Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Total AUM
Total Accounts
10Y AUM Change
Private Funds
Private funds reported by Northland Asset Management
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Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Total Employees
Clients per Employee
10Y Employee Change
Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.
Ownership
Reported direct and indirect ownership ranges
Each range applies to a separate reported relationship and should not be added together.
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
0%25%50%75%100%
NORTHLAND CAPITAL HOLDINGS, INC.Direct owner · Schedule AInterest in NORTHLAND ASSET MANAGEMENT
75%+
FIRST NATIONAL OF NEBRASKA, INC.Indirect owner · Schedule BInterest in NORTHLAND CAPITAL HOLDINGS, INC.
75%+
LAURITZEN CORPORATIONIndirect owner · Schedule BInterest in FIRST NATIONAL OF NEBRASKA, INC.
25% to < 50%
JOHN R. LAURITZEN IRREVOCABLE TRUSTIndirect owner · Schedule BInterest in LAURITZEN CORPORATION
25% to < 50%
Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Northland Asset Management.
Reported ownership and control details
Form ADV · Filing date 2026-09-22 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | RANDY GENE NITZSCHECEO, PRESIDENTIndividual | NORTHLAND ASSET MANAGEMENT | Less than 5%Code NA | Yes | CEO, PRESIDENT09/2002 | Schedule APDF page 27 |
| 2 | NORTHLAND CAPITAL HOLDINGS, INC.DIRECT OWNERDomestic entity | NORTHLAND ASSET MANAGEMENT | 75% or moreCode E | Yes | DIRECT OWNER01/2004 | Schedule APDF page 27 |
| 3 | DUSTIN RICHARD ALDENCHIEF FINANCIAL OFFICER, FINOPIndividual | NORTHLAND ASSET MANAGEMENT | Less than 5%Code NA | Yes | CHIEF FINANCIAL OFFICER, FINOP08/2017 | Schedule APDF page 27 |
| 4 | TRACI LEE SPANIERCHIEF COMPLIANCE OFFICERIndividual | NORTHLAND ASSET MANAGEMENT | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER05/2021 | Schedule APDF page 27 |
| 5 | TIFFANY DAWN HENNDIRECTORIndividual | NORTHLAND ASSET MANAGEMENT | Less than 5%Code NA | Yes | DIRECTOR05/2023 | Schedule APDF page 27 |
| 6 | CHRISTOPHER ROBERT RUGGIERODIRECTORIndividual | NORTHLAND ASSET MANAGEMENT | Less than 5%Code NA | No | DIRECTOR03/2026 | Schedule APDF page 27 |
| 7 | FIRST NATIONAL OF NEBRASKA, INC.DIRECT OWNERDomestic entity | NORTHLAND CAPITAL HOLDINGS, INC. | 75% or moreCode E | Yes | DIRECT OWNER05/2023 | Schedule BPDF page 28 |
| 8 | LAURITZEN CORPORATIONDIRECT OWNERDomestic entity | FIRST NATIONAL OF NEBRASKA, INC. | 25% to less than 50%Code C | No | DIRECT OWNER06/1997 | Schedule BPDF page 28 |
| 9 | JOHN R. LAURITZEN IRREVOCABLE TRUSTDIRECT OWNERDomestic entity | LAURITZEN CORPORATION | 25% to less than 50%Code C | No | DIRECT OWNER06/1984 | Schedule BPDF page 28 |
| 10 | FIRST NATIONAL BANK OF OMAHATRUSTEEDomestic entity | JOHN R. LAURITZEN IRREVOCABLE TRUST | Percentage not specifiedCode F | No | TRUSTEE12/1972 | Schedule BPDF page 28 |
Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.
Compliance & Disclosures
Filing dated 9/22/2026 11:59:00 AM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
RIA or supervised-person involvementThe RIA reported that none of the events below involve the firm or its supervised persons.RIA responseNo
AFelonies2 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?No
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions3 Yes2 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions3 Yes2 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?Yes
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?Yes
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions1 Yes3 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 11 source blocks
Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.
regulatory · block 1PDF pages 28–30
- Regulator name — filed text
- NASD NATIONAL ASSOCIATION OF SECURITIES DEALERS
- Monetary/Fine Amount — filed text
- $ 5,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM WAS FINED $5000.00 WHICH WAS PAID ON OR ABOUT 3/20/2007.
Other filed details
Description of allegations — filed text
NASD RULE 606 NORTHLAND FAILED TO MAKE PUBLICLY AVAILABLE FOR THE 4TH CALENDAR QUARTER OF 2004 THROUGH THE THIRD CALENDAR QUARTER OF 2005 A COMPLETE REPORT ON ITS ROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITEIS DURING THOSE QUARTERS.
