Synergy Investment Group, Llc

Allegations: NASD RULES 1060(B), 2110, 2210(B), 2210(C), 2210(D), 2220(B), 2220(C), 2220(D), 3010(A) 3011(A), 3011(B), 3011(C), 3011(E), 3110(C), MSRB RULE G-41: THE FIRM FAILED TO ADEQUATELY ENFORCE ITS OWN PROCEDURES OR OTHERWISE COMPLY WITH THE REQUIREMENTS OF NASD RULE 3011. THE FIRM FAILED TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO DETECT AND CAUSE THE REPORTING OF SUSPICIOUS CUSTOMER ACTIVITY; FAILED TO DETECT, INVESTIGATE, AND CONDUCT DUE DILIGENCE WHEN RED FLAGS ASSOCIATED WITH SUSPICIOUS ACTIVITY WERE PRESENT; FAILED TO FILE SUSPICIOUS ACTIVITY REPORTS (SARS) WHEN RED FLAGS ASSOCIATED WITH SUSPICIOUS ACTIVITY WERE PRESENT; AND FAILED TO FOLLOW SUPERVISORY PROCEDURES, IN THAT IT FAILED TO CONDUCT APPROPRIATE RISK-BASED DUE DILIGENCE FOR CORRESPONDENT ACCOUNTS OF FOREIGN FINANCIAL INSTITUTIONS OWNED BY CUSTOMERS, AND FAILED TO IMPLEMENT ADEQUATE SUPERVISORY PROCEDURES TO MONITOR THE SUSPICIOUS ACTIVITY IN THOSE ACCOUNTS. THE FIRM FAILED TO PERFORM ANTI-MONEY LAUNDERING CUSTOMER IDENTIFICATION REVIEWS FOR CUSTOMERS, AS REQUIRED BY ITS PROCEDURES, WHICH WOULD HAVE REVEALED THAT SEVERAL ACCOUNTS APPEARED TO BE SHELL VEHICLES FOR POSSIBLE SECURITIES FRAUD. THE FIRM DID NOT ADEQUATELY TEST ITS ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM AND DURING A TWO YEAR PERIOD THE FIRM DIDN'T CONDUCT ANY ANTI-MONEY LAUNDERING TRAINING. THE FIRM FAILED TO PROVIDE TO ITS CUSTOMERS DOCUMENTS THAT DISCLOSED THE COMPENSATION BEING PAID TO NON-REGISTERED FOREIGN FINDERS, WHO ACCORDINGLY DID NOT MEET THE REQUIREMENTS TO RECEIVE SUCH COMPENSATION, AND THE CUSTOMERS' CONFIRMATION STATEMENTS FAILED TO INDICATE THAT A REFERRAL OR FINDER'S FEE WAS BEING PAID. THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RULES RELATING TO ITS FOREIGN FINDERS AND FOREIGN ASSOCIATES BUSINESS. THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA'S ADVERTISING RULES, RESULTING IN THE FOLLOWING: FAILING TO OBTAIN THE APPROVAL OF A REGISTERED PRINCIPAL WITH REGARD TO ADDITIONS AND CHANGES TO THE FIRM'S WEBSITE; FAILING TO MAINTAIN ALL ADVERTISEMENT IN A SEPARATE FILE; FAILING TO FILE WITH FINRA ADVERTISEMENTS CONTAINING REFERENCE TO OPTIONS, MUTUAL FUNDS, AND VARIABLE ANNUITIES; AND THE WEBSITE CONTAINING CONTENT VIOLATIONS SUCH AS LINKS TO MISLEADING WEBSITES, FAILING TO MEET OPTIONS COMMUNICATIONS STANDARDS, AND EXAGGERATED AND UNWARRANTED STATEMENTS. 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 AND FINED $75,000. Summary: FIRM PAID FINE AFTER AWC.

Allegations: SEC SECTIONS 15(C) AND 17 (A) OF THE SECURITIES EXCHANGE ACT, SEC RULES 15C3-1, 17A-3. 17A-4, 17A-5, NASD RULES 2110,3110: THE MEMBER FIRM ENGAGED IN A SECURITIES BUSINESS WHILE FAILING TO MAINTAIN ITS REQUIRED MINIMUM NET CAPITAL. THE FIRM'S NET CAPITAL COMPUTATIONS WERE MATERIALLY INACCURATE, IN THAT THEY FAILED TO REFLECT AN UNSECURED DEBIT BALANCE ON ITS BOOKS AND RECORDS AND,INSTEAD, INDICATED THAT THE FIRM HAD SATISFIED ITS MINIMUM NET CAPITAL REQUIREMENTS. FOR THESE REASONS, THE FIRM'S NET CAPITAL COMPUTATION DEFICIENCIES ALSO CAUSED ITS FOCUS IIA REPORTS THAT IT SUBMITTED TO FINRA TO BE MATERIALLY INACCURATE FOR THE QUARTERS ENDING DECEMBER 31, 2007, MARCH 31, 2008 AND JUNE 30,2008. 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 AND FINED $25,000. Summary: FIRM PAID FINE AFTER AWC.

