Oppenheimer & Co.. Inc..

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:
3208059
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No

Name:
FRIEDRICH, BILL, MICHAEL
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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).

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:
1714280
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GREECHAN, JOSETTE, LEE
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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).

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:
2416301
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GAUSTER, ERIC, ROBERT
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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).

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:
815757
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BEN, LOREN, GARY
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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).

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:
467113
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
WILKES, LAWRENCE, R
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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).

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) 
STATE OF NEVADA, OFFICE OF THE SECRETARY OF STATE, SECURITIES DIVISION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CONSENT AGREEMENT & ORDER IN LIEU OF CEASE AND DESIST PROCEEDINGS
3.
Date Initiated (MM/DD/YYYY): 
11/20/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:

116-116-MCF
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE INVESTIGATION DETERMINED THAT BETWEEN JANUARY 2003 AND NOVEMBER 2015, RESPONDENT FAILED TO COMPLY WITH NAC 90.330, WHICH
REQUIRES THE LICENSUE OF ALL INVESTMENT ADVISOR REPRESENTATIVES ENGAGED IN SECURITIES-RELATED BUSINESS IN OR FROM THE STATE OF
NEVADA.
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:
Consent
11. Resolution Date (MM/DD/YYYY):
11/20/2018
 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: $ 8,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
CONSENT AGREEMENT & ORDER IN LIEU OF CEASE AND DESIST PROCEEDINGS
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: 
CIVIL FINE - $8000.00 AND INVESTIGATIVE FINE - $569.58
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 INVESTIGATION DETERMINED THAT BETWEEN JANUARY 2003 AND NOVEMBER 2015, RESPONDENT FAILED TO COMPLY WITH NAC 90.330, WHICH
REQUIRES THE LICENSUE OF ALL INVESTMENT ADVISOR REPRESENTATIVES ENGAGED IN SECURITIES-RELATED BUSINESS IN OR FROM THE STATE OF
NEVADA.

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:
5195259
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
VANECH, DAVID, C
(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) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY
2.
Principal Sanction:
Suspension
Other Sanctions: 
FINE OF $3,000.00 AND WITHIN 60 DAYS OF THE ACCEPTING OF THE AWC RESPONDENT WILL COMPLETE 10 HOURS OF CONTINUING EDUCATION
THROUGH A PROVIDER NOT UNACCEPTABLE TO FINRA
3.
Date Initiated (MM/DD/YYYY): 
09/17/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2018060817701
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Other
Other Product Types: 
CONTINUING EDUCATION REQUIREMENTS

7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
BETWEEN JANUARY 2014 AND FEBRUARY 2018 MR. VANECH REQUESTED HIS CLIENT SERVICE ASSOCIATE TO COMPLETE CONTINUING EDUCATION
MODULES ON HIS BEHALF, AND DID NOT COMPLETE THIS TRAINING HIMSELF, IN VIOLATION OF FINRA RULE 2010.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
09/19/2019
 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: $ 3,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
MR. VANECH SHALL WITHIN 60 DAYS OF THE ACCEPTANCE OF THE AWC COMPLETE THE TEN HOURS OF CONTINUING EDUCATION THROUGH A
PROVIDER NOT UNACCEPTABLE TO FINRA.
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: 
MR. VANECH IS SUSPENDED FROM ASSOCIATION WITH ANY FINRA FIRM IN ANY CAPACITY FOR THREE MONTHS. THE SANCTIONS IMPOSED SHALL
BE EFFECTIVE ON A DATE SET BY FINRA STAFF.
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).
BETWEEN JANUARY 2014 AND FEBRUARY 2018 MR. VANECH REQUESTED HIS CLIENT SERVICE ASSOCIATE TO COMPLETE CONTINUING EDUCATION
MODULES ON HIS BEHALF, AND DID NOT COMPLETE THIS TRAINING HIMSELF, IN VIOLATION OF FINRA RULE 2010. MR. VANECH WAS SUSPENDED FROM
ASSOCIATION WITH ANY FINRA FIRM IN ANY CAPACITY FOR THREE MONTHS, FINED $3,000 AND MUST COMPLETE TEN HOURS OF CONTINUING
EDUCATION THROUGH A PROVIDER NOT UNACCEPTABLE TO FINRA.

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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
12/30/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2016050948101
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Unit Investment Trust(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN SUPERVISORY PROCEDURES
(WSPS), THAT WERE REASONABLY DESIGNED TO SUPERVISE THE SUITABILITY OF REPRESENTATIVES' RECOMMENDATIONS TO CUSTOMERS AS THEY
PERTAIN TO EARLY ROLLOVERS OF UNIT INVESTMENT TRUSTS (UITS).
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
12/30/2019
 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: $ 800,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
N/A
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 FIRM WAS CENSURED, FINED $800,000, AND ORDERED TO PAY RESTITUTION TO THE CUSTOMERS IN THE TOTAL AMOUNT OF $3,874,206.90
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).
IN RESOLVING THIS MATTER, FINRA HAS RECOGNIZED THE FIRM'S EXTRAORDINARY COOPERATION.

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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
12/20/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2016050508501
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
RECORD NOT HELD TERMS AND CONDITIONS ON ITS ORDER MEMORANDA FOR INSTITUTIONAL CUSTOMERS OF ONE OF THE FIRM'S TRADING DESKS
AND FOR THE SAME ORDERS, IT TRANSMITTED REPORTS TO OATS THAT FAILED TO CONTAIN THAT NOT HELD SPECIAL HANDLING CODE. THE FINDINGS
ALSO INCLUDED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND ESTABLISH, MAINTAIN, AND ENFORCE WSPS
REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES OF FINRA CONCERNING MAINTAINING ACCURATE BOOKS AND RECORDS,
SPECIFICALLY ORDER MEMORANDA.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
12/20/2019
 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: $ 85,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING
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 FIRM WAS CENSURED, FINED $85,000 AND REQUIRED TO REVISE ITS WSPS.
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 FIRM WAS CENSURED, FINED $85,000 AND REQUIRED TO REVISE ITS WSPS.

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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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).

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:
5195259
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
VANECH, DAVID, C
(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) 
STATE OF MASSACHUSETTS
2.
Principal Sanction:
Other
Other Sanctions: 
CONDITIONAL REGISTRATION
3.
Date Initiated (MM/DD/YYYY): 
07/14/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
R-2021-0045

5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
VANECH WAS PREVIOUSLY THE SUBJECT OF A FINRA REGULATORY ACTION AS A RESULT OF ALLOWING HIS CLIENT SERVICE ASSOCIATE AT HIS
MEMBER FIRM COMPLETE HIS FIRM ELEMENT CONTINUING EDUCATION MODULES ON HIS BEHALF. AT THE TIME OF THE PREVIOUS ACTION,
OPPENHEIMER REMOVED VANECH'S MASSACHUSETTS REGISTRATION. NOW, IN ORDER TO RE-REGISTER VANECH, MASSACHUSETTS HAS REQUIRED A
CONSENT ORDER.
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:
Consent
11. Resolution Date (MM/DD/YYYY):
07/14/2021
 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:
FOR A PERIOD OF TWO (2) YEARS FROM THE DATE OF THE ENTRY OF THIS ORDER, HEIGHTENED SUPERVISION OF VANECH MUST, AT A MINIMUM,
INCLUDE THE FOLLOWING: A. FOR ALL OF VANECH'S CONTINUING EDUCATION TRAINING, VANECH MUST NOTIFY HIS SUPERVISOR, AS TO THE
TITLE(S) OF THE CONTINUING EDUCATION TRAINING COMPLETED, THE DATE COMPLETED, AND SUBMIT A SIGNED STATEMENT ATTESTING TO THE
FACT THAT VANECH PERSONALLY COMPLETED THE TRAINING (THE "TRAINING ATTESTATION"). THE TRAINING ATTESTATION MUST BE
MEMORIALIZED IN WRITING AND A COPY MUST BE PLACED INTO VANECH'S PERSONNEL FILE; B. ON AN ANNUAL BASIS, THE COMPLIANCE
DEPARTMENT MUST REVIEW THE TRAINING ATTESTATION(S) SUBMITTED BY VANECH AND INTERNALLY VERIFY VANECH'S CONTINUING EDUCATION
TRAINING WAS COMPLETED PERSONALLY BY VANECH. ALL REVIEWS MUST BE UNDERTAKEN TO DETECT AND PREVENT POTENTIAL SECURITIES
LAW AND OPPENHEIMER POLICY AND PROCEDURE VIOLATIONS AND BE MEMORIALIZED IN WRITING INCLUDING BUT NOT LIMITED TO, THE STEPS
THE COMPLIANCE DEPARTMENT TOOK TO VERIFY THE TRAINING WAS COMPLETED PERSONALLY BY VANECH, THE RESULTS OF THE REVIEW AND
ANY ACTIONS TAKEN. A COPY OF THE REVIEW MUST BE MEMORIALIZED INWRITING BY THE COMPLIANCE DEPARTMENT; AND C. THE COMPLIANCE
DEPARTMENT'S ANNUAL AUDIT OF THE BRANCH OFFICE MUST OCCUR AT THE BRANCH OFFICE, TO THE EXTENT POSSIBLE DUE TO DIFFICULTIES
ARISING FROM THE COVID-19PANDEMIC, AND MUST INCLUDE A MANDATORY REVIEW OF VANECH'S CONTINUING EDUCATION REQUIREMENTS
AND TRAINING ATTESTATION(S) IN VANECH'S PERSONNEL FILE. ALL REVIEWS MUST BE UNDERTAKEN TO DETECT AND PREVENT POTENTIAL
SECURITIES LAW AND OPPENHEIMER POLICY AND PROCEDURE VIOLATIONS AND BE MEMORIALIZED IN WRITING INCLUDING BUT NOT LIMITED
TO, TITLE(S) OF TRAINING COMPLETED, DATE COMPLETED, THE COMPLIANCE DEPARTMENT'S VERIFICATION THAT THE TRAINING WAS
COMPLETED PERSONALLY BY VANECH, AND WHETHER A CORRESPONDING TRAINING ATTESTATION WAS LOCATED IN VANECH'S PERSONNEL FILE.
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: 
FOR A PERIOD OF TWO (2) YEARS FROM THE DATE OF THE ENTRY OF THIS ORDER, HEIGHTENED SUPERVISION OF VANECH MUST, AT A MINIMUM,
INCLUDE THE FOLLOWING: A. FOR ALL OF VANECH'S CONTINUING EDUCATION TRAINING, VANECH MUST NOTIFY HIS SUPERVISOR, AS TO THE
TITLE(S) OF THE CONTINUING EDUCATION TRAINING COMPLETED, THE DATE COMPLETED, AND SUBMIT A SIGNED STATEMENT ATTESTING TO THE
FACT THAT VANECH PERSONALLY COMPLETED THE TRAINING (THE "TRAINING ATTESTATION"). THE TRAINING ATTESTATION MUST BE
MEMORIALIZED IN WRITING AND A COPY MUST BE PLACED INTO VANECH'S PERSONNEL FILE; B. ON AN ANNUAL BASIS, THE COMPLIANCE
DEPARTMENT MUST REVIEW THE TRAINING ATTESTATION(S) SUBMITTED BY VANECH AND INTERNALLY VERIFY VANECH'S CONTINUING EDUCATION
TRAINING WAS COMPLETED PERSONALLY BY VANECH. ALL REVIEWS MUST BE UNDERTAKEN TO DETECT AND PREVENT POTENTIAL SECURITIES
LAW AND OPPENHEIMER POLICY AND PROCEDURE VIOLATIONS AND BE MEMORIALIZED IN WRITING INCLUDING BUT NOT LIMITED TO, THE STEPS
THE COMPLIANCE DEPARTMENT TOOK TO VERIFY THE TRAINING WAS COMPLETED PERSONALLY BY VANECH, THE RESULTS OF THE REVIEW AND
ANY ACTIONS TAKEN. A COPY OF THE REVIEW MUST BE MEMORIALIZED INWRITING BY THE COMPLIANCE DEPARTMENT; AND C. THE COMPLIANCE
DEPARTMENT'S ANNUAL AUDIT OF THE BRANCH OFFICE MUST OCCUR AT THE BRANCH OFFICE, TO THE EXTENT POSSIBLE DUE TO DIFFICULTIES
ARISING FROM THE COVID-19PANDEMIC, AND MUST INCLUDE A MANDATORY REVIEW OF VANECH'S CONTINUING EDUCATION REQUIREMENTS
AND TRAINING ATTESTATION(S) IN VANECH'S PERSONNEL FILE. ALL REVIEWS MUST BE UNDERTAKEN TO DETECT AND PREVENT POTENTIAL

( )
SECURITIES LAW AND OPPENHEIMER POLICY AND PROCEDURE VIOLATIONS AND BE MEMORIALIZED IN WRITING INCLUDING BUT NOT LIMITED
TO, TITLE(S) OF TRAINING COMPLETED, DATE COMPLETED, THE COMPLIANCE DEPARTMENT'S VERIFICATION THAT THE TRAINING WAS
COMPLETED PERSONALLY BY VANECH, AND WHETHER A CORRESPONDING TRAINING ATTESTATION WAS LOCATED IN VANECH'S PERSONNEL FILE.
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).
TWO YEARS AFTER THE DATE OF ENTRY OF THE ORDER, VANECH WILL SUBMIT AN AFFIDAVIT STATING THAT HE HAS FULLY COMPLIED WITH ALL
CONDITIONS OF THE ORDER. REGISTRATION CONDITIONS APPLIED TO VANECH'S AGENT REGISTRATION IN MASSACHUSETTS DUE TO DISCLOSURES

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:
4137948
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HURTADO, CESAR, AUGUSTO
(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) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY
2.
Principal Sanction:
Suspension
Other Sanctions: 
CIVIL AND ADMINISTRATIVE PENALTY; UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
08/06/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2017055890901
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Options
Other Product Types: 
OIL & GAS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, HURTADO CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE
RECOMMENDED AND EFFECTED UNSUITABLE PUT SPREAD INVESTMENT STRATEGIES IN THE ACCOUNTS OF TWO CUSTOMERS. THE FINDINGS STATED
THAT THIS MATTER AROSE FROM THE FILING OF A UNIFORM APPLICATION FOR SECURITIES INDUSTRY REGISTRATION OR TRANSFER FORM (FORM U4)
THAT DISCLOSED CUSTOMER COMPLAINTS REGARDING HURTADO'S CONDUCT. THE FINDINGS ALSO STATED THAT HURTADO UNDERSTOOD THAT PUT
SPREADS ARE DESIGNED AS A RISK-CONTAINMENT STRATEGY AND RECOMMENDED SUCH INVESTMENTS, HOWEVER, WITH CERTAIN PUT SPREAD
TRANSACTIONS, HE RECOMMENDED THAT THE CUSTOMERS FOREGO THIS RISK MITIGATION MECHANISM. THE FINDINGS ALSO STATED THAT IN MANY
INSTANCES, AFTER THE CUSTOMER HELD THE SECURITY FOR A PERIOD OF TIME, HURTADO RECOMMENDED THAT THE CUSTOMER SELL THE SECURITY
AT A LOSS LARGER THAN THE ORIGINAL PUT SPREAD'S MAXIMUM LOSS. THE FINDINGS ALSO STATED THAT HURTADO ALSO MAGNIFIED THE RISK OF
NUMEROUS PUT SPREAD TRANSACTIONS, AND SUBSEQUENT ASSIGNMENTS, BY RECOMMENDING THAT THE TWO CUSTOMERS FUND ASSIGNMENTS ON
MARGIN, THUS INCREASING RISK BY EXPOSING THE ACCOUNT TO MARGIN CALLS AND BY REQUIRING THE CUSTOMER TO PAY INTEREST ON THE MARGIN
LOAN. THE FINDINGS ALSO STATED THAT BOTH ACCOUNTS SAW INDIVIDUAL ASSIGNMENTS OF NEARLY $1 MILLION FUNDED ON MARGIN. THE FINDINGS
ALSO STATED THAT HURTADO ALSO RECOMMENDED THAT THE CUSTOMERS OVER-CONCENTRATE THEIR OPTIONS INVESTMENTS IN THE ENERGY
SECTOR, FURTHER INCREASING THE RISK OF LOSS ONCE THE CUSTOMERS TOOK ASSIGNMENT OF THE SUBJECT SECURITIES. THE FINDINGS ALSO
STATED THAT HURTADO'S RECOMMENDATIONS CAUSED APPROXIMATELY $1.6 MILLION IN NET LOSSES FOR THE TWO CUSTOMERS. THE FINDINGS ALSO
STATED THAT BOTH CUSTOMERS SETTLED CLAIMS AGAINST HURTADO'S MEMBER FIRM IN CONNECTION WITH HIS CONDUCT FOR A TOTAL AMOUNT OF
$560,000, TO WHICH HURTADO PERSONALLY CONTRIBUTED $280,000.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
08/06/2021
 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: $ 5,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
HURTADO WILL ATTEND AND SATISFACTORILY COMPLETE 10 HOURS OF CONTINUING EDUCATION CONCERNING OPTIONS TRADING AND

CUSTOMER SUITABILITY, BY A PROVIDER NOT UNACCEPTABLE TO FINRA.
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: 
SUSPENDED IN ALL CAPACITIES FOR 45 DAYS, BEGINNING SEPT 7, 2021 AND ENDING OCTOBER 21, 2021.
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).
WITHOUT ADMITTING OR DENYING THE FINDINGS, HURTADO CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE
RECOMMENDED AND EFFECTED UNSUITABLE PUT SPREAD INVESTMENT STRATEGIES IN THE ACCOUNTS OF TWO CUSTOMERS. THE FINDINGS STATED
THAT THIS MATTER AROSE FROM THE FILING OF A UNIFORM APPLICATION FOR SECURITIES INDUSTRY REGISTRATION OR TRANSFER FORM (FORM U4)
THAT DISCLOSED CUSTOMER COMPLAINTS REGARDING HURTADO'S CONDUCT. THE FINDINGS ALSO STATED THAT HURTADO UNDERSTOOD THAT PUT
SPREADS ARE DESIGNED AS A RISK-CONTAINMENT STRATEGY AND RECOMMENDED SUCH INVESTMENTS, HOWEVER, WITH CERTAIN PUT SPREAD
TRANSACTIONS, HE RECOMMENDED THAT THE CUSTOMERS FOREGO THIS RISK MITIGATION MECHANISM. THE FINDINGS ALSO STATED THAT IN MANY
INSTANCES, AFTER THE CUSTOMER HELD THE SECURITY FOR A PERIOD OF TIME, HURTADO RECOMMENDED THAT THE CUSTOMER SELL THE SECURITY
AT A LOSS LARGER THAN THE ORIGINAL PUT SPREAD'S MAXIMUM LOSS. THE FINDINGS ALSO STATED THAT HURTADO ALSO MAGNIFIED THE RISK OF
NUMEROUS PUT SPREAD TRANSACTIONS, AND SUBSEQUENT ASSIGNMENTS, BY RECOMMENDING THAT THE TWO CUSTOMERS FUND ASSIGNMENTS ON
MARGIN, THUS INCREASING RISK BY EXPOSING THE ACCOUNT TO MARGIN CALLS AND BY REQUIRING THE CUSTOMER TO PAY INTEREST ON THE MARGIN
LOAN. THE FINDINGS ALSO STATED THAT BOTH ACCOUNTS SAW INDIVIDUAL ASSIGNMENTS OF NEARLY $1 MILLION FUNDED ON MARGIN. THE FINDINGS
ALSO STATED THAT HURTADO ALSO RECOMMENDED THAT THE CUSTOMERS OVER-CONCENTRATE THEIR OPTIONS INVESTMENTS IN THE ENERGY
SECTOR, FURTHER INCREASING THE RISK OF LOSS ONCE THE CUSTOMERS TOOK ASSIGNMENT OF THE SUBJECT SECURITIES. THE FINDINGS ALSO
STATED THAT HURTADO'S RECOMMENDATIONS CAUSED APPROXIMATELY $1.6 MILLION IN NET LOSSES FOR THE TWO CUSTOMERS. THE FINDINGS ALSO
STATED THAT BOTH CUSTOMERS SETTLED CLAIMS AGAINST HURTADO'S MEMBER FIRM IN CONNECTION WITH HIS CONDUCT FOR A TOTAL AMOUNT OF
$560,000, TO WHICH HURTADO PERSONALLY CONTRIBUTED $280,000.