Sanction detail — filed text
$5,000 FINE
Full extracted filing text
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) NASD NATIONAL ASSOCIATION OF SECURITIES DEALERS 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: FINE $5,000 3. Date Initiated (MM/DD/YYYY): 03/20/2007 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 20060045897-01 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): NASD RULE 606 NORTHLAND FAILED TO MAKE PUBLICLY AVAILABLE FOR THE 4TH CALENDAR QUARTER OF 2004 THROUGH THE THIRD CALENDAR QUARTER OF 2005 A COMPLETE REPORT ON ITS ROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITEIS DURING THOSE QUARTERS. 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): 03/20/2007 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: NONE 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: $5,000 FINE 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, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM WAS FINED $5000.00 WHICH WAS PAID ON OR ABOUT 3/20/2007.
regulatory · block 2PDF pages 30–32
- Regulator name — filed text
- NASD NATIONAL ASSOCIATION OF SECURITIES DEALERS
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
WITHOUT OR ADMITTING OR DENYING THE FINDS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM ACCEPTED THE FINE OF $10000.00 WHICH WAS PAID IN FULL ON 1/7/2007.
Other filed details
Description of allegations — filed text
NORTHLAND TRANSFERRED INVESTOR FUNDS FOR PRIVATE PLACEMENT OFFERINGS TO AN ESCROW ACCOUNT UNDER THE CONTROL OF AFFILATED COMPANY NORTHLAND TRUST SERVICES. NORTHLAND RELEASED INVESTOR FUNDS PRIOR TO CONTINGENCY BEING MET WITH BONA FIDE INVESTORS, AS DIRECTORS OR OFFICERS PARTICIPATED IN OFFERING AND THIS DISCLOSURE WAS NOT INCLUDED IN THE PPM
Sanction detail — filed text
$10,000 PAID IN FULL ON 1/7/2007
Full extracted filing text
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) NASD NATIONAL ASSOCIATION OF SECURITIES DEALERS 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: $10,000 FINE 3. Date Initiated (MM/DD/YYYY): 12/11/2006 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: E0420050078-01 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: PRIVATE PLACEMENT 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): NORTHLAND TRANSFERRED INVESTOR FUNDS FOR PRIVATE PLACEMENT OFFERINGS TO AN ESCROW ACCOUNT UNDER THE CONTROL OF AFFILATED COMPANY NORTHLAND TRUST SERVICES. NORTHLAND RELEASED INVESTOR FUNDS PRIOR TO CONTINGENCY BEING MET WITH BONA FIDE INVESTORS, AS DIRECTORS OR OFFICERS PARTICIPATED IN OFFERING AND THIS DISCLOSURE WAS NOT INCLUDED IN THE PPM 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): 12/21/2006 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: $10,000 PAID IN FULL ON 1/7/2007 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 OR ADMITTING OR DENYING THE FINDS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM ACCEPTED THE FINE OF $10000.00 WHICH WAS PAID IN FULL ON 1/7/2007.
regulatory · block 3PDF pages 32–33
- Regulator name — filed text
- FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)
- Monetary/Fine Amount — filed text
- $ 5,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
THE FIRM FOUND THAT MOST OF THE TRADE REPORTING VIOLATIONS WERE DUE TO MISUNDERSTANDING OF HOW THE SYSTEM WAS REPORTING TRADES AND ALSO THE REPORTS PROVIDED WERE NOT GOOD INDICATORS OF REPORTING PROBLEMS. THE FIRM HAS CORRECTED SYSTEM ISSUES AND HAVE SUBSCRIBED TO NASDAQ'S SYSTEM IN ORDER TO TRACK REPORTS IN REAL TIME. THE WRITTEN SUPERVISORY PROCEDURES WERE UPDATED AND PROVIDED TO FINRA FOR REVIEW AND WERE FOUND TO BE SATISFACTORY.
Other filed details
Description of allegations — filed text
THE FIRM WAS CITED FOR VARIOUS TRADE REPORTING VIOLATIONS DUE TO INCORRECT TRADE INDICATORS AND FAILURE TO DISCLOSE TRADE CAPACITY AND MARKET MAKER STATUS ON CUSTOMER CONFIRMATIONS. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WERE ALSO FOUND TO BE INADEQUATE.
