THE O.N. EQUITY SALES COMPANYCINCINNATI, OH 45242 Regulated by FINRA Chicago Office Mailing Address...

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BrokerCheck Report THE O.N. EQUITY SALES COMPANY Section Title Report Summary Firm History CRD# 2936 1 8 Firm Profile 2 - 7 Page(s) Firm Operations 9 - 15 Disclosure Events 16

Transcript of THE O.N. EQUITY SALES COMPANYCINCINNATI, OH 45242 Regulated by FINRA Chicago Office Mailing Address...

BrokerCheck Report

THE O.N. EQUITY SALES COMPANY

Section Title

Report Summary

Firm History

CRD# 2936

1

8

Firm Profile 2 - 7

Page(s)

Firm Operations 9 - 15

Disclosure Events 16

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THE O.N. EQUITY SALES COMPANY

CRD# 2936

SEC# 8-14161

Main Office Location

ONE FINANCIAL WAYCINCINNATI, OH 45242Regulated by FINRA Chicago Office

Mailing Address

P.O. BOX 371CINCINNATI, OH 45201-0371

Business Telephone Number

513-794-6794

Report Summary for this Firm

This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.

Disclosure Events

Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.

Are there events disclosed about this firm? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 6

Arbitration 2

Firm Profile

This firm is classified as a corporation.

This firm was formed in Ohio on 08/22/1968.

Its fiscal year ends in December.

Firm History

Information relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.

Firm Operations

Is this brokerage firm currently suspended with anyregulator? No

This firm conducts 13 types of businesses.

This firm is affiliated with financial or investmentinstitutions.

This firm does not have referral or financialarrangements with other brokers or dealers.

This firm is registered with:

• the SEC• 1 Self-Regulatory Organization• 52 U.S. states and territories

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This firm is classified as a corporation.

This firm was formed in Ohio on 08/22/1968.

CRD#

This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.

Firm Profile

Firm Names and Locations

Its fiscal year ends in December.

THE O.N. EQUITY SALES COMPANY

SEC#

2936

8-14161

Main Office Location

Mailing Address

Business Telephone Number

Doing business as THE O.N. EQUITY SALES COMPANY

513-794-6794

Regulated by FINRA Chicago Office

ONE FINANCIAL WAYCINCINNATI, OH 45242

P.O. BOX 371CINCINNATI, OH 45201-0371

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This section provides information relating to all direct owners and executive officers of the brokerage firm.

Direct Owners and Executive Officers

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

OHIO NATIONAL LIFE INSURANCE

PARENT COMPANY

75% or more

No

Domestic Entity

08/1968

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

BLEY, JEFFREY ALLEN JR

DIRECTOR, VICE PRESIDENT, SALES & CHIEF FINANCIAL OFFICER

Less than 5%

No

Individual

06/2016

Yes

2401481

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position

Percentage of Ownership

Position Start Date

HUFFMAN, GARY THOMAS

DIRECTOR

Less than 5%

Individual

06/2016

1032890

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

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Direct Owners and Executive Officers (continued)

Firm Profile

Percentage of Ownership

Is this a public reportingcompany?

Does this owner direct themanagement or policies ofthe firm?

Less than 5%

No

Yes

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

MCEVOY, PATRICK HENRY

CHARIMAN, PRESIDENT & CHIEF EXECUTIVE OFFICER

Less than 5%

No

Individual

06/2016

Yes

1796543

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

PLANTE, KIMBERLY ANNE

SECRETARY

Less than 5%

No

Individual

10/2014

Yes

4933358

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

TURNER, BARBARA ANN

1876752

Legal Name & CRD# (if any):

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Direct Owners and Executive Officers (continued)

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

DIRECTOR

Less than 5%

No

Individual

05/2018

Yes

1876752

Is this a domestic or foreignentity or an individual?

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

VANHOY, ANDREW JOSEPH

CHIEF COMPLIANCE OFFICER

Less than 5%

No

Individual

01/2013

Yes

3012299

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position

Percentage of Ownership

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

WESTBROCK, NANCY M

CHIEF OPERATIONS OFFICER

Less than 5%

Individual

05/2015

Yes

5637288

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

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Direct Owners and Executive Officers (continued)

Firm Profile

Is this a public reportingcompany?

Does this owner direct themanagement or policies ofthe firm?

No

Yes

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This section provides information relating to any indirect owners of the brokerage firm.

Indirect Owners

Firm Profile

OHIO NATIONAL FINANCIAL SERVICES, INC.

SHAREHOLDER

OHIO NATIONAL LIFE INSURANCE COMPANY

75% or more

No

Domestic Entity

07/1998

Yes

Legal Name & CRD# (if any):

Is this a domestic or foreignentity or an individual?

Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established

Percentage of Ownership

Does this owner direct themanagement or policies ofthe firm?

Is this a public reportingcompany?

OHIO NATIONAL MUTUAL HOLDINGS, INC.

SHAREHOLDER

OHIO NATIONAL FINANCIAL SERVICES, INC.

75% or more

No

Domestic Entity

02/1998

Yes

Legal Name & CRD# (if any):

Is this a domestic or foreignentity or an individual?

Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established

Percentage of Ownership

Does this owner direct themanagement or policies ofthe firm?

Is this a public reportingcompany?

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Firm History

This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

No information reported.

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Firm Operations

RegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.

This firm is currently registered with the SEC, 1 SRO and 52 U.S. states and territories.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

This firm has ceased activity as a government securities broker or dealer:

Yes

Yes

No

No

Federal Regulator Status Date Effective

SEC Approved 10/26/1968

Self-Regulatory Organization Status Date Effective

FINRA Approved 12/16/1968

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Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 06/11/1982

Alaska Approved 11/06/1998

Arizona Approved 10/20/1987

Arkansas Approved 01/24/1989

California Approved 07/31/1986

Colorado Approved 02/01/1983

Connecticut Approved 09/06/1991

Delaware Approved 03/21/1991

District of Columbia Approved 09/07/1986

Florida Approved 11/09/1983

Georgia Approved 09/22/1981

Hawaii Approved 11/03/2003

Idaho Approved 01/01/1969

Illinois Approved 03/13/1969

Indiana Approved 10/21/1981

Iowa Approved 07/14/1983

Kansas Approved 02/03/1986

Kentucky Approved 07/16/1982

Louisiana Approved 09/04/1986

Maine Approved 02/14/1995

Maryland Approved 11/10/1983

Massachusetts Approved 07/19/1988

Michigan Approved 02/03/1983

Minnesota Approved 07/15/1982

Mississippi Approved 12/12/1983

Missouri Approved 02/11/1986

Montana Approved 01/29/1985

Nebraska Approved 10/08/1981

Nevada Approved 07/18/1983

New Hampshire Approved 10/18/1994

New Jersey Approved 09/04/1987

New Mexico Approved 06/06/1986

New York Approved 01/19/1993

U.S. States &Territories

Status Date Effective

North Carolina Approved 07/15/1982

North Dakota Approved 10/21/1981

Ohio Approved 07/16/1982

Oklahoma Approved 05/25/1988

Oregon Approved 10/24/1981

Pennsylvania Approved 04/08/1969

Puerto Rico Approved 07/10/1997

Rhode Island Approved 08/29/1994

South Carolina Approved 06/13/1986

South Dakota Approved 10/03/1984

Tennessee Approved 08/17/1981

Texas Approved 05/16/1984

Utah Approved 08/25/1986

Vermont Approved 01/02/1996

Virginia Approved 07/11/1983

Washington Approved 08/16/1984

West Virginia Approved 09/30/1981

Wisconsin Approved 09/30/1987

Wyoming Approved 08/29/1984

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Firm Operations

Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.

This firm currently conducts 13 types of businesses.

Types of Business

Broker or dealer retailing corporate equity securities over-the-counter

Broker or dealer selling corporate debt securities

Mutual fund retailer

U S. government securities dealer

U S. government securities broker

Municipal securities dealer

Municipal securities broker

Broker or dealer selling variable life insurance or annuities

Broker or dealer selling oil and gas interests

Put and call broker or dealer or option writer

Broker or dealer selling tax shelters or limited partnerships in primary distributions

Non-exchange member arranging for transactions in listed securities by exchange member

Broker or dealer involved in a networking, kiosk or similar arrangment with a: bank, savings bank or association, orcredit union

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Firm Operations

Clearing Arrangements

This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does not refer or introduce customers to other brokers and dealers.

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Firm Operations

Industry Arrangements

This firm does have books or records maintained by a third party.

This firm does have accounts, funds, or securities maintained by a third party.

This firm does have customer accounts, funds, or securities maintained by a third party.

This firm does not have individuals who control its management or policies through agreement.

This firm does not have individuals who wholly or partly finance the firm's business.

