Oneamerica Securities, Inc.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, SMITH CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE MADE UNSUITABLE RECOMMENDATIONS FOR A FAMILY TRUST FORMED BY A SENIOR MARRIED COUPLE. THE FINDINGS STATED THAT SMITH AND ANOTHER REGISTERED REPRESENTATIVE AT HIS MEMBER FIRM FIRM RECOMMENDED THAT THE TRUST PURCHASE A DEFERRED VARIABLE ANNUITY FOR APPROXIMATELY $540,000 AND FUND THAT PURCHASE THROUGH TWO WITHDRAWALS FROM AN INDEXED ANNUITY OWNED BY THE TRUST. SMITH WAS AWARE THAT FUNDING THE PURCHASE OF THE VARIABLE ANNUITY WITH WITHDRAWALS FROM THE TRUST'S EXISTING ANNUITY COULD RESULT IN NEGATIVE TAX CONSEQUENCES FOR THE TRUST AND WAS ALSO AWARE THAT THE RECOMMENDATION TO PURCHASE THE VARIABLE ANNUITY WOULD NOT BE SUITABLE IF IT CAUSED NEGATIVE TAX CONSEQUENCES FOR THE TRUST. HOWEVER, NEITHER SMITH NOR THE OTHER REPRESENTATIVE RESEARCHED HOW THE TRUST MIGHT BE ABLE TO PURCHASE THE VARIABLE ANNUITY WITHOUT NEGATIVE TAX CONSEQUENCES. INSTEAD, SMITH RECOMMENDED THAT THE TRUST WITHDRAW FUNDS FROM THE INDEXED ANNUITY VIA TWO CHECKS PAYABLE TO THE TRUST AND IMMEDIATELY ENDORSE THE CHECKS AS PAYABLE TO THE FIRM IN ORDER TO FUND THE PURCHASE OF THE VARIABLE ANNUITY. THE TRUST, THROUGH ITS TRUSTEE, FOLLOWED SMITH'S RECOMMENDATIONS. SMITH MISTAKENLY BELIEVED THAT HAVING THE TRUST IMMEDIATELY ENDORSE THE CHECKS AS PAYABLE TO THE FIRM WOULD AVOID ANY ADVERSE TAX CONSEQUENCES, BUT HE DID NOT CONFIRM THAT BELIEF. THE WITHDRAWAL OF THE FUNDS FROM THE INDEXED ANNUITY WERE, IN FACT, TAXABLE EVENTS THAT RESULTED IN NEGATIVE TAX CONSEQUENCES TO THE TRUST. THE ADVERSE TAX CONSEQUENCES COULD HAVE BEEN AVOIDED IF SMITH OR THE OTHER REPRESENTATIVE HAD RECOMMENDED THE NEW VARIABLE ANNUITY BE PURCHASED AS A TAX-FREE 1035 EXCHANGE, BUT THEY FAILED TO RESEARCH THAT OPTION. Status: Final Sanction Detail: SUSPENDED IN ALL CAPACITIES FOR THREE MONTHS BEGINNING 6/21/2022 Summary: SUSPENSION WAS COMPLETED 9/20/2022 AND MONETARY PENALTY PAID.

Allegations: THE FIRM HELD A VIRGINIA INSURANCE LICENSE AND DID NOT HAVE THE REQUISITE CHARTER OR CERTIFICATE ON FILE WITH THE VIRGINIA CLERK OF THE COMMISSION. Status: Final Sanction Detail: NO SANCTIONS WERE ORDERED BEYOND THE INITIAL LICENSE REVOCATION. Summary: AFTER RENEWING ITS AGENCY INSURANCE LICENSE WITH THE BUREAU OF INSURANCE IN MARCH, DUE TO AN ADMINISTRATIVE OVERSIGHT, THE FIRM FAILED TO RENEW ITS CERTIFICATE WITH THE CLERK OF THE COMMISSION. THE FIRM RECEIVED NOTICE OF THE ADMINISTRATIVE TERMINATION OF ITS AGENCY LICENSE ON JUNE 30. THE FIRM PROMPTLY RENEWED ITS CERTIFICATE WITH THE CLERK AND ITS AGENCY INSURANCE LICENSE WAS REINSTATED ON JULY 7.