Allegations: NASD RULE 2110 AND ARTICAL V, SECTION 3 OF THE NASD BY-LAWS FROM ABOUT DECEMBER 2004 THROUGH MARCH 2006, RBC CENTURA SECURITIES FAILED TO FILE 11 OF 12 TERMINATION NOTICES (FORM U-5) FOR RBC REGISTERED PERSONNEL WITHIN THE TIME PERIOD PRESCRIBED BY ARTICAL V, SECTION 3 OF THE NASD BY-LAWS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THERFORE THE FIRM IS CENSURED AND FINED $7,500. Summary: FIRM PAID FINE AFTER AWC SIGNED.

Allegations: FAILED TO TIMELY REPORT TO OATS 3251 REPORTABLE ORDER EVENTS (ROE'S)AND FAILURE TO SUPERVISE THE OATS FILING Status: Final Sanction Detail: $4000 FINE FOR OATS, $5000 FINE FOR FAILURE TO SUPERVISE, AND MUST CORRECT SUPERVISORY PROCEDURES Summary: $4000 FINE FOR OATS, $5000 FINE FOR FAILURE TO SUPERVISE, AND MUST CORRECT SUPERVISORY PROCEDURES

Allegations: NASD RULES 2110,3070-RESPONDENT MEMBER RECEIVED CUSTOMER COMPLAINTS AND REPORTED THEM LATE TO NASD IN VIOLATION OF NASD RULE 3070 (C) Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SYNERGY INVESTMENT GROUP, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $5000.00, JOINTLY AND SEVERALLY. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SYNERGY INVESTMENT GROUP, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED AND FINED $5000.00, JOINTLY AND SEVERALLY.

Allegations: NASD RULES 2110, 3010 - RESPONDENT MEMBER, ACTING THROUGH AN EMPLOYEE, FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE LAWS, RULES AND REGULATIONS WITH RESPECT TO ITS "ON-LINE" AND "DEEP DISCOUNT" BUSINESS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SYNERGY INVESTMENT GROUP, LLC CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED, AND JOINTLY AND SEVERALLY FINED $25,000.00 Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, JONES CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE HE IS SUSPENDED FROM ASSOCIATION WITH ANY NASD MEMBER IN ANY PRINCIPAL CAPACITY FOR 10 BUSINESS DAYS AND FINED $25,000, JOINTLY AND SEVERALLY. SUSPENSION EFFECTIVE WITH THE OPENING OF BUSINESS ON MAY 1, 2006, AND CONCLUDE AT THE CLOSE OF BUSINESS ON MAY 12, 2006.