Control Persons/Financing

Name: PERSHING LLC

Business Address: ONE PERSHING PLAZAJERSEY CITY, NJ 07399

CRD #: 7560

Effective Date: 01/10/1995

Description: THE O.N. EQUITY SALES COMPANY HAS AN INTRODUCING BROKERDEALER ARRANGEMENT WITH PERSHING

Name: PERSHING LLC

Business Address: ONE PERSHING PLAZAJERSEY CITY, NJ 07399

CRD #: 7560

Effective Date: 01/10/1995

Description: THE O.N. EQUITY SALES COMPANY HAS A FULLY DISCLOSEDINTRODUCING BROKER DEALER ARRANGEMENT WITH PERSHING

Name: PERSHING LLC

Business Address: ONE PERSHING PLAZAJERSEY CITY, NJ 07399

CRD #: 7560

Effective Date: 01/10/1995

Description: THE O.N. EQUITY SALES COMPANY HAS A FULLY DISCLOSEDINTRODUCING BROKER DEALER ARRANGEMENT WITH PERSHING

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Firm Operations

Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.

This firm is, directly or indirectly:

· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.

Yes

No

No

01/17/1996

ONE FINANCIAL WAYCINCINNATI, OH 45242

107528

OHIO NATIONAL INVESTMENTS INC is under common control with the firm.

OWNED BY THE SAME PARENT COMPANY.Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

No

01/17/1996

ONE FINANCIAL WAYCINCINNATI, OH 45242

41081

OHIO NATIONAL EQUITIES, INC. is under common control with the firm.

WHOLESALE BROKER DEALER FOR PARENT COMPANYDescription:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

105662

ON INVESTMENT MANAGEMENT CO is controlled by the firm.

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Firm Operations

Organization Affiliates (continued)

Yes

No

No

10/03/1969

ONE FINANCIAL WAYCINCINNATI, OH 45242

105662

RETAIL INVESTMENT ADVISOR AFFILIATE OF THE O.N. EQUITY SALESCOMPANY

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

This firm is not directly or indirectly, controlled by the following:

· bank holding company· national bank· state member bank of the Federal Reserve System· state non-member bank· savings bank or association· credit union· or foreign bank

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Disclosure Events

All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.

Final On AppealPending

Regulatory Event 0 6 0

Arbitration N/A 2 N/A

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Disclosure Event Details

What you should know about reported disclosure events:

1. BrokerCheck provides details for any disclosure event that was reported in CRD. It also includessummary information regarding FINRA arbitration awards in cases where the brokerage firm wasnamed as a respondent.

2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a brokerage firm is required to disclose a

particular criminal event.3. Disclosure events in BrokerCheck reports come from different sources:

o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firmand a regulator report information for the same event, both versions of the event will appear in theBrokerCheck report. The different versions will be separated by a solid line with the reporting sourcelabeled.

4. There are different statuses and dispositions for disclosure events: o A disclosure event may have a status of pending, on appeal, or final.

§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently

being appealed.§ A "final" event has been concluded and its resolution is not subject to change.

o A final event generally has a disposition of adjudicated, settled or otherwise resolved.§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter,

or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.

§ A "settled" matter generally involves an agreement by the parties to resolve the matter.Please note that firms may choose to settle customer disputes or regulatory matters forbusiness or other reasons.

§ A "resolved" matter usually involves no payment to the customer and no finding ofwrongdoing on the part of the individual broker. Such matters generally involve customerdisputes.

5. You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure events contained in this BrokerCheck report.

Regulatory - Final

This type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission,foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation orsuspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federalcontractor.

Disclosure 1 of 6

Reporting Source: Regulator

Allegations: THE DIVISION ALLEGES THAT ONESCO FAILED TO SUPERVISE FORMERREGISTERED REPRESENTATIVE, JOSHUA RAY ABERNATHY, WHILE HE WASEMPLOYED BY THEIR FIRM. ABERNATHY MISAPPROPRIATED FUNDS FROMAT LEAST FOURTEEN (14) INVESTORS WHILE EMPLOYED BY ONESCO.

Current Status: Final

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Initiated By: VIRGINIA STATE CORPORATION COMMISSION

Principal Sanction(s)/ReliefSought:

Restitution

Other Sanction(s)/ReliefSought:

Date Initiated: 04/23/2019

Docket/Case Number: SEC-2017-00023

URL for Regulatory Action: WWW.SCC.VIRGINIA.GOV/DOCKETSEARCH#/CASEDETAILS/137323

Principal Product Type: Other

Other Product Type(s): PROMISSORY NOTES, STOCK OPTIONS.

Allegations: THE DIVISION ALLEGES THAT ONESCO FAILED TO SUPERVISE FORMERREGISTERED REPRESENTATIVE, JOSHUA RAY ABERNATHY, WHILE HE WASEMPLOYED BY THEIR FIRM. ABERNATHY MISAPPROPRIATED FUNDS FROMAT LEAST FOURTEEN (14) INVESTORS WHILE EMPLOYED BY ONESCO.

