Osaic Institutions, Inc.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO IDENTIFY AND APPLY SALES CHARGE DISCOUNTS TO CERTAIN CUSTOMERS' ELIGIBLE PURCHASES OF UNIT INVESTMENT TRUSTS (UITS) RESULTING IN CUSTOMERS PAYING EXCESSIVE SALES CHARGES OF APPROXIMATELY $109,628. THE FINDINGS STATED THAT THE FIRM HAS PAID RESTITUTION TO ALL AFFECTED CUSTOMERS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLY DESIGNED TO ENSURE THAT CUSTOMERS RECEIVED SALES CHARGE DISCOUNTS ON ALL ELIGIBLE UIT PURCHASES. THE FIRM RELIED PRIMARILY ON ITS REGISTERED REPRESENTATIVES TO ENSURE THAT CUSTOMERS RECEIVED APPROPRIATE UIT SALES CHARGE DISCOUNTS, DESPITE THE FACT THAT THE FIRM DID NOT EFFECTIVELY INFORM AND TRAIN REPRESENTATIVES AND THEIR SUPERVISORS TO IDENTIFY AND APPLY SUCH SALES CHARGE DISCOUNTS. Status: Final Sanction Detail: THE FIRM IS CENSURED, FINED $150,000, AND PAID RESTITUTION OF 109,627.84 TO CUSTOMERS. Summary: BROKER/DEALER ONLY MATTER INVOLVING A UIT TRADING SWEEP.

Allegations: NASD RULES 2110 AND 31010(A) AND (B): BI INVESTMENTS, LLC FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN PROCEDURES RELATING TO ITS VARIABLE ANNUITY BUSINESS THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE FEDERAL SECURITIES LAWS AND REGULATIONS AND NASD RULES. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE THE FIRM IS CENSURED, FINED $100,000 AND UNDERTAKES TO RETAIN AN INDEPENDENT CONSULTANT WITHIN 60 DAYS TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF THE FIRM'S POLICIES, SYSTEMS AND PROCEDURES(WRITTEN OR OTHERWISE) AND TRAINING RELATING TO VARIABLE ANNUITIES. THE FIRM'S CHIEF COMPLIANCE OFFICER SHALL SUBMIT A CERTIFICATION TO FINRA THAT EACH AND EVERY REGISTERED REPRESENTATIVE OF THE FIRM HAS RECEIVED, REVIEWED AND AGREED TO COMPLY WITH THE FIRM'S WRITTEN SUPERVISORY PROCEDURES.

Allegations: THE RESPONDENT ACTED AS A DEALER IN THE STATE OF ILLINOIS WITHOUT BEING PROPERLY REGISTERED IN VIOLATION OF SECTION 12.A AND 12.C OF THE ILLINOIS SECURITIES LAW. Status: Final Sanction Detail: TOTAL AMOUNT $10,100 INCLUDING $6,500 CHARACTERIZED AS A FINE AND $3,600 CHARACTERIZED AS BACK REGISTRATION FEES. NO OTHER SANCTION. MATTER CLOSED. Summary: THE FIRM ENTERED INTO A CONSENT ORDER WITH THE STATE OF ILLINOIS REGARDING THE INADVERTENT PERFORMANCE OF CERTAIN SECURITIES ACTIVITIES IN THE STATE OF ILLINOIS, GERNERALLY INVOLVING CLIENTS WHO HAD RELOCATED TO ILLINOIS FROM STATES IN WHICH THE FIRM WAS REGISTERED. THE FIRM ENTERED INTO A STIPULATION AND PAID A STIPULATED SUM OF $10,100.00, $6,500.00 OF WHICH WAS CHARACTERIZED AS A FINE AND $3,600.00 OF WHICH WAS CHARACTERIZED AS BACK REGISTRATION FEES.

Allegations: AS A BROKER-DEALER, FAILED TO REASONABLY SUPERVISE ITS REGISTERED REPRESENTATIVES OPERATING ON BANK PREMISES. Status: Final Sanction Detail: N/A Summary: IN JULY OF 2018, INFINEX ENTERED INTO A CONSENT ORDER WITH THE COMMONWEALTH OF MASSACHUSETTS REGARDING INFINEX'S FAILURE TO REASONABLY SUPERVISE SEVERAL TRANSACTIONS EXECUTED BY FOUR REGISTERED REPRESENTATIVES AFFILIATED WITH THREE BANKS IN NETWORKING RELATIONSHIPS WITH INFINEX. WITHOUT ADMITTING OR DENYING THE FINDINGS, INFINEX CONSENTED TO A CENSURE, FINE, RESTITUTION TO CLIENT ACCOUNTS AND THE ENGAGEMENT OF A CONSULTANT TO REVIEW INFINEX'S SUPERVISORY POLICIES AND PROCEDURES.