Allegations: THE DIVSION ALLEGES THAT OAS COMMITTED 5 VIOLATIONS OF M.G.L.C.175, BY ACTING AS AN INSURACNE PRODUCER IN MASSACHUSETTS WITHOUT BEING LICENSED. THE PENALTY FOR WACH AND EVERY VIOLATION OF M.G.LC. 175 IS A FINE OF NOT MORE THAN $100.00. Status: Final Sanction Detail: 125.00

Allegations: AS PART OF A SETTLEMENT MADE BY ITS PARENT AMERICAN UNITED LIFE INSURANCE COMPANY (AUL)WITH THE MARYLAND SECURITIES DEPT, AUL EQUITY SALES CORP. AGREED TO A CONSENT ORDER WITHOUT ADMITTING OR DENYING THE FINDINGS THAT IT FAILED TO SUPERVISE AN AGENT OF AUL WHO MISAPPROPRIATED A CLIENT'S FUNDS IN AN FIXED ANNUITY INSURANCE CONTRACT. AT NO TIME DID THE AGENT SELL ANY REGISTERED SECURITIES PRODUCTS THROUGH AUL EQUITY SALES CORP. Status: Final Sanction Detail: FIRM AGREED TO PAY $25,108 ON DECEMBER 7, 1999 TO THE ESTATE OF THE CLIENT IN LIEU OF A FINE. Summary: THIS ACTION WAS TAKEN BASED ON THE FINDINGS THAT A FORMER INSURANCE AGENT OF AMERICAN UNITED LIFE INSURANCE COMPANY (AUL) WHO WAS ALSO A REGISTERED REPRESENTATIVE OF AUL AND AUL EQUITY SALES CORP. MISAPPROPRIATED $20,000 OF ONE CLIENT'S FUNDS WITHDRAWN FROM AN AUL FIXED ANNUITY INSURANCE CONTRACT.