Resolution Date: 04/23/2019

Resolution:

Other Sanctions Ordered:

Sanction Details: THE DIVISION ORDERED O.N. EQUITY TO PAY $40,000 BACK TO HARMEDINVESTORS ON A PRO RATA BASIS.

Regulator Statement THE DIVISION ALLEGES THAT ONESCO FAILED TO ADEQUATELY MONITORABERNATHY'S USE OF HIS PERSONAL EMAIL ACCOUNT TO COMMUNICATEWITH CLIENTS DURING THE TIME HE WAS REGISTERED WITH ONESCO.THE DIVISION ALSO ALLEGES THAT ONESCO VIOLATED ITS OWN POLICIESAND PROCEDURES AS THEY RELATED TO CONDUCTING BRANCH OFFICEAUDITS ON NEW BRANCH OFFICES. THE DIVISION ALLEGED THAT IFONESCO HAD COMPLIED WITH THESE REQUIREMENTS AND OBLIGATIONS,IT WOULD HAVE DISCOVERED ABERNATHY'S FRAUDULENT ACTIVITIES.

AS A RESULT, ABERNATHY WAS ABLE TO SOLICIT AND MISAPPROPRIATEFUNDS FROM AT LEAST 14 INVESTORS WHILE HE WAS EMPLOYED BYONESCO. PRIOR TO THE ENTRY OF THE ORDER ONESCSO MADEPAYMENTS TOTALING $469,667 TO HARMED INVESTORS.

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Sanctions Ordered: Disgorgement/Restitution

Settled

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THE DIVISION ALLEGES THAT ONESCO FAILED TO ADEQUATELY MONITORABERNATHY'S USE OF HIS PERSONAL EMAIL ACCOUNT TO COMMUNICATEWITH CLIENTS DURING THE TIME HE WAS REGISTERED WITH ONESCO.THE DIVISION ALSO ALLEGES THAT ONESCO VIOLATED ITS OWN POLICIESAND PROCEDURES AS THEY RELATED TO CONDUCTING BRANCH OFFICEAUDITS ON NEW BRANCH OFFICES. THE DIVISION ALLEGED THAT IFONESCO HAD COMPLIED WITH THESE REQUIREMENTS AND OBLIGATIONS,IT WOULD HAVE DISCOVERED ABERNATHY'S FRAUDULENT ACTIVITIES.

AS A RESULT, ABERNATHY WAS ABLE TO SOLICIT AND MISAPPROPRIATEFUNDS FROM AT LEAST 14 INVESTORS WHILE HE WAS EMPLOYED BYONESCO. PRIOR TO THE ENTRY OF THE ORDER ONESCSO MADEPAYMENTS TOTALING $469,667 TO HARMED INVESTORS.

iReporting Source: Firm

Initiated By: VIRGINIA STATE CORPORATION COMMISSION

Principal Sanction(s)/ReliefSought:

Restitution

Other Sanction(s)/ReliefSought:

Date Initiated: 04/23/2019

Docket/Case Number: SEC-2017-00023

Principal Product Type: Other

Other Product Type(s): PROMISSORY NOTES, STOCK OPTIONS

Allegations: THE DIVISION ALLEGES THAT THE O.N. EQUITY SALES COMPANY FAILEDTO SUPERVISE FORMER REGISTERED REPRESENTATIVE JOSHUA RAYABERNATHY WHILE HE WAS EMPLOYED BY THEIR FIRM. ABERNATHYMISAPPROPRIATED FUNDS FROM AT LEAST FOURTEEN (14) INVESTORSWHILE EMPLOYED BY THE FIRM.

Current Status: Final

Resolution Date: 04/23/2019

Resolution:

Other Sanctions Ordered:

Sanction Details: THE DIVISION ORDERED O.N. EQUITY TO PAY $40,000 TO HARMEDINVESTORS ON A PRO RATA BASIS.

Firm Statement THE DIVISION ALLEGES THAT O.N. EQUITY FAILED TO ADEQUATELYMONITOR ABERNATHY'S USE OF HIS PERSONAL EMAIL ACCOUNT TOCOMMUNICATE WITH CUSTOMERS DURING THE TIME HE WASREGISTERED WITH THE FIRM. THE DIVISION ALSO ALLEGES THAT O.N.EQUITY VIOLATED ITS OWN POLICIES AND PROCEDURES AS THEYRELATED TO CONDUCTING BRANCH OFFICE AUDITS ON NEW BRANCHLOCATIONS. THE DIVISION ALLEGED THAT IF O.N. EQUITY WOULD HAVECOMPLIED WITH THESE REQUIREMENTS AND OBLIGATIONS, IT WOULDHAVE DISCOVERED ABERNATHY'S FRAUDULENT ACTIVITIES. AS A RESULT,ABERNATHY WAS ABLE TO SOLICIT AND MISAPPROPRIATE FUNDS FROMAT LEAST 14 INVESTORS WHILE HE WAS EMPLOYED WITH THE FIRM.PRIOR TO THE ENTRY OF THE ORDER O.N. EQUITY MADE PAYMENTSTOTALING $469,667 TO HARMED INVESTORS.