Sanction detail — filed text
FINE WAS PAID BY APPLICANT VIA CHECK ON JULY 19,2010
Full extracted filing text
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) FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 07/15/2010 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2008012608401 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Equity - OTC Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE FIRM WAS CITED FOR VARIOUS TRADE REPORTING VIOLATIONS DUE TO INCORRECT TRADE INDICATORS AND FAILURE TO DISCLOSE TRADE CAPACITY AND MARKET MAKER STATUS ON CUSTOMER CONFIRMATIONS. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WERE ALSO FOUND TO BE INADEQUATE. 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): 07/15/2010 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: 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: FINE WAS PAID BY APPLICANT VIA CHECK ON JULY 19,2010 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 FOUND THAT MOST OF THE TRADE REPORTING VIOLATIONS WERE DUE TO MISUNDERSTANDING OF HOW THE SYSTEM WAS REPORTING TRADES AND ALSO THE REPORTS PROVIDED WERE NOT GOOD INDICATORS OF REPORTING PROBLEMS. THE FIRM HAS CORRECTED SYSTEM ISSUES AND HAVE SUBSCRIBED TO NASDAQ'S SYSTEM IN ORDER TO TRACK REPORTS IN REAL TIME. THE WRITTEN SUPERVISORY PROCEDURES WERE UPDATED AND PROVIDED TO FINRA FOR REVIEW AND WERE FOUND TO BE SATISFACTORY.
regulatory · block 4PDF pages 34–35
- Regulator name — filed text
- THE NASDAQ STOCK MARKET LLC (NASDAQ)
- Monetary/Fine Amount — filed text
- $ 7,500.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
THE FIRM CORRECTED SYSTEM ISSUES AND UPDATED AND SUBSRIBED TO NASDAQ'S SERVICE TO BETTER MONITOR REPORTING, AS WELL AS, UPDATING WRITTEN SUPERVISORY PROCEDURES.
Other filed details
Description of allegations — filed text
THE FIRM FAILED TO CORRECTLY INDICATE WHETHER ORDERS WERE A BUY, SHORT SALE OR LONG SALE WHICH ARE VIOLATIONS OF NASDAQ RULE 4755.
Sanction detail — filed text
APPLICANT WILL PAY THE FINE VIA CHECK AS SOON AS INVOICE IS RECEIVED FROM NASDAQ IN AUGUST 2010.
Full extracted filing text
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) THE NASDAQ STOCK MARKET LLC (NASDAQ) 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 05/12/2010 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2008012608402 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Equity - OTC Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE FIRM FAILED TO CORRECTLY INDICATE WHETHER ORDERS WERE A BUY, SHORT SALE OR LONG SALE WHICH ARE VIOLATIONS OF NASDAQ RULE 4755. 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): 07/15/2010 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: APPLICANT WILL PAY THE FINE VIA CHECK AS SOON AS INVOICE IS RECEIVED FROM NASDAQ IN AUGUST 2010. 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 CORRECTED SYSTEM ISSUES AND UPDATED AND SUBSRIBED TO NASDAQ'S SERVICE TO BETTER MONITOR REPORTING, AS WELL AS, UPDATING WRITTEN SUPERVISORY PROCEDURES.
regulatory · block 5PDF pages 35–37
- Regulator name — filed text
- UNITED STATES SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 220,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
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 $220,000 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.
Other filed details
Description of allegations — filed text
SEC ADMIN RELEASES 33-9946; 34-76043; SEPTEMBER 30, 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 NORTHLAND SECURITIES, 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.
Sanction detail — filed text
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 $220,000 AND COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.
Full extracted filing text
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):
09/30/2015
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-16858
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 33-9946; 34-76043; SEPTEMBER 30, 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 NORTHLAND
SECURITIES, 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.
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):
09/30/2015
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: $ 220,000.00
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 $220,000 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 $220,000 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.regulatory · block 6PDF pages 37–39
- Regulator name — filed text
- NASD NATIONAL ASSOCIATION OF SECURITIES DEALERS
- Monetary/Fine Amount — filed text
- $ 5,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
NASD RULE 606 NORTHLAND FAILED TO MAKE PUBLICLY AVAILABLE FOR THE 4TH CALENDAR QUARTER OF 2004 THROUGH THE THIRD CALENDAR QUARTER OF 2005 A COMPLETE REPORT ON ITS ROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITEIS DURING THOSE QUARTERS.
Sanction detail — filed text
$5,000 FINE
Full extracted filing text
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) NASD NATIONAL ASSOCIATION OF SECURITIES DEALERS 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: FINE $5,000 3. Date Initiated (MM/DD/YYYY): 03/20/2007 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 20060045897-01 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): NASD RULE 606 NORTHLAND FAILED TO MAKE PUBLICLY AVAILABLE FOR THE 4TH CALENDAR QUARTER OF 2004 THROUGH THE THIRD CALENDAR QUARTER OF 2005 A COMPLETE REPORT ON ITS ROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITEIS DURING THOSE QUARTERS. 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): 03/20/2007 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: NONE 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: $5,000 FINE 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).
