Oriental Financial Services Llc

Allegations: ORIENTAL ACCEPTED AND CONSENTED, WITHOUT ADMITTING OR DENYING THE FINDINGS, THAT THEY DID NOT FILE CUSTOMER COMPLAINTS STATISTICAL INFORMATION IN A TIMELY MANNER, IN VIOLATION OF NASD CONDUCTS RULE 3070(C) AND 2110 AND FINRA RULE 2010. FURTHERMORE, ORIENTAL DID NOT DISCLOSE CERTAIN REPORTABLE EVENTS, IN VIOLATION OF NASD CONDUCT RULES 3070(C) AND 2110 AND FINRA RULE 2010. IN ADDITION, ORIENTAL DID NOT TO FILE FORM U4S AND U5S IN A TIMELY MANNER, IN VIOLATION OF ARTICLE V, SECTIONS 2 AND 3 OF FINRA'S BY-LAWS AND NASD CONDUCT RULE 2110 AND FINRA RULE 2010. Status: Final Sanction Detail: TOTAL AMOUNT OF FINE $15,000. DATE PAID 4/18/2012

Allegations: FROM 2000 TO AUGUST 5, 2013, ORIENTAL FAILED TO DISCLOSE THE MARKUPS AND MARKDOWNS CHARGED ON APPROXIMATELY 2,800 RISKLESS PRINCIPAL TRANSACTIONS IN PUERTO RICO CLOSED-END FUNDS ("PR CEFS"). IN ADDITION, ORIENTAL FAILED TO ESTABLISH MAINTAIN A SUPERVISORY SYSTEM REASONABLE DESIGNED TO ACHIEVE COMPLIANCE WITH SECURITIES EXCHANGE ACT ("SEA") RULE 10B-10. AS SUCH, ORIENTAL VIOLATED SEA RULE 10B-10(A)(2)(II)(A), NASD RULE 2230 (FOR CONDUCT BEFORE JUNE 17, 2011), 3010(A), AND 2110 (FOR CONDUCT BEFORE DECEMBER 15, 2008), AND FINRA RULES 2232 (FOR CONDUCT AFTER JUNE 16, 2011) AND 2010 (FOR CONDUCT AFTER DECEMBER 14, 2008). IN ADDITION, BETWEEN JULY 1, 2011, AND JUNE 30, 2013, ORIENTAL FAILED TO ESTABLISH MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM AND PROCEDURES REASONABLY DESIGNED TO IDENTIFY AND REVIEW CONCENTRATED SECURITIES PURCHASES, INCLUDING PUERTO RICO MUNICIPAL BONDS AND PR CEFS. AS SUCH, ORIENTAL VIOLATED NASD RULE 3010(A) AND (B) AND FINRA RULE 2010. Status: Final Sanction Detail: MONETARY FINE $245,000 PAID ON DECEMBER 15, 2014. Summary: IN JUNE 2013, ORIENTAL REPORTED TO FINRA ON FORM 4530 THAT IT HAD NOT DISCLOSED ON CUSTOMERS' CONFIRMATIONS THE MARKUPS AND MARKDOWNS FOR RISKLESS PRINCIPAL TRANSACTION IN PR CEFS. ON AUGUST 5, 2013, ORIENTAL CORRECTED THE DEFICENCY BY BEGINNING TO DISCLOSE TO CUSTOMERS THE MARKS UPS AND MARKDOWNS AND AMENDED THE FIRM'S PROCEDURES TO REFLECT THE DISCLOSURE REQUIREMENT FOR RISKLESS PRINCIPAL TRANSACTION IN PR CEFS. IN ADDITION, DURING THE REGULAR EXAMINATION OF 2013, FINRA DETERMINED THAT DURING THE PERIOD BETWEEN JULY 1, 2011 AND JUNE 30, 2013, ORIENTAL SOLICITED CONCENTRATED PURCHASES OF PR SECURITIES. ORIENTAL HAS ENGAGED A CONSULTANT TO PERFORM SELF-REVIEW ACCOUNTS IN ORDER TO IDENTIFY POTENTIAL UNSUITABLE PURCHASES OF PR SECURITIES AND REPORT TO FINRA AND RESTITUE TO CUSTOMER ANY MISCONDUCT.AS REQUIRED IN THE AGREEMENT BETWEEN FINRA AND OFS, PRIOR TO JUNE 30, 2015 OFS CONDUCTED A REVIEW OF OFS' PURCHASE TRANSACTIONS CONDUCTED IN PUERTO RICO SECURITIES (MUTUAL FUNDS AND GOVERNMENT BONDS) BETWEEN DECEMBER 14, 2012 AND JUNE 30, 2013 ASSISTED BY A CONSULTANT. AS A RESULT OF THE REVIEW, OFS PROVIDED RESTITUTION PAYMENT FOR 95 TRANSACTIONS CONCENTRATED IN PUERTO RICO ASSETS FOR A TOTAL PAYMENT OF $2,109,917.