Allegations: THE STATE OF CONNECTICUT DEPARTMENT OF BANKING ALLEGED THAT INFINEX INVESTMENTS, INC., FORMERLY KNOWN AS CONNECTICUT ASSOCIATION SECURITIES, INC., EFFECTED CERTAIN TRANSACTIONS IN SECURITIES IN CONNECTICUT FROM UNREGISTERED BRANCHES AND FAILED TO SUPERVISE CERTAIN AGENTS IN CONNECTION WITH SUCH ACTIVITIES. Status: Final Sanction Detail: A FINE IN THE AMOUNT OF $1,000.00 WAS PAID ON OR ABOUT APRIL 6, 1996. Summary: INFINEX INVESTMENTS, INC HAS FULLY COMPLIED WITH ALL OF THE TERMS AND CONDITIONS OF THE STIPULATION AND AGREEMENT WITH THE STATE OF CONNECTICUT DEPARTMENT OF BANKING.

Allegations: NEW YORK INSURANCE DEPARTMENT ALLEGED THAT FIRM FILED INCORRECT INSURANCE LICENSE APPLICATIONS IN 2004. Status: Final Sanction Detail: PENALTY OF $2,250.00 AGAINST INSURANCE AGENCY PAID 6/01/2009. ACKNOWLEDGED AND FINALIZED BY STATE OF NEW YORK 6/02/2009. MATTER CLOSED. Summary: IN APPLYING FOR INSURANCE LICENSURE IN 2004, THE FIRM INADVERTENTLY FAILED TO DISCLOSE A MATTER FROM 1996 AND ANOTHER MATTER CONCERNING ONE INDIVIDUAL OF WHICH THE FIRM HAD NO NOTICE. THE FIRM VOLUNTARILY DISCLOSED THE INADVERTENT OVERSIGHT. STIPULATION ENTERED INTO TO RESOLVE THE MATTER WITHOUT FURTHER COST TO THE FIRM.

Allegations: INFINEX, IN ITS CAPACITY AS AN INVESTMENT ADVISER, VOLUNTARILY PARTICIPATED IN THE SEC'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE. PURSUANT TO THE INITIATIVE, INFINEX SELF-REPORTED TO THE SEC THAT IT FAILED TO ADEQUATELY DISCLOSE CONFLICTS OF INTEREST RELATED TO THE SALE OF HIGHER COST MUTUAL FUND SHARE CLASSES WHEN LOWER COST SHARE CLASSES WERE AVAILABLE BY PLACING CLIENTS IN MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES WHEN LOWER COST SHARE CLASSES MAY HAVE BEEN AVAILABLE. Status: Final Sanction Detail: THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $865,932.01 AND PREJUDGMENT INTEREST OF $112,766.80, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. Summary: RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE RESPONDENT'S OFFER. RESPONDENT SELF-REPORTED TO THE COMMISSION THE VIOLATIONS DISCUSSED IN THIS ORDER PURSUANT TO THE DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE ("SCSD INITIATIVE"). ACCORDINGLY, THIS ORDER AND RESPONDENT'S OFFER ARE BASED ON THE INFORMATION SELF-REPORTED BY RESPONDENT.

