On July 23, 2009, FINRA announced that it fined McDonald Investments (now KeyBanc Capital Markets, Inc.), IFMG Securities, Wells Fargo Investments, LLC, PNC Investments and WM Financial Services, Inc. (now Chase Investment Services Corp.) $1.65 million for inadequate sales procedures and deficient supervision of sales activities relating to variable annuity, mutual fund and UIT transactions. According to FINRA, between 2004 and 2006 the firms engaged in a pattern of selling to elderly bank customers investment products which were either ineligible or inappropriate based on the customers’ age. FINRA also found that the firms’ supervisory procedures with respect to suitability were inadequate. For example, in some cases, the firms’ procedures failed to provide sales representatives with guidance on how to determine suitability in variable annuity transactions.