Sanctions Ordered: Disgorgement/Restitution

Settled

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THE DIVISION ALLEGES THAT O.N. EQUITY FAILED TO ADEQUATELYMONITOR ABERNATHY'S USE OF HIS PERSONAL EMAIL ACCOUNT TOCOMMUNICATE WITH CUSTOMERS DURING THE TIME HE WASREGISTERED WITH THE FIRM. THE DIVISION ALSO ALLEGES THAT O.N.EQUITY VIOLATED ITS OWN POLICIES AND PROCEDURES AS THEYRELATED TO CONDUCTING BRANCH OFFICE AUDITS ON NEW BRANCHLOCATIONS. THE DIVISION ALLEGED THAT IF O.N. EQUITY WOULD HAVECOMPLIED WITH THESE REQUIREMENTS AND OBLIGATIONS, IT WOULDHAVE DISCOVERED ABERNATHY'S FRAUDULENT ACTIVITIES. AS A RESULT,ABERNATHY WAS ABLE TO SOLICIT AND MISAPPROPRIATE FUNDS FROMAT LEAST 14 INVESTORS WHILE HE WAS EMPLOYED WITH THE FIRM.PRIOR TO THE ENTRY OF THE ORDER O.N. EQUITY MADE PAYMENTSTOTALING $469,667 TO HARMED INVESTORS.

Disclosure 2 of 6

i

Reporting Source: Regulator

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 07/24/2008

Docket/Case Number: EAF0401040001

Principal Product Type: Annuity(ies) - Variable

Other Product Type(s):

Allegations: NASD RULES 2110, 3010(A) AND 3010(B): THE FIRM FAILED TO ESTABLISH,MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM, INCLUDING WRITTENPROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE SECURITIES LAWS AND REGULATIONS AND FINRA RULESREGARDING VARIABLE ANNUITIES (VA) TRANSACTIONS. ITS SUPERVISORYSYSTEM WAS DEFICIENT IN THAT, IT DID NOT ENSURE THAT THEPRINCIPAL APPROVING VA EXCHANGES OR REPLACEMENTS HAD CERTAININFORMATION RELEVANT TO REVIEW OF THE SUITABILITYDETERMINATION OF REGISTERED REPRESENTATIVES IN ALL CASESRESULTING, IN MANY INSTANCES PRINCIPALS APPROVED VA EXCHANGESAND REPLACEMENTS WITHOUT HAVING INFORMATION THAT MAY HAVEBEEN MATERIAL TO A SUITABILITY ANALYSIS, SUCH AS: SURRENDERCHANGES, DEATH BENEFITS, CONTRACT COSTS AND FEES, AND RIDERS.THE FIRM PERMITTED DESIGNATED PRINCIPALS IN ITS OFFICES OFSUPERVISORY JURISDICTION TO SELF-APPROVE THEIR OWN SALES OFNON-PROPRIETARY VA(S) TO CUSTOMERS.

Current Status: Final

Resolution Date: 07/24/2008

Resolution:

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT MEMBERFIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OFFINDINGS; THEREFORE, FIRM IS CENSURED AND FINED $70,000.

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Sanctions Ordered: CensureMonetary/Fine $70,000.00

iReporting Source: Firm

Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

$70,000 FINE

Date Initiated: 12/01/2004

Docket/Case Number: EAF0401040001

Principal Product Type: Annuity(ies) - Variable

Other Product Type(s):

Allegations: BETWEEN JANUARY 1, 2003 AND DECEMBER 31, 2004 THE O.N. EQUITYSALES COMPANY FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE ASUPERVISORY SYSTEM, INCLUDING WRITTEN PROCEDURES FOR VATRANSACTIONS, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITHAPPLICABLE SECURITIES LAWS AND REGULATIONS AND FINRA RULES.

Current Status: Final

Resolution Date: 07/24/2008

Resolution:

Other Sanctions Ordered:

Sanction Details: A $70,000 FINE WAS LEVIED AGAINST THE APPLICANT THAT IS BEING PAIDBY CHECK.