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:
1540292
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MICHIENZI, ANDREW
(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) 
MASSACHUSETTS
2.
Principal Sanction:
Undertaking
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/24/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
R-2022-0030
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
MORGAN STANLEY
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
GIVEN THE FACTS AND CIRCUMSTANCES SURROUNDING MICHIENZI'S APRIL 2021 TERMINATION FROM MORGAN STANLEY, THE MASSACHUSETTS
SECURITIES DIVISION ALLOWED MICHIENZI'S REGISTRATION AS AN INVESTMENT ADVISER REPRESENTATIVE IN MASSACHUSETTS AND ALLOWED HIS
CONTINUED REGISTRATION AS A BROKER-DEALER AGENT IN MASSACHUSETTS PURSUANT TO A TWO (2) YEAR PLAN OF HEIGHTENED SUPERVISION.
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:
Consent
11. Resolution Date (MM/DD/YYYY):
05/24/2022
 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:
GIVEN THE FACTS AND CIRCUMSTANCES SURROUNDING MICHIENZI'S APRIL 2021 TERMINATION FROM MORGAN STANLEY, THE MASSACHUSETTS
SECURITIES DIVISION ALLOWED MICHIENZI'S REGISTRATION AS AN INVESTMENT ADVISER REPRESENTATIVE IN MASSACHUSETTS AND ALLOWED
HIS CONTINUED REGISTRATION AS A BROKER-DEALER AGENT IN MASSACHUSETTS PURSUANT TO A TWO (2) YEAR PLAN OF HEIGHTENED
SUPERVISION.
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: 
NOT APPLICABLE
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).
GIVEN THE FACTS AND CIRCUMSTANCES SURROUNDING MICHIENZI'S APRIL 2021 TERMINATION FROM MORGAN STANLEY, THE MASSACHUSETTS
SECURITIES DIVISION ALLOWED MICHIENZI'S REGISTRATION AS AN INVESTMENT ADVISER REPRESENTATIVE IN MASSACHUSETTS AND ALLOWED HIS
CONTINUED REGISTRATION AS A BROKER-DEALER AGENT IN MASSACHUSETTS PURSUANT TO A TWO (2) YEAR PLAN OF HEIGHTENED SUPERVISION.

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:
5059630
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
PEJOUHESH, ARIYA
(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) 
FINRA
2.
Principal Sanction:
Suspension
Other Sanctions: 
$10,000 FINE.
3.
Date Initiated (MM/DD/YYYY): 
07/07/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2022075178601
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
MORGAN STANLEY
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, PEJOUHESH CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE IMPROPERLY
DIRECTED AND ALLOWED HIS INTERN AT HIS MEMBER FIRM TO COMPLETE 14 HOURS OF CONTINUING EDUCATION (CE) COURSES RELATED TO
PEJOUHESH'S CERTIFIED FINANCIAL PLANNER (CFP) DESIGNATION ON HIS BEHALF, RATHER THAN COMPLETING THEM HIMSELF AFTER HIS CFP
CERTIFICATION WAS DEEMED RELINQUISHED DUE TO, AMONG OTHER THINGS, HIS FAILURE TO COMPLETE REQUIRED CE.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
07/07/2023
 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: $ 10,000.00
 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: 
SUSPENDED FROM 8/7/2023 THROUGH 9/6/2023 IN ALL REGISTERED CAPACITIES.
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).
WITHOUT ADMITTING OR DENYING THE FINDINGS, PEJOUHESH CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE IMPROPERLY
DIRECTED AND ALLOWED HIS INTERN AT HIS MEMBER FIRM TO COMPLETE 14 HOURS OF CONTINUING EDUCATION (CE) COURSES RELATED TO
PEJOUHESH'S CERTIFIED FINANCIAL PLANNER (CFP) DESIGNATION ON HIS BEHALF, RATHER THAN COMPLETING THEM HIMSELF AFTER HIS CFP
CERTIFICATION WAS DEEMED RELINQUISHED DUE TO, AMONG OTHER THINGS, HIS FAILURE TO COMPLETE REQUIRED CE.

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:
6887787
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HANEY, SOPHIA, ELENA
(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) 
DISTRICT OF COLUMBIA DEPARTMENT OF INSURANCE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/21/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NONE
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Insurance
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE LICENSEE UNKNOWINGLY ENGAGED IN THE BUSINESS OF INSURANCE DURING THE PERIOD THE LICENSEE'S PRODUCER LICENSE LAPSED BY
SELLING INSURANCE AND RECEIVING COMMISSIONS (4/30/23-6/6/23). THE LICENSEE SHALL PAY A FINE TO THE DEPARTMENT IN THE AMOUNT OF
$250.00
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:
Order
11. Resolution Date (MM/DD/YYYY):
08/21/2023
 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: $ 250.00
 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: 
CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S). MONETARY/FINE AMOUNT OF $250.00
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 LICENSEE UNKNOWINGLY ENGAGED IN THE BUSINESS OF INSURANCE DURING THE PERIOD THE LICENSEE'S PRODUCER LICENSE LAPSED BY
SELLING INSURANCE AND RECEIVING COMMISSIONS (4/30/23-6/6/23). THE LICENSEE SHALL PAY A FINE TO THE DEPARTMENT IN THE AMOUNT OF
$250.00

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:
4137948
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
HURTADO, CESAR, AUGUSTO
(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) 
FLORIDA DEPARTMENT OF FINANCIAL SERVICES
2.
Principal Sanction:
Suspension
Other Sanctions: 

3.
Date Initiated (MM/DD/YYYY): 
03/23/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
307114-23-AG
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON 3/23/2023, FLORIDA DEPARTMENT OF FINANCIAL SERVICES ENTERED AN ORDER OF SUSPENSION FOR A PERIOD OF FORTY-FIVE DAYS. DURING THE
SUSPENSION OF THE LICENSE OR APPOINTMENTS AND UNTIL THE LICENSE IS REINSATED, THE RESPONDENT SHALL NOT ENGAGE IN OR ATTEMPT OR
PROFESS TO ENGAGE IN ANY TRANSACTION OR BUSINESS FOR WHICH A LICENSE OR APPOINTMENT IS REQUIRED.
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:
Order
11. Resolution Date (MM/DD/YYYY):
03/23/2023
 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: 
SUSPENSION OF 45 DAYS. START DATE: 3/23/2023; END DATE: 5/6/2023
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).
ON 3/23/2023, FLORIDA DEPARTMENT OF FINANCIAL SERVICES ENTERED AN ORDER OF SUSPENSION FOR A PERIOD OF FORTY-FIVE DAYS. DURING THE
SUSPENSION OF THE LICENSE OR APPOINTMENTS AND UNTIL THE LICENSE IS REINSATED, THE RESPONDENT SHALL NOT ENGAGE IN OR ATTEMPT OR
PROFESS TO ENGAGE INANY TRANSACTION OR BUSINESS FOR WHICH A LICENSE OR APPOINTMENT IS REQUIRED.

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) 
CBOE EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
09/07/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. URE-146-01/STAR NO. 20200685197
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Options
Other Product Types: 

7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
OPPENHEIMER & CO. INC VIOLATED CBOE RULES 4.24 AND 8.16 IN THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WSPS REASONABLY
DESIGNED TO ENSURE COMPLIANCE WITH EXCHANGE LOPR RULES.
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:
Consent
11. Resolution Date (MM/DD/YYYY):
09/14/2023
 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: $ 450,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
AN UNDERTAKING DETAILED IN THE LETTER OF CONSENT
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: 
A CENSURE, A MONETARY FINE IN THE AMOUNT OF $450,000 AND AN UNDERTAKING DETAILED IN THE LETTER OF CONSENT.
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).
OPPENHEIMER & CO. INC VIOLATED CBOE RULES 4.24 AND 8.16 IN THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WSPS REASONABLY
DESIGNED TO ENSURE COMPLIANCE WITH EXCHANGE LOPR RULES. A CENSURE, A MONETARY FINE IN THE AMOUNT OF $450,000 AND AN
UNDERTAKING DETAILED IN THE LETTER OF CONSENT.

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:
1263265
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
VATTEROTT, DANIEL, HERNAN
(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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
12/04/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2021070570001
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
MORGAN STANLEY
6.
Principal Product Type:
No Product
Other Product Types: 
N/A
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, VATTEROTT CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE CAUSED HIS
MEMBER FIRM TO MAINTAIN INACCURATE BOOKS AND RECORDS BY FALSIFYING THE REPRESENTATIVE CODE FOR TRADES IN HIS FIRM'S ORDER ENTRY
SYSTEM, CAUSING THE TRADE CONFIRMATIONS TO SHOW AN INACCURATE REPRESENTATIVE CODE. THE FINDINGS STATED THAT VATTEROTT ENTERED
INTO AN AGREEMENT THROUGH WHICH HE AGREED TO SERVICE CERTAIN CUSTOMER ACCOUNTS, INCLUDING EXECUTING TRADES FOR THOSE
ACCOUNTS, UNDER A JOINT REPRESENTATIVE CODE THAT HE SHARED WITH THE ESTATE OF A FORMER REPRESENTATIVE. THE AGREEMENT SET FORTH
WHAT PERCENTAGES OF THE COMMISSIONS VATTEROTT AND THE FORMER REPRESENTATIVE'S ESTATE EARNED ON TRADES PLACED USING THE JOINT
REPRESENTATIVE CODE. VATTEROTT PLACED TRADES IN ACCOUNTS THAT WERE COVERED BY THE AGREEMENT USING A REPRESENTATIVE CODE OTHER
THAN THE ONE HE SHOULD HAVE USED. SPECIFICALLY, ALTHOUGH HIS FIRM'S SYSTEM CORRECTLY PREPOPULATED THE TRADES WITH THE JOINT
REPRESENTATIVE CODE VATTEROTT SHARED WITH THE REPRESENTATIVE'S ESTATE PURSUANT TO THE JOINT PRODUCTION AGREEMENT, VATTEROTT

ENTERED THE TRANSACTIONS UNDER A DIFFERENT REPRESENTATIVE CODE. VATTEROTT CHANGED THE CODES BECAUSE HE MISTAKENLY BELIEVED
THAT THE JOINT PRODUCTION AGREEMENT DID NOT APPLY TO NEW ASSETS ADDED TO ACCOUNTS SUBJECT TO THE AGREEMENT AND THAT HE WAS
AUTHORIZED TO ENTER THE TRADES USING THE OTHER REPRESENTATIVE CODE. HOWEVER, VATTEROTT DID NOT DO ANYTHING TO CONFIRM HIS
UNDERSTANDING, SUCH AS ASKING THE ESTATE WHETHER HE COULD CHANGE THE REPRESENTATIVE CODES ON THE TRADES AT ISSUE OR SPEAKING
WITH HIS FIRM TO VERIFY WHETHER THE TRANSACTIONS AT ISSUE WERE SUBJECT TO THE JOINT PRODUCTION AGREEMENT. AFTER VATTEROTT'S FIRM
PAID RESTITUTION TO THE REPRESENTATIVE'S ESTATE, VATTEROTT REIMBURSED THE FIRM APPROXIMATELY $87,500, WHICH IS THE APPROXIMATE
AMOUNT OF THE ADDITIONAL COMMISSION THAT HE RECEIVED AS A RESULT OF CHANGING THE REPRESENTATIVE CODE ON THE TRADES.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
12/04/2023
 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: $ 5,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S)
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: 
SUSPENSION FOR 6 MONTHS IN ALL REGISTRATION CAPACITIES. START DATE: 01/02/2024. END DATE: 07/01/2024.
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).
WITHOUT ADMITTING OR DENYING THE FINDINGS, VATTEROTT CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE CAUSED HIS
MEMBER FIRM TO MAINTAIN INACCURATE BOOKS AND RECORDS BY FALSIFYING THE REPRESENTATIVE CODE FOR TRADES IN HIS FIRM'S ORDER ENTRY
SYSTEM, CAUSING THE TRADE CONFIRMATIONS TO SHOW AN INACCURATE REPRESENTATIVE CODE. THE FINDINGS STATED THAT VATTEROTT ENTERED
INTO AN AGREEMENT THROUGH WHICH HE AGREED TO SERVICE CERTAIN CUSTOMER ACCOUNTS, INCLUDING EXECUTING TRADES FOR THOSE
ACCOUNTS, UNDER A JOINT REPRESENTATIVE CODE THAT HE SHARED WITH THE ESTATE OF A FORMER REPRESENTATIVE. THE AGREEMENT SET FORTH
WHAT PERCENTAGES OF THE COMMISSIONS VATTEROTT AND THE FORMER REPRESENTATIVE'S ESTATE EARNED ON TRADES PLACED USING THE JOINT
REPRESENTATIVE CODE. VATTEROTT PLACED TRADES IN ACCOUNTS THAT WERE COVERED BY THE AGREEMENT USING A REPRESENTATIVE CODE OTHER
THAN THE ONE HE SHOULD HAVE USED. SPECIFICALLY, ALTHOUGH HIS FIRM'S SYSTEM CORRECTLY PREPOPULATED THE TRADES WITH THE JOINT
REPRESENTATIVE CODE VATTEROTT SHARED WITH THE REPRESENTATIVE'S ESTATE PURSUANT TO THE JOINT PRODUCTION AGREEMENT, VATTEROTT
ENTERED THE TRANSACTIONS UNDER A DIFFERENT REPRESENTATIVE CODE. VATTEROTT CHANGED THE CODES BECAUSE HE MISTAKENLY BELIEVED
THAT THE JOINT PRODUCTION AGREEMENT DID NOT APPLY TO NEW ASSETS ADDED TO ACCOUNTS SUBJECT TO THE AGREEMENT AND THAT HE WAS
AUTHORIZED TO ENTER THE TRADES USING THE OTHER REPRESENTATIVE CODE. HOWEVER, VATTEROTT DID NOT DO ANYTHING TO CONFIRM HIS
UNDERSTANDING, SUCH AS ASKING THE ESTATE WHETHER HE COULD CHANGE THE REPRESENTATIVE CODES ON THE TRADES AT ISSUE OR SPEAKING
WITH HIS FIRM TO VERIFY WHETHER THE TRANSACTIONS AT ISSUE WERE SUBJECT TO THE JOINT PRODUCTION AGREEMENT. AFTER VATTEROTT'S FIRM
PAID RESTITUTION TO THE REPRESENTATIVE'S ESTATE, VATTEROTT REIMBURSED THE FIRM APPROXIMATELY $87,500, WHICH IS THE APPROXIMATE
AMOUNT OF THE ADDITIONAL COMMISSION THAT HE RECEIVED AS A RESULT OF CHANGING THE REPRESENTATIVE CODE ON THE TRADES. MATTER
RESOLVED 12/04/2023 BY AWC. CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S) OF $5,000. SUSPENSION FOR 6 MONTHS IN ALL REGISTRATION
CAPACITIES. SUSPENSION START DATE: 01/02/2024. END DATE: 07/01/2024.

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:
1263265
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
VATTEROTT, DANIEL, HERNAN
(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) 
STATE OF MISSOURI
2.
Principal Sanction:
Suspension
Other Sanctions: 
MONETARY PENALTY OTHER THAN FINES
3.
Date Initiated (MM/DD/YYYY): 
03/28/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AP-24-05
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

OPPENHEIMER & CO. INC.
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE ENFORCEMENT SECTION OF THE MISSOURI SECURITIES DIVISION ALLEGES AN ACTION THAT CONSTITUTES SUFFICIENT GROUNDS TO DISCIPLINE
RESPONDENT IN ACCORDANCE WITH SECTIONS 409.4-412(B) AND (C).
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:
Consent
11. Resolution Date (MM/DD/YYYY):
03/28/2024
 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: $ 4,000.00
 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: 
SUSPENSION IN ALL CAPACITIES FOR 3 MONTHS 3 DAYS. SUSPENSION START DATE: 3/28/2024. SUSPENSION END DATE: 7/1/2024. CONSENT
ORDER WAS ISSUED ON 3/28/2024 AND MONETARY FINE WAS PAID IN FULL AS OF 3/28/2024.
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 ENFORCEMENT SECTION OF THE MISSOURI SECURITIES DIVISION ALLEGES AN ACTION THAT CONSTITUTES SUFFICIENT GROUNDS TO DISCIPLINE
RESPONDENT IN ACCORDANCE WITH SECTIONS 409.4-412(B) AND (C). SUSPENSION IN ALL CAPACITIES FOR 3 MONTHS 3 DAYS. SUSPENSION START
DATE: 3/28/2024. SUSPENSION END DATE: 7/1/2024. CONSENT ORDER WAS ISSUED ON 3/28/2024 AND $4,000 MONETARY FINE WAS PAID IN FULL AS
OF 3/28/2024.

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) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/29/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2013037792401
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
SECURITIZED PRODUCTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
REPORT THE CORRECT TIME OF TRADE EXECUTIONS FOR TRANSACTIONS IN TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)-ELIGIBLE
SECURITIZED PRODUCTS AND FAILED TO SHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDA OF BROKERAGE ORDERS.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
10/29/2014
 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: $ 10,000.00
 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 FIRM WAS CENSURED AND FINED $10,000
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).

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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
01/06/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2011025957001
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
ESTABLISH AND MAINTAIN AN ADEQUATE SYSTEM TO MONITOR, SUPERVISE, AND CONTROL ITS EXTENSION OF MARGIN LOANS FOR FOREIGN
SOVEREIGN DEBT. THE FINDINGS STATED THAT THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) DID NOT ADDRESS HOW TO ASSESS THE
RISKS OF EXTENDING MARGIN CREDIT FOR FOREIGN SOVEREIGN BONDS. THE FIRM FAILED TO DEDICATE SUFFICIENT SUPERVISORY RESOURCES TO
MONITORING THE RISK OF HOLDING BELOW-INVESTMENT-GRADE FOREIGN SOVEREIGN BONDS AND FAILED TO TAKE SUFFICIENT STEPS TO ASSESS
WHETHER A READY MARKET EXISTED FOR BELOW-INVESTMENT-GRADE FOREIGN SOVEREIGN BONDS. THE FINDINGS ALSO STATED THAT THE FIRM
FAILED TO REASONABLY SUPERVISE THE TRANSFER OF ASSETS SECURING A MARGIN LOAN FROM ONE PARTY TO ANOTHER.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
01/06/2015
 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: $ 250,000.00
 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 FIRM IS CENSURED AND FINED $250,000.
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).

