On Investment Management Co.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE

CRD
Number:
2936
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
THE O.N. EQUITY SALES
COMPANY
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
VIRGINIA STATE CORPORATION COMMISSION
2.
Principal Sanction:
Restitution
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/23/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
SEC-2017-00023
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
THE O.N. EQUITY SALES COMPANY
6.
Principal Product Type:
Other
Other Product Types: 
PROMISSORY NOTES, STOCK OPTIONS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DIVISION ALLEGES THAT THE O.N. EQUITY SALES COMPANY FAIL TO SUPERVISE FORMER REGISTERED REPRESENTATIVE, JOSHUA RAY ABERNATHY,
WHILE HE WAS EMPLOYED BY THEIR FIRM. ABERNATHY MISAPPROPRIATED FUNDS FROM AT LEAST FOURTEEN (14) INVESTORS WHILE EMPLOYED BY
THE O.N. EQUITY SALES COMPANY.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled

11. Resolution Date (MM/DD/YYYY):
04/23/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE DIVISION ORDERED THE O.N. EQUITY SALES COMPANY TO PAY $40,000 BACK TO HARMED INVESTORS ON A PRO RATA BASIS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE DIVISION ALLEGES THAT THE O.N. EQUITY SALES COMPANY FAILED TO ADEQUATELY MONITOR ABERNATHY'S USE OF HIS PERSONAL EMAIL
ACCOUNT TO COMMUNICATE WITH CLIENTS DURING THE TIME HE WAS REGISTERED WITH THE FIRM. THE DIVISION ALSO ALLEGES THAT THE FIRM
VIOLATED ITS OWN POLICIES AND PROCEDURES AS RELATED TO CONDUCTING BRANCH OFFICE AUDITS ON NEW BRANCH OFFICES. THE DIVISION
ALLEGED THAT IF THE FIRM HAD COMPLIED WITH THESE REQUIREMENTS AND OBLIGATIONS, IT WOULD HAVE DISCOVERED ABERNATHY'S FRAUDULENT
ACTIVITIES. AS A RESULT, ABERNATHY WAS ABLE TO SOLICIT AND MISAPPROPRIATE FUNDS FROM AT LEAST 14 INVESTORS WHILE HE WAS EMPLOYED
BY FIRM. PRIOR TO THE ENTRY OF THE ORDER, THE O.N. EQUITY SALES COMPANY MADE PAYMENTS TOTALING $469,667 TO HARMED INVESTORS.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.

If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURED - AGREED TO PAY DISGORGEMENT, PREJUDGEMENT INTEREST, AND A CIVIL PENALTY.
3.
Date Initiated (MM/DD/YYYY): 
01/11/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 3-20701
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
MONEY MARKET FUND(S)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FOR THE PERIOD FROM 2014 THROUGH MARCH 2017, ONIMCO ADVISED CLIENTS TO PURCHASE OR HOLD MUTUAL FUND SHARE CLASSES THAT PAID
12B-1 FEES TO ONIMCO OR ITS AFFILIATED BROKER-DEALER INSTEAD OF LOWER-COST SHARE CLASSES FOR THE SAME FUNDS FOR WHICH THE
CLIENTS WERE ELIGIBLE. THE SEC FURTHER STATED THAT, STARTING NO LATER THAN 2014, ONIMCO RECOMMENDED OR INVESTED FOR ADVISORY
CLIENT'S MUTUAL FUNDS OR SHARE CLASSES OR CASH SWEEPS THAT PAID REVENUE SHARING PAYMENTS TO ONIMCO'S AFFILIATED BROKER-DEALER
INSTEAD OF LOWER-COST FUNDS OR SHARE CLASSES FOR THE SAME MUTUAL FUNDS OR CASH SWEEPS FOR WHICH THE CLIENTS WERE ELIGIBLE. THE
ORDER STATED THAT ONIMCO DID NOT ADEQUATELY DISCLOSE THESE CONFLICTS OF INTEREST, AND THAT THE FAILURE TO DO SO CONSTITUTED
BREACHES OF ONIMCO'S FIDUCIARY DUTY, DUTY TO SEEK BEST EXECUTION, OBLIGATION TO MAINTAIN AN EFFECTIVE COMPLIANCE PROGRAM, AND
THAT THIS CONDUCT VIOLATED SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. THE SEC'S
ORDER CAN BE FOUND AT HTTPS://WWW.SEC.GOV/LITIGATION/ADMIN/2022/IA-5944.PDF.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
01/11/2022
 Exact
 Explanation
If not exact, provide explanation:
ORDER WAS FINALIZED ON 1/11/2022. UNDERTAKINGS IN PROCESS. DISCLOSURE DOCUMENTS UPDATED CONCERNING MUTUAL FUND SHARE CLASS
SELECTION AND 12B-1 FEES, NTF REVENUE SHARING, AND SWEEP ACCOUNT REVENUE SHARING. EVALUATE AND MOVE CUSTOMERS TO LOWER-COST
AND NOT NTF REVENUE AS ORDERED. UPDATE FIRM POLICIES AND PROCEDURES. NOTIFY AFFECTED INVESTORS AND SEND COPY OF THE ORDER TO