Show 5 more source blocks
regulatory · block 7PDF pages 39–41
- Regulator name — filed text
- NASD NATIONAL ASSOCIATION OF SECURITIES DEALERS
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
NORTHLAND TRANSFERRED INVESTOR FUNDS FOR PRIVATE PLACEMENT OFFERINGS TO AN ESCROW ACCOUNT UNDER THE CONTROL OF AFFILATED COMPANY NORTHLAND TRUST SERVICES. NORTHLAND RELEASED INVESTOR FUNDS PRIOR TO CONTINGENCY BEING MET WITH BONA FIDE INVESTORS, AS DIRECTORS OR OFFICERS PARTICIPATED IN OFFERING AND THIS DISCLOSURE WAS NOT INCLUDED IN THE PPM
Sanction detail — filed text
$10,000 PAID IN FULL ON 1/7/2007
Full extracted filing text
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) NASD NATIONAL ASSOCIATION OF SECURITIES DEALERS 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: $10,000 FINE 3. Date Initiated (MM/DD/YYYY): 12/11/2006 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: E0420050078-01 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: PRIVATE PLACEMENT 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): NORTHLAND TRANSFERRED INVESTOR FUNDS FOR PRIVATE PLACEMENT OFFERINGS TO AN ESCROW ACCOUNT UNDER THE CONTROL OF AFFILATED COMPANY NORTHLAND TRUST SERVICES. NORTHLAND RELEASED INVESTOR FUNDS PRIOR TO CONTINGENCY BEING MET WITH BONA FIDE INVESTORS, AS DIRECTORS OR OFFICERS PARTICIPATED IN OFFERING AND THIS DISCLOSURE WAS NOT INCLUDED IN THE PPM 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): 12/21/2006 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: $10,000 PAID IN FULL ON 1/7/2007 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).
regulatory · block 8PDF pages 41–43
- Regulator name — filed text
- CBOE BZX EXCHANGE, INC.
- Monetary/Fine Amount — filed text
- $ 7,500.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
THE FIRM WAS CENSURED, FINED $7,500 AND REQUIRED TO ENSURE THAT THE ASSOCIATED PERSON DISCUSSED IN THE AWC BECOMES QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BZX, ASSUMING THE FIRM INTENDS FOR THE ASSOCIATED PERSON TO HAVE A ROLE IN SUPERVISING THE TRADING ACTIVITIES OF THE FIRM ON BZX GOING FORWARD. UNTIL THIS ASSOCIATED PERSON BECOMES QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL, THE INDIVIDUAL SHALL HAVE NO ROLE IN SUPERVISING THE FIRM'S TRADING ACTIVITIES ON BZX. THE FIRM SHALL INFORM FINRA THAT THE ASSOCIATED PERSON BECAME QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BZX. ALTERNATIVELY, IF THE FIRM DECIDES THAT THE ASSOCIATED PERSON SHALL NOT HAVE A ROLE IN SUPERVISING THE FIRM'S TRADING ACTIVITIES ON BZX GOING FORWARD, THE INFORMATION TO FINRA SHALL PROVIDE NOTICE OF THAT DECISION AND THE DATE OF THAT DECISION. THE DECISION IN THIS MATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE, THIS AWC WILL BECOME FINAL AUGUST 14, 2018. PAYMENT WAS REMITTED ON 7/26/2018. THE SUPERVISORY STRUCTURE WAS REVISED AND A QUALIFIED SERIES 24 SECURITIES TRADER PRINCIPAL IS NOW SUPERVISING THE TRADING DESK ACTIVITIES.
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REGISTER ONE ASSOCIATED PERSON AS BOTH A SERIES 57 GENERAL SECURITIES REPRESENTATIVE AND SERIES 24 GENERAL SECURITIES PRINCIPAL WITH BZX. THE SAME ASSOCIATED PERSON WAS ALSO NOT QUALIFIED OR REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BZX EVEN THOUGH THE PERSON HAD RESPONSIBILITY OVER SECURITIES TRADING ACTIVITIES ON BZX. ALTHOUGH THE PERSON HAD PASSED THE SERIES 24 EXAMINATION, THE PERSON HAD NOT PASSED THE SERIES 57 PREREQUISITE EXAMINATION. THE FINDINGS STATED THAT SEPARATELY, THE FIRM FAILED TO REGISTER A DIFFERENT ASSOCIATED PERSON, THE FIRM'S CHIEF COMPLIANCE OFFICER, AS A SERIES 7 GENERAL SECURITIES REPRESENTATIVE WITH BZX. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO FOLLOW ITS WRITTEN SUPERVISORY PROCEDURES TO ENSURE THAT ITS ASSOCIATED PERSONS WERE PROPERLY REGISTERED WITH THE EXCHANGE.