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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
03/26/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2009017408102
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
UNSPECIFIED SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
SUPERVISE ITS REGISTERED REPRESENTATIVE WHO MISAPPROPRIATED FUNDS FROM HIS CUSTOMERS AND EXCESSIVELY TRADED THEIR ACCOUNT.
FINRA BARRED THE REPRESENTATIVE FOR, AMONG OTHER THINGS, STEALING APPROXIMATELY $6 MILLION FROM HIS CUSTOMERS AND EXCESSIVELY
TRADING AND CHURNING HIS CUSTOMERS' ACCOUNTS, IN WILLFUL VIOLATION OF SECTION 10(B) OF THE SECURITIES EXCHANGE ACT AND RULE 10B-
5 THEREUNDER. THE FINDINGS STATED THAT THE FIRM FAILED TO CONDUCT AN ADEQUATE PRE-HIRE INVESTIGATION OF THE REPRESENTATIVE AND
FAILED TO PLACE HIM ON HEIGHTENED SUPERVISION. THE FIRM FAILED TO INVESTIGATE THE CIRCUMSTANCES OF THE TWELVE DISCLOSURES THAT
APPEARED IN HIS CRD RECORD OR SUBJECT HIM TO HEIGHTENED SUPERVISION. WHEN THE REPRESENTATIVE JOINED THE FIRM, HIS CRD RECORD
REPORTABLE EVENTS INCLUDED CRIMINAL CHARGES INVOLVING LARCENY OR POSSESSION OF STOLEN PROPERTY, A TERMINATION FOR CAUSE, A NEW
YORK STOCK EXCHANGE INVESTIGATION, A PERSONAL BANKRUPTCY, AND CUSTOMER COMPLAINTS THAT WITH ALLEGED UNAUTHORIZED TRADING. THE
FINDINGS ALSO STATED THAT THE FIRM FAILED TO SUPERVISE THE REPRESENTATIVE. THE FIRM WAS MADE AWARE THAT HE WAS ENGAGED IN
UNDISCLOSED OUTSIDE BUSINESS ACTIVITIES, AND FAILED TO MONITOR OR IDENTIFY NUMEROUS RED FLAGS DEMONSTRATING THAT HE AND/OR ITS
CUSTOMERS WERE WIRING CUSTOMER FUNDS TO ACCOUNTS HE CONTROLLED. THE FIRM FAILED TO PLACE HIM ON HEIGHTENED SUPERVISION AFTER
IT BECAME AWARE OF SERIOUS ALLEGATIONS OF FRAUD AND DECEIT THAT HE SETTLED FOR $3 MILLION. THE FIRM FAILED TO TAKE ACTION TO
RESTRICT HIS TRADING IN CUSTOMER ACCOUNTS AFTER ITS INTERNAL ANALYSIS SHOWED THAT HE WAS TRADING MULTIPLE CUSTOMER ACCOUNTS AT
LEVELS CONSIDERED PRESUMPTIVELY EXCESSIVE. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO MAINTAIN POLICIES AND PROCEDURES
CAPABLE OF DETECTING AND PREVENTING CERTAIN POTENTIALLY FRAUDULENT THIRD PARTY WIRES, INCLUDING WIRES BETWEEN ITS CUSTOMERS'
ACCOUNTS AND ITS REGISTERED REPRESENTATIVES OR THEIR OUTSIDE BUSINESS ACTIVITIES. FINRA FOUND THAT FOR OVER THREE YEARS THE FIRM'S
PROCEDURES RELATED TO EXCESSIVE TRADING WERE UNREASONABLE BECAUSE THEY DID NOT PROVIDE FOR SPECIFIC ACTION TO BE TAKEN WHEN
TRADING ACTIVITY WAS UNSUITABLE FOR ANY CUSTOMER OR WHEN CUSTOMER ACCOUNTS REPEATEDLY TRIGGERED THE FIRM'S EXCEPTION REPORTS.
THE FIRM'S INADEQUATE PROCEDURES RELATED TO EXCESSIVE TRADING CONTRIBUTED TO ITS FAILURE TO REASONABLY SUPERVISE ITS
REPRESENTATIVE. FINRA ALSO FOUND THAT THE FIRM, THROUGH ITS LEGAL DEPARTMENT, FAILED TO TIMELY MAKE 320 REQUIRED UPDATES RELATED
TO ARBITRATIONS AND OTHER LEGAL MATTERS ON FORMS U4 AND U5 FILINGS. AS A RESULT, REGULATORS, THE INVESTING PUBLIC, AND OTHER
MEMBER FIRMS WERE UNAWARE OF SERIOUS ALLEGATIONS MADE AGAINST THE FIRM'S CURRENT AND FORMER REGISTERED REPRESENTATIVES,
INCLUDING THIS PARTICULAR REPRESENTATIVE. MOREOVER, PERSONNEL IN THE FIRM'S LEGAL DEPARTMENT WERE AWARE THAT THE DEPARTMENT
WAS NOT MAKING TIMELY FILINGS. THE FIRM'S LEGAL DEPARTMENT ALSO CONTINUED TO FAIL TO MAKE CERTAIN REQUIRED FILINGS EVEN AFTER IT
WAS PUT ON NOTICE OF THE NECESSITY OF MAKING SPECIFIC FILINGS BY FINRA. THE FIRM FAILED TO MAINTAIN OR IMPLEMENT SUPERVISORY
PROCEDURES RELATED TO FILING U4 AND U5 AMENDMENTS. IN ADDITION, FINRA DETERMINED THAT THE FIRM FAILED TO TIMELY RESPOND TO FINRA'S
REQUESTS FOR DOCUMENTS AND INFORMATION RELATED TO THE REPRESENTATIVE AND THE FIRM'S SUPERVISION OF THE REPRESENTATIVE.
MOREOVER, FINRA FOUND THAT THE FIRM FAILED TO MAINTAIN IN A READILY ACCESSIBLE FORMAT ITS RECORDS OF ITS SUPERVISORS' REVIEWS OF
THE REPRESENTATIVE'S EMAILED CORRESPONDENCE. AS A RESULT, THE FIRM FAILED TO PRODUCE RECORDS REFLECTING THE SUPERVISORY REVIEW
OF ITS REPRESENTATIVE'S EMAILS UNTIL MORE THAN TWO YEARS AFTER THEY WERE ORIGINALLY REQUESTED BY FINRA, AND AFTER ORIGINALLY
REPRESENTING TO FINRA THAT IT DID NOT MAINTAIN THE RECORDS.
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:
Acceptance, Waiver & Consent(AWC)

11. Resolution Date (MM/DD/YYYY):
03/26/2015
 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: $ 2,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS; THE FIRM UNDERSTANDS THAT THIS SETTLEMENT INCLUDES A FINDING THAT IT FAILED TO SUPERVISE AN INDIVIDUAL WHO
VIOLATED SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND THAT UNDER ARTICLE III, SECTION 4 OF FINRA'S BY-LAWS, THIS
MAKES THE FIRM SUBJECT TO A STATUTORY DISQUALIFICATION WITH RESPECT TO MEMBERSHIP.
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 FIRM IS CENSURED, FINED $2,500,000, ORDERED TO PAY $1,251,076.10 IN RESTITUTION TO CUSTOMERS AND REQUIRED TO RETAIN AN
INDEPENDENT CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF THE FIRM'S SUPERVISORY POLICIES, SYSTEMS AND
PROCEDURES (WRITTEN AND OTHERWISE) AND TRAINING RELATING TO WIRE TRANSFERS, FORM U4/U5 REPORTING, AND EXCESSIVE TRADING
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).

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:
140485
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
OPPENHEIMER ALTERNATIVE
INVESTMENT MANAGEMENT,
LLC
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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).

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: 
3.
Date Initiated (MM/DD/YYYY): 
01/27/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-16361
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Penny Stock(s)
Other Product Types: 
UNREGISTERED DISTRIBUTION OF THE SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
SEC ADMIN RELEASES 33-9711 AND 34-74141, AND ACCOUNTING AND AUDITING ENFORCEMENT RELEASE 3621 / JANUARY 27, 2015: THE SECURITIES
AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST
PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST OPPENHEIMER & CO. INC. IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,
OPPENHEIMER HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. OPPENHEIMER ADMITS THE
COMMISSION'S JURISDICTION OVER IT AND OVER THE SUBJECT MATTER OF THESE PROCEEDINGS, ADMITS THE FACTS, ACKNOWLEDGES THAT ITS
CONDUCT VIOLATED THE FEDERAL SECURITIES LAWS, AND CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-
DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE
ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. ON THE BASIS OF THIS ORDER AND
RESPONDENT'S OFFER, THE COMMISSION FINDS THAT: OPPENHEIMER ENGAGED IN TWO SEPARATE COURSES OF CONDUCT, EACH OF WHICH
VIOLATED THE FEDERAL SECURITIES LAWS. OPPENHEIMER I: BETWEEN JULY 2008 AND MAY 2009, OPPENHEIMER EXECUTED SALES OF BILLIONS OF
SHARES OF PENNY STOCKS FOR AN ACCOUNT IN THE NAME OF ITS CUSTOMER, A BROKER-DEALER LICENSED IN THE BAHAMAS. ALTHOUGH THE
CUSTOMER PURPORTEDLY MAINTAINED A PROPRIETARY ACCOUNT, OPPENHEIMER KNEW THAT THE CUSTOMER WAS ACTUALLY EXECUTING
TRANSACTIONS AND PROVIDING BROKERAGE SERVICES FOR ITS CUSTOMERS, MANY OF WHOM WERE U.S. PERSONS. THROUGH THIS CONDUCT, THE
CUSTOMER ACTED AS A BROKER IN THE UNITED STATES EVEN THOUGH IT WAS NOT REGISTERED WITH THE COMMISSION AS REQUIRED BY THE
FEDERAL SECURITIES LAWS. THE CUSTOMER PROVIDED OPPENHEIMER WITH AN IRS FORM W-8BEN, WHICH PURPORTEDLY EXEMPTED IT FROM U.S.
TAX WITHHOLDING BASED ON A FALSE CERTIFICATION THAT IT WAS THE SOLE OWNER OF ALL OF THE INCOME GENERATED IN ITS OPPENHEIMER
ACCOUNT. OPPENHEIMER, HOWEVER, KNEW THAT THE CUSTOMER'S CUSTOMERS (AND NOT IT) WERE THE BENEFICIAL OWNERS OF THE SECURITIES
DEPOSITED, SOLD AND OR TRANSFERRED. AS A RESULT OPPENHEIMER KNEW OR SHOULD HAVE KNOWN THAT THE CUSTOMER'S IRS WITHHOLDING
FORM WAS FALSE AND COULD NOT BE RELIED ON. THUS, OPPENHEIMER FAILED TO PROPERLY WITHHOLD AND REMIT TAXES TO THE IRS, AND
THEREFORE BECAME LIABLE FOR TAXES IT WAS OBLIGATED TO WITHHOLD. OPPENHEIMER, HOWEVER, FAILED TO RECORD THIS LIABILITY AND
RESULTING EXPENSES, WHICH CAUSED ITS BOOKS AND RECORDS TO BECOME INACCURATE. OPPENHEIMER'S RECORDS WERE ALSO INACCURATE
BECAUSE THEY REFLECTED THE ACCOUNT IN WHICH THE CUSTOMER'S CUSTOMERS' SHARES WERE DEPOSITED, SOLD AND TRANSFERRED AS A
PROPRIETARY ACCOUNT OF THE CUSTOMER, RATHER THAN AN ACCOUNT FOR THE CUSTOMER'S CUSTOMERS. IN INSTANCES WHEN SUSPICIOUS
ACTIVITY OCCURRED IN THE CUSTOMER'S ACCOUNT, OPPENHEIMER FAILED TO FILE THE REQUISITE SUSPICIOUS ACTIVITY REPORTS. BY THESE
CONDUCTS OPPENHEIMER WILLFULLY AIDED AND ABETTED AND WAS A CAUSE OF THE CUSTOMER'S VIOLATION OF SECTION 15(A) OF THE EXCHANGE
ACT; VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULES 17A-3(A)(2), 17A-3(A)(9); AND WILLFULLY VIOLATED SECTION 17(A) OF THE
EXCHANGE ACT AND RULE 17A-8. (CONT. IN COMMENT SECTION) 8.
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:
Order
11. Resolution Date (MM/DD/YYYY):
01/27/2015
 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: $ 5,078,129.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution

 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PREJUDGMENT INTEREST AND 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 FIRM SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 15(A) AND
17(A) OF THE EXCHANGE ACT AND RULES 17A-3 AND 17A-8 THEREUNDER AND OF SECTION 5 OF THE SECURITIES ACT; IS CENSURED; SHALL PAY
TO THE COMMISSION $4,168,400 IN DISGORGEMENT; $753,471 IN PREJUDGMENT INTEREST; AND $5,078,129 IN CIVIL PENALTIES. THE FIRM
SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER.
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).
(CONT. FROM ALLEGATIONS SECTION) OPPENHEIMER II: FROM OCTOBER 6, 2009 THROUGH DECEMBER 10, 2010, OPPENHEIMER, THROUGH A
REGISTERED REPRESENTATIVE THEN ASSOCIATED WITH OPPENHEIMER AND HIS IMMEDIATE SUPERVISOR, WILLFULLY VIOLATED SECTIONS 5(A) AND
(C) OF THE SECURITIES ACT WHEN IT ENGAGED IN THE UNREGISTERED DISTRIBUTION OF THE SECURITIES ON BEHALF OF A CUSTOMER. THE OVER 2.5
BILLION CUMULATIVE SHARES SOLD THROUGH THE CUSTOMER'S ACCOUNT GENERATED APPROXIMATELY $12,000,000 IN PROCEEDS OF WHICH
OPPENHEIMER WAS PAID $588,400 IN COMMISSIONS. NO REGISTRATION STATEMENT WAS ON FILE OR IN EFFECT AS TO THE CUSTOMER'S OFFERS
AND SALES OF SECURITIES AS REQUIRED BY SECTION 5 OF THE SECURITIES ACT. THE CUSTOMER'S OFFERS AND RE-SALES DID NOT COMPLY WITH
RULE 144 OR QUALIFY FOR SECTION 4(A)(1) OR ANY OTHER EXEMPTION UNDER THE FEDERAL SECURITIES LAWS. AS A CONSEQUENCE, OPPENHEIMER
WILLFULLY VIOLATED SECTIONS 5(A) AND (C) OF THE SECURITIES ACT. IN FAILING TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES
REASONABLY DESIGNED TO PREVENT AND DETECT OPPENHEIMER PERSONNEL'S VIOLATIONS OF SECTION 5, OPPENHEIMER ALSO FAILED REASONABLY
TO SUPERVISE. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE TO IMPOSE THE SANCTIONS AGREED TO IN OPPENHEIMER'S
OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THAT OPPENHEIMER: CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY
FUTURE VIOLATIONS OF SECTIONS 15(A) AND 17(A) OF THE EXCHANGE ACT AND RULES 17A-3 AND 17A-8 THEREUNDER AND OF SECTION 5 OF THE
SECURITIES ACT; IS CENSURED; SHALL PAY TO THE COMMISSION $10 MILLION COMPRISED OF $4,168,400 IN DISGORGEMENT; $753,471 IN
PREJUDGMENT INTEREST; AND $5,078,129 IN CIVIL PENALTIES. THE FIRM SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER. A
PENALTY AMOUNT THAT INCLUDES AN ADDITIONAL $10 MILLION IS APPROPRIATE FOR THE CONDUCT AT ISSUE HEREIN, HOWEVER, IN LIGHT OF THE
CIVIL MONEY PENALTY PAID BY OPPENHEIMER TO THE U.S. TREASURY DEPARTMENT'S FINANCIAL CRIMES ENFORCEMENT NETWORK (FINCEN) IN IN THE
MATTER OF OPPENHEIMER & CO. INC., NUMBER 2015-01, NO ADDITIONAL PENALTY IS BEING ORDERED AT THIS TIME. OPPENHEIMER'S TOTAL
OBLIGATION TO PAY IN THIS PROCEEDING WOULD BE $20 MILLION IN THE EVENT IT FAILS TO PAY ITS $10 MILLION OF A CIVIL MONEY PENALTY TO
FINCEN. PAYMENT OF DISGORGEMENT, PREJUDGMENT INTEREST, AND $78,129 IN CIVIL PENALTIES WILL BE DUE TEN (10) DAYS AFTER INSTITUTION OF
THIS ORDER, WITH THE REMAINING $5,000,000 IN CIVIL PENALTIES, AND INTEREST ACCRUED PURSUANT TO 31 U.S.C. 3717, DUE NO LATER THAN THE
SECOND ANNIVERSARY OF THE INSTITUTION OF THIS ORDER. THE COMMISSION ACKNOWLEDGES THAT OPPENHEIMER HAS PLACED CERTAIN ASSETS
IN ESCROW WHICH OPPENHEIMER BELIEVES WILL SATISFY THE PAYMENT REQUIRED TO BE MADE BY THE SECOND ANNIVERSARY OF THE INSTITUTION
OF THIS ORDER; HOWEVER, OPPENHEIMER RETAINS ITS PAYMENT OBLIGATION IRRESPECTIVE OF ANY AMOUNTS REALIZED BY PAYMENT FROM, SALE
OF, OR REDEMPTION OF, ANY ESCROWED ASSETS.

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) 
NASDAQ STOCK MARKET
2.
Principal Sanction:
Censure
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/30/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2012033488501
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
DISPLAY IMMEDIATELY 31 CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION, WHEN EACH SUCH ORDER WAS AT A PRICE
THAT WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCH SECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BID OR
OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCH SECURITY, AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS
CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SUCH SECURITY. THE CONDUCT VIOLATED SECURITIES
EXCHANGE ACT OF 1934 RULE 604 OF REGULATION NMS.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
01/30/2015
 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: $ 7,500.00
 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 FIRM WAS CENSURED AND FINED $7,500.
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).

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:
105559
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
OPPENHEIMER ASSET
MANAGEMENT
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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).

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) 
INVESTOR PROTECTION DIRECTOR FOR THE STATE OF DELAWARE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
06/25/2015
 Exact
 Explanation

If not exact, provide explanation:
4.
Docket/Case Number:
IPU CASE NO. 11-2-4
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
VARIOUS INVESTMENTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DELAWARE ALLEGES THAT THE FIRM VIOLATED 6DEL C 7316(A)(10) (2002) BY FAILING TO SUPERVISE AN FA AND FAILING TO COMPLY WITH CERTAIN
ASPECTS OF ITS COMPLIANCE SYSTEM.
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:
Consent
11. Resolution Date (MM/DD/YYYY):
06/25/2015
 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: $ 685,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
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: 
WITHOUT ADMITTING OR DENYING ANY WRONGDOING ON THE PART OF OPPENHEIMER OR ANY OF ITS AGENTS OR FORMER AGENTS,
OPPENHEIMER AGREED TO PAY $685,000. TO THE DELAWARE INVESTOR PROTECTION FUND AND AGREED TO CERTAIN UNDERTAKINGS.
OPPENHEIMER PAID THE PENALTY ON OR ABOUT JULY 2, 2015 AND WAS ORDERED TO REFRAIN FROM COMMITTING ANY FUTURE VIOLATIONS OF
THE ACT.
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 AFOREMENTIONED UNDERTAKINGS AGREED TO ARE AS FOLLOWS: OPPENHEIMER SHALL DEVELOP AND MAINTAIN POLICIES, PROCEDURES AND
SYSTEMS THAT REASONABLY SUPERVISE THE ACTIVIITES OF ITS BROKER-DEALER AGENTS, INVESTMENT ADVISORS, AND BRANCH OFFICE MANAGERS,
AND ENSURE FULL COMPLIANCE BY ITS OFFICERS, AGENTS, EMPLOYEES, AND REPRESENTATIVES WITH THEIR AND OPPENHEIMERS RESPONSIBILITIES
TO THEIR CLIENTS.