Sanctions Ordered: CensureMonetary/Fine $70,000.00

Acceptance, Waiver & Consent(AWC)

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Sanction Details: A $70,000 FINE WAS LEVIED AGAINST THE APPLICANT THAT IS BEING PAIDBY CHECK.

Firm Statement WITHOUT ADMITTING OR DENYING THE FINDINGS IN THE AWC, THE O.N.EQUITY SALES COMPANY AGREED TO A CENSURE AND FINE OF $70,000.

Disclosure 3 of 6

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Reporting Source: Regulator

Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 09/18/2007

Docket/Case Number: 2005002433801

Principal Product Type: Other

Other Product Type(s): TRACE-ELIGIBLE SECURITIES

Allegations: NASD RULE 6230(B) - THE O.N. EQUITY SALES COMPANY FAILED TOREPORT TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THATIT WAS REQUIRED TO REPORT.

Current Status: Final

Resolution Date: 09/18/2007

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $10,000.

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Sanctions Ordered: CensureMonetary/Fine $10,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source:

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Reporting Source: Firm

Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

Date Initiated: 09/17/2007

Docket/Case Number: 20050024338-01

Principal Product Type: Debt - Corporate

Other Product Type(s):

Allegations: NASD RULE 6230(B) - THE O.N. EQUITY SALES COMPANY FAILED TOREPORT TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THATIT WAS REQUIRED TO REPORT.

Current Status: Final

Resolution Date: 09/17/2007

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $10,000.

Sanctions Ordered: CensureMonetary/Fine $10,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 4 of 6

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Reporting Source: Regulator

Initiated By: NEVADA

Date Initiated: 06/05/2002

Docket/Case Number: A02-68

URL for Regulatory Action:

Allegations: THE O.N. EQUITY SALES COMPANY OPERATED AN UNLICENSED BRANCHOFFICE IN THE STATE OF NEVADA FROM JUNE 1990 UNTIL JANUARY 2002IN VIOLATION OF NRS 90.360 AND NAC 90.392.

Current Status: Final

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Principal Sanction(s)/ReliefSought:

Civil and Administrative Penalt(ies) /Fine(s)

Other Sanction(s)/ReliefSought:

ACCEPTANCE, WAIVER, AND CONSENT AND LETTER OF CAUTION

Principal Product Type: No Product

Other Product Type(s):

Resolution Date: 06/05/2002

Resolution:

Other Sanctions Ordered: ACCEPTANCE, WAIVER, AND CONSENT

Sanction Details: WARNED NOT TO HAVE ANOTHER UNLICENSED BRANCH

Regulator Statement THE O.N. EQUITY SALES COMPANY OPERATED AN UNLICENSED BRANCHOFFICE IN THE STATE OF NEVADA FROM JUNE 1990 TO JANUARY 2002.

Sanctions Ordered: CensureMonetary/Fine $5,500.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Initiated By: STATE OF NEVADA

Principal Sanction(s)/ReliefSought:

Civil and Administrative Penalt(ies) /Fine(s)

Other Sanction(s)/ReliefSought:

Date Initiated: 05/15/2002

Docket/Case Number: A02-068

Principal Product Type: No Product

Other Product Type(s):

Allegations: FAILURE TO REGISTER A LOCATION AS A BRANCH PURSUANT TO CHAPTER90 OF NEVADA REVISED STATUTES

Current Status: Final

Resolution Date: 07/03/2002

Resolution:

Other Sanctions Ordered:

Sanctions Ordered: CensureMonetary/Fine $5,500.00

Acceptance, Waiver & Consent(AWC)

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Other Sanctions Ordered:

Sanction Details: CENSURE & CIVIL FINE FOR UNLICENSED BRANCH $5,500BRANCH LICENSING FEES FOR 11 YEARS $550.00TOTAL AMOUNT PAID ON 06/3/2002

Firm Statement IN 1990 OUR COMPLIANCE OFFICER MISINTERPRETED NEVADA'S BRANCHFILING REQUIREMENTS AND WITHDREW THE BRANCH REGISTRATION FORA NEVADA LOCATION. OUR FIRM RECENTLY CONDUCTED A REVIEW OFSTATE BRANCH REQUIREMENTS AND AN AUDIT OF ALL LOCATIONS TOENSURE COMPLIANCE WITH STATE LAWS. THIS INTERNAL AUDIT OF STATEBRANCH REQUIREMENTS RESULTED IN OUR DETERMINING THAT WEMUST REGISTER AN ACTIVE LOCATION IN NEVADA AS A BRANCH. WEALERTED NEVADA TO THIS FACT AND REGISTERED THE LOCATION INACCORDANCE WITH NEVADA STATUTES.