Sanction detail — filed text
THE SUPERVISORY STRUCTURE WAS REVISED AND A QUALIFIED SERIES 24 SECURITIES TRADER PRINCIPAL IS NOW SUPERVISING THE TRADING DESK ACTIVITIES.
Full extracted filing text
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 BZX EXCHANGE, INC. 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 07/17/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2017053084601 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 REGISTER ONE ASSOCIATED PERSON AS BOTH A SERIES 57 GENERAL SECURITIES REPRESENTATIVE AND SERIES 24 GENERAL SECURITIES PRINCIPAL WITH BZX. THE SAME ASSOCIATED PERSON WAS ALSO NOT QUALIFIED OR REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BZX EVEN THOUGH THE PERSON HAD RESPONSIBILITY OVER SECURITIES TRADING ACTIVITIES ON BZX. ALTHOUGH THE PERSON HAD PASSED THE SERIES 24 EXAMINATION, THE PERSON HAD NOT PASSED THE SERIES 57 PREREQUISITE EXAMINATION. THE FINDINGS STATED THAT SEPARATELY, THE FIRM FAILED TO REGISTER A DIFFERENT ASSOCIATED PERSON, THE FIRM'S CHIEF COMPLIANCE OFFICER, AS A SERIES 7 GENERAL SECURITIES REPRESENTATIVE WITH BZX. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO FOLLOW ITS WRITTEN SUPERVISORY PROCEDURES TO ENSURE THAT ITS ASSOCIATED PERSONS WERE PROPERLY REGISTERED WITH THE EXCHANGE. 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): 07/26/2018 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: $ 7,500.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: REQUIRED TO INSURE THE SERIES 24 SUPERVISOR OF THE TRADING DESK IS REGISTERED AS A SECURITIES 24 SECURITIES TRADER. 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 SUPERVISORY STRUCTURE WAS REVISED AND A QUALIFIED SERIES 24 SECURITIES TRADER PRINCIPAL IS NOW SUPERVISING THE TRADING DESK ACTIVITIES. 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 $7,500 AND REQUIRED TO ENSURE THAT THE ASSOCIATED PERSON DISCUSSED IN THE AWC BECOMES QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BZX, ASSUMING THE FIRM INTENDS FOR THE ASSOCIATED PERSON TO HAVE A ROLE IN SUPERVISING THE TRADING ACTIVITIES OF THE FIRM ON BZX GOING FORWARD. UNTIL THIS ASSOCIATED PERSON BECOMES QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL, THE INDIVIDUAL SHALL HAVE NO ROLE IN SUPERVISING THE FIRM'S TRADING ACTIVITIES ON BZX. THE FIRM SHALL INFORM FINRA THAT THE ASSOCIATED PERSON BECAME QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BZX. ALTERNATIVELY, IF THE FIRM DECIDES THAT THE ASSOCIATED PERSON SHALL NOT HAVE A ROLE IN SUPERVISING THE FIRM'S TRADING ACTIVITIES ON BZX GOING FORWARD, THE INFORMATION TO FINRA SHALL PROVIDE NOTICE OF THAT DECISION AND THE DATE OF THAT DECISION. THE DECISION IN THIS MATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE, THIS AWC WILL BECOME FINAL AUGUST 14, 2018. PAYMENT WAS REMITTED ON 7/26/2018. THE SUPERVISORY STRUCTURE WAS REVISED AND A QUALIFIED SERIES 24 SECURITIES TRADER PRINCIPAL IS NOW SUPERVISING THE TRADING DESK ACTIVITIES.
regulatory · block 9PDF pages 43–45
- Regulator name — filed text
- CBOE BYX EXCHANGE, INC.