Allegations: IN 2012 AND 2013, WHILE OPERATING AS BBVA SECURITIES OF PUERTO RICO, INC., OFS SECURITIES, INC. ("OFS SECURITIES") FAILED TO PRODUCE CERTAIN DOCUMENTS AND INFORMATION PRIOR TO THE START OF A FINRA ARBITRATION HEARING AS ORDERED BY THE ARBITRATION PANEL AND INACCURATELY REPRESENTED TO THE CLAIMANT THAT IT DID NOT HAVE RESPONSIVE DOCUMENTS UNDER ITS CONTROL. OFS SECURITIES SHOULD HAVE BEEN AWARE THAT, AND ACTIVELY CONSIDERED WHETHER, RESPONSIVE DOCUMENTS AND INFORMATION COULD BE LOCATED IN ITS WAREHOUSE OR OBTAINED FROM ITS CLEARING FIRM. HOWEVER, OFS FAILED TO PRODUCE THE DOCUMENTS TO THE CLAIMANT UNTIL THE HEARING HAD ALREADY BEGUN AND THEREBY VIOLATED FINRA RULE 2010 AND IM-12000. Status: Final Sanction Detail: MONETARY FINE $50,000 PAID ON JUNE 3, 2015. Summary: PURSUANT TO RULE 9216 OF FINRA'S CODE OF PROCEDURE, OFS SECURITIES, INC. SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") PROPOSING A SETTLEMENT OF THE ALLEGED RULE VIOLATION. FINRA ACCEPTED THE AWC ON MAY 21, 2015. OFS SECURITIES ACCEPTED AND CONSENTED TO THE ENTRY OF FINRA'S FINDINGS, A CENSURE AND A $50,000 FINE, AND WAIVED CERTAIN PROCEDURAL RIGHTS.

Allegations: DURING THE PERIOD FROM JULY 1, 2013 THROUGH SEPTEMBER 30, 2013, THE FIRM PURCHASED/SOLD MUNICIPAL SECURITIES FOR 5 CUSTOMERS ACCOUNTS AT AN AGGREGATE PRICE (INCLUDING ANY MARK-DOWN OR MARK-UP) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE BROKER, DEALER OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. Status: Final Sanction Detail: OFS PAID THE FINE TO FINRA AND THE RESTITUTION TO THE INVESTORS.

Allegations: ORIENTAL FINANCIAL SERVICES (OFS) ACCEPTED AND CONSENTED, WITHOUT ADMITTING OR DENYING THE FINDINGS; THAT IN TWO ARBITRATION SETTLEMENTS IN AUGUST AND SEPTEMBER 2015, OFS INCLUDED LANGUAGE CONDITIONING ON THESE CUSTOMER AGREEMENTS TO CONSENT TO, AND NOT TO OPPOSE EXPUNGEMENT OF THEIR CLAIMS FROM THE CRD SYSTEM. AS A RESULT, THIS VIOLATED FINRA RULES 2081 AND 2010. Status: Final Sanction Detail: OFS TO PAY $20,000 TO FINRA UPON CONTACT FROM FINRA FINANCE DEPARTMENT. CONTACTED FINRA IN MAY 31,2019 AND PAYMENT WAS SENT ON JUNE 6,2019.