Allegations: FINRA RULE 2010, NASD RULES 2110, 3010: THE FIRM'S WRITTEN SUPERVISORY PROCEDURES REGARDING DUE DILIGENCE FOR PRIVATE PLACEMENTS WERE INADEQUATE. THE FIRM CREATED WRITTEN SUPERVISORY PROCEDURES FOR THE DUE DILIGENCE OF NEW OFFERINGS AND NEW PRODUCTS, INCLUDING PRIVATE PLACEMENTS. THE WRITTEN SUPERVISORY PROCEDURES IDENTIFIED A NEW PRODUCT/SENIOR TEAM MADE UP OF THE GENERAL COUNSEL, COMPLIANCE AND THE CHIEF FINANCIAL OFFICER, AND THE NEW PRODUCT/ SENIOR TEAM WAS RESPONSIBLE FOR APPROVING NEW OFFERINGS. THE WRITTEN SUPERVISORY PROCEDURES LIMITED THE FIRM'S REVIEW OF A NEW PRODUCT TO INFORMATION PROVIDED BY THE ISSUER. THE WRITTEN SUPERVISORY PROCEDURES RELATING TO DUE DILIGENCE OF NEW PRODUCTS WERE INADEQUATE BECAUSE THE PROCEDURES DID NOT REQUIRE THE FIRM TO OBTAIN INFORMATION FROM SOURCES OTHER THAN THE ISSUER; THE PROCEDURES FAILED TO ENSURE THAT A REASONABLE INQUIRY OF THE ISSUER AND ITS MANAGEMENT TEAM WAS CONDUCTED; AND THE PROCEDURES DID NOT ENSURE THAT THE OFFERINGS WOULD BE PROPERLY SUPERVISED AFTER APPROVED FOR SALE. CONSEQUENTLY, THE FIRM FAILED TO ESTABLISH WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO PREVENT FRAUD AND UNSUITABLE RECOMMENDATIONS IN THE SALE OF PRIVATE PLACEMENTS. ALTHOUGH THE WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE, THE FIRM AND ITS DIRECTOR OF COMPLIANCE DID NOT EVEN FOLLOW THE PROCEDURES THAT DID EXIST. THE PROCEDURES FOR APPROVAL OF A NEW PRODUCT REQUIRED THAT A CHECKLIST BE COMPLETED AND THAT THE APPROVED CHECKLIST BE RETAINED IN THE NEW PRODUCT FILE. THE NEW PRODUCT REVIEW ALSO REQUIRED THAT THE FILE DETERMINE IF THE PRODUCT WAS BENEFICIAL TO CUSTOMERS, WHICH CUSTOMERS WOULD BE TARGETED, DOCUMENTATION OF THE FEATURES AND RISKS OF THE NEW PRODUCT, DETERMINATION OF WHETHER WRITTEN DISCLOSURES OR EDUCATIONAL INFORMATION SHOULD BE PROVIDED TO POTENTIAL CUSTOMERS. THE PROCEDURES REQUIRED THAT ALL OF THESE STEPS BE COMPLETED PRIOR TO THE OFFERING OF THE NEW PRODUCT TO CUSTOMERS. DOCUMENTATION OF THE ANALYSIS WAS TO BE KEPT IN THE DUE DILIGENCE FILE. THE DIRECTOR OF COMPLIANCE SIGNED THE SELLING AGREEMENT FOR AN OFFERING. THE FIRM, THROUGH THE DIRECTOR OF COMPLIANCE, FAILED TO FOLLOW THE WRITTEN PROCEDURES WITH REGARDS TO THE APPROVAL OF THE OFFERING. PRIOR TO BECOMING REGISTERED WITH THE FIRM, AN INDIVIDUAL WAS A REGISTERED REPRESENTATIVE WITH ANOTHER BROKER-DEALER AND HAD SOLD OVER $9 MILLION IN PRIOR PRIVATE PLACEMENTS ISSUED BY AN ISSUER AND SOUGHT TO SELL THE MOST RECENT ISSUE BY THE ISSUER SUBSIDIARY. THE REPRESENTATIVE WISHED TO CHANGE BROKER-DEALER AND CONTACTED THE FIRM REGARDING POSSIBLE EMPLOYMENT AND APPROVAL OF THE SALE OF THE SUBSIDIARY'S OFFERING BY THE FIRM WAS A CRUCIAL FACTOR INFLUENCING HIS DECISION TO LOIN THE FIRM. IN AN EFFORT TO EXPEDITE THE HIRING OF AN INDIVIDUAL, THE DIRECTOR OF COMPLIANCE APPROVED THE SELLING AGREEMENT 34 MINUTES AFTER READING THE PPM. THE DIRECTOR OF COMPLIANCE APPROVED THE SELLING AGREEMENT, DESPITE THE FACT THAT THE ISSUER HAD NOT PROVIDED THE REQUESTED DUE DILIGENCE CHECKLIST. NEITHER THE DIRECTOR OF COMPLIANCE NOR ANYONE ELSE AT THE FIRM CONDUCTED THE NEW PRODUCT ANALYSIS REQUIRED BY THE WRITTEN SUPERVISORY PROCEDURES. IF THE FIRM HAD ESTABLISHED, IMPLEMENTED, AND ENFORCED REASONABLE SUPERVISORY PROCEDURES FOR DUE DILIGENCE ON PRIVATE PLACEMENTS, IT WOULD HAVE DISCOVERED THAT THE ISSUER HAD MISSED PAYMENTS ON OTHER OFFERINGS AND THAT A STATE HAD CHARGED THE ISSUER'S CHIEF EXECUTIVE OFFICER WITH FRAUD AND BARRED HIM FROM THE INSURANCE INDUSTRY. REASONABLE DUE DILIGENCE AFTER APPROVAL OF THE SELLING AGREEMENT WOULD HAVE APPRISED THE FIRM OF DEFAULTS ON OTHER OFFERINGS AND THE SIGNIFICANT RED FLAGS CONTAINED IN THE BUTTONWOOD REPORTS. THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ALL APPLICABLE REGULATORY REQUIREMENTS WITH RESPECT TO THE PRIVATE PLACEMENTS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, CONSENT WAS MADE TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF THE FINDINGS, THEREFORE IT IS CENSURED AND FINED $20,000. THE LEVEL OF SANCTIONS TAKES INTO ACCOUNT RESTITUITON PAYMENTS MADE TO THE CUSTOMERS OF $148,750 BY THE FIRM. THE FIRM HAS PROVIDED PROOF OF RESTITUTION TO FINRA. FINE PAID IN FULL DECEMBER 16, 2011. Summary: FIRM FILED AN AWC WITH FINRA.