- Monetary/Fine Amount — filed text
- $ 7,500.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
THE FIRM WAS CENSURED, FINED $7,500 AND REQUIRED TO ENSURE THAT THE ASSOCIATED PERSON DISCUSSED IN THE AWC BECOMES QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BYX, ASSUMING THE FIRM INTENDS FOR THE ASSOCIATED PERSON TO HAVE A ROLE IN SUPERVISING THE TRADING ACTIVITIES OF THE FIRM ON BYX GOING FORWARD. UNTIL THIS ASSOCIATED PERSON BECOMES QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL, THE INDIVIDUAL SHALL HAVE NO ROLE IN SUPERVISING THE FIRM'S TRADING ACTIVITIES ON BYX. THE FIRM SHALL INFORM FINRA THAT THE ASSOCIATED PERSON BECAME QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BYX. ALTERNATIVELY, IF THE FIRM DECIDES THAT THE ASSOCIATED PERSON SHALL NOT HAVE A ROLE IN SUPERVISING THE FIRM'S TRADING ACTIVITIES ON BYX GOING FORWARD, THE INFORMATION TO FINRA SHALL PROVIDE NOTICE OF THAT DECISION AND THE DATE OF THAT DECISION. THE DECISION IN THIS MATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE, THIS AWC WILL BECOME FINAL AUGUST 14, 2018. PAYMENT WAS REMITTED 7/26/2018. THE SUPERVISORY STRUCTURE WAS REVISED AND A QUALIFIED SERIES 24 SECURITIES TRADER PRINCIPAL IS NOW SUPERVISING THE TRADING DESK ACTIVITIES.
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REGISTER ONE ASSOCIATED PERSON AS BOTH A SERIES 7 GENERAL SECURITIES REPRESENTATIVE AND SERIES 24 GENERAL SECURITIES PRINCIPAL WITH BYX. THE SAME ASSOCIATED PERSON WAS ALSO NOT QUALIFIED OR REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BYX EVEN THOUGH THE PERSON HAD RESPONSIBILITY OVER SECURITIES TRADING ACTIVITIES ON BYX. ALTHOUGH THE PERSON HAD PASSED THE SERIES 24 EXAMINATION, THE PERSON HAD NOT PASSED THE SERIES 57 PREREQUISITE EXAMINATION. THE FINDINGS STATED THAT SEPARATELY, THE FIRM FAILED TO REGISTER A DIFFERENT ASSOCIATED PERSON, THE FIRM'S CHIEF COMPLIANCE OFFICER, AS A SERIES 7 GENERAL SECURITIES REPRESENTATIVE WITH BYX. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO FOLLOW ITS WRITTEN SUPERVISORY PROCEDURES TO ENSURE THAT ITS ASSOCIATED PERSONS WERE PROPERLY REGISTERED WITH THE EXCHANGE.
Sanction detail — filed text
THE SUPERVISORY STRUCTURE WAS REVISED AND A QUALIFIED SERIES 24 SECURITIES TRADER PRINCIPAL IS NOW SUPERVISING THE TRADING DESK ACTIVITIES.
Full extracted filing text
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 BYX EXCHANGE, INC. 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 07/17/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2017053084602 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 REGISTER ONE ASSOCIATED PERSON AS BOTH A SERIES 7 GENERAL SECURITIES REPRESENTATIVE AND SERIES 24 GENERAL SECURITIES PRINCIPAL WITH BYX. THE SAME ASSOCIATED PERSON WAS ALSO NOT QUALIFIED OR REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BYX EVEN THOUGH THE PERSON HAD RESPONSIBILITY OVER SECURITIES TRADING ACTIVITIES ON BYX. ALTHOUGH THE PERSON HAD PASSED THE SERIES 24 EXAMINATION, THE PERSON HAD NOT PASSED THE SERIES 57 PREREQUISITE EXAMINATION. THE FINDINGS STATED THAT SEPARATELY, THE FIRM FAILED TO REGISTER A DIFFERENT ASSOCIATED PERSON, THE FIRM'S CHIEF COMPLIANCE OFFICER, AS A SERIES 7 GENERAL SECURITIES REPRESENTATIVE WITH BYX. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO FOLLOW ITS WRITTEN SUPERVISORY PROCEDURES TO ENSURE THAT ITS ASSOCIATED PERSONS WERE PROPERLY REGISTERED WITH THE EXCHANGE. 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): 07/26/2018 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: $ 7,500.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: REQUIRED TO INSURE THE SERIES 24 SUPERVISOR OF THE TRADING DESK IS REGISTERED AS A SECURITIES 24 SECURITIES TRADER. 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 SUPERVISORY STRUCTURE WAS REVISED AND A QUALIFIED SERIES 24 SECURITIES TRADER PRINCIPAL IS NOW SUPERVISING THE TRADING DESK ACTIVITIES. 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 $7,500 AND REQUIRED TO ENSURE THAT THE ASSOCIATED PERSON DISCUSSED IN THE AWC BECOMES QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BYX, ASSUMING THE FIRM INTENDS FOR THE ASSOCIATED PERSON TO HAVE A ROLE IN SUPERVISING THE TRADING ACTIVITIES OF THE FIRM ON BYX GOING FORWARD. UNTIL THIS ASSOCIATED PERSON BECOMES QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL, THE INDIVIDUAL SHALL HAVE NO ROLE IN SUPERVISING THE FIRM'S TRADING ACTIVITIES ON BYX. THE FIRM SHALL INFORM FINRA THAT THE ASSOCIATED PERSON BECAME QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BYX. ALTERNATIVELY, IF THE FIRM DECIDES THAT THE ASSOCIATED PERSON SHALL NOT HAVE A ROLE IN SUPERVISING THE FIRM'S TRADING ACTIVITIES ON BYX GOING FORWARD, THE INFORMATION TO FINRA SHALL PROVIDE NOTICE OF THAT DECISION AND THE DATE OF THAT DECISION. THE DECISION IN THIS MATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE, THIS AWC WILL BECOME FINAL AUGUST 14, 2018. PAYMENT WAS REMITTED 7/26/2018. THE SUPERVISORY STRUCTURE WAS REVISED AND A QUALIFIED SERIES 24 SECURITIES TRADER PRINCIPAL IS NOW SUPERVISING THE TRADING DESK ACTIVITIES.