Allegations: AS PART OF A SETTLEMENT WITH THE FLORIDA DIVISION OF SECURITIES, AUL EQUITY SALES CORP. AGREED TO A STIPULATION AND CONSENT AGREEMENT WITHOUT ADMITTING OR DENYING THE FINDINGS IT CONDUCTED SECURITIES BUSINESS PRIOR TO BRANCH OFFICE REGISRATION PURSUANT TO THE STATE OF FLORIDA STATUTES. Status: Final Sanction Detail: FIRM AGREED TO PAY A $7500.00 ADMINISTRATIVE FINE TO THE FLORIDA DEPT OF SECURITIES AND TO COMPLY FULLY WITH FLORIDA STATUTES IN ALL FUTURE ACTIVITIES. Summary: THIS ACTION WAS TAKEN BASED ON THE FINDINGS THAT AUL EQUITY SALES CORP. CONDUCTED SECURITIES BUSINESS IN THE STATE OF FLORIDA PRIOR TO BRANCH OFFICE REGISTRATION PURSUANT TO FLORIDA STATUTES.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FILED SOME OF ITS REPRESENTATIVES' FORM U4 AMENDMENTS MORE THAN 30 DAYS AFTER THE FIRM LEARNED FACTS OR CIRCUMSTANCES GIVING RISE TO THE AMENDMENTS. THE FINDINGS STATED THAT THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) FAILED TO PROVIDE ADEQUATE GUIDANCE TO REPRESENTATIVES ON REPORTING FORM U4 UPDATES TO THE FIRM BY FAILING TO INDICATE THE REQUISITE TIME PERIOD FOR MAKING SUCH UPDATES, AS WELL AS THE TYPES OF EVENTS THAT WOULD NECESSITATE THESE UPDATES. THE FIRM SUBSEQUENTLY REVISED ITS POLICIES AND PROCEDURES TO PROVIDE SUFFICIENT GUIDANCE TO ITS REPRESENTATIVES, HOWEVER, THE FIRM'S IMPLEMENTATION OF THE REVISED POLICIES WAS DEFICIENT. SPECIFICALLY, ALTHOUGH THE FIRM WARNED REPRESENTATIVES THAT THEY MAY BE FINED IF THEY MADE UNTIMELY NOTIFICATIONS TO THE FIRM OF POTENTIAL FORM U4 AMENDMENTS, THE FIRM THEN DELAYED ENFORCEMENT OF THAT REVISED POLICY. THE FIRM'S RELIANCE UPON INADEQUATE WSPS, IN ADDITION TO ITS DELAY IN IMPLEMENTING ITS REVISED POLICIES AND PROCEDURES, CAUSED THE FIRM'S SYSTEM OF SUPERVISION TO BE UNREASONABLY DESIGNED TO ENFORCE COMPLIANCE WITH FINRA BY-LAWS ARTICLE V, SECTION 2(C). Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $20,000.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO MAKE REASONABLE INQUIRIES OR OTHERWISE FOLLOW-UP ON MULTIPLE RED FLAGS THAT INDICATED A REGISTERED REPRESENTATIVE ASSOCIATED WITH THE FIRM WAS MAKING UNSUITABLE OPTIONS RECOMMENDATIONS AND CAUSING AN IMPROPER AND/OR UNAUTHORIZED TRANSFER OF FUNDS TO A THIRD PARTY. THE FINDINGS STATED THAT THE FIRM LACKED AN ADEQUATE SYSTEM AND PROCEDURES TO SUPERVISE OPTIONS TRADES AND TRANSMITTALS TO THIRD PARTIES. THE FIRM HAD INADEQUATE PROCEDURES THAT DESCRIBED HOW OPTIONS TRANSACTIONS WOULD BE REVIEWED, APPROVED AND MONITORED. IN PRACTICE, THE REVIEW WAS LIMITED TO VERIFYING THAT THE TRANSACTIONS WERE WITHIN THE LEVEL OF OPTIONS TRADING FOR WHICH THE ACCOUNT HAD BEEN APPROVED. THERE WERE NO DISCUSSIONS WITH THE REGISTERED REPRESENTATIVE, HIS BRANCH MANAGER OR THE CUSTOMERS ABOUT ANY OF THE FLAGGED TRANSACTIONS. THE FINDINGS ALSO STATED THAT THE FIRM HAD AN INADEQUATE SYSTEM AND PROCEDURE TO CONFIRM A REQUESTED TRANSMITTAL OF FUNDS TO A THIRD PARTY. AS A RESULT, THE REGISTERED REPRESENTATIVE WAS ABLE TO IMPROPERLY CAUSE $51,800 TO BE TRANSFERRED FROM A CUSTOMER'S ACCOUNT AT THE FIRM TO ANOTHER CUSTOMER'S ACCOUNT AT A DIFFERENT FINRA MEMBER FIRM. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $75,000.

Allegations: SELLING OF UNREGISTERED SECURITIES Status: Final Sanction Detail: RESPONDENT RETURNED COMMISSIONS IN THE AMOUNT OF $1600.00 Summary: ADVISOR UNKOWNINGLY SOLD UNREGISTERED SECURITIES WHICH AT THE TIME WERE PERMITTED TO BE SOLD AS INSURANCE PRODUCTS IN FLORIDA. ADVISOR PROPERLY AMENDED U4 PRIOR TO SELLING THESE PRODUCTS AND RECEIVED WRITTEN APPROVAL BY PRUDENTIAL. LATER, THE STATE OF FLORIDA REGULARTORY AUTHORIITIES DEEMED THESE VIATICAL LIFE SETTLEMENT CONTRACTS TO BE UNREGISTERED SECURITIES. ADVISOR AGREED TO RETURN COMMISSIONS AS REQUESTED AND HAD ALREADY STOPPED SELLING THE PRODUCTS IN EARLY 2004.