Thoroughbred Financial Services, LLC

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:
356789
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
PARKER, THOMAS JENKINS
(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) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURE, CIVIL MONETARY PENALTIES, DISGORGEMENT AND PREJUDGEMENT INTEREST
3.
Date Initiated (MM/DD/YYYY): 
12/21/2018
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
ADMIN PROCEEDING FILE NO 3-18952
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
SEC ADMIN RELEASE 34-84918: IA RELEASE 40-5090 / DECEMBER 21, 2018: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS
IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE,
INSTITUTED PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS 203(E), 203(F), AND 203(K)
OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AGAINST THOROUGHBRED FINANCIAL SERVICES, LLC ("TFS" OR THE "FIRM"), THOMAS
JENKINS PARKER ("PARKER"), AND LAWRENCE RANDALL "RANDY" HARTLEY ("HARTLEY") (COLLECTIVELY, "RESPONDENTS"). IN ANTICIPATION OF THE
INSTITUTION OF THESE PROCEEDINGS, TFS, PARKER, AND HARTLEY HAVE SUBMITTED OFFERS OF SETTLEMENT (THE "OFFERS") WHICH THE
COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON
BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS
TO THE COMMISSION'S JURISDICTION OVER RESPONDENTS AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED,
RESPONDENTS CONSENT TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION
15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTIONS 203(E), 203(F), AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING
FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND DESIST ORDER ("ORDER"), AS SET FORTH BELOW. ON THE BASIS OF THIS ORDER
AND RESPONDENTS' OFFERS, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE FROM BREACHES OF FIDUCIARY DUTY AND INADEQUATE
DISCLOSURES BY TFS, A REGISTERED INVESTMENT ADVISER AND BROKER-DEALER, PARKER AND HARTLEY IN CONNECTION WITH THEIR MUTUAL FUND
SHARE CLASS SELECTION PRACTICES, AS WELL AS MISLEADING STATEMENTS AND OMISSIONS THEY MADE UPON REVISING TFS'S PRACTICES AFTER A
COMMISSION EXAMINATION. BETWEEN AT LEAST OCTOBER 2012 AND AUGUST 2016 (THE "RELEVANT PERIOD"), RESPONDENTS INVESTED,
RECOMMENDED OR HELD CERTAIN ADVISORY CLIENT ASSETS IN MUTUAL FUND SHARE CLASSES THAT PAID FEES PURSUANT TO RULE 12B-1 UNDER THE
INVESTMENT COMPANY ACT OF 1940 ("12B-1 FEES") INSTEAD OF AVAILABLE, LOWER-COST SHARE CLASSES OF THE SAME FUNDS WITHOUT 12B-1
FEES. TFS (AS A BROKER-DEALER) AND PARKER AND HARTLEY (AS TFS REGISTERED REPRESENTATIVES) RECEIVED THE 12B-1 FEES BASED ON THESE
INVESTMENTS. THESE PRACTICES CREATED A CONFLICT OF INTEREST, WERE CONTRARY TO RESPONDENTS' DISCLOSURES REGARDING TFS'S CODE OF
ETHICS, AND WERE NOT DISCLOSED ADEQUATELY TO FIRM CLIENTS IN TFS'S FORMS ADV OR OTHERWISE. RESPONDENTS ALSO BREACHED THEIR DUTY
TO SEEK BEST EXECUTION FOR THEIR CLIENTS BY INVESTING THEM IN MUTUAL FUND SHARE CLASSES WITH 12B-1 FEES RATHER THAN LOWER-COST
SHARE CLASSES OF THE SAME FUNDS. MOREOVER, BY CHOOSING HIGHER-COST SHARE CLASSES FOR FIRM CLIENTS, TFS, IN SOME CLIENT
TRANSACTIONS, AVOIDED PAYING CERTAIN MUTUAL FUND TRANSACTION CLEARANCE, OR "TICKET," CHARGES THAT TFS OTHERWISE WOULD HAVE
PAID. DURING THE RELEVANT PERIOD, TFS FAILED TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO
PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION
PRACTICES. FINALLY, IN THE PROCESS OF CONVERTING CLIENTS TO LOWER-COST SHARE CLASSES AFTER RECEIVING A COMMISSION EXAMINATION
DEFICIENCY LETTER IN APRIL 2016, VARIOUS FIRM INVESTMENT ADVISER REPRESENTATIVES ("IARS"), INCLUDING PARKER AND HARTLEY, MADE
MISLEADING STATEMENTS AND OMISSIONS TO CLIENTS ABOUT THE PRIOR COSTS AND AVAILABILITY OF LOWER-COST SHARE CLASSES, WHILE AT THE
SAME TIME ASKING MANY OF THE SAME CLIENTS TO AGREE TO HIGHER ACCOUNT MANAGEMENT FEES, WHICH NEARLY ALL CLIENTS ACCEPTED. BY
VIRTUE OF THIS CONDUCT, TFS, PARKER, AND HARTLEY WILLFULLY VIOLATED SECTION 206(2) OF THE ADVISERS ACT, AND TFS ALSO WILLFULLY
VIOLATED SECTIONS 206(4) AND 207 OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
12/21/2018
 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: $ 260,000.00
 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: 
RESPONDENT SHALL CEASE AND DESIST; IS CENSURED; AND SHALL PAY DISGORGEMENT OF $740,250.20,PREJUDGEMENT INTEREST OF
$108,368.10 AND A CIVIL PENALTY OF $260,000.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO A SEC CEASE AND DESIST ORDER AND CENSURE, IN ADDITION TO
DISGORGEMENT, PREJUDGEMENT INTEREST AND A CIVIL PENALTY. DETAILS OF THE FINDINGS ARE DESCRIBED IN SECTION 7