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) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/18/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-16629
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Municipal
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):

SEC ADMIN RELEASES 33-9836; 34-75230, JUNE 18, 2015: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC
INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST OPPENHEIMER & CO. INC.
("RESPONDENT"). RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVES VIOLATIONS OF AN
ANTIFRAUD PROVISION OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITING OF CERTAIN MUNICIPAL
SECURITIES OFFERINGS. RESPONDENT, A REGISTERED BROKER-DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAIN OFFERINGS AND AS A
RESULT, FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIAL REPRESENTATIONS IN OFFICIAL
STATEMENTS ISSUED IN CONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENT OFFERING AND SELLING MUNICIPAL SECURITIES ON
THE BASIS OF MATERIALLY MISLEADING DISCLOSURE DOCUMENTS. THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THE COMMISSION
PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION (MCDC) INITIATIVE.
OPPENHEIMER UNDERSTANDS THAT ON THE SAME DATE, THE SEC ANNOUNCED PUBLIC ADMINISTRATIVE AND CEASE AND DESIST PRECEEDINGS
SIMILIAR TO THE ONE DISCLOSED HEREIN AGAINST THIRTY FIVE (35) OTHER UNDERWRITER BROKER/DEALERS.
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:
Order
11. Resolution Date (MM/DD/YYYY):
06/18/2015
 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: $ 400,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
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 RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)
(2)OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $400,000 AND COMPLY WITH THE UNDERTAKINGS ENUMERATED IN
THE OFFER OF SETTLEMENT.
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).
IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE
COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON
BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE
COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, RESPONDENT CONSENTS TO THE
ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF
1933 AND SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-
DESIST ORDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS
AGREED TO IN RESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THAT RESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING OR
CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OF THE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THIS ORDER,
PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $400,000 TO THE SECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENT
CONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES AND PROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIES UNDERWRITING
DUE DILIGENCE

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) 
CHICAGO BOARD OPTIONS EXCHANGE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/30/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
15-0079/ 20150462954
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Options
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):

g
g
y
(y
p
p
p
)
IN JULY, 2015 , THE BUSINESS CONDUCT COMMITTEE OF THE CHICAGO BOARD OPTIONS EXCHANGE ISSUED A STATEMENT OF CHARGES, IN THE
MATTER OF OPPENHEIMER & CO. INC. STAR NO. 20150462954, ALLEGING THAT OPPENHEIMER VIOLATE EXCHANGE RULE 3.6A BY FAILING TO TWO
ASSOCIATED PERSONS AS PROPRIETARY TRADER PRINCIPALS,5 ASSOCIATED PERSONS AS PROPRIETARY TRADERS, AND THE CHIEF COMPLIANCE
OFFICER AS PROPRIETARY TRADER COMPLIANCE OFFICER.
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:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
10/20/2015
 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: $ 20,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
A $20,000 FINE AND A CENSURE.
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: 
ON OCTOBER 20, 2015 THE BUSINESS CONDUCT COMMITTEE OF THE CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED UNDER FILE NO.
15-0070, STAR NO. 20150462954 ISSUED ITS DECISION ACCEPTING THE OFFER OF SETTLEMENT IN THE MATTER OF OPPENHEIMER & CO. INC.
("THE DECISION"). THE DECISION DETERMINED THAT OPPENHEIMER WAS AN EXCHANGE TRADING PERMIT HOLDER APPROVED TO TRANSACT
BUSINESS WITH THE PUBLIC. AS A RESULT OF A ROUTINE EXAMINATION IT WAS DETERMINED THAT ON VARIOUS DATES FROM NOVEMBER 5,
2011 THROUGH JUNE 9, 2014, OPPENHEIMER FAILED TO REGISTER TWO (2) ASSOCIATED PERSONS AS PROPRIETARY TRADING PRINCIPAL WITH
CBOE. DURING THE SAME PERIOD OF TIME OPPENHEIMER FAILED TO REGISTER FICE (5) ASSOCIATED PERSONS AS PROPRIETARY TRADERS, AND
FROM MAY 1, 2013 THROUGH SEPTEMBER 17, 2013 OPPENHEIMER FAILED TO REGISTER ITS CHIEF COMPLIANCE OFFICER AS A PROPRIETARY
TRADING COMPLIANCE OFFICER. OPPENHEIMER WAS SANCTIONED, AND ORDERED TO PAY $20,000.00 TO THE CBOE.
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).

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) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/07/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2012034713201
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
UNSPECIFIED SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT, IN TRANSACTIONS
FOR OR WITH A CUSTOMER, THE FIRM FAILED TO USE REASONABLE DILIGENCE TO ASCERTAIN THE BEST INTER-DEALER MARKET AND FAILED TO BUY
OR SELL IN SUCH MARKET SO THAT THE RESULTANT PRICE TO ITS CUSTOMERS WAS AS FAVORABLE AS POSSIBLE UNDER PREVAILING MARKET
CONDITIONS. THESE VIOLATIONS RESULTED IN A TOTAL OF $109.15 IN RESTITUTION, WHICH THE FIRM HAS CONFIRMED WAS PAID. THE FINDINGS
STATED THAT THE FIRM FAILED TO ACCURATELY REPORT THE CORRECT EXECUTION PRICE TO THE OVER-THE-COUNTER REPORTING FACILITY (OTCRF)
AND FAILED TO SHOW THE CORRECT ORDER RECEIPT TIME AND TIME OF EXECUTION ON THE MEMORANDUM OF BROKERAGE ORDERS. THE FINDINGS
ALSO STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH
RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND NASD AND FINRA RULES PERTAINING TO THE FIRM'S BEST EXECUTION
OBLIGATIONS IN OTC SECURITIES.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
10/07/2015
 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: $ 21,000.00
 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 FIRM WAS CENSURED AND FINED $21,000.
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).

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) 
UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/26/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2015-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Penny Stock(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK ("FINCEN") ALLEGED THAT
OPPENHEIMER & CO. INC. ("OPPENHEIMER") WILLFULLY VIOLATED THE BANK SECRECY ACT BY (A) FAILING TO IMPLEMENT AND ADEQUATE ANTI-
MONEY LAUNDERING PROGRAM, 31 U.S.C.S. 5318(H) AND 31 C.F.R.S. 1023.210;(B) FAILED TO IMPLEMENT AN ADEQUATE DUE DILIGENCE PROGRAM
FOR A FOREIGN CORRESPONDENT ACCOUNT, 31 U.S.C.S. 5318(I)(1) AND 31C.F.R.S. 1023.610; AND (C) FAILED TO COMPLY WITH NOTIFICATION
REQUIREMENTS UNDER RULES IMPOSING SPECIAL MEASURES UNDER SECTION 311 OF THE USA PATRIOT ACT AGAINST THREE FOREIGN FINANCIAL
INSTITUTIONS OF PRIMARY MONEY LAUNDERING CONCERN. 31 CFRS. 1010.653, 1010.654, 1010.655.
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:
Consent
11. Resolution Date (MM/DD/YYYY):
01/26/2015
 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: $ 20,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PROVIDE FINCEN COPIES OF ANY REPORTS OR OTHER RECOMMENDATIONS PREPARED BY AN INDEPENDENT CONSULTANT RETAINED TO REVIEW
AND PROVIDE RECOMMENDATIONS FOR CERTAIN ASPECTS OF ITS COMPLIANCE PROGRAM, INCLUDING ITS AML PROGRAM.
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: 
OPPENHEIMER ADMITTED THAT IT VIOLATED THE BANK SECRECY ACT AND CONSENTED TO THE ASSESSMENT OF A CIVIL MONEY PENALTY IN THE
AMOUNT OF $20 MILLION, OF WHICH $10 MILLION WAS CONCURRENT WITH THE PENALTY, DISGORGEMENT AND PREJUDGMENT INTEREST
IMPOSED BY THE SEC IN CONNECTION WITH IN THE MATTER OF OPPENHEIMER & CO. INC., ADMINISTRATIVE PROCEEDING FILE NO. 3-16361
(JAN. 27, 2015). OPPENHEIMER PAID $5 MILLION OF THE $10 MILLION PENALTY TO FINCEN ON FEBRUARY 9, 2015 AND THE REMAINING $5
MILLION PENALTY IS DUE TO BE PAID TO FINCEN BY JANUARY 27, 2017.
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).

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) 
NEW MEXICO SECURITIES DIVISION
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/20/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
14-03-0028
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Other
Other Product Types: 
BANK BONDS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN NOVEMBER, 2014 THE NEW MEXICO SECURITIES DIVISION FILED A NOTICE OF CONTEMPLATED ACTION, IN THE MATTER OF OPPENHEIMER AND
ROYCE SIMPSON, NN. 14-03-0028 ('THE NOTICE"). THE NOTICE ALLEGED THAT CERTAIN FEDERAL NATIONAL MORTGAGE ASSOCIATION AND FEDERAL
LOAN HOME BANK BONDS, PURCHASED BY BERNALILLO COUNTY WERE UNSUITABLE, AND THAT CO- RESPONDENT SIMPSON'S ACTIVITIES WEREN'T
SUPERVISED. THE MATTER HAS NOT BEEN SCHEDULED FOR A HEARING.
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:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
10/19/2015
 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: $ 215,000.00
 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: 
ON OCTOBER 19, 2015 OPPENHEIMER & CO. INC. ("OPPENHEIMER") ENTERED A STIPULATION AND AGREEMENT WITH THE DIRECTOR OF THE

SECURITIES DIVISION OF THE NEW MEXICO REGULATION AND LICENSING DEPARTMENT RESOLVING A NOTICE OF CONTEMPLATED ACTION,
DATED NOVEMBER 20, 2014, CAPTIONED IN THE MATTER OF OPPENHEIMER & CO. INC. AND ROYCE SIMPSON, CASE NO. 14-03-0028. THE
STIPULATION AND AGREEMENT DETERMINED THAT THE DIVISION, WHILE REVIEWING THE TRADING ACTIVITY FOR BERNALILLO COUNTY FROM
2012 THROUGH 2013, DETERMINED THAT THERE MAY HAVE BEEN CERTAIN SUPERVISORY DEFICIENCIES AT OPPENHEIMER IN ADVISING THE
TREASURER'S OFFICE OF BERNALILLO COUNTY DURING THE PERIOD OF TIME IN QUESTION THROUGH OPPENHEIMER'S AGENT, ROYCE SIMPSON.
OPPENHEIMER DISPUTES THAT CLAIM AS SET FORTH IN THE NOTICE OF CONTEMPLATED ACTION; FURTHER, THE STIPULATION AND AGREEMENT
WAS NOT INTENDED TO MODIFY ANY OF OPPENHEIMER'S OBLIGATIONS UNDER EXISTING LAW, AND IN FACT OPPENHEIMER MADE CERTAIN
REVISIONS IN ITS INTERNAL POLICIES INVOLVING THE INVESTMENT OF PUBLIC FUNDS. OPPENHEIMER ALSO AGREED TO REMIT TO THE DIVISION
THE AMOUNT OF $215,000.00, TO BE ALLOCATED TO THE INVESTOR EDUCATION FUND FOR THE BENEFIT OF LICENSEES AND CONSUMERS
WITHIN OF NEW MEXICO. OPPENHEIMER MADE THAT PAYMENT ON NOVEMBER 7, 2015. OPPENHEIMER ALSO AGREED TO COMMIT TO A FULL
IMPLEMENTATION OF IMPROVED SUPERVISORY PROCEDURES, WHICH IT ALREADY ADOPTED, FOR SERVICING POLITICAL SUBDIVISIONS
THROUGHOUT NEW MEXICO. AS A RESULT, THE DIVISION RELEASED AND DISCHARGED OPPENHEIMER FROM MANY AND ALL CLAIMS, AND
DISMISSED THE NOTICE OF CONTEMPLATED ACTION WITH PREJUDICE AGAINST OPPENHEIMER.
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).

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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
11/24/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2014041053201
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
MUNICIPAL SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THE CALL DATE AND DOLLAR PRICE OF THE CALL IN TRANSACTIONS IN MUNICIPAL
SECURITIES EXECUTED ON THE BASIS OF A YIELD TO CALL. THE FINDINGS STATED THAT THE FIRM ALSO FAILED TO PROVIDE WRITTEN NOTIFICATION
DISCLOSING TO ITS CUSTOMER THE CORRECT NEXT POTENTIAL CALL DATE IN TRANSACTIONS IN CONTINUOUSLY CALLABLE MUNICIPAL SECURITIES
EXECUTED ON THE BASIS OF A YIELD TO CALL. THE FINDINGS ALSO STATED THAT THE FIRM PROVIDED WRITTEN NOTIFICATION IMPROPERLY
DISCLOSING TO ITS CUSTOMER A YIELD TO CALL IN TRANSACTIONS IN MUNICIPAL SECURITIES WITH A VARIABLE INTEREST RATE. THE FINDINGS ALSO
INCLUDED THAT THE FIRM FAILED TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THE CORRECT LOWEST EFFECTIVE YIELD IN A
TRANSACTION IN A MUNICIPAL SECURITY. FINRA FOUND THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY
DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO APPLICABLE SECURITIES LAWS AND REGULATIONS, AND MSRB RULES, CONCERNING
CUSTOMER CONFIRMATIONS FOR MUNICIPAL SECURITIES TRANSACTIONS.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
11/24/2015
 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: $ 15,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING
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 FIRM WAS CENSURED, FINED $15,000, AND IS REQUIRED TO REVISE ITS WSPS.
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).

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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
N/A

3.
Date Initiated (MM/DD/YYYY): 
12/22/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2013038149001
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Municipal
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT FROM JANUARY
2009 THROUGH SEPTEMBER 2014, THE FIRM FAILED TO REASONABLY SUPERVISE AND TO HAVE AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING
ADEQUATE WRITTEN SUPERVISORY PROCEDURES (WSPS), TO ADDRESS SHORT POSITIONS IN TAX-EXEMPT MUNICIPAL BONDS THAT RESULTED
PRIMARILY FROM TRADING ERRORS. THE FINDINGS STATED THAT AS A RESULT OF THESE SUPERVISORY FAILURES, THE FIRM INACCURATELY
REPRESENTED TO ITS CUSTOMERS HOLDING MUNICIPAL BONDS THAT AT LEAST $188,974.38 IN INTEREST THAT THE FIRM PAID TO THOSE CUSTOMERS
WAS EXEMPT FROM TAXATION. THE FIRM DID NOT HOLD THE BONDS ON BEHALF OF THE CUSTOMERS AND THE INTEREST THAT THE CUSTOMERS
RECEIVED WAS PAID BY THE FIRM AND THUS TAXABLE AS ORDINARY INCOME. THE FIRM FAILED TO CONSIDER, AND ITS DIVIDEND DEPARTMENT THAT
WAS RESPONSIBLE FOR DISTRIBUTING AND RECONCILING THE INTEREST OWED TO CUSTOMERS DID NOT TAKE INTO ACCOUNT, WHETHER THE
INTEREST PAID TO CUSTOMERS SHOULD BE CODED AS NON-TAXABLE WHEN THE INTEREST WAS PAID BY THE FIRM RATHER THAN THE MUNICIPAL
ISSUER. THE FINDINGS ALSO STATED THAT THE FIRM DID NOT PROVIDE ADEQUATE GUIDANCE OR OVERSIGHT ON HOW AND WHEN MUNICIPAL SHORT
POSITIONS SHOULD BE COVERED. AS A RESULT OF THE FIRM'S PROCEDURES, OR LACK THEREOF, REGARDING MUNICIPAL SHORT POSITIONS IN
BRANCH ERROR ACCOUNTS AND FIRM TRADING ACCOUNTS, MANY OF THE SHORT POSITIONS WERE NOT COVERED IN A TIMELY FASHION. THIS
DEFICIENCY MAY HAVE BEEN PROLONGED DUE TO THE DIFFICULTY OF COVERING THESE POSITIONS IN LIGHT OF THE CHARACTERISTICS OF
MUNICIPAL SECURITIES AS WELL AS THE LIMITED AMOUNT OUTSTANDING OF A PARTICULAR MUNICIPAL BOND. IN 2013, THE FIRM RECOGNIZED THAT
SHORT POSITIONS WERE NOT BEING COVERED IN A TIMELY FASHION AND SUBSEQUENTLY REVISED ITS PROCEDURES TO REDUCE THE NUMBER OF
AGED SHORT POSITIONS. NEVERTHELESS, DURING THE RELEVANT PERIOD, THE FIRM OFTEN DID NOT COVER MUNICIPAL SHORT POSITIONS. THE FIRM
HAS ALSO IMPLEMENTED REVISED PROCEDURES TO MINIMIZE ITS SHORT MUNICIPAL BOND POSITIONS AND TO PROPERLY REPORT FIRM-PAID
INTEREST AS TAXABLE. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO DISCLOSE TO CUSTOMERS THAT THEY WERE NOT RECEIVING TAX-
EXEMPT INTEREST WHEN THE FIRM WAS SHORT MUNICIPAL BONDS. IN ADDITION, THE FIRM SENT INACCURATE FORMS 1099 TO CERTAIN CUSTOMERS
WHO RECEIVED FIRM-PAID INTEREST FOR 2009 THROUGH 2014 AND ALSO SENT INACCURATE ACCOUNT STATEMENTS TO CERTAIN CUSTOMERS THAT
INCORRECTLY CLASSIFIED FIRM-PAID INTEREST AS TAX-EXEMPT WHEN IT SHOULD HAVE BEEN CLASSIFIED AS TAXABLE. IN 2013, FINRA EXAMINATION
STAFF FOUND THAT THE FIRM HAD INACCURATELY REPORTED FIRM-PAID INTEREST FROM SHORT MUNICIPAL BOND POSITIONS TO CUSTOMERS ON
FORMS 1099 AND ACCOUNT STATEMENTS. THEREAFTER, THE FIRM IMPLEMENTED REVISED PROCEDURES TO MINIMIZE ITS SHORT MUNICIPAL
POSITIONS AND PROPERLY REPORT FIRM-PAID INTEREST AS TAXABLE ON THE FORMS 1099 ISSUED TO CUSTOMERS. THE FIRM HAS ALSO AGREED IN
PRINCIPAL WITH THE IRS TO MAKE A PAYMENT TO RELIEVE ITS CUSTOMERS OF THE BURDEN OF FILING AMENDED TAX RETURNS AND PAYING
ADDITIONAL FEDERAL INCOME TAX. FINRA FOUND THAT DURING THE RELEVANT PERIOD, THE FIRM DID NOT MAINTAIN RECORDS IDENTIFYING
PARTICULAR CUSTOMER ACCOUNTS THAT OFFSET ITS SHORT MUNICIPAL BOND POSITIONS. THE FIRM'S SHORT POSITIONS WERE HELD IN AGGREGATE
AND NOT ALLOCATED TO SPECIFIED CUSTOMERS. BECAUSE THE FIRM'S SHORT MUNICIPAL BOND POSITIONS WERE NOT OFFSET AGAINST SPECIFIC
CUSTOMER HOLDINGS, THE FIRM WAS UNABLE TO ACCURATELY REPORT TAXABLE INCOME TO ITS CUSTOMERS WHO WERE RECEIVING FIRM-PAID
INTEREST AS TAXABLE INCOME.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
12/22/2015
 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: $ 225,000.00
 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 FIRM WAS CENSURED AND FINED $225,000.00
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).

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) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/22/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2014041832801
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Municipal
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT EFFECTED
CUSTOMER TRANSACTIONS IN A MUNICIPAL SECURITY IN AN AMOUNT LOWER THAN THE MINIMUM DENOMINATION OF THE ISSUE WHICH WERE NOT
SUBJECT TO AN EXCEPTION UNDER THE RULE. THE FINDINGS STATED THAT THE FIRM FAILED TO DISCLOSE ALL MATERIAL FACTS CONCERNING
MUNICIPAL SECURITIES TRANSACTIONS AT OR PRIOR TO THE TIME OF TRADE. SPECIFICALLY, THE FIRM FAILED TO INFORM ITS CUSTOMER THAT THE
MUNICIPAL SECURITIES TRANSACTION WAS IN AN AMOUNT BELOW THE MINIMUM DENOMINATION OF THE ISSUE.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
12/22/2015
 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: $ 200,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
RESCISSION
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 FIRM WAS CENSURED, FINED $200,000 AND MUST OFFER RESCISSION TO THE CUSTOMERS WHO PURCHASED SECURITIES AT EITHER THE
ORIGINAL PURCHASE PRICE OR THE CURRENT FAIR MARKET VALUE, WHICHEVER IS HIGHER.
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).

