Buttonwood Partners, Inc.

Allegations: THE AWC ALLEGES THAT BUTTONWOOD FAILED TO ACCEPT ACT TRADES WITHIN THE TIME REQUIRED, REPORTED 3 CQS TRADES THAT AGGREGATED THE VOLUME OF TWO OR MORE TRADES, AND REPORTED LATE NASDAQ AND CQS TRADES WITHOUT THE ".SLD" MODIFIER AND, ACTING THROUGH MR. JACOBSON, FAILED TO ESTABLISH AND ENFORCE SUPERVISORY PROCEDURES TO ACHIEVE COMPLIANCE WITH APPLICABLE ACT RULES. Status: Final Sanction Detail: FINE HAS BEEN PAID. Summary: MATTER IS CONCLUDED. ALLEGATIONS STEM PRIMARILY FROM FIRM NOT TIMELY FILING REPORTS DUE UNDER ACT. THE FIRM HAS SINCE ENTERED INTO GIVE-UP AGREEMENTS WITH EXECUTING FIRMS AND HAS LIMITED ITS DIRECTED BUSINESS TO PREVENT SIMILAR REPORTING OVERSIGHTS.

Allegations: FAILURE TO REPORT: 29 MUNICIPAL TRADES TIMELY; 30 MUNI TRADES WITH ACCURATE EXECUTION TIMES; 2 MUNI TRADES; 2 MUNI TRADES WITH ACCURATE PRICES; 1 TRACE ELIGIBLE TRADE; AND 13 TRACE ELIGIBLE TRADES WITH ACCURATE EXECUTION TIMES. ALSO FAILED: TO HAVE WRITTEN PROCEDURES COVERING NEW G-14 RULES; TO HAVE ACCURATE ORDER TIMES ON MEMOS FOR 29 MUNI TRADES; AND TO HAVE ACCURATE TIME STAMPS ON 7 MUNI ORDER MEMOS. Status: Final Sanction Detail: THE FULL AMOUNT OF THE FINE WAS PAID BY THE APPLICANT, IN FULL, BY BANK CHECK. Summary: THESE RECORDKEEPING MATTERS AROSE FROM AN EXAMINATION CONDUCTED BY THE NASD DURING EARLY 2005. THE EXCEPTIONS MENTIONED ABOVE WERE OVERSIGHTS AND NOT REFLECTIVE OF THE FIRM'S DAY-TO-DAY OPERATIONS AND PROCEDURES.