Disclosure 5 of 6

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Reporting Source: Firm

Initiated By: SECURITY EXCHANGE COMMISSION

Principal Sanction(s)/ReliefSought:

Bar

Other Sanction(s)/ReliefSought:

SUSPENSION

Date Initiated: 03/05/1996

Docket/Case Number: 3-9124

Principal Product Type: Direct Investment(s) - DPP & LP Interest(s)

Other Product Type(s):

Allegations: FAILURE TO SUPERVISE

Current Status: Final

Resolution Date: 04/22/1997

Resolution:

Other Sanctions Ordered:

Sanction Details: SUSPENDED FROM ASSOCIATION WITH ANY BROKER DEALER,INVESTMENT ADVISER, INVESTMENT COMPANY OR MUNCIPAL SECURITIESDEALER FOR A PERIOD OF THREE MONTHS (5/5/97 - 08/4/97).

Sanctions Ordered: Monetary/Fine $5,000.00Suspension

Order

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Firm Statement FAILURE TO SUPERVISE

Disclosure 6 of 6

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Reporting Source: Regulator

Initiated By: SECURITIES AND EXCHANGE COMMISSION

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 09/30/1996

Docket/Case Number:

Principal Product Type:

Other Product Type(s):

Allegations:

Current Status: Final

Resolution Date: 09/30/1996

Resolution:

Other Sanctions Ordered:

Sanction Details:

Regulator Statement <10/4/96 SEC NEWS DIGEST ISSUE NO. 96-188, DATED OCTOBER 2,1996, ENFORCEMENT PROCEEDINGS DISCLOSE: "ADMINISTRATIVEPROCEEDINGS INSTITUTED AGAINST THE O.N. EQUITIES SALESCOMPANY"; THE COMMISSION ANNOUNCED THAT ADMINISTRATIVEPROCEEDINGS HAVE BEEN INSTITUTED AGAINST THE O.N. EQUITIESSALES COMPANY (ONESCO), A BROKER-DEALER REGISTERED WITH THECOMMISSION. SIMULTANEOUSLY WITH THE INSTITUTION OF THEPROCEEDING, ONESCO SUBMITTED AN OFFER OF SETTLEMENT WHICHTHECOMMISSION HAS DETERMINED TO ACCEPT. UNDER THE TERMS OF THESETTLEMENT, ONESCO HAS CONSENTED TO A CENSURE, THE IMPOSITIONOF A $40,000 CIVIL PENALTY, AND TO IMPLEMENT CERTAINUNDERTAKINGS.

11-26-96, 62 SEC DOCKET 2860, DATED OCTOBER 29, 1996,DISCLOSES: SEC CENSURE AND FINE IS DATED SEPTEMBER 30, 1996THE COMMISSION'S ORDER FINDS THAT ONESCO FAILED TO REASONABLYSUPERVISE MICHAEL D. GIBSON, A REGISTERED REPRESENTATIVEFORMERLY ASSOCIATED WITH THE FIRM, IN CONNECTION WITH GIBSON'SFRAUDULENT OFFER AND SALE OF THE UNREGISTERED SECURITIES OFC'EST LESTIAL WATERS, INC. (CWI). SPECIFICALLY, THE ORDERFINDS THAT, DURING HIS ASSOCIATION WITH ONESCO, GIBSON SOLDOVER $2.7 MILLION IN CWI BONDS MISREPRESENTING, AMONG OTHERTHINGS, THAT EACH BOND WAS FULLY SECURED WITH A FIRST LIENINTEREST IN CERTAIN CWI ASSETS. SEE SEC v. C'EST LESTIALWATERS, INC., ET AL., CIV. NO. 95-642 (W.D.PA.) (APRIL 27,1995)(L.R. NO. 14484, MAY 2, 1995). THE ORDER FURTHER FINDS THATONESCO FAILED TO ESTABLISH PROCEDURES, AND A SYSTEM FORAPPLYING SUCH PROCEDURES, WHICH WOULD REASONABLY BEEXPECTED TODETECT AND PREVENT GIBSON'S CONDUCT. (REL. 34-37755)

Sanctions Ordered: CensureMonetary/Fine $40,000.00

Consent

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<10/4/96 SEC NEWS DIGEST ISSUE NO. 96-188, DATED OCTOBER 2,1996, ENFORCEMENT PROCEEDINGS DISCLOSE: "ADMINISTRATIVEPROCEEDINGS INSTITUTED AGAINST THE O.N. EQUITIES SALESCOMPANY"; THE COMMISSION ANNOUNCED THAT ADMINISTRATIVEPROCEEDINGS HAVE BEEN INSTITUTED AGAINST THE O.N. EQUITIESSALES COMPANY (ONESCO), A BROKER-DEALER REGISTERED WITH THECOMMISSION. SIMULTANEOUSLY WITH THE INSTITUTION OF THEPROCEEDING, ONESCO SUBMITTED AN OFFER OF SETTLEMENT WHICHTHECOMMISSION HAS DETERMINED TO ACCEPT. UNDER THE TERMS OF THESETTLEMENT, ONESCO HAS CONSENTED TO A CENSURE, THE IMPOSITIONOF A $40,000 CIVIL PENALTY, AND TO IMPLEMENT CERTAINUNDERTAKINGS.