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) 
SOUTH CAROLINA SECURITIES DIVISION
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/04/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
14115 AND 15062
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.

6.
Principal Product Type:
Other
Other Product Types: 
PRIVATE INVESTMENTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SECURITIES DIVISION OF THE OFFICE OF THE ATTORNEY GENERAL FOR SOUTH CAROLINA DETERMINED THAT OPPENHEIMER, WITHOUT ADMITTING
OR DENYING THE FINDINGS, FAILED TO DETECT AND REPORT THE ACTIVITIES OF MARK HOTTON (CRD# 2346843), A FORMER REGISTERED
REPRESENTATIVE AND ONE OTHER, UNIDENTIFIED REPRESENTATIVE. THIS RELATES TO A RESIDENT OF SOUTH CAROLINA, AND HOTTON'S
RECOMMENDATION THAT THE CLIENT INVEST IN PRIVATE INVESTMENTS FROM NOVEMBER 2005 THROUGH OCTOBER 2008. OPPENHEIMER PAID A FINE
OF $150,000 AND REIMBURSED COSTS OF $25,000.
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:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
05/04/2016
 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: $ 150,000.00
 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 SECURITIES DIVISION OF THE OFFICE OF THE ATTORNEY GENERAL FOR SOUTH CAROLINA DETERMINED THAT OPPENHEIMER, WITHOUT
ADMITTING OR DENYING THE FINDINGS, FAILED TO DETECT AND REPORT THE ACTIVITIES OF MARK HOTTON (CRD# 2346843), A FORMER
REGISTERED REPRESENTATIVE AND ONE OTHER, UNIDENTIFIED REPRESENTATIVE. THIS RELATES TO A RESIDENT OF SOUTH CAROLINA, AND
HOTTON'S RECOMMENDATION THAT THE CLIENT INVEST IN PRIVATE INVESTMENTS FROM NOVEMBER 2005 THROUGH OCTOBER 2008.
OPPENHEIMER PAID A FINE OF $150,000 AND REIMBURSED COSTS OF $25,000.
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).

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) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/07/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2013038180801
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Other
Other Product Types: 
NON-TRADITIONAL ETFS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT FOR OVER FOUR
YEARS, IT FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A REASONABLY-DESIGNED SUPERVISORY SYSTEM AND WSPS REGARDING THE SALES OF
LEVERAGED, INVERSE, AND INVERSE-LEVERAGED EXCHANGE-TRADED FUNDS (NON-TRADITIONAL ETFS). THE FINDINGS STATED THAT IN RESPONSE TO
FINRA'S REGULATORY NOTICE 09-31, THE FIRM INSTITUTED WSPS THAT PROHIBITED REPRESENTATIVES FROM SOLICITING RETAIL CUSTOMERS TO
PURCHASE NON-TRADITIONAL ETFS. THE WSPS PERMITTED UNSOLICITED PURCHASES OF NON-TRADITIONAL ETFS BY RETAIL CUSTOMERS, BUT ONLY IF
THE CUSTOMER WAS "PRE-QUALIFIED." TO MEET THIS PRE-QUALIFICATION REQUIREMENT, THE FIRM'S WSPS REQUIRED THAT REPRESENTATIVES

OBTAIN A "LEVERAGED ETF REPRESENTATION LETTER" (THE "ETF QUALIFICATION LETTER") FROM EACH CUSTOMER SEEKING TO PURCHASE A NON-
TRADITIONAL ETF. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ENFORCE ITS WSPS PROHIBITING THE SOLICITATION OF NON-TRADITIONAL
ETF PURCHASES FOR RETAIL CUSTOMERS IN SEVERAL RESPECTS. FIRST, THE FIRM DID NOT ADEQUATELY TRAIN ITS SUPERVISORS AND REGISTERED
REPRESENTATIVES ON THE PROHIBITION AGAINST SOLICITED NON-TRADITIONAL ETF PURCHASES. SECOND, THE FIRM DID NOT PREVENT
REPRESENTATIVES AND THE TRADING DESK FROM ENTERING SOLICITED NON-TRADITIONAL ETF TRADES IN THE FIRM'S ORDER-ENTRY SYSTEM. THIRD,
THE FIRM DID NOT USE AN EFFECTIVE SURVEILLANCE REPORT TO IDENTIFY SOLICITED NON-TRADITIONAL ETF TRADES. AS A RESULT, THE FIRM'S
REPRESENTATIVES CONTINUED TO SOLICIT NON-TRADITIONAL ETF PURCHASES FROM RETAIL CUSTOMERS IN VIOLATION OF THE FIRM'S POLICIES. THE
FIRM ALSO FAILED TO ENFORCE ITS WSPS BY ALLOWING RETAIL CUSTOMERS TO MAKE UNSOLICITED NON-TRADITIONAL ETF PURCHASES EVEN
THOUGH THE CUSTOMERS WERE NOT PRE-QUALIFIED, EITHER BECAUSE THEY DID NOT HAVE AN ETF QUALIFICATION LETTER ON FILE OR BECAUSE
THEY FAILED TO MEET THE PRE-QUALIFICATION CRITERIA SET FORTH IN THE ETF QUALIFICATION LETTER. AS A RESULT, UNSOLICITED NON-
TRADITIONAL ETF PURCHASES CONTINUED TO BE EXECUTED FOR CUSTOMERS WHO WERE NOT PRE-QUALIFIED IN VIOLATION OF THE FIRM'S
POLICIES. THE FINDINGS ALSO INCLUDED THAT THE FIRM DID NOT ESTABLISH AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING THE USE OF
EXCEPTION REPORTS, TO EFFECTIVELY MONITOR HOLDING PERIODS FOR NON-TRADITIONAL ETFS. A PRIMARY RISK WITH NON-TRADITIONAL ETFS IS
THAT THEIR PERFORMANCE OVER LONGER PERIODS OF TIME CAN DIFFER SIGNIFICANTLY FROM THE PERFORMANCE OF THEIR UNDERLYING INDEX OR
BENCHMARK, PARTICULARLY IN VOLATILE MARKETS. THE FIRM'S FAILURE TO HAVE AN ADEQUATE SUPERVISORY SYSTEM TO MONITOR HOLDING
PERIODS FOR NON-TRADITIONAL ETFS CONTRIBUTED TO CUSTOMER LOSSES. FINRA FOUND THAT ALTHOUGH THE FIRM'S WSPS PROHIBITED
SOLICITATION OF NON-TRADITIONAL ETFS, ITS REPRESENTATIVES NONETHELESS CONTINUED TO OFFER THESE SECURITIES TO RETAIL CUSTOMERS.
BEFORE DOING SO, THE FIRM DID NOT PERFORM AN ADEQUATE REASONABLE BASIS SUITABILITY ANALYSIS OF NON-TRADITIONAL ETFS TO
UNDERSTAND THE RISKS AND FEATURES ASSOCIATED WITH NON-TRADITIONAL ETFS. THE FIRM REPRESENTATIVES SOLICITED AND EFFECTED NON-
TRADITIONAL ETF PURCHASES THAT WERE UNSUITABLE FOR SPECIFIC CUSTOMERS. CERTAIN OF THE FIRM'S REPRESENTATIVES RECOMMENDED THESE
COMPLEX AND SPECULATIVE PRODUCTS TO NUMEROUS CUSTOMERS WITH CONSERVATIVE INVESTMENT OBJECTIVES, CERTAIN OF WHOM WERE
ELDERLY. MOREOVER, SOME OF THESE CUSTOMERS HELD NON-TRADITIONAL ETF POSITIONS FOR EXTENDED PERIODS OF TIME - OFTEN MONTHS AND
SOMETIME YEARS. FOR EXAMPLES, AN 89-YEAR CONSERVATIVE CUSTOMER WITH ANNUAL INCOME OF $50,000 HELD 96 SOLICITED NON-TRADITIONAL
ETF POSITIONS FOR AN AVERAGE OF 32 DAYS (AND FOR UP TO 470 DAYS) FOR A NET LOSS OF $51,847. ALSO, A 91-YEAR CONSERVATIVE CUSTOMER
WITH AN ANNUAL INCOME OF $30,000 HELD 56 SOLICITED NON-TRADITIONAL ETF POSITIONS FOR AN AVERAGE OF 48 DAYS (AND FOR UP TO 706
DAYS) FOR A NET LOSS OF $11,161. (CONTINUE IN COMMENT)
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/07/2016
 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: $ 2,250,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PLUS INTEREST ON RESTITUTION
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 FIRM WAS CENSURED, FINED $2,250,000, AND ORDERED TO PAY $716,831.80, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS.
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).
CONTINUE FROM ALLEGATIONS SECTION)- ADDITIONALLY, A 67-YEAR CONSERVATIVE CUSTOMER WITH AN ANNUAL INCOME OF $40,000 HELD TWO
SOLICITED NON-TRADITIONAL ETF POSITIONS IN HER ACCOUNT FOR 729 DAYS FOR A LOSS OF $2,746.

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) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/20/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2013038725201
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:

Other
Other Product Types: 
UNSPECIFIED SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
REPORT SHORT INTEREST POSITIONS ON MULTIPLE SETTLEMENT DATES, AND INACCURATELY REPORTED SHORT POSITIONS. THE FINDINGS STATED
THAT THE FIRM ERRONEOUSLY REPORTED "FAIL TO RECEIVE" POSITIONS ON MULTIPLE SETTLEMENT DATES IN THE FIRM'S "BUY-IN ACCOUNT" AS
SHORT INTEREST POSITIONS, WHEN SUCH POSITIONS SHOULD NOT HAVE BEEN REPORTED TO FINRA. THE FINDINGS ALSO STATED THAT THE FIRM
FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE
SECURITIES LAWS AND REGULATIONS AND NASD AND FINRA RULES CONCERNING SHORT INTEREST REPORTING TO ENSURE COMPLIANCE WITH NASD
RULE 3360 AND FINRA RULE 4560. IN ADDITION, WHILE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES IDENTIFIED AN INDIVIDUAL RESPONSIBLE
FOR CONDUCTING A REVIEW, THE FREQUENCY OF SUCH REVIEW, AND A DESCRIPTION OF HOW THE REVIEW SHOULD BE DOCUMENTED, THE FIRM'S
SUPERVISORY STEPS DID NOT CONTAIN A PERIODIC REVIEW OF THE FIRM'S SHORT INTEREST REPORTING LOGIC TO ASCERTAIN THAT IT WAS
OPERATING PROPERLY AND THAT IT CAPTURED THE REQUIRED INFORMATION.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/20/2016
 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: $ 275,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING: REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES.
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 FIRM WAS CENSURED, FINED $275,000 AND UNDERTAKES TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES.
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).

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) 
MICHIGAN
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CONSENT AGREEMENT & ORDER IN LIEU OF CEASE & DESIST PROCEEDINGS
3.
Date Initiated (MM/DD/YYYY): 
07/19/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
328306
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE INVESTIGATION DETERMINED THAT RESPONDENT WAS RESPONSIBLE FOR SUBMITTING THE RELEVANT INVESTMENT ADVISER REPRESENTATIVE
REGISTRATION APPLICATION MATERIALS FOR FORTY (40) MICHIGAN INDIVIDUAL REPRESENTATIVES, BUT THAT IT FAILED TO DO SO FROM THE
EFFECTIVE DATE OF THE SECURITIES ACT ON OCTOBER 1, 2009 (AS EXTENDED BY VARIOUS TRANSITION ORDERS) THROUGH LATE 2015/EARLY 2016.
RESPONDENT HAS NOT IDENTIFIED ANY EXEMPTION, EXCEPTION, PREEMPTION, OR EXCLUSION JUSTIFYING ITS FAILURE TO REGISTER THESE 40
INVESTMENT ADVISER REPRESENTATIVES IN MICHIGAN FROM OCTOBER 1, 2009 (THE DATE THE REGISTRATION REQUIREMENT BECAME EFFECTIVE)
THROUGH THEIR ACTUAL REGISTRATION DATE IN LATE 2015/EARLY 2016.

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:
Consent
11. Resolution Date (MM/DD/YYYY):
07/19/2016
 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: $ 900,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
CONSENT AGREEMENT & ORDER IN LIEU OF CEASE & DESIST PROCEEDINGS
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: 
CIVIL FINE- $900,000
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).

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) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/17/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2015046355401
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT OVER THE COURSE
OF SEVERAL YEARS, IT FAILED TO ESTABLISH, MAINTAIN, AND IMPLEMENT SUPERVISORY SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO
ACHIEVE COMPLIANCE WITH CERTAIN SECURITIES REGULATIONS AND FINRA AND NASD RULES, AND TO REPORT VIOLATIONS OF THOSE RULES TO
FINRA WHERE APPROPRIATE. THE FINDINGS STATED THAT THE FIRM FAILED TO REPORT REQUIRED INFORMATION TO FINRA, APPLY APPLICABLE SALES
CHARGE WAIVERS TO ITS CUSTOMERS, AND PRODUCE RELEVANT DOCUMENTS TO CUSTOMERS WHO HAD FILED ARBITRATIONS AGAINST IT FOR
FAILING TO SUPERVISE A FORMER REGISTERED REPRESENTATIVE. THE FINDINGS ALSO STATED THAT IN PARTICULAR, THE FIRM FAILED TO TIMELY MAKE
365 REQUIRED FILINGS WITH FINRA PURSUANT TO FINRA RULE 4530 AND ITS PREDECESSOR RULES, TO REPORT, AMONG OTHER THINGS, REGULATORY
FINDINGS OF SECURITIES LAWS VIOLATIONS, DISCIPLINARY ACTIONS TAKEN BY THE FIRM AGAINST ITS EMPLOYEES, SETTLEMENTS OF SECURITIES-
RELATED ARBITRATION AND LITIGATION CLAIMS, AND THE INSTITUTION OF SECURITIES-RELATED CIVIL LITIGATION AGAINST THE FIRM. THE FIRM DID
NOT MAINTAIN PROCEDURES THAT GAVE DIRECTION TO THE FIRM'S EMPLOYEES ON MAKING THE DISCLOSURES REQUIRED BY FINRA RULES 4530(A),
(B), AND (F). THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO TIMELY FILE REQUIRED FORM U4 AMENDMENTS DISCLOSING THAT TWO OF ITS
EMPLOYEES HAD RECEIVED WELLS NOTICES FROM THE SECURITIES AND EXCHANGE COMMISSION. ALTHOUGH THE FIRM HAD IMPLEMENTED REVISED
REPORTING PROCEDURES AS A RESULT OF A FINRA INVESTIGATION THAT SUBSEQUENTLY RESULTED IN A PREVIOUS LETTER OF ACCEPTANCE, WAIVER,
AND CONSENT, IT FAILED TO IMPLEMENT PROCEDURES THAT ADEQUATELY ADDRESSED ITS SEPARATE REPORTING OBLIGATIONS PURSUANT TO FINRA
RULES 4530 (A), (B), AND (F), AND ITS OBLIGATION TO REPORT REGULATORY EVENTS ON FORMS U4. THE FIRM FAILED TO MAINTAIN ADEQUATE
WRITTEN PROCEDURES TO ENSURE THAT REGULATORY EVENTS, INCLUDING WELLS NOTICES, WERE REPORTED ON FORMS U4 AND U5. ALL OF THE
FIRM'S SUPERVISORY AND COMPLIANCE PROCEDURES FAILED TO SPECIFICALLY ADDRESS REPORTING REGULATORY EVENTS, INCLUDING WELLS
NOTICES. AS A RESULT OF THE FIRM'S INADEQUATE PROCEDURES, EMPLOYEES IN ITS VARIOUS DEPARTMENTS WERE UNCERTAIN OF THEIR INDIVIDUAL
RESPONSIBILITY FOR ENSURING THAT REGULATORY EVENTS WERE DISCLOSED ON FORMS U4 AND U5. FINRA FOUND THAT THE FIRM DISADVANTAGED
CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL
FUNDS WITHOUT A FRONT-END SALES CHARGE (ELIGIBLE CUSTOMERS). THESE ELIGIBLE CUSTOMERS WERE INSTEAD SOLD CLASS A SHARES WITH A
FRONT-END SALES CHARGE OR CLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHER ONGOING FEES AND EXPENSES. DURING THE
PERIOD, THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT THE

ELIGIBLE CUSTOMERS RECEIVED THE BENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM FAILED TO REASONABLY SUPERVISE THE
APPLICATION OF SALES CHARGE WAIVERS TO ELIGIBLE MUTUAL FUND SALES. THE FIRM RELIED ON ITS FINANCIAL ADVISORS TO DETERMINE THE
APPLICABILITY OF SALES CHARGE WAIVERS, BUT FAILED TO MAINTAIN ADEQUATE WRITTEN POLICIES OR PROCEDURES TO ASSIST FINANCIAL
ADVISORS IN MAKING THIS DETERMINATION. IN ADDITION, THE FIRM FAILED TO ADEQUATELY NOTIFY AND TRAIN ITS FINANCIAL ADVISORS REGARDING
THE AVAILABILITY OF MUTUAL FUND SALES CHARGE WAIVERS FOR ELIGIBLE CUSTOMERS. THE FIRM FAILED TO ADOPT ADEQUATE CONTROLS TO
DETECT INSTANCES IN WHICH IT DID NOT PROVIDE SALES CHARGE WAIVERS TO ELIGIBLE CUSTOMERS IN CONNECTION WITH THEIR MUTUAL FUND
PURCHASES. FINRA ALSO FOUND THAT THE FIRM FAILED TO PRODUCE CERTAIN RESPONSIVE DOCUMENTS TO SEVEN ARBITRATION CLAIMANTS WHO
ALLEGED THAT THE FIRM FAILED TO SUPERVISE THE FORMER REGISTERED REPRESENTATIVE.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
11/17/2016
 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: $ 1,575,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING AND REMEDIATION PAYMENTS
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 FIRM WAS CENSURED AND FINED $1,575,000. REMEDIATION PAYMENTS TOTALING $703,122 TO BE PAID TO THE SEVEN SETS OF
ARBITRATION CLAIMANTS, AND ADDITIONAL REMEDIATION TOTALING APPROXIMATELY $1,142,619 PAID TO THE ELIGIBLE CUSTOMERS WHO,
FROM JANUARY 2009 TO AUGUST 2016, QUALIFIED FOR, BUT DID NOT RECEIVE, THE APPLICABLE MUTUAL FUND SALES CHARGE WAIVERS. THE
FIRM IS REQUIRED TO CERTIFY TO FINRA ENFORCEMENT, WITHIN 90 DAYS OF THE ISSUANCE OF THE AWC THAT IT HAS ADOPTED AND
IMPLEMENTED WRITTEN SUPERVISORY POLICIES AND PROCEDURES REASONABLY DESIGNED TO ADDRESS THE DEFICIENCIES IDENTIFIED IN THE
AWC.
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 FIRM SELF-REPORTED TO FINRA THAT ELIGIBLE CUSTOMERS HAD NOT RECEIVED AVAILABLE SALES CHARGE WAIVERS. AS A RESULT OF THE
FAILURE OF THE FIRM TO APPLY AVAILABLE SALES CHARGE WAIVERS, THE FIRM ESTIMATES THAT ELIGIBLE CUSTOMERS WERE OVERCHARGED BY
APPROXIMATELY $1,010,327 FOR MUTUAL FUND PURCHASES MADE. AS PART OF THIS SETTLEMENT, THE FIRM HAS PAID RESTITUTION TO ELIGIBLE
CUSTOMERS, WHICH IS ESTIMATED TO TOTAL $1,142,619 (I.E., THE AMOUNT ELIGIBLE CUSTOMERS WERE OVERCHARGED, INCLUSIVE OF INTEREST).
THE FIRM WILL ALSO ENSURE THAT RETIREMENT AND CHARITABLE WAIVERS ARE APPROPRIATELY APPLIED TO ALL FUTURE TRANSACTIONS. SOLELY
WITH RESPECT TO THE PORTION OF THIS MATTER THAT RELATES TO THE FIRM'S FAILURE TO PROVIDE SALES CHARGE WAIVERS, FINRA HAS
RECOGNIZED THE COOPERATION OF THE FIRM FOR HAVING: INITIATED IN AUGUST 2015, PRIOR TO DETECTION OR INTERVENTION BY A REGULATOR,
AN INVESTIGATION TO IDENTIFY WHETHER ELIGIBLE CUSTOMERS RECEIVED SALES CHARGE WAIVERS DURING THE RELEVANT PERIOD; PROMPTLY
ESTABLISHED A PLAN OF REMEDIATION FOR ELIGIBLE CUSTOMERS WHO DID NOT RECEIVE APPROPRIATE SALES CHARGE WAIVERS; PROMPTLY SELF-
REPORTED TO FINRA; PROMPTLY TAKEN ACTION AND REMEDIAL STEPS TO CORRECT THE VIOLATIVE CONDUCT; AND EMPLOYED SUBSEQUENT
CORRECTIVE MEASURES, PRIOR TO DETECTION OR INTERVENTION BY A REGULATOR, TO REVISE ITS PROCEDURES TO AVOID RECURRENCE OF THE
MISCONDUCT.