Allegations: SEC EXCHANGE ACT RULESS 17A-3, 17A-4, FINRA RULE 2010, NASD RULES 2110, 3010, 3110, MSRB RULES G-8, G-9, G-27; WITH RESPECT TO 43 CORPORATE BOND TRANSACTIONS, THE FIRM FAILED TO MAINTAIN ADEQUATE ORDER TICKETS AS FOLLOWS: TEN OF THE ORDER TICKETS DID NOT REFLECT THE ORDER TYPE; FOUR OF THE ORDER TICKETS DID NOT REFLECT WHETHER THE TRADE WAS SOLICITED OR UNSOLICITED; TWO OF THE ORDER TICKETS DID NOT DISCLOSE THE FIRM'S CAPACITY; AND TWO OF THE ORDER TICKETS REFLECTED A TIME OF EXECUTION THAT WAS BEFORE THE TIME OF ORDER ENTRY. WITH RESPECT TO 45 MUNICIPAL BOND TRANSACTIONS, THE FIRM FAILED TO MAINTAIN ADEQUATE ORDER TICKETS AS FOLLOWS: EIGHT OF THE ORDER TICKETS DID NOT REFLECT THE ORDER TYPE; THREE OF THE ORDER TICKETS DID NOT REFLECT WHETHER THE TRADE WAS SOLICITED OR UNSOLICITED; AND ONE ORDER TICKET REFLECTED A TIME OF EXECUTION THAT WAS BEFORE THE TIME OF ORDER ENTRY. MOREOVER, THE FIRM FAILED TO MAINTAIN ITS CORPORATE AND MUNICIPAL BOND ORDER TICKET INFORMATION IN AN EASILY ACCESSIBLE PLACE FOR A PERIOD OF TWO YEARS, AS REQUIRED BY EXCHANGE ACT RULE 17A-4(B) AND MSRB RULE G-9(D). FOR EXAMPLE, THE FIRM WAS UNABLE TO PROVIDE A COMPREHENSIVE RESPONSE TO FINRA STAFF'S REQUEST FOR SUCH INFORMATION FOR OVER SEVEN MONTHS. IN ADDITION, THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, AND ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS), REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH CORPORATE AND MUNICIPAL BOND ORDER TICKET RECORDKEEPING AND RETENTION REQUIREMENTS. SPECIFICALLY, THE PROCEDURES FAILED TO PROVIDE INSTRUCTION OR GUIDANCE TO FIRM PERSONNEL ON THE MANNER IN WHICH REQUIRED TICKET INFORMATION WOULD BE OBTAINED AND PRESERVED. THE FIRM DID NOT PROVIDE FOR THE ADEQUATE TRAINING OF FIRM STAFF WITH RESPECT TO THE COMPREHENSIVE ENTRY OF ALL REQUIRED ORDER TICKET INFORMATION AND FOR THE RETRIEVAL OF THAT INFORMATION WITHIN A REASONABLE TIME FRAME. Status: Final Sanction Detail: WITHOOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE IT IS CENSURED AND FINED $15,000 ($7,500 OF WHICH PERTAINS TO THE VIOLATIONS OF MSRB RULES G-8, G-9, AND G-27).