regulatory · block 10FIRST NATIONAL BANK OF OMAHAPDF pages 45–46
- Advisory affiliate name — filed text
- FIRST NATIONAL BANK OF OMAHA
- Regulator name — filed text
- OFFICE OF THE COMPTROLLER OF THE CURRENCY
- Monetary/Fine Amount — filed text
- $ 3,000,000.00
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS AS HIGHLIGHTED ABOVE IN ITEM 7, FNBO AGREED TO SANCTIONS IMPOSED AS DESCRIBED ABOVE IN ITEM 12.
Other filed details
Description of allegations — filed text
THE OCC ALLEGED THAT FNBO ENGAGED IN UNFAIR BILLING PRACTICES WITH REGARD TO IDENTITY PROTECTION PRODUCTS THAT RESULTED IN VIOLATIONS OF SECTION S OF THE FEDERAL TRADE COMMISSION ACT.
Sanction detail — filed text
WITHOUT ADMITTING OR DENYING THE OCC ALLEGATIONS, FNBO AGREED TO CEASE AND DESIST FROM VIOLATING SECTION 5 OF THE FTC ACT AND TO PAY A CIVIL MONETARY PENALTY OF $3,000,000 AND MAKE FULL REIMBURSEMENTS TO ELIGIBLE CUSTOMERS. BOTH THE OCC AND CFPB TOGETHER HAVE JOINTLY ORDERED THE REPAYMENT TO CUSTOMERS WHICH IS ESTIMATED TO TOTAL $27.75 MILLION. FINALLY, FNBO AGREED TO THE IMPOSITION OF CERTAIN REMEDIAL MEASURES IN THE AREAS OF THIRD-PARTY VENDOR MANAGEMENT AND UNFAIR AND DECEPTIVE ACTS AND PRACTICES RISK MANAGEMENT.
Full extracted filing text
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: This advisory affiliate is a Firm an Individual Registered: Yes No Name: FIRST NATIONAL BANK OF OMAHA (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) OFFICE OF THE COMPTROLLER OF THE CURRENCY 2. Principal Sanction: Cease and Desist Other Sanctions: CIVIL MONEY PENALTIES AND CUSTOMER REMEDIATION 3. Date Initiated (MM/DD/YYYY): 08/16/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: AA-EC-201S-71 AND AA-EC-201S-72 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: IDENTITY PROTECTION PRODUCTS 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE OCC ALLEGED THAT FNBO ENGAGED IN UNFAIR BILLING PRACTICES WITH REGARD TO IDENTITY PROTECTION PRODUCTS THAT RESULTED IN VIOLATIONS OF SECTION S OF THE FEDERAL TRADE COMMISSION 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: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 08/16/2016 Exact Explanation If not exact, provide explanation: RESOLUTION IS ONGOING DUE TO REPAYMENT OF CUSTOMERS. 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 3,000,000.00 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: WITHOUT ADMITTING OR DENYING THE OCC ALLEGATIONS, FNBO AGREED TO CEASE AND DESIST FROM VIOLATING SECTION 5 OF THE FTC ACT AND TO PAY A CIVIL MONETARY PENALTY OF $3,000,000 AND MAKE FULL REIMBURSEMENTS TO ELIGIBLE CUSTOMERS. BOTH THE OCC AND CFPB TOGETHER HAVE JOINTLY ORDERED THE REPAYMENT TO CUSTOMERS WHICH IS ESTIMATED TO TOTAL $27.75 MILLION. FINALLY, FNBO AGREED TO THE IMPOSITION OF CERTAIN REMEDIAL MEASURES IN THE AREAS OF THIRD-PARTY VENDOR MANAGEMENT AND UNFAIR AND DECEPTIVE ACTS AND PRACTICES RISK MANAGEMENT. 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 ALLEGATIONS AS HIGHLIGHTED ABOVE IN ITEM 7, FNBO AGREED TO SANCTIONS IMPOSED AS DESCRIBED ABOVE IN ITEM 12.