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) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/29/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2015044484601
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Debt - Municipal
Other Product Types: 

7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED ON 43
OCCASIONS TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THE CALL DATE AND DOLLAR PRICE OF THE CALL IN 43
TRANSACTIONS IN MUNICIPAL SECURITIES EXECUTED ON THE BASIS OF A YIELD TO CALL. THE FINDINGS STATED THAT THE FIRM FAILED ON THREE
OCCASIONS TO PROVIDE WRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THE CORRECT LOWEST EFFECTIVE YIELD IN THREE TRANSACTIONS
IN MUNICIPAL SECURITIES AND PROVIDED ON ONE OCCASION WRITTEN NOTIFICATION IMPROPERLY DISCLOSING TO ITS CUSTOMER A YIELD TO CALL
IN ONE TRANSACTION IN A MUNICIPAL SECURITY WITH A VARIABLE INTEREST RATE.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
11/29/2016
 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: $ 20,000.00
 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 FIRM WAS CENSURED AND FINED $20,000.
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).

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) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/03/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-16243
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
NON-INVESTMENT GRADE OR "JUNK" BONDS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
SEC ADMIN RELEASE 34-73509, NOVEMBER 3, 2014: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC
INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B),
15B(C)(2) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AGAINST OPPENHEIMER & CO., INC. ("OPPENHEIMER" OR "RESPONDENT"). IN
ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS
DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE
COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THE
COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, RESPONDENT CONSENTS TO THE
ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTIONS 15(B), 15B(C)(2) AND 21C OF
THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. ON THE BASIS
OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT: THESE PROCEEDINGS INVOLVE THE SALE OF NON-INVESTMENT GRADE OR
"JUNK" BONDS ISSUED BY THE COMMONWEALTH OF PUERTO RICO ("PUERTO RICO") BY OPPENHEIMER, A REGISTERED BROKER-DEALER AND
MUNICIPAL SECURITIES DEALER, TO CUSTOMERS IN AMOUNTS BELOW THE MINIMUM DENOMINATION OF THE ISSUE. RULE G-15(F) PROMULGATED BY
THE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") PROHIBITS DEALERS FROM EFFECTING CUSTOMER TRANSACTIONS IN MUNICIPAL
SECURITIES IN AMOUNTS BELOW THE MINIMUM DENOMINATIONS OF THE ISSUES. MINIMUM DENOMINATIONS ARE GENERALLY INTENDED TO LIMIT
SALES OF MUNICIPAL SECURITIES TO RETAIL CUSTOMERS FOR WHOM SUCH BONDS MAY NOT BE SUITABLE, BUT THE PROSCRIPTIONS OF RULE G-15(F)
APPLY TO ALL TRANSACTIONS WITH CUSTOMERS, REGARDLESS OF WHETHER THE SECURITIES ARE SUITABLE FOR THE CUSTOMER. IN MARCH 2014,

OPPENHEIMER VIOLATED MSRB RULE G-15(F) BY EXECUTING THREE UNSOLICITED SALES TRANSACTIONS IN THE PUERTO RICO BONDS WITH
CUSTOMERS IN AMOUNTS BELOW THE $100,000 MINIMUM DENOMINATION OF THE ISSUE ESTABLISHED BY THE ISSUER, PUERTO RICO, AND SPECIFIED
IN THE OFFICIAL STATEMENT. THE LIMITED EXCEPTIONS PROVIDED UNDER MSRB RULE G-15(F) FOR CUSTOMER TRANSACTIONS IN MUNICIPAL
SECURITIES BELOW THE MINIMUM DENOMINATION OF AN ISSUE DID NOT APPLY TO THESE TRANSACTIONS. RESPONDENT DID NOT HAVE ANY POLICIES
OR PROCEDURES CONCERNING MSRB RULE G-15(F). AS A RESULT OF THE CONDUCT, RESPONDENT WILLFULLY VIOLATED MSRB RULE G-15(F). AS A
RESULT OF RESPONDENT'S WILLFUL VIOLATIONS OF MSRB RULE G-15(F), RESPONDENT WILLFULLY VIOLATED SECTION 15B(C)(1) OF THE EXCHANGE
ACT.
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:
Order
11. Resolution Date (MM/DD/YYYY):
11/03/2014
 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: $ 61,200.00
 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: 
ACCORDINGLY, IT IS HEREBY ORDERED THAT: RESPONDENT CEASE-AND-DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY
FUTURE VIOLATIONS OF SECTION 15B(C)(1) OF THE EXCHANGE ACT AND MSRB RULE G-15(F) . RESPONDENT IS CENSURED. RESPONDENT SHALL,
WITHIN SEVEN (7) DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $61,200. RESPONDENT WILLFULLY
VIOLATED MSRB RULE G-15(F). AS A RESULT OF RESPONDENT'S WILLFUL VIOLATIONS OF MSRB RULE G-15(F), RESPONDENT WILLFULLY
VIOLATED SECTION 15B(C)(1) OF THE EXCHANGE ACT.
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).
IN DETERMINING TO ACCEPT THE OFFER, THE COMMISSION CONSIDERED REMEDIAL ACTS PROMPTLY UNDERTAKEN BY RESPONDENT. AFTER IT WAS
MADE AWARE THAT IT HAD EFFECTED CUSTOMER TRANSACTIONS IN THE 2014 BONDS BELOW THE MINIMUM DENOMINATION OF THE ISSUE,
RESPONDENT CANCELLED THE TRANSACTIONS. RESPONDENT WILL UNDERTAKE TO REVIEW THE ADEQUACY OF ITS EXISTING POLICIES AND
PROCEDURES RELATING TO COMPLIANCE WITH MSRB RULE G-15(F). AFTER THAT REVIEW, RESPONDENT WILL MAKE SUCH CHANGES AS ARE
NECESSARY TO EFFECT COMPLIANCE WITH MSRB RULE G-15(F), INCLUDING ADOPTING NEW POLICIES AND PROCEDURES OR SUPPLEMENTING
EXISTING POLICIES AND PROCEDURES. RESPONDENT WILL IMPLEMENT THESE POLICIES AND PROCEDURES, AND CONDUCT TRAINING AS TO THE
POLICIES AND PROCEDURES AND COMPLIANCE WITH MSRB RULE G-15(F). RESPONDENT WILL INFORM COMMISSION STAFF NO LATER THAN SIX (6)
MONTHS AFTER THE ENTRY OF THIS ORDER THAT IT HAS COMPLIED WITH THE ABOVE UNDERTAKINGS.

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) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/01/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2013038869101
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Debt - Municipal
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IN SIX
TRANSACTIONS, IT PURCHASED MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPAL SECURITIES FOR ITS
OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY MARK-UP OR MARK-DOWN) THAT WAS NOT FAIR AND REASONABLE, TAKING
INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO

THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION
WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER, OR MUNICIPAL SECURITIES
DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/01/2017
 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: $ 20,000.00
 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 FIRM WAS CENSURED, FINED $20,000, AND ORDERED TO PAY $10,301.44, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS.
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).

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) 
CBOE
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
10/04/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20150451860
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Options
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIOD BETWEEN JANUARY 19, 2010 AND JUNE 30, 2015 (THE REVIEW PERIOD), THE FIRM OVER-REPORTED OPTIONS POSITIONS TO THE
LARGE OPTIONS POSITION REPORT (LOPR) IN APPROXIMATELY 260,890 INSTANCES BECAUSE OF A CODING ERROR IN ITS LOPR LOGIC THAT CAUSED:
(I) RECORDS THAT WERE PROCESSED ON AN "AS OF" BASIS TO CLOSE A POSITION TO BE ERRONEOUSLY PROCESSED AS NEW OPENING POSITIONS
RATHER THAN CLOSING POSITIONS; AND (II) DISPARATE REPORTING OF CANCELLATION AND REBOOKING ACTIVITY TO THE LOPR FOLLOWING TRADE
CORRECTIONS. AS A RESULT, THE FIRM VIOLATED CBOE (EXCHANGE) RULES 4.2, 4.24 AND 4.13. DURING THE REVIEW PERIOD, THE FIRM'S
SUPERVISORY SYSTEM WAS INADEQUATE WITH RESPECT TO ACHIEVING COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS
POSITIONS TO THE LOPR SYSTEM. ADDITIONALLY, DURING THE REVIEW PERIOD AND THROUGH MAY 2017, THE FIRM'S WRITTEN SUPERVISORY
PROCEDURES WERE INADEQUATE WITH RESPECT TO ACHIEVING COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS POSITIONS
TO THE LOPR SYSTEM. SPECIFICALLY, THEY FAILED TO SPECIFY: (I) WHAT REVIEWS THE FIRM CONDUCTED, INCLUDING THE STEPS TO BE TAKEN IN
CONNECTION WITH SUCH REVIEWS, TO DETECT ISSUES RELATING TO THE FORMATTING OF ITS LOPR REPORT, ACTING-IN-CONCERT ACTIVITY, AND
REJECTED LOPR SUBMISSIONS; (II) THE PERSON(S) RESPONSIBLE FOR CONDUCTING SUCH REVIEWS; (III) THE FREQUENCY OF SUCH REVIEWS; AND
(IV) HOW THE REVIEWS ARE TO BE DOCUMENTED. AS A RESULT, THE FIRM VIOLATED EXCHANGE RULES 748(G) (FOR THE PERIOD PRIOR TO NOVEMBER
23, 2012), 748(H) (FOR THE PERIOD ON AND AFTER NOVEMBER 23, 2012), AND 707.
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:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
10/05/2017
 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: $ 625,000.00
 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 FIRM WAS CENSURED AND FINED $625,000.
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 FIRM MADE AND ENTERED INTO AN OFFER OF SETTLEMENT, STIPULATION OF FACTS AND CONSENT TO SANCTIONS, PURSUANT TO EXCHANGE RULE
4.13, SOLELY FOR THE PURPOSES OF THESE PROCEEDINGS AND TO SETTLE AND CONCLUDE ALL DISCIPLINARY ACTIONS BY THE EXCHANGE BASED ON
OR ARISING OUT OF THE FACTS HEREINAFTER STIPULATED. THE FIRM STIPULATES TO THE FACTS, CONSENTS TO THE CONCLUSION OF VIOLATIONS OF
CERTAIN PROVISIONS OF EXCHANGE RULES, AND CONSENTS TO THE IMPOSITION OF SANCTIONS SPECIFICALLY INCLUDING, BUT NOT LIMITED TO,
CONSENTING TO PAY THE FINE IMPOSED BY THE BUSINESS CONDUCT COMMITTEE CONSISTENT WITH THE OFFER, AND TO COMPLY WITH ALL OTHER
SANCTIONS, ALL AS HEREINAFTER SET FORTH, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR CONCLUSIONS IN THE STATEMENT OF
CHARGES. IN DETERMINING TO RESOLVE THIS MATTER, THE COMMITTEE TOOK INTO ACCOUNT THE FIRM'S ENSUING COOPERATION THROUGHOUT
FINRA'S INVESTIGATION AND THE SUBSEQUENT REMEDIAL MEASURES IMPLEMENTED BY THE FIRM, INCLUDING SIGNIFICANT SYSTEM ENHANCEMENTS.

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) 
NASDAQ PHLX LLC
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
10/04/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2014043493501
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Options
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIOD BETWEEN JANUARY 19, 2010 AND JUNE 30, 2015 (THE REVIEW PERIOD), THE FIRM OVER-REPORTED OPTIONS POSITIONS TO THE
LARGE OPTIONS POSITION REPORT (LOPR) IN APPROXIMATELY 260,890 INSTANCES BECAUSE OF A CODING ERROR IN ITS LOPR LOGIC THAT CAUSED:
(I) RECORDS THAT WERE PROCESSED ON AN "AS OF" BASIS TO CLOSE A POSITION TO BE ERRONEOUSLY PROCESSED AS NEW OPENING POSITIONS
RATHER THAN CLOSING POSITIONS; AND (II) DISPARATE REPORTING OF CANCELLATION AND REBOOKING ACTIVITY TO THE LOPR FOLLOWING TRADE
CORRECTIONS. AS A RESULT, THE FIRM VIOLATED NASDAQ PHLX LLC (EXCHANGE) RULES 1003 AND 707. DURING THE REVIEW PERIOD, THE FIRM'S
SUPERVISORY SYSTEM WAS INADEQUATE WITH RESPECT TO ACHIEVING COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS
POSITIONS TO THE LOPR SYSTEM. ADDITIONALLY, DURING THE REVIEW PERIOD AND THROUGH MAY 2017, THE FIRM'S WRITTEN SUPERVISORY
PROCEDURES WERE INADEQUATE WITH RESPECT TO ACHIEVING COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS POSITIONS
TO THE LOPR SYSTEM. SPECIFICALLY, THEY FAILED TO SPECIFY: (I) WHAT REVIEWS THE FIRM CONDUCTED, INCLUDING THE STEPS TO BE TAKEN IN
CONNECTION WITH SUCH REVIEWS, TO DETECT ISSUES RELATING TO THE FORMATTING OF ITS LOPR REPORT, ACTING-IN-CONCERT ACTIVITY, AND
REJECTED LOPR SUBMISSIONS; (II) THE PERSON(S) RESPONSIBLE FOR CONDUCTING SUCH REVIEWS; (III) THE FREQUENCY OF SUCH REVIEWS; AND
(IV) HOW THE REVIEWS ARE TO BE DOCUMENTED. AS A RESULT, THE FIRM VIOLATED EXCHANGE RULES 748(G) (FOR THE PERIOD PRIOR TO NOVEMBER
23, 2012), 748(H) (FOR THE PERIOD ON AND AFTER NOVEMBER 23, 2012), AND 707.
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:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
10/05/2017
 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: $ 75,000.00
 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 FIRM WAS CENSURED AND FINED $75,000.
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 FIRM MADE AND ENTERED INTO AN OFFER OF SETTLEMENT, STIPULATION OF FACTS AND CONSENT TO SANCTIONS, PURSUANT TO EXCHANGE RULE
960.7, SOLELY FOR THE PURPOSES OF THESE PROCEEDINGS AND TO SETTLE AND CONCLUDE ALL DISCIPLINARY ACTIONS BY THE EXCHANGE BASED
ON OR ARISING OUT OF THE FACTS HEREINAFTER STIPULATED. THE FIRM STIPULATES TO THE FACTS, CONSENTS TO THE CONCLUSION OF VIOLATIONS
OF CERTAIN PROVISIONS OF EXCHANGE RULES, AND CONSENTS TO THE IMPOSITION OF SANCTIONS SPECIFICALLY INCLUDING, BUT NOT LIMITED TO,
CONSENTING TO PAY THE FINE IMPOSED BY THE BUSINESS CONDUCT COMMITTEE CONSISTENT WITH THE OFFER, AND TO COMPLY WITH ALL OTHER
SANCTIONS, ALL AS HEREINAFTER SET FORTH, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR CONCLUSIONS IN THE STATEMENT OF
CHARGES. IN DETERMINING TO RESOLVE THIS MATTER, THE COMMITTEE TOOK INTO ACCOUNT THE FIRM'S ENSUING COOPERATION THROUGHOUT
FINRA'S INVESTIGATION AND THE SUBSEQUENT REMEDIAL MEASURES IMPLEMENTED BY THE FIRM, INCLUDING SIGNIFICANT SYSTEM ENHANCEMENTS.
(ASSOCIATED CASE NO. PHLX ENFORCEMENT 2017-14)

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) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
03/11/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-19040
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
SEC ADMIN RELEASE IA 5137, MARCH 11, 2019: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST
THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED AGAINST OPPENHEIMER & CO. INC. AND ITS AFFILIATE
OPPENHEIMER ASSET MANAGEMENT INC. (TOGETHER, "RESPONDENTS"). ON THE BASIS OF THIS ORDER AND RESPONDENTS' OFFERS, THE COMMISSION
FINDS THAT THESE PROCEEDINGS ARISE OUT OF BREACHES OF FIDUCIARY DUTY AND INADEQUATE DISCLOSURES BY THE RESPONDENTS IN
CONNECTION WITH THEIR MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE FEES IT RECEIVED. AT TIMES DURING THE RELEVANT PERIOD,
RESPONDENTS PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF
LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. RESPONDENTS RECEIVED 12B-1 FEES IN CONNECTION
WITH THESE INVESTMENTS. RESPONDENTS FAILED TO DISCLOSE IN THEIR FORM ADV OR OTHERWISE THE CONFLICTS OF INTEREST RELATED TO (A)
THEIR RECEIPT OF 12B-1 FEES, AND/OR (B) THEIR SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. DURING THE RELEVANT
PERIOD, RESPONDENTS RECEIVED 12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH MUTUAL FUND SHARE CLASSES. AS A RESULT OF
THE CONDUCT, RESPONDENTS WILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT.
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:
Order
11. Resolution Date (MM/DD/YYYY):
03/11/2019
 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:
UNDERTAKINGS AND PREJUDGMENT INTEREST
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 RESPONDENTS SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS
206(2) AND 207 OF THE ADVISERS ACT. RESPONDENTS ARE CENSURED, SHALL, JOINTLY AND SEVERALLY, PAY DISGORGEMENT OF $3,169,123
AND PREJUDGMENT INTEREST OF $359,254, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.
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).
RESPONDENTS HAVE SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. IN VIEW OF THE FOREGOING, THE
COMMISSION DEEMS IT APPROPRIATE IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE RESPONDENTS' OFFERS.
RESPONDENTS SELF-REPORTED TO THE COMMISSION THE VIOLATIONS DISCUSSED IN THIS ORDER PURSUANT TO THE DIVISION OF ENFORCEMENT'S
SHARE CLASS SELECTION DISCLOSURE INITIATIVE ("SCSD INITIATIVE"). ACCORDINGLY, THIS ORDER AND RESPONDENTS' OFFERS ARE BASED ON THE
INFORMATION SELF-REPORTED BY RESPONDENTS.