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS. THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO SUBJECT NON-TRADITIONAL EXCHANGE-TRADED FUNDS (ETFS) TO THE SAME LEVEL OF REVIEW AS OTHER NEW PRODUCTS OFFERED FOR SALE TO RETAIL BROKERAGE CUSTOMERS. THE FINDINGS STATED THAT INSTEAD, THE FIRM ALLOWED ITS REGISTERED REPRESENTATIVES TO RECOMMEND TO CUSTOMERS NON-TRADITIONAL ETFS WITHOUT PERFORMING REASONABLE DILIGENCE TO UNDERSTAND THE RISKS AND FEATURES ASSOCIATED WITH IT. THE FIRM PERMITTED REPRESENTATIVES WHO RECEIVED MINIMAL TRAINING ON NON-TRADITIONAL ETFS AND WHO FAILED TO PERFORM REASONABLE DILIGENCE TO UNDERSTAND THE RISKS AND FEATURES OF THE PRODUCT, TO RECOMMEND TO CUSTOMERS TRANSACTIONS IN NON-TRADITIONAL ETFS. BY FIALING TO EMPLOY REASONABLE DILIGENCE REGARDING NON-TRADITIONAL ETFS, THE FIRM MISSED THE OPPORTUNITY TO EVALUATE CRITICAL ASPECTS OF THESE PRODUCTS INCLUDING THE IMPLICATIONS OF THE DAILY RESET AND LEVEDRAGE COMPONENTS AND TO ESTABLISH APPROPRIATE TRAINING AND SUPERVISION PROTOCOLS. ACCORDINGLY, THESE RECOMMENDATIONS LACKED A REASONABLE BASIS AND WERE UNSUITABLE. THE FINDINGS ALSO STATED THAT SOME NON-TRADITIONAL ETFS PURCHASES THAT THE FIRM RECOMMENDED, ACTING THROUGH SEVERAL BROKERS, WERE ALSO UNSUITABLE UNDER A CUSTOMER-SPECIFIC SUITABILITY THEORY AS THE RECOMMENDATIONS WERE MADE TO CUSTOMERS WITH CONSERVATIVE INVESTMENT OBJECTIVES AND/OR RISK TOLERANCES. THE PROSPECTUSES FOR THE NON-TRADITIONAL ETFS THAT THE FIRM SOLD GENERALLY ADVISED THAT THEY SHOULD NOT BE HELD MORE THAN ONE TRADING SESSION OR AS LONG-TERM INVESTMENTS. NOTWITHSTANDING THAT STATEMENT IN THE PROSPECTUSES, NON-TRADITIONAL ETFS WERE MAINTAINED IN CUSTOMER ACCOUNTS FOR LONGER THAN SEVEN BUSINESS DAYS. CUSTOMERS WHO HAD CONSERVATIVE INVESTMENT OBJECTIVES AND/OR RISK TOLERANCES AND WHOSE ETFS WERE HELD FOR SEVEN OR MORE DAYS, LOST MONEY ON THEIR INVESTEMENTS. THESE UNSUITABLE NON-TRADITIONAL ETF RECOMMENDATIONS RESULTED IN CUSTOMER LOSSES OF $287,171.75. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES (WSPS), TO MONITOR AND REVIEW THE SALE OF NON-TRADITIONAL ETFS TO ITS RETAIL CUSTOMERS AND THE FIRM FAILED TO ESTABLISH AND MAINTAIN SPECIFIC WSPS FOR THE REVIEW OF NON-TRADITIONAL EFT TRANSACTIONS. THE SUPERVISORY REVIEWS THAT THE FIRM'S PRINCIPALS PERFORMED OF TRANSACTIONS INVOLVING NON-TRADITONAL ETFS WERE INADEQUATE. THEY FAILED TO INCORPORATE THE COMPLEXITIES AND UNIQUE RISKS ASSOCIATED WITH THESE SECURITIES, SUCH AS THEIR DAILY RESET AND LEVERAGE FEATURES. INSTEAD, THE FIRM'S PRINCIPALS REVIEWED NON-TRADTIONAL ETF TRANSACTIONS FOR SUITABILITY IN THE SAME MANNER THEY REVIEWED TRADES INVOLVING THE FIRM'S OTHER SECURITIES PRODUCTS. THE FIRM MADE NO CHANGES TO ITS SUPERVISORY SYSTEM TO INCORPORATE GUIDANCE PROVIDED IN A REGULATORY NOTICE IN REVIEWING ETF ACTIVITY UNTIL AUGUST 2009, WHEN IT IMPLEMENTED WSPS FOR THE REVIEW OF NON-TRADITIONAL ETFS. THE FIRM FAILED TO EMPLOY A SYSTEM TO IDENTIFY WHICH OF THE ETFS BEING SOLD BY THE FIRM'S REGISTERED REPRESENTATIVES WERE NON-TRADITIONAL AND THEREFOR SUBJECT TO GREATER SCRUTINY. NEITHER THE FIRM'S TRADE BLOTTERS NOR ITS GENERAL SUPERVISORY REPORTS WERE CODED TO ALERT SUPERVISORS REGARDING THE LENGTH OF TIME CUSTOMERS HAD BEEN HOLDING NON-TRADITIONAL ETFS. THE FIRM'S SUPERVISORY SYSTEM WAS INADEQUATE TO DETECT AND MONITOR HOLDING PERIODS OF NON-TRADITIONAL ETFS IN CUSTOMER ACCOUNTS. THE FIRM DID NOT UTILIZE EXCEPTION REPORTS OR OTHER SURVEILLANCE TO MONITOR ETF ACTIVITY SPECIFICALLY INCLUDING THE CLASSIFICATION OF ETS AS LEVERAGED OR INVERSE. THE FIRM FAILED TO CONDUCT ANY TRAINING OR PROVIDE ANY WRITTEN GUIDANCE FOR ITS REGISTERED PERSONNEL REGARDING THE SALE AND SUPERVISION OF NON-TRADTIONAL ETFS. Status: Final Sanction Detail: SEE ABOVE