11-26-96, 62 SEC DOCKET 2860, DATED OCTOBER 29, 1996,DISCLOSES: SEC CENSURE AND FINE IS DATED SEPTEMBER 30, 1996THE COMMISSION'S ORDER FINDS THAT ONESCO FAILED TO REASONABLYSUPERVISE MICHAEL D. GIBSON, A REGISTERED REPRESENTATIVEFORMERLY ASSOCIATED WITH THE FIRM, IN CONNECTION WITH GIBSON'SFRAUDULENT OFFER AND SALE OF THE UNREGISTERED SECURITIES OFC'EST LESTIAL WATERS, INC. (CWI). SPECIFICALLY, THE ORDERFINDS THAT, DURING HIS ASSOCIATION WITH ONESCO, GIBSON SOLDOVER $2.7 MILLION IN CWI BONDS MISREPRESENTING, AMONG OTHERTHINGS, THAT EACH BOND WAS FULLY SECURED WITH A FIRST LIENINTEREST IN CERTAIN CWI ASSETS. SEE SEC v. C'EST LESTIALWATERS, INC., ET AL., CIV. NO. 95-642 (W.D.PA.) (APRIL 27,1995)(L.R. NO. 14484, MAY 2, 1995). THE ORDER FURTHER FINDS THATONESCO FAILED TO ESTABLISH PROCEDURES, AND A SYSTEM FORAPPLYING SUCH PROCEDURES, WHICH WOULD REASONABLY BEEXPECTED TODETECT AND PREVENT GIBSON'S CONDUCT. (REL. 34-37755)

iReporting Source: Firm

Initiated By: SECURITIES EXCHANGE COMMISSION

Principal Sanction(s)/ReliefSought:

Censure

Other Sanction(s)/ReliefSought:

CIVIL PENALTY

Date Initiated: 09/30/1996

Docket/Case Number: 2860

Principal Product Type: Direct Investment(s) - DPP & LP Interest(s)

Other Product Type(s):

Allegations: FAILURE TO REASONABLY SUPERVISE MICHAEL D. GIBSON INCONNECTION WITH THE SALE OF THE UNREGISTERED SECURITIES OFC'EST LESTIAL WATERS, INC.

Current Status: Final

Resolution Date: 09/30/1996

Resolution:

Other Sanctions Ordered:

Sanctions Ordered: CensureMonetary/Fine $40,000.00

Settled

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Other Sanctions Ordered:

Sanction Details: UNDER TERMS OF THE SETTLEMENT, ONESCO CONSENTED TO ACENSURE, THE IMPOSITION OF A $40,000 CIVIL PENALTY, AND TOIMPLEMENT CERTAIN UNDERTAKINGS. PAYMENTS HAVE BEEN MADE ANDMATTER HAS BEEN SETTLED.

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Arbitration Award - Award / Judgment

Brokerage firms are not required to report arbitration claims filed against them by customers; however, BrokerCheckprovides summary information regarding FINRA arbitration awards involving securities and commodities disputesbetween public customers and registered securities firms in this section of the report. The full text of arbitration awards issued by FINRA is available at www.finra.org/awardsonline.

Disclosure 1 of 2

Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

NASD

09/07/2004

04-05563

ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE;ACCOUNT RELATED-NEGLIGENCE

DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OFSECURITIES

$1,000,000.00

AWARD AGAINST PARTY

08/11/2006

$124,491.00

There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.

Disclosure 2 of 2

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Reporting Source: Regulator

Type of Event: ARBITRATION

Arbitration Forum:

Case Initiated:

Case Number:

Allegations:

FINRA

09/14/2012

12-03231

ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSIONOF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURETO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE

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Disputed Product Type:

Sum of All Relief Requested:

Disposition:

Disposition Date:

Sum of All Relief Awarded:

$50,000.00

AWARD AGAINST PARTY

10/18/2013

$25,000.00

There may be a non-monetary award associated with this arbitration.Please select the Case Number above to view more detailed information.

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End of Report

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