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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
UNSPECIFIED SECURITIES
3.
Date Initiated (MM/DD/YYYY): 
04/22/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2018057952801
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Other
Other Product Types: 
UNSPECIFIED SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT NEGLIGENTLY
MISREPRESENTED COST BASIS INFORMATION ON CUSTOMER ACCOUNT STATEMENTS AND FORMS 1099 AND MADE AND PRESERVED INACCURATE
ACCOUNT STATEMENTS. THE FINDINGS STATED THAT THE INDIVIDUAL WHO SUPERVISED THE GROUP THAT OPERATED THE FIRM'S DATABASE SYSTEM IN
WHICH IT MAINTAINED COST BASIS INFORMATION, AS WELL AS INFORMATION ABOUT THE TAXABLE GAIN OR LOSS RESULTING FROM ITS CUSTOMERS'
SECURITIES TRANSACTIONS, DID NOT UNDERSTAND THE REGULATIONS APPLICABLE TO POST-SETTLEMENT COST BASIS CHANGES. AS A RESULT, THE
FIRM REGULARLY GRANTED REQUESTS TO CHANGE COST BASIS INFORMATION IN THE CASE OF PARTIAL LIQUIDATIONS OF SECURITIES POSITIONS,
EVEN WHEN REQUESTS TO CHANGE THE TAX LOT SOLD WERE MADE AFTER THE SETTLEMENT DATE. EACH SUCH INSTANCE RESULTED IN THE FIRM
ISSUING AT LEAST ONE FORM 1099 IN WHICH IT MISREPRESENTED THE ADJUSTED BASIS AND ALSO RESULTED IN THE FIRM SENDING TO THE
CUSTOMER ONE OR MORE MONTHLY ACCOUNT STATEMENTS IN WHICH IT MISREPORTED ADJUSTED BASIS AND RELATED REALIZED AND UNREALIZED
GAIN OR LOSS INFORMATION. EMAILS AND DOCUMENTS PERTAINING TO THESE CHANGES, WHERE THEY EXIST, SHOWED THAT THE FIRM'S REGISTERED
REPRESENTATIVES AND OTHER OPERATIONS PERSONNEL, FOR THE MOST PART, LIKEWISE LACKED A PROPER UNDERSTANDING OF THE REGULATIONS
APPLICABLE TO POST-SETTLEMENT COST BASIS CHANGES. THE FIRM'S DATABASE SYSTEM THAT WAS SUPPOSED TO HAVE KEPT TRACK OF MANUAL
CHANGES TO COST BASIS LACKED BASIC INFORMATION ABOUT COST BASIS CHANGES, INCLUDING THE REASON FOR THE CHANGES. THIS DATABASE
SYSTEM ALSO CONTAINED FIELDS THAT COULD BE OVERWRITTEN AFTER THE DATE OF THE CHANGE. AS A RESULT, THERE WERE NUMEROUS INSTANCES
IN WHICH INFORMATION CONCERNING MANUAL COST BASIS CHANGES HAD BEEN OVERWRITTEN AND COULD NOT BE RETRIEVED.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
04/22/2021
 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: $ 525,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING
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 FIRM WAS CENSURED, FINED $525,000 AND REQUIRED TO RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW
OF THE ADEQUACY OF ITS PROCEDURES, SYSTEMS, AND CONTROLS TO TRACK AND REPORT COST BASIS INFORMATION RELATING TO ANY
UPDATES AND CHANGES MADE TO COST BASIS INFORMATION FOR CUSTOMER SECURITIES TRANSACTIONS.
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).

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) 
NYSE AMERICAN LLC
2.
Principal Sanction:
Other
Other Sanctions: 
OPTIONS
3.
Date Initiated (MM/DD/YYYY): 
06/21/2021
 Exact
 Explanation
If not exact, provide explanation:
DATE THE AWC BECAME FINAL
4.
Docket/Case Number:
20191200063 & 20201000112
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Options
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
ADHERE TO GOOD BUSINESS PRACTICES WITH RESPECT TO ITS HANDLING OF CUSTOMER OPTIONS ORDERS. THE FINDINGS STATED THAT BY
INSTRUCTING AN NYSE AMERICAN FLOOR BROKER TO PREEMPTIVELY CROSS AND SELL CALLS AT $1.70 BEFORE THE STOCK REACHED THE LIQUIDITY
PROVIDER'S CONTINGENT BID PRICE, A FIRM TRADER WAS ABLE TO AVOID COMPETITION FROM ON-FLOOR MARKET MAKERS IN THE TRADING CROWD.
THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO OBTAIN PRIOR AGREEMENT OF ITS CUSTOMER BEFORE NULLIFYING AND ADJUSTING A TRADE TO
A WORSE PRICE FOR THE CUSTOMER. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM
AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH ITS OBLIGATIONS FOR HANDLING CERTAIN CUSTOMER OPTIONS ORDERS
TRANSMITTED TO A FLOOR BROKER ON THE NYSE AMERICAN TRADING FLOOR. THE FIRM DID NOT CONDUCT A REVIEW OF OPTIONS ORDERS SENT TO
THE NYSE AMERICAN TRADING FLOOR WHERE AN EXECUTION WAS SUBSEQUENTLY NULLIFIED AND/OR ADJUSTED, AND SO DID NOT IDENTIFY TWO
TRADES. NOR DID THE FIRM HAVE ANY POLICIES OR PROCEDURES IN PLACE REQUIRING EMPLOYEES TO OBTAIN PRIOR CUSTOMER AGREEMENT FOR
PRICE ADJUSTMENTS. FINALLY, A DESK SUPERVISOR GAVE THE INSTRUCTIONS TO IMPROPERLY ADJUST THE PRICE ON A TRADE. FINRA FOUND THAT
THE FIRM IMPLEMENTED NEW PROCEDURES REQUIRING OPTIONS DESK EMPLOYEES TO DOCUMENT AND NOTIFY COMPLIANCE OF ALL TRADE
NULLIFICATIONS AND PRICE ADJUSTMENTS, AND TO OBTAIN PRIOR WRITTEN CUSTOMER AGREEMENT FOR ANY NULLIFIED OR ADJUSTED TRADES. THE
FIRM ALSO NOW CONDUCTS A DAILY REVIEW OF A REPORT IDENTIFYING ALL TRADE AMENDMENTS, ADJUSTMENTS, AND CANCELLATIONS. IN
CONNECTION WITH NYSE REGULATION'S INVESTIGATION, THE FIRM OFFERED THE CUSTOMER WHO WAS IMPACTED BY A TRADE RESTITUTION IN THE
AMOUNT OF $11,160.
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:
Acceptance, Waiver & Consent(AWC)

11. Resolution Date (MM/DD/YYYY):
06/21/2021
 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: $ 175,000.00
 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 FIRM WAS CENSURED AND FINED $175,000.
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).

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) 
NYSE ARCA, INC.
2.
Principal Sanction:
Other
Other Sanctions: 
OPTIONS
3.
Date Initiated (MM/DD/YYYY): 
03/24/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2022-05-13-00029
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Options
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED NYSE
ARCA RULE 11.1(B). THE FINDINGS STATED THAT THE FIRM FAILED TO OBTAIN THE MOST ADVANTAGEOUS TERMS FOR A CUSTOMER OPTIONS ORDER,
AND ALSO FAILED TO OBTAIN THE AGREEMENT OF ITS CUSTOMER PRIOR TO INSTRUCTING THE FLOOR BROKER TO NULLIFY AND ADJUST THE TRADE.
THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN SUPERVISORY SYSTEMS AND WRITTEN SUPERVISORY PROCEDURES
(WSPS) REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH ITS OBLIGATIONS FOR CERTAIN CUSTOMER OPTIONS ORDERS. THE FIRM DID NOT
HAVE POLICIES OR PROCEDURES IN PLACE REGARDING ITS OBLIGATIONS FOR THE HANDLING OF NOT-HELD ORDERS, INCLUDING WITH RESPECT TO
TRADE NULLIFICATION. ACCORDINGLY, THE FIRM VIOLATED NYSE ARCA RULES 11.18(B) AND (C).
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
03/24/2023
 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: $ 90,000.00
 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 FIRM WAS CENSURED AND FINED $90,000. IN CONNECTION WITH NYSE REGULATION'S INVESTIGATION, THE FIRM OFFERED THE CUSTOMER
RESTITUTION IN THE AMOUNT OF $25,400.
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).

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) 

CBOE EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
09/07/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. URE-146-01/STAR NO. 20200685197
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Options
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
OPPENHEIMER & CO. INC VIOLATED CBOE RULES 4.24 AND 8.16 IN THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WSPS REASONABLY
DESIGNED TO ENSURE COMPLIANCE WITH EXCHANGE LOPR RULES.
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:
Consent
11. Resolution Date (MM/DD/YYYY):
09/14/2023
 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: $ 450,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
AN UNDERTAKING DETAILED IN THE LETTER OF CONSENT
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: 
A CENSURE, A MONETARY FINE IN THE AMOUNT OF $450,000 AND AN UNDERTAKING DETAILED IN THE LETTER OF CONSENT.
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).

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) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
02/09/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-21852
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
No Product

Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE
AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, AGAINST OPPENHEIMER & CO. INC. ("OPPENHEIMER" OR "RESPONDENT"). IN
ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT ("OFFER") THAT THE
COMMISSION HAS DETERMINED TO ACCEPT. THE COMMISSION FINDS THAT OPPENHEIMER EMPLOYEES SENT AND RECEIVED OFF-CHANNEL
COMMUNICATIONS THAT RELATED TO THE BUSINESS OF THE BROKER-DEALER. RESPONDENT DID NOT MAINTAIN OR PRESERVE THE SUBSTANTIAL
MAJORITY OF THESE WRITTEN COMMUNICATIONS. RESPONDENT'S FAILURE WAS FIRM-WIDE AND INVOLVED EMPLOYEES AT ALL LEVELS OF AUTHORITY.
OPPENHEIMER'S SUPERVISORS, WHO WERE RESPONSIBLE FOR SUPERVISING JUNIOR EMPLOYEES, ROUTINELY COMMUNICATED OFF-CHANNEL USING
THEIR PERSONAL DEVICES. IN FACT, SENIOR MANAGEMENT, MANAGING DIRECTORS, AND OTHER OPPENHEIMER EMPLOYEES ACROSS THE FIRM
RESPONSIBLE FOR SUPERVISING JUNIOR EMPLOYEES THEMSELVES FAILED TO COMPLY WITH OPPENHEIMER'S POLICIES BY COMMUNICATING USING
NON-OPPENHEIMER APPROVED METHODS ON THEIR PERSONAL DEVICES ABOUT OPPENHEIMER'S BROKER-DEALER BUSINESS. OPPENHEIMER'S
WIDESPREAD FAILURE TO IMPLEMENT ITS POLICIES AND PROCEDURES THAT PROHIBIT SUCH COMMUNICATIONS LED TO ITS FAILURE TO REASONABLY
SUPERVISE ITS EMPLOYEES WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT. DURING THE TIME PERIOD THAT OPPENHEIMER
FAILED TO MAINTAIN AND PRESERVE OFF-CHANNEL COMMUNICATIONS ITS EMPLOYEES SENT AND RECEIVED RELATED TO THE BROKER-DEALER
BUSINESS, OPPENHEIMER RECEIVED AND RESPONDED TO COMMISSION SUBPOENAS FOR DOCUMENTS AND RECORDS REQUESTS IN NUMEROUS
COMMISSION INVESTIGATIONS. AS A RESULT, OPPENHEIMER RECORDKEEPING FAILURES LIKELY IMPACTED THE COMMISSION'S ABILITY TO CARRY OUT
ITS REGULATORY FUNCTIONS AND INVESTIGATE VIOLATIONS OF THE FEDERAL SECURITIES LAWS ACROSS THESE INVESTIGATIONS. COMMISSION
STAFF UNCOVERED OPPENHEIMER'S MISCONDUCT AFTER COMMENCING A RISK-BASED INITIATIVE TO INVESTIGATE THE USE OF OFF-CHANNEL AND
UNPRESERVED COMMUNICATIONS AT BROKER-DEALERS. OPPENHEIMER HAS INITIATED A REVIEW OF ITS RECORDKEEPING FAILURES AND BEGUN A
PROGRAM OF REMEDIATION. AS SET FORTH IN THE UNDERTAKINGS BELOW, OPPENHEIMER WILL RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT
TO REVIEW AND ASSESS OPPENHEIMER'S REMEDIAL STEPS RELATING TO ITS RECORDKEEPING PRACTICES, POLICIES AND PROCEDURES, RELATED
SUPERVISORY PRACTICES, AND EMPLOYMENT ACTIONS. AS A RESULT, OPPENHEIMER WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND
RULE 17A-4(B)(4) THEREUNDER.
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:
Order
11. Resolution Date (MM/DD/YYYY):
02/09/2024
 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: $ 12,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
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 FIRM IS ORDERED TO CEASE AND DESIST, IS CENSURED, SHALL COMPLY WITH UNDERTAKINGS ENUMERATED IN THE ORDER, AND SHALL PAY
A CIVIL PENALTY OF $12,000,000.
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).
OPPENHEIMER WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4) THEREUNDER. ACCORDINGLY, IT IS HEREBY
ORDERED THAT RESPONDENT CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)
OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER, IS CENSURED, SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER AND
SHALL PAY A CIVIL PENALTY OF $12,000,000.

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) 
COMMODITY FUTURES TRADING COMMISSION
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
03/19/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
24-04

5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION") HAS REASON TO BELIEVE THAT FROM AT LEAST 2019 TO THE PRESENT ("RELEVANT
PERIOD"), OPPENHEIMER & CO. INC. ("OPPENHEIMER" OR "RESPONDENT") VIOLATED, AS SET FORTH BELOW, SECTION 4G OF THE COMMODITY
EXCHANGE ACT ("ACT"), AND COMMISSION REGULATIONS ("REGULATIONS") 1.31, 1.35, AND 166.3. THEREFORE, THE COMMISSION DEEMS IT
APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED TO DETERMINE WHETHER
RESPONDENT ENGAGED IN THE VIOLATIONS SET FORTH HEREIN AND TO DETERMINE WHETHER ANY ORDER SHOULD BE ISSUED IMPOSING REMEDIAL
SANCTIONS. IN ANTICIPATION OF THE INSTITUTION OF AN ADMINISTRATIVE PROCEEDING, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT
("OFFER"), WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. THE COMMISSION FINDS THAT OPPENHEIMER EMPLOYEES, INCLUDING THOSE AT
SENIOR LEVELS, COMMUNICATED BOTH INTERNALLY AND EXTERNALLY USING UNAPPROVED METHODS, INCLUDING VIA PERSONAL TEXT MESSAGES
AND, IN THE CASE OF AT LEAST ONE EMPLOYEE, WHATSAPP MESSAGES. THESE WRITTEN COMMUNICATIONS WERE SENT AND RECEIVED BY
OPPENHEIMER EMPLOYEES AND INCLUDED MESSAGES RELATED TO OPPENHEIMER'S BUSINESS AS A COMMISSION REGISTRANT THAT WERE REQUIRED
TO BE MAINTAINED UNDER COMMISSION-MANDATED RECORDKEEPING REQUIREMENTS. THESE WRITTEN COMMUNICATIONS VIA UNAPPROVED
METHODS GENERALLY WERE NOT MAINTAINED AND PRESERVED BY OPPENHEIMER, AND OPPENHEIMER GENERALLY WOULD NOT HAVE BEEN ABLE TO
FURNISH THE COMMUNICATIONS PROMPTLY TO A COMMISSION REPRESENTATIVE IF AND WHEN REQUESTED. AS A RESULT, OPPENHEIMER VIOLATED,
AS SET FORTH BELOW, SECTION 4G OF THE ACT, AND REGULATIONS 1.31 AND 1.35. IN ADDITION, THE USE OF UNAUTHORIZED COMMUNICATION
METHODS BY OPPENHEIMER EMPLOYEES TO CONDUCT FIRM BUSINESS VIOLATED OPPENHEIMER'S OWN POLICIES AND PROCEDURES, WHICH
PROHIBITED SUCH COMMUNICATIONS. OPPENHEIMER DID NOT MAINTAIN ADEQUATE INTERNAL CONTROLS WITH RESPECT TO THE USE OF
UNAPPROVED COMMUNICATION METHODS FOR BUSINESS-RELATED COMMUNICATIONS. INDEED, SOME OF THE VERY SAME SUPERVISORY PERSONNEL
AT OPPENHEIMER RESPONSIBLE FOR ENSURING COMPLIANCE WITH OPPENHEIMER'S POLICIES AND PROCEDURES THEMSELVES UTILIZED
UNAPPROVED METHODS OF COMMUNICATION TO ENGAGE IN BUSINESS-RELATED COMMUNICATIONS, IN VIOLATION OF FIRM POLICY. BECAUSE
OPPENHEIMER FAILED TO IMPLEMENT A DILIGENT SUPERVISORY SYSTEM TO ENSURE COMPLIANCE WITH COMMISSION RECORDKEEPING
REQUIREMENTS AND THE FIRM'S OWN POLICIES AND PROCEDURES, AND BECAUSE THE USE OF UNAUTHORIZED COMMUNICATION METHODS RESULTED
IN THE FIRM'S FAILURE TO MAINTAIN COMMISSION-REQUIRED RECORDS, OPPENHEIMER FAILED TO DILIGENTLY SUPERVISE MATTERS RELATED TO ITS
BUSINESS AS A COMMISSION REGISTRANT IN VIOLATION OF REGULATION 166.3.
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:
Order
11. Resolution Date (MM/DD/YYYY):
03/19/2024
 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: $ 1,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
CONDITIONS & 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 FIRM IS ORDERED TO CEASE AND DESIST FROM VIOLATING SECTION 4G OF THE ACT, AND REGULATIONS 1.31, 1.35, AND 166.3, IS FINED
$1,000,000, AND HALL COMPLY WITH THE CONDITIONS AND UNDERTAKINGS SET FORTH IN THE OFFER.
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).
ACCORDINGLY, IT IS HEREBY ORDERED THAT OPPENHEIMER AND ITS SUCCESSORS AND ASSIGNS SHALL CEASE AND DESIST FROM VIOLATING SECTION
4G OF THE ACT, AND REGULATIONS 1.31, 1.35, AND 166.3, IS FINED $1,000,000, AND RESPONDENT AND ITS SUCCESSORS AND ASSIGNS SHALL
COMPLY WITH THE CONDITIONS AND UNDERTAKINGS SET FORTH IN THE OFFER.

