 2003, the NASD sanctioned Average, finding that the firm’s supervisory system did not provide for supervision reasonably designed to achieve compliance with applicable securities laws and regulations.

In February 2004, the NASD censured and fined Average more than $2.2 million for failing to give its customers commission discounts to which they were entitled and for failure to adequately supervise its representatives.

In February 2004, the U.S. Securities and Exchange Commission issued a cease-and-desist order against Average for failure to give customers commission discounts to which they were entitled. The SEC also fined Average $1.1 million.

In November 2004, the NASD censured and fined Average $450,000 for failing to timely file 390 amendments to Forms U4 and U5 which, if timely filed, would have put the public on notice of 390 additional regulatory actions or criminal actions by Average representatives.

In November 2005, the NASD sanctioned Average for failing to maintain a system of written procedures to supervise its registered representatives.

In December 2005, the NASD censured and fined Average $2.4 million for inadequate supervisory and compliance policies and procedures.

In June 2005, the NASD censured and fined Average $3.6 million for violations involving allowing mutual fund companies to have undue influence on Average’s sales force.

This pattern concerns IW. Adequate supervision is essential to investor protection.

(*) In light of the forgoing, IW gives Mr. Money an IW score of 47 on a scale of 40 to 80. A score of 40 indicates a broker that, in IW’s opinion, the client should avoid altogether. A score of 80 indicates a broker who has been tested by bear markets and yet has no customer complaints, no disciplinary history, no negative information in the IW database, and no areas that raise concern for a former SEC Enforcement Branch Chief.

(*) IW rates brokers on a 40 to 80 scale with a higher score reflecting IW’s opinion, based on historical information, that the investor’s assets are safe from intentional or reckless misconduct by the broker or his firm. IW expresses no opinion on the value of the customer’s investments or on the broker’s investment selection ability. A single new fact can radically change the IW score and indicate a need for immediate action. Please consider upgrading to enhanced or maximum protection through IW’s Wiinnow™ or Constant Patrol™ products.