regulatory · block 11FIRST NATIONAL BANK OF OMAHAPDF pages 46–48
- Advisory affiliate name — filed text
- FIRST NATIONAL BANK OF OMAHA
- Regulator name — filed text
- CONSUMER FINANCIAL PROTECTION BUREAU
- Monetary/Fine Amount — filed text
- $ 4,500,000.00
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS AS HIGHLIGHTED ABOVE IN ITEM 7, FNBO AGREED TO SANCTIONS IMPOSED AS DESCRIBED ABOVE IN ITEM 12.
Other filed details
Description of allegations — filed text
THE CFPB ALLEGED THAT FNBO ENGAGED IN UNFAIR BILLING AND ENROLLMENT PRACTICES WITH RESPECT TO DEBT CANCELLATION AND CREDIT MONITORING PRODUCTS THAT RESULTED IN VIOLATIONS OF SECTIONS 1031 AND 1036 OF THE CONSUMER FINANCIAL PROTECTION ACT OF 2010.
Sanction detail — filed text
WITHOUT ADMITTING OR DENYING THE CFPB ALLEGATIONS, FNBO, PURSUANT TO THE ORDER, AGREED TO PAY A CIVIL MONETARY PENALTY OF $4,500,000 AND MAKE FULL REIMBURSEMENTS TO ELIGIBLE CUSTOMERS. BOTH THE OCC AND CFPB TOGETHER HAVE JOINTLY ORDERED THE REPAYMENT TO CUSTOMERS WHICH IS ESTIMATED TO TOTAL $27.75 MILLION. FINALLY, FNBO AGREED TO THE IMPOSITION OF CERTAIN REMEDIAL MEASURES IN THE AREAS OF ADD-ON PRODUCTS, SERVICE PROVIDER MONITORING AND UNFAIR AND DECEPTIVE ACTS AND PRACTICES RISK MANAGEMENT.
Full extracted filing text
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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: This advisory affiliate is a Firm an Individual Registered: Yes No Name: FIRST NATIONAL BANK OF OMAHA (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) CONSUMER FINANCIAL PROTECTION BUREAU 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CUSTOMER REMEDIATION 3. Date Initiated (MM/DD/YYYY): 08/25/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2016-CFPB-0014 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: DEBT CANCELLATION AND CREDIT MONITORING PRODUCTS 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE CFPB ALLEGED THAT FNBO ENGAGED IN UNFAIR BILLING AND ENROLLMENT PRACTICES WITH RESPECT TO DEBT CANCELLATION AND CREDIT MONITORING PRODUCTS THAT RESULTED IN VIOLATIONS OF SECTIONS 1031 AND 1036 OF THE CONSUMER FINANCIAL PROTECTION ACT OF 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: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 08/25/2016 Exact Explanation If not exact, provide explanation: ORDER REQUIRES REDRESS PLAN TO BE PERFORMED UNTIL APPROVED BY CFPB. 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 4,500,000.00 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: WITHOUT ADMITTING OR DENYING THE CFPB ALLEGATIONS, FNBO, PURSUANT TO THE ORDER, AGREED TO PAY A CIVIL MONETARY PENALTY OF $4,500,000 AND MAKE FULL REIMBURSEMENTS TO ELIGIBLE CUSTOMERS. BOTH THE OCC AND CFPB TOGETHER HAVE JOINTLY ORDERED THE REPAYMENT TO CUSTOMERS WHICH IS ESTIMATED TO TOTAL $27.75 MILLION. FINALLY, FNBO AGREED TO THE IMPOSITION OF CERTAIN REMEDIAL MEASURES IN THE AREAS OF ADD-ON PRODUCTS, SERVICE PROVIDER MONITORING AND UNFAIR AND DECEPTIVE ACTS AND PRACTICES RISK MANAGEMENT. 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 ALLEGATIONS AS HIGHLIGHTED ABOVE IN ITEM 7, FNBO AGREED TO SANCTIONS IMPOSED AS DESCRIBED ABOVE IN ITEM 12.
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