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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
05/07/2024
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
2017052438501
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Other
Other Product Types: 
DIRECT BUSINESS TRANSACTIONS AND HELD AWAY SECURITIES TRANSACTIONS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
REASONABLY SUPERVISE TRANSACTIONS THAT ITS REGISTERED REPRESENTATIVES PLACED DIRECTLY WITH PRODUCT SPONSORS ON BEHALF OF FIRM
CUSTOMERS (I.E., DIRECT BUSINESS TRANSACTIONS OR HELD AWAY SECURITIES TRANSACTIONS). THE FINDINGS STATED THAT THE FIRM DID NOT
TAKE STEPS REASONABLY DESIGNED TO ENSURE THAT DIRECT BUSINESS TRANSACTIONS APPEARED ON THE FIRM'S DAILY TRADE BLOTTER, CAUSING
THE FIRM TO FAIL TO RUN TRANSACTIONS, INCLUDING DIVIDEND REINVESTMENTS, FOR CUSTOMERS THROUGH EXCEPTION REPORTS USED TO
IDENTIFY POTENTIAL SALES PRACTICE VIOLATIONS, INCLUDING POTENTIALLY UNSUITABLE TRANSACTIONS. THE FIRM ALSO FAILED TO ENSURE THAT IT
COLLECTED INFORMATION FOR CUSTOMERS' INVESTMENT PROFILES, SUCH AS THE CUSTOMERS' AGES, INVESTMENT TIME HORIZONS, AND LIQUIDITY
NEEDS, THAT WAS RELEVANT FOR MAKING CERTAIN SUITABILITY DETERMINATIONS. SUBSEQUENTLY, THE FIRM REVISED ITS WSPS TO PROHIBIT DIRECT
TRANSACTIONS WITH MUTUAL FUND COMPANIES UNLESS A CORRESPONDING ACCOUNT HAS BEEN ESTABLISHED AT THE FIRM. THE FIRM ALSO
INSTITUTED PROCEDURES TO VERIFY THAT EACH DIRECT BUSINESS MUTUAL FUND TRANSACTION IS HOUSED IN A FIRM ACCOUNT OR, IF NOT, TO
REQUIRE REGISTERED REPRESENTATIVES TO PROMPTLY OBTAIN A NEW ACCOUNT APPLICATION AND OPEN AN ACCOUNT FOR THE CUSTOMER. THE
FIRM ALSO ESTABLISHED PROGRESSIVE DISCIPLINE MEASURES IF REPRESENTATIVES FAILED TO OBTAIN NEW ACCOUNT APPLICATIONS. ULTIMATELY,
THE FIRM BEGAN A RETROSPECTIVE REVIEW OF ITS DIRECT BUSINESS TRANSACTIONS DURING THE RELEVANT PERIOD. THAT REVIEW INVOLVED
IDENTIFYING THE DIRECT BUSINESS TRANSACTIONS THAT THE FIRM FAILED TO INCLUDE ON ITS TRADE BLOTTER AND REVIEWING THE TRANSACTIONS
ACCORDING TO THE PARAMETERS USED BY THE FIRM'S EXCEPTION REPORTING SYSTEM. THE FIRM ATTEMPTED TO COLLECT MISSING INFORMATION
ABOUT CUSTOMERS' INVESTMENT PROFILES. THE SUITABILITY OF CERTAIN OF THE TRANSACTIONS COULD NOT BE DETERMINED BECAUSE THE FIRM
WAS UNABLE TO COLLECT COMPLETE INFORMATION AT THE TIME OF THE RETROSPECTIVE REVIEW ABOUT CUSTOMERS' INVESTMENT PROFILES,
INCLUDING THEIR INVESTMENT TIME HORIZONS OR LIQUIDITY NEEDS THAT WOULD HAVE BEEN RELEVANT AT THE TIME OF THE PURCHASE.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
05/07/2024
 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: $ 500,000.00
 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 FIRM WAS CENSURED AND FINED $500,000.
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).

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) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/04/2026
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2023077058901

5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
OPPENHEIMER & CO. INC.
6.
Principal Product Type:
Other
Other Product Types: 
UNSPECIFIED SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT ITS CUSTOMER
ACCOUNT STATEMENTS CONTAINED INACCURATE AND MISLEADING INFORMATION CONCERNING COLLATERALIZED MORTGAGE OBLIGATIONS (CMOS)
ISSUED BY PRIVATE ENTITIES (PRIVATE LABEL CMOS). THE FINDINGS STATED THAT THE FIRM GENERATED AND SENT AN ESTIMATED 150,000 ACCOUNT
STATEMENTS TO MORE THAN 800 CUSTOMERS THAT MISCATEGORIZED ALL PRIVATE LABEL CMOS IN EACH CUSTOMER'S ACCOUNT UNDER THE HEADING
"GOVERNMENT AGENCY BONDS." CATEGORIZING PRIVATE LABEL CMOS AS GOVERNMENT AGENCY BONDS WAS INACCURATE AND MISLEADING BECAUSE
IT SUGGESTED THAT THE CMOS WERE GUARANTEED BY THE U.S. GOVERNMENT OR A GOVERNMENT-SPONSORED ENTITY. AFTER BEING ADVISED BY
FINRA OF THE INACCURACIES, THE FIRM MADE AN EFFORT TO ADDRESS THE ISSUE BY CHANGING THE CATEGORIZATION OF PRIVATE LABEL CMOS IN
CUSTOMER ACCOUNT STATEMENTS FROM "GOVERNMENT AGENCY BONDS" TO "CORPORATE BONDS." HOWEVER, THIS CHARACTERIZATION WAS
INACCURATE BECAUSE PRIVATE LABEL CMOS DIFFER FROM CORPORATE BONDS IN SEVERAL RESPECTS. THE FINDINGS ALSO STATED THAT THE FIRM
FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WSPS, REASONABLY DESIGNED TO REVIEW THE ACCURACY OF CUSTOMER
ACCOUNT STATEMENTS. ALTHOUGH THE FIRM'S WSPS REQUIRED FIRM PERSONNEL TO CONDUCT A BI-MONTHLY REVIEW OF A SAMPLE OF CUSTOMER
ACCOUNT STATEMENTS, THE REVIEW PRIMARILY FOCUSED ON THE ACCURACY OF NUMERICAL VALUES REPORTED IN THE STATEMENTS AND DID NOT
INCLUDE ANY REVIEW TO DETERMINE WHETHER CUSTOMER HOLDINGS WERE ACCURATELY CATEGORIZED. THE FIRM FAILED TO DETECT THAT PRIVATE
LABEL CMOS WERE INACCURATELY CATEGORIZED AS GOVERNMENT AGENCY BONDS AND CORPORATE BONDS IN CUSTOMER ACCOUNT STATEMENTS.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
05/04/2026
 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: $ 250,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
REQUIRED TO COMPLY WITH THE UNDERTAKING ENUMERATED IN THE AWC
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: 
REQUIRED TO COMPLY WITH THE UNDERTAKING ENUMERATED IN THE AWC
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).

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.) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Relief Sought:
Injunction
Other Relief Sought: 
DISGORGEMENT; PREJUDGMENT INTEREST; CIVIL MONETARY PENALTY
3.
Filing Date of Court Action (MM/DD/YYYY):
09/13/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Debt - Municipal
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): 
UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK - NEW YORK - 1:22-CV-07801
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
OPPENHEIMER & CO. INC.

7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
THE SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION"), FOR ITS COMPLAINT AGAINST OPPENHEIMER & CO. INC. ("OPPENHEIMER" OR
"DEFENDANT"), ALLEGES THAT THIS ACTION CONCERNS OPPENHEIMER'S REPEATED FAILURES TO COMPLY WITH THE REQUIREMENTS OF THE "LIMITED
OFFERING EXEMPTION," WHICH EXEMPTS CERTAIN "LIMITED OFFERINGS" OF MUNICIPAL SECURITIES FROM THE GENERAL REQUIREMENT TO PROVIDE
DISCLOSURES TO INVESTORS. THE LIMITED OFFERING EXEMPTION REQUIRES, AMONG OTHER THINGS, THAT UNDERWRITERS LIKE OPPENHEIMER HAVE
A REASONABLE BELIEF THAT THE MUNICIPAL SECURITIES ARE BEING SOLD ONLY TO SOPHISTICATED INVESTORS THAT ARE EACH BUYING THE
SECURITIES FOR A SINGLE ACCOUNT WITHOUT A PLAN TO DISTRIBUTE THEM. YET, FROM JUNE 15, 2017 THROUGH APRIL 27, 2022 (THE "RELEVANT
PERIOD"), OPPENHEIMER SOLD SECURITIES IN AT LEAST 354 MUNICIPAL OFFERINGS IN PURPORTED RELIANCE ON THE LIMITED OFFERING EXEMPTION
WHEN IT HAD NOT SATISFIED THE EXEMPTION REQUIREMENTS ("VIOLATIVE OFFERINGS"). IN EACH VIOLATIVE OFFERING, OPPENHEIMER SOLD
MUNICIPAL SECURITIES TO BROKER-DEALERS AND/OR INVESTMENT ADVISERS WHEN OPPENHEIMER DID NOT HAVE A REASONABLE BELIEF THAT THOSE
ENTITIES WERE BUYING FOR THEIR OWN ACCOUNTS. IN FACT, OPPENHEIMER KNEW OR SHOULD HAVE KNOWN THOSE ENTITIES MAY HAVE BEEN
BUYING THE SECURITIES ON BEHALF OF THEIR CUSTOMER AND/OR CLIENT ACCOUNTS. DESPITE THIS, OPPENHEIMER MADE NO INQUIRY TO
DETERMINE IF THOSE ENTITIES WERE BUYING ON BEHALF OF THEIR CUSTOMERS AND/OR CLIENTS AND, IF SO, WHETHER SUCH INVESTORS MET THE
EXEMPTION CRITERIA. THUS, OPPENHEIMER FAILED TO SATISFY THE LIMITED OFFERING EXEMPTION BECAUSE IT SOLD THE MUNICIPAL SECURITIES
WITHOUT A REASONABLE BELIEF THAT THE BROKER-DEALERS AND/OR INVESTMENT ADVISERS, OR ANY CUSTOMERS AND/OR CLIENTS ON WHOSE
BEHALF THEY MAY HAVE BEEN BUYING, WERE BOTH SOPHISTICATED AND BUYING THE SECURITIES FOR A SINGLE ACCOUNT. THROUGHOUT THE
RELEVANT PERIOD, OPPENHEIMER LACKED POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT IT COMPLIED WITH THE LIMITED
OFFERING EXEMPTION WHEN ACTING AS UNDERWRITER IN LIMITED OFFERINGS OF MUNICIPAL SECURITIES. AT THE SAME TIME, OPPENHEIMER MADE
DECEPTIVE STATEMENTS TO MUNICIPAL SECURITIES ISSUERS BY REPRESENTING THAT IT WOULD AND DID COMPLY WITH THE LIMITED OFFERING
EXEMPTION REQUIREMENTS. OPPENHEIMER WAS NEGLIGENT IN MAKING THESE STATEMENTS BECAUSE ITS REGULAR PRACTICE WAS TO NOT OBTAIN
THE INFORMATION NECESSARY TO KNOW WHETHER ITS SALES OF MUNICIPAL SECURITIES WOULD OR DID MEET THE LIMITED OFFERING EXEMPTION
REQUIREMENTS. THE 354 VIOLATIVE OFFERINGS THAT OPPENHEIMER CONDUCTED DID NOT MEET THE LIMITED OFFERING EXEMPTION REQUIREMENTS,
AND OPPENHEIMER KNEW OR SHOULD HAVE KNOWN ITS STATEMENTS TO THE CONTRARY WERE DECEPTIVE. IN CONNECTION WITH THE 354
VIOLATIVE OFFERINGS IT CONDUCTED, OPPENHEIMER REALIZED AT LEAST $1,938,580 IN NET PROFITS. UPON INFORMATION AND BELIEF,
OPPENHEIMER CONTINUES TO UNDERWRITE WHAT IT PURPORTS TO BE LIMITED OFFERINGS OF NEW ISSUE MUNICIPAL SECURITIES WITHOUT
SATISFYING THE LIMITED OFFERING EXEMPTION REQUIREMENTS. UPON INFORMATION AND BELIEF, OPPENHEIMER HAS ALSO FAILED TO IMPLEMENT
WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE LIMITED OFFERING EXEMPTION. ACCORDINGLY,
OPPENHEIMER VIOLATED EXCHANGE ACT RULE 15C2-12, MSRB RULE G-27, MSRB RULE G-17, AND EXCHANGE ACT SECTION 15B(C)(1).
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):
 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:
Other
12. Resolution Date (MM/DD/YYYY): 
12/10/2025
 Exact
 Explanation
If not exact, provide explanation:
JUDGMENT ENTERED BY CONSENT
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $ 1,200,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
SHALL COMPLY WITH ALL OF THE UNDERTAKINGS AND AGREEMENTS SET FORTH THEREIN.
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:
THE FIRM WAS PERMANENTLY RESTRAINED AND ENJOINED, FINED $1,200,000, AND SHALL COMPLY WITHALL OF THE UNDERTAKINGS AND
AGREEMENTS SET FORTH IN THE FINAL JUDGMENT.
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). 
ON DECEMBER 10, 2025, A FINAL JUDGMENT WAS ENTERED, BY CONSENT, AGAINST OPPENHEIMER & CO. INC.WHEREIN IT WAS PERMANENTLY

RESTRAINED AND ENJOINED FROM VIOLATING RULE 15C2-12 AND SECTION15B(C)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"),
AND RULES G-17 AND G-27 OFMSRB. THE FIRM SHALL PAY A CIVIL PENALTY IN THE AMOUNT OF $1,200,000 TO THE SEC, AND SHALL COMPLYWITH ALL
OF THE UNDERTAKINGS AND AGREEMENTS SET FORTH IN THE FINAL JUDGMENT.

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.) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Relief Sought:
Injunction
Other Relief Sought: 
DISGORGEMENT; PREJUDGMENT INTEREST; CIVIL MONETARY PENALTY
3.
Filing Date of Court Action (MM/DD/YYYY):
09/13/2022
 Exact
 Explanation

If not exact, provide explanation:
4.
Principal Product Type:
Debt - Municipal
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): 
UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK - NEW YORK - 1:22-CV-07801
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
OPPENHEIMER & CO. INC.
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
THE SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION"), FOR ITS COMPLAINT AGAINST OPPENHEIMER & CO. INC. ("OPPENHEIMER" OR
"DEFENDANT"), ALLEGES THAT THIS ACTION CONCERNS OPPENHEIMER'S REPEATED FAILURES TO COMPLY WITH THE REQUIREMENTS OF THE "LIMITED
OFFERING EXEMPTION," WHICH EXEMPTS CERTAIN "LIMITED OFFERINGS" OF MUNICIPAL SECURITIES FROM THE GENERAL REQUIREMENT TO PROVIDE
DISCLOSURES TO INVESTORS. THE LIMITED OFFERING EXEMPTION REQUIRES, AMONG OTHER THINGS, THAT UNDERWRITERS LIKE OPPENHEIMER HAVE
A REASONABLE BELIEF THAT THE MUNICIPAL SECURITIES ARE BEING SOLD ONLY TO SOPHISTICATED INVESTORS THAT ARE EACH BUYING THE
SECURITIES FOR A SINGLE ACCOUNT WITHOUT A PLAN TO DISTRIBUTE THEM. YET, FROM JUNE 15, 2017 THROUGH APRIL 27, 2022 (THE "RELEVANT
PERIOD"), OPPENHEIMER SOLD SECURITIES IN AT LEAST 354 MUNICIPAL OFFERINGS IN PURPORTED RELIANCE ON THE LIMITED OFFERING EXEMPTION
WHEN IT HAD NOT SATISFIED THE EXEMPTION REQUIREMENTS ("VIOLATIVE OFFERINGS"). IN EACH VIOLATIVE OFFERING, OPPENHEIMER SOLD
MUNICIPAL SECURITIES TO BROKER-DEALERS AND/OR INVESTMENT ADVISERS WHEN OPPENHEIMER DID NOT HAVE A REASONABLE BELIEF THAT THOSE
ENTITIES WERE BUYING FOR THEIR OWN ACCOUNTS. IN FACT, OPPENHEIMER KNEW OR SHOULD HAVE KNOWN THOSE ENTITIES MAY HAVE BEEN
BUYING THE SECURITIES ON BEHALF OF THEIR CUSTOMER AND/OR CLIENT ACCOUNTS. DESPITE THIS, OPPENHEIMER MADE NO INQUIRY TO
DETERMINE IF THOSE ENTITIES WERE BUYING ON BEHALF OF THEIR CUSTOMERS AND/OR CLIENTS AND, IF SO, WHETHER SUCH INVESTORS MET THE
EXEMPTION CRITERIA. THUS, OPPENHEIMER FAILED TO SATISFY THE LIMITED OFFERING EXEMPTION BECAUSE IT SOLD THE MUNICIPAL SECURITIES
WITHOUT A REASONABLE BELIEF THAT THE BROKER-DEALERS AND/OR INVESTMENT ADVISERS, OR ANY CUSTOMERS AND/OR CLIENTS ON WHOSE
BEHALF THEY MAY HAVE BEEN BUYING, WERE BOTH SOPHISTICATED AND BUYING THE SECURITIES FOR A SINGLE ACCOUNT. THROUGHOUT THE
RELEVANT PERIOD, OPPENHEIMER LACKED POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT IT COMPLIED WITH THE LIMITED
OFFERING EXEMPTION WHEN ACTING AS UNDERWRITER IN LIMITED OFFERINGS OF MUNICIPAL SECURITIES. AT THE SAME TIME, OPPENHEIMER MADE
DECEPTIVE STATEMENTS TO MUNICIPAL SECURITIES ISSUERS BY REPRESENTING THAT IT WOULD AND DID COMPLY WITH THE LIMITED OFFERING
EXEMPTION REQUIREMENTS. OPPENHEIMER WAS NEGLIGENT IN MAKING THESE STATEMENTS BECAUSE ITS REGULAR PRACTICE WAS TO NOT OBTAIN
THE INFORMATION NECESSARY TO KNOW WHETHER ITS SALES OF MUNICIPAL SECURITIES WOULD OR DID MEET THE LIMITED OFFERING EXEMPTION
REQUIREMENTS. THE 354 VIOLATIVE OFFERINGS THAT OPPENHEIMER CONDUCTED DID NOT MEET THE LIMITED OFFERING EXEMPTION REQUIREMENTS,
AND OPPENHEIMER KNEW OR SHOULD HAVE KNOWN ITS STATEMENTS TO THE CONTRARY WERE DECEPTIVE. IN CONNECTION WITH THE 354
VIOLATIVE OFFERINGS IT CONDUCTED, OPPENHEIMER REALIZED AT LEAST $1,938,580 IN NET PROFITS. UPON INFORMATION AND BELIEF,
OPPENHEIMER CONTINUES TO UNDERWRITE WHAT IT PURPORTS TO BE LIMITED OFFERINGS OF NEW ISSUE MUNICIPAL SECURITIES WITHOUT
SATISFYING THE LIMITED OFFERING EXEMPTION REQUIREMENTS. UPON INFORMATION AND BELIEF, OPPENHEIMER HAS ALSO FAILED TO IMPLEMENT
WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE LIMITED OFFERING EXEMPTION. ACCORDINGLY,
OPPENHEIMER VIOLATED EXCHANGE ACT RULE 15C2-12, MSRB RULE G-27, MSRB RULE G-17, AND EXCHANGE ACT SECTION 15B(C)(1).
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):
 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:
Judgment Rendered
12. Resolution Date (MM/DD/YYYY): 
12/10/2025
 Exact
 Explanation
If not exact, provide explanation:
JUDGMENT ENTERED BY CONSENT
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $ 1,200,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:

SHALL COMPLY WITH ALL OF THE UNDERTAKINGS AND AGREEMENTS SET FORTH THEREIN.
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:
THE FIRM WAS PERMANENTLY RESTRAINED AND ENJOINED, FINED $1,200,000, AND SHALL COMPLY WITH ALL OF THE UNDERTAKINGS AND
AGREEMENTS SET FORTH IN THE FINAL JUDGMENT.
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). 
ON DECEMBER 10, 2025, A FINAL JUDGMENT WAS ENTERED, BY CONSENT, AGAINST OPPENHEIMER & CO. INC. WHEREIN IT WAS PERMANENTLY
RESTRAINED AND ENJOINED FROM VIOLATING RULE 15C2-12 AND SECTION 15B(C)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"),
AND RULES G-17 AND G-27 OF MSRB. THE FIRM SHALL PAY A CIVIL PENALTY IN THE AMOUNT OF $1,200,000 TO THE SEC, AND SHALL COMPLY WITH ALL
OF THE UNDERTAKINGS AND AGREEMENTS SET FORTH IN THE FINAL JUDGMENT.