AFFECTED INVESTORS.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 1,238,653.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
THE ORDER, AMONG OTHER THINGS, CENSURED ONIMCO AND ORDERED ONIMCO TO CEASE-AND-DESIST FROM ANY FUTURE VIOLATIONS OF
SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER, AND TO PAY $866,257 IN
DISGORGEMENT, $162,396 IN PREJUDGMENT INTEREST, AND A $210,000 CIVIL MONETARY PENALTY. ONIMCO CONSENTED TO ENTRY OF THE
ORDER WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS (EXCEPT AS TO JURISDICTION AND THE SUBJECT MATTER OF THE ACTION, WHICH
WAS ADMITTED) AND UNDERTOOK TO: REVIEW DISCLOSURES CONCERNING ITS SELECTION PROCESS FOR MUTUAL FUNDS, SHARE CLASSES,
AND CASH SWEEPS; EVALUATE WHETHER TO MOVE CLIENTS TO DIFFERENT MUTUAL FUNDS, SHARE CLASSES, OR CASH SWEEPS; EVALUATE AND
REVIEW FOR EFFECTIVENESS ONIMCO'S COMPLIANCE POLICIES AND PROCEDURES; NOTIFY AFFECTED INVESTORS OF THE TERMS OF THE
ORDER; AND CERTIFY COMPLIANCE WITH ITS UNDERTAKINGS.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE ORDER, AMONG OTHER THINGS, CENSURED ONIMCO AND ORDERED ONIMCO TO CEASE-AND-DESIST FROM ANY FUTURE VIOLATIONS OF
SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER, AND TO PAY $866,257 IN
DISGORGEMENT, $162,396 IN PREJUDGMENT INTEREST, AND A $210,000 CIVIL MONETARY PENALTY. PAYMENT IN PROCESS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE ORDER, AMONG OTHER THINGS, CENSURED ONIMCO AND ORDERED ONIMCO TO CEASE-AND-DESIST FROM ANY FUTURE VIOLATIONS OF SECTIONS
206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER, AND TO PAY $866,257 IN DISGORGEMENT, $162,396 IN
PREJUDGMENT INTEREST, AND A $210,000 CIVIL MONETARY PENALTY. ONIMCO CONSENTED TO ENTRY OF THE ORDER WITHOUT ADMITTING OR
DENYING THE SEC'S FINDINGS (EXCEPT AS TO JURISDICTION AND THE SUBJECT MATTER OF THE ACTION, WHICH WAS ADMITTED) AND UNDERTOOK TO:
REVIEW DISCLOSURES CONCERNING ITS SELECTION PROCESS FOR MUTUAL FUNDS, SHARE CLASSES, AND CASH SWEEPS; EVALUATE WHETHER TO
MOVE CLIENTS TO DIFFERENT MUTUAL FUNDS, SHARE CLASSES, OR CASH SWEEPS; EVALUATE AND REVIEW FOR EFFECTIVENESS ONIMCO'S
COMPLIANCE POLICIES AND PROCEDURES; NOTIFY AFFECTED INVESTORS OF THE TERMS OF THE ORDER; AND CERTIFY COMPLIANCE WITH ITS
UNDERTAKINGS. PRIOR TO THE ENTRY OF THE ORDER, IN MARCH 2017, ONIMCO BEGAN REBATING 12B-1 FEES TO CLIENTS ON A GOINGFORWARD
BASIS. PRIOR TO THE ENTRY OF THE ORDER, ONIMCO AND ITS AFFILIATES IMPLEMENTED REMEDIAL MEASURES INCLUDING CEASING RECEIVING
REVENUE SHARING ON CLIENT ADVISORY ASSETS INVESTED IN MUTUAL FUNDS AND TRANSITIONING ITS CASH SWEEP OPTIONS FOR ITS CLIENTS TO
MONEY MARKET FUNDS THAT DO NOT PAY REVENUE SHARING TO ONIMCO OR ONIMCO'S AFFILIATES, AS WELL AS REVISING DISCLOSURES AS
DESCRIBED IN THE ORDER. THE SEC'S ORDER CAN BE FOUND AT HTTPS://WWW.SEC.GOV/LITIGATION/ADMIN/2022/IA-5944.PDF.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates

One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
JAMES SHELTON
2.
Principal Relief Sought:
Money Damages (Private/Civil Complaint)
Other Relief Sought: 
3.
Filing Date of Court Action (MM/DD/YYYY):
10/15/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
No Product
Other Product Types: 
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
DISTRICT COURT OF DALLAS COUNTY, TX
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
CUSTOMER ALLEGES MISAPPROPRIATION OF FUNDS BY A IAR OF THE FIRM; FIRM IS NAME AS A RESPONDENT.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
10/19/2025
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
12. Resolution Date (MM/DD/YYYY): 

 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
CUSTOMER ALLEGES IAR MISAPPROPRIATED FUNDS, INCLUDING PROCEEDS FROM AN INVESTMENT ADVISORY ACCOUNT(S) HELD BY O.N. INVESTMENT
MANAGEMENT COMPANY WHILE REGISTERED